ML16288A749

Salem Nuclear Generating Station, Units 1 and 2 - Regulatory Audit Summary Regarding License Amendment Request to Modify Chilled Water System Requirements (CAC Nos. MF6724 and MF6725)

ML16288A749
Person / Time
Site:	Salem
Issue date:	10/31/2016
From:	Carleen Parker Plant Licensing Branch 1
To:	Sena P P Public Service Enterprise Group
Parker C J, NRR/DORL/LPLI-II, 415-1603
References
CAC MF6724, CAC MF6725
Download: ML16288A749 (14)

Text

Mr. Peter P. Sena, Ill President PSEG Nuclear LLC -N09 P.O. Box 236 October 31, 2016 Hancocks Bridge, NJ 08038

SUBJECT: SALEM NUCLEAR GENERATING STATION, UNIT NOS. 1 AND 2 -REGULATORY AUDIT SUMMARY REGARDING LICENSE AMENDMENT REQUEST TO MODIFY CHILLED WATER SYSTEM REQUIREMENTS (CAC NOS. MF6724 AND MF6725)

Dear Mr. Sena:

By letter dated September 11, 2015, 1 as supplemented by letters dated November 5, 2015; March 31, 2016; August 12, 2016; and August 30, 2016,2 PSEG Nuclear LLC (the licensee) submitted a request for changes to the Salem Nuclear Generating Station (Salem), Unit Nos. 1 and 2, Technical Specifications (TSs). The requested changes would revise the TSs to support planned plant modifications to implement chiller replacements, for performing maintenance, and for unplanned operational issues. To support its review of the license amendment request, the U.S. Nuclear Regulatory Commission (NRC) staff conducted a regulatory audit at the Salem site from May 23 to May 26, 2016, to verify information submitted by the licensee and the supporting calculations. The NRC staff completed its audit efforts from NRC headquarters in Rockville, Maryland, and conducted an exit meeting by teleconference on August 31, 2016. The regulatory audit summary is enclosed. 1 Agencywide Documents Access and Management System (ADAMS) Accession No. ML 15254A387 2 ADAMS Accession Nos. ML 15309A750, ML 16091A237, ML 16225A436, and ML 16243A227, respectively If you have any questions, please contact me at (301) 415-1603 or Carleen.Parker@nrc.gov. Docket Nos. 50-272 and 50-311

Enclosure:

Regulatory Audit Report cc w/enclosure: Distribution via Listserv

Sincerely,.1 i (;J )J Carleen J. arker, Project Manager Plant Licensing Branch 1-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Background REGULATORY AUDIT SUMMARY FOR AUDIT TO SUPPORT REVIEW OF LICENSE AMENDMENT REQUEST TO MODIFY CHILLED WATER SYSTEM REQUIREMENTS PSEG NUCLEAR LLC SALEM NUCLEAR GENERATING STATION, UNIT NOS. 1 AND 2 DOCKET NOS. 50-272 AND 50-311 By letter dated September 11, 2015, 1 as supplemented by letters dated November 5, 2015; March 31, 2016; August 12, 2016; and August 30, 2016,2 PSEG Nuclear LLC (PSEG or the licensee) submitted a request for changes to the Salem Nuclear Generating Station (Salem), Unit Nos. 1 and 2, Technical Specifications (TSs). The requested changes would revise the TSs to support planned plant modifications to implement chiller replacements, for performing maintenance, and for unplanned operational issues. Specifically, the license amendment request (LAR) proposes to add two limiting condition for operation (LCO) configurations and two surveillance requirements to TS 3/4.7.10, "Chilled Water System-Auxiliary Building Subsystem." In addition, the LAR requests a change to TS 3/4.7.6, "Control Room Emergency Air Conditioning System," to add a note limiting single control room emergency air conditioning system train alignment during the two new proposed LCO 3.7.10 configurations. The U.S. Nuclear Regulatory Commission (NRC) staff is performing a detailed review of these proposed TS changes. Due to the complexity of the proposed TS changes, supporting calculations, and computer-based modelling, the staff determined that face-to-face interactions at the Salem site could resolve complex technical issues more quickly than several rounds of request for additional information (RAI) questions with followup responses from the licensee. Face-to-face interactions also allowed the staff to review and assess physical aspects of the LAR at the site through field walkdowns. The NRC staff conducted the regulatory audit of the Salem chilled water system LAR in accordance with the Office of Nuclear Reactor Regulation (NRR) Office Instruction LIC-111, "Regulatory Audits," in order to gain a better understanding of the licensee's calculations and other aspects of the LAR. 1 Agencywide Documents Access and Management System (ADAMS) Accession No. ML 15254A387 2 ADAMS Accession Nos. ML 15309A750, ML 16091 A237, ML 16225A436, and ML 16243A227, respectively Enclosure

-2 -Audit Dates and Location The on-site portion of the regulatory audit was held at the Salem site from May 23 to May 26, 2016. The remainder of the audit was conducted from the NRC headquarters facility located in Rockville, Maryland. An exit meeting was conducted by teleconference on August 31, 2016. Tables 2 and 3 below show the attendance list tor the entrance meeting and status briefing held on-site. Table 4 below shows the attendance list tor the exit meeting. Audit Team Members The on-site audit team consisted of:

• Larry Wheeler, Audit Team Lead, Balance of Plant Branch Technical Reviewer

• Nicholas Hobbs, Balance of Plant Branch Technical Reviewer

• Thomas Wengert, Salem Project Manager, Plant Licensing Branch 1-2 Support staff and management from NRC headquarters consisted of:

• Nageswara Karipineni, Balance of Plant Branch Technical Reviewer

• Robert Dennig, Balance of Plant Branch Chief

• Matthew Hamm, Technical Specifications Branch Technical Reviewer

• Carleen Parker, Salem Project Manager, Plant Licensing Branch 1-2 Licensee staff who participated in key discussions are listed in Tables 2, 3, and 4 of this summary. Audit Summary The purpose of this confirmatory audit was to determine if calculations performed by PSEG for Salem support the bases tor the proposed changes to the TSs. The areas of focus during the audit were the calculation methodologies, assumptions, and results used to reach conclusions in the LAR and associated RAI responses. There were 21 items identified during the audit related to the PSEG LAR. Table 1 of this summary provides a detailed list of these items and how they were resolved. At the end of the on-site portion of the audit, the staff conducted a status briefing. At that time, many open and unresolved items existed, which included these highlights:

• GOTHIC file review

• Technical issues related to flow and temperature margins

• Format issues of proposed TS 3/4.7.10

• Proposed completion times for configurations b and c, after chiller replacement The final exit of this audit was done by teleconference on August 31, 2016. The NRC staff exited with no open items. RAI responses (References 12 and 13 listed below) closed out eight audit open items as shown in Table 1.

-3 -In summary, the audit was very beneficial to the NRC staff's understanding of the calculations and computer-based model (GOTHIC) used in support of the LAR. The NRC staff found that the calculations adequately supported the proposed TS changes and that PSEG's calculation methodologies, assumptions, and results are reasonable, in order to reach the conclusions presented in the LAR. References PSEG calculations (primary focus of audit) and drawings: 1. PSEG Nuclear Calculation No. S-C-SW-MDC-1967, "Service Water System Thermal Hydraulic Model," Revision 8. 2. PSEG Nuclear Calculation No. S-C-CH-MDC-2319, "Hydraulic Evaluation of Salem Unit 1 and Unit 2 Chilled Water Systems during Reduced Chiller Availability," Revision 1. 3. PSEG Nuclear Calculation No. S-C-CH-MDC-2282, "Chiller Service Water Flow Requirements," Revision 2. 4. PSEG Nuclear Calculation No. S-C-CAV-MDC-2320, "Evaluation of the Control Area Ventilation System during Chilled Water System Chiller Replacement," Revision 1. 5. PSEG Calculation No. S-5-ZZ-MEE-1680, "Historical River Temperature Data," Revision 0. 6. PSEG Vendor Technical Document 903136(001 ), MPR-4027, "Salem Chilled Water System Evaluation to Support Reduction in Required Chillers," Revision 0. 7. Piping and instrumentation drawings for various related systems, including the chilled water system. 8. GOTHIC model. 9. PSEG LAR dated September 11, 2015 (ADAMS Accession No. ML 15254A387). 10. PSEG LAR supplement dated November 5, 2015 (ADAMS Accession No. ML 15309A750). 11. RAI response dated March 31, 2016 (ADAMS Accession No. ML 16091A237). 12. RAI response dated August 12, 2016 (ADAMS Accession No. ML 16225A436). 13. RAI response dated August 30, 2016 (ADAMS Accession No. ML 16243A227).

-4-Table 1: Audit Summary Audit NRC Request PSEG Response Resolution RAI No. Item 1 Followup to RAI response #11: Response was uploaded to Closed: Tube plugging is addressed and was None SharePoint site. evaluated in PSEG response -no negative Are calculation bounding and include effects to calculations. tube pluaaing. 2 Followup to RAI response #11: Response was uploaded to Closed: Based on 2% decrease in EOG None SharePoint site. frequency; thus, motor revolutions per minute Are calculation bounding and include (rpms) are reduced by 2%. Delta T is reduced emergency diesel generator (EOG) by 0.2 °F. There is sufficient room frequency TS low band tolerances. temperature margin to cover this. 3 Followup to RAI response #11: Pump curve provided. Closed. No issues identified with pump runout. None Any concerns with Auxiliary Building Chilled Water (AB CH) pump runout with needed flow > 400 gallons per minute (gpm) (pump rated at 370 gpm). 4 Followup to RAI response #13: Response was uploaded to Closed: Calculations will be performed as part None SharePoint site. of the design change process with new chiller When will all the calculations that ratings of 62.5 tons. Chiller outlet temperature support the new chillers be completed. to be 44 °F or less. 5 Followup to RAI response #12: Response was uploaded to Closed to new RAI SBPB-17 to address RAI SBPB-SharePoint site. allowed contiguous time periods for being in 17 Staff's concern with using the proposed configurations b and c. Proposed was TS (configurations band c) for 60 days contiguous for configuration b and operational conveniences (180-day 45 days for configuration c post chiller window). replacement. 6 General concern # 6: Response was uploaded to Closed: PSEG stated that the bounding None SharePoint site. service water (SW) temperature for chiller 78.3 °F is the bounding service water replacements and November 1 -April 30 temperate for November 1 -April 30. configuration will be added to the updated final Need licencing place to list this new safety analysis report. temperature limit, TS, TS bases, and final safety analysis report.

-5 -7 Followup to RAI response Main Control Room (MCR) Closed to new RAI SBPB-19 to address RAI SBPB-Cross-tie #1 : limit of 76 °F is for comfort, temperature margins and MCR and other 19. for equipment qualification areas. Calculations indicate there is -26 °F Setpoint alarms for relay room and (EQ) limits are higher. temperature margin for EQ and 0.2 °F for electrical room. 85 °F is the setpoint personnel comfort. alarms for relay and equipment rooms. 8 General concern # 8: Memo states that transfer Closed to new RAI SBPB-18 to address chiller RAI SBPB-from configuration b to replacement in configuration c and the 18. It appears PSEG said they want the configuration c within 2 transition between configuration b to c. ability to use configuration c for chiller hours, and this includes replacement in case configuration b is unlocking cross-tie valves. not working. Question 8 and 15 are related. 9a General concern # 9a: Response was uploaded to Closed to new RAI SBPB-17. Proposed to RAI SBPB-SharePoint site. changed TS to allow 45 days of contiguous 17. Duration of needed repairs for being in period for configuration c. configuration c is not well defined. 9b General concern # 9b: Response was uploaded to Closed to new RAI STSB-4 to address RAI SharePoint site. proposed TS formatting. STSB-4. Subpart 4 of configuration b appears to describe a requirement; however, the single train alignment has additional actions. The TS column does not state the dual CREAC alignment has no special actions. Possible rewrite.

-6 -10 Followup to RAI response #11: Response was uploaded to Closed: IST minimum performance vs. None SharePoint site. calculation will be aligned for the AB CH Service water (SW) and AB CH pumps pumps. Calculations remain valid. There are -Are calculations related to pump flow no operability issues. SW pumps IST and using TS allowance or ASME OM calculation are in alignment. Code allowance. Calculations include 10% degraded pump curves. 11 Followup to RAI response #TS-1: Response was uploaded to Closed: Formal training will be provided on None SharePoint site. the new chiller TS. First of a kind TS with tables and alignment; will operators be adequately trained to this new format. 12 General concern # 12: Response was uploaded to Closed. SW flow margin described as if None SharePoint site. related to MCR comfort and not EQ. With Table 4-15, 2% SW flow margin. recirculation water pumps on (68 °F) and off Explain details of recirculation and For SW -2% margin and (80 °F) setpoints. other margins. does not account for recirculation flow of 154 gpm. Flow margins are established in calculation and input into heat load and temperature marQins. 13 General concern # 13: Response was uploaded to Closed to new RAI SBPB-19 -general RAI SBPB-SharePoint site. discussion on margin. 19. Flow margins are part of input into heat load margins. (See ITEM A) Tables 4-17, 4-18 (0% flow marQin,

-7 -5.6% flow accident margin). Help to tie in with temperature marqin. 14 General concern #14: Response was uploaded to Closed to new RAI SBPB-18. PSEG plans to RAI SBPB-SharePoint site. start with chiller replacement in configuration 18. Proposed TS note 5 states to transition b, and configuration c would be a contingency to configuration c if two of the required configuration. chillers become inoperable (for example, while in chiller replacement confiquration b). 15 General concern #15: Memo states that transition Closed. Transition between configuration b None between configuration b to and c can be accomplished safely within 6 It appears PSEG said it wants the configuration c within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> (2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> needed). See response for ability to use configuration c for chiller hours, and this includes Question 8 for more information. replacement in case configuration b is unlocking cross-tie valves. not working. Can the station transition from b to c safely within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. Are the cross-tie valves locked closed. Question 8 and 15 are related. 16 General concern #16: PSEG provided disk of the Closed: None GOTHIC files that support GOTHIC executable files are needed this LAR. The NRC staff reviewed the GOTHIC files for review. after the site visit. Followup questions: 1) Were the chilled water flow measurements taken during the heatup test? 2) Did the heatup test include verification that all the heat loads in the control room envelope are actually present at the time of the test? PSEG response: GOTHIC sensitivity was supported by two followup letters: MPR Associates Inc. letter dated 8/18/16, and Enercon letter dated 8/17/16. The NRC staff

-8 -finds that the GOTHIC analysis results support this LAR and adequately define over a 25 °F margin in EQ when only two operable chillers remain for the SW conditions (November 1-April 30) with loads isolated per the proposed TS configurations. 17 General concern #17: Closed to new RAI STSB Closed to new RAI STSB-3. RAI STSB-#3. 3. "CONFIGURATION" and "APPLICABILITY" are capitalized, but not defined in Salem TS 18 General concern #18: Closed to new RAI STSB Closed to new RAI STSB-3. RAI STSB-#3. 3. "Configuration" vs. "alignment" Consider revising between "configuration" and "alignment" in Salem TS? Ensure consistent use. 19 RAI response: Data from the heatup Closed. Data from the heatup events from None Cross-tie #3 events from 2008 are not 2008 are not available. available. Benchmark info in GOTHIC model -E-mail from PSEG: In followup to your questions related to room heatup. Is it questions below on the 2008 events, I had based on actual loss of chiller events both Operations and Engineering look to see (January 22, 2008, and May 27, 2008). what information we had from the events, and there was no specific data recorded from either of these events beyond a recording in the Control Room (CR) narrative log of the maximum temperature during the May 2008 event (see below). However, the initial temperatures were not recorded. The maximum temperature recorded in the log below was about 60 minutes after the expansion tank level was lost. Without any specific data, there is not any useful information for benchmarking.

-9 -CR at 76 °F; Equipment Room at 79 °F, and Relay Room at 81 °F. These are the highest temperatures noted during loss of all chillers. 20 Followup to RAI response #20: NA Closed: Salem NRC Senior Resident None Inspector (SRI) found work order for this Expansion tanks auto makeup not repair. Outside the scope of this audit -SRI working. Is this addressed as an to review. operator work-around. 21 General concern #21: Verbal response to identify Closed. Correlation between LAR tables and None the table data. calculations verified. Review correlation between all LAR tables and calculations.

-10 -Table 2 NRC Audit -Attendees May 24, 2016 (Site Entrance) Larry Wheeler NRC-NRR Tom Wengert NRC-NRR Matt Hamm (by phone) NRC-NRR Nick Hobbs NRC-NRR Brian Thomas PSEG Justin Hargrave PSEG Ben Frazier MPR Associates Inc. Robert DeNight PSEG Kevin King PSEG Ken Knaide PSEG Paul Duke PSEG Elliot Rosenfelk New Jersey Department of Environmental Protection Matthew Pennington PSEG Jason Stairs PSEG Jeffery Owad PSEG Patrick Martinu PSEG Pat Finney NRC-SRI Table 3 NRC Audit -Attendees May 26, 2016 (Status Briefing) Bob Dennig (by phone) NRC-NRR Andy Hon (by phone) NRC-NRR Larry Wheeler NRC-NRR Tom Wengert NRC-NRR Rao Karipineni (by phone) NRC-NRR Matt Hamm (by phone) NRC-NRR Nick Hobbs NRC-NRR Robert DeNight PSEG Ken Knaide PSEG Sam Markos PSEG Paul Duke PSEG Justin Hargrave PSEG Jim Barnes PSEG Kevin King PSEG Bob Garver PSEG Brian Thomas PSEG Ben Frazier MPR Associates Inc. Pat Finney NRC-SRI

-11 -Table 4 NRC Audit -Attendees August 31, 2016 (Exit; Teleconference) Larrv Wheeler NRC-NRR Carleen Parker NRC-NRR Rao Karipineni NRC-NRR Matt Hamm NRC-NRR Eric Carr PSEG Jason Stairs PSEG Jeff Owad PSEG Paul Duke PSEG Justin Hargrave PSEG Tom Cachaza PSEG Kevin King PSEG Brian Thomas PSEG Ben Frazier MPR Associates Inc.