ML080670052

Units, 1 and 2, Issuance of License Amendments 288 and 272, Surveillance Requirements for Containment Building Penetrations

ML080670052
Person / Time
Site:	Salem
Issue date:	03/13/2008
From:	Richard Ennis NRC/NRR/ADRO/DORL/LPLI-2
To:	Levis W Public Service Enterprise Group
Ennis R, NRR/DORL, 415-1420
Shared Package
ML080670042	List: ML080670052 ML080670064 ML080670082
References
TAC MD8219, TAC MD8220
Download: ML080670052 (17)

Text

March 13, 2008 Mr. William Levis President & Chief Nuclear Officer PSEG Nuclear LLC - N09 Post Office Box 236 Hancocks Bridge, NJ 08038

SUBJECT:

SALEM NUCLEAR GENERATING STATION, UNIT NOS. 1 AND 2, ISSUANCE OF EXIGENT AMENDMENTS RE: SURVEILLANCE REQUIREMENTS FOR CONTAINMENT BUILDING PENETRATIONS (TAC NOS. MD8219 AND MD8220)

Dear Mr. Levis:

The Commission has issued the enclosed Amendment Nos. 288 and 272 to Facility Operating License Nos. DPR-70 and DPR-75 for the Salem Nuclear Generating Station (Salem), Unit Nos. 1 and 2. These amendments consist of changes to the Technical Specifications (TSs) and the facility operating licenses in response to your application dated March 5, 2008. The amendments revise the surveillance requirements for TS 3/4.9.4, Containment Building Penetrations.

A copy of the related Safety Evaluation (SE) is enclosed. The SE describes the exigent circumstances under which the amendments were issued and the final determination of no significant hazards. The Notice of Issuance, addressing the final no significant hazards determination and opportunity for a hearing, will be included in the Commission's next regular biweekly Federal Register notice.

Sincerely,

/ra/

Richard B. Ennis, Senior Project Manager Plant Licensing Branch I-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-272 and 50-311

Enclosures:

1. Amendment No. 288 to License No. DPR-70

2. Amendment No. 272 to License No. DPR-75

3. Safety Evaluation cc w/encls: See next page

March 13, 2008 Mr. William Levis President & Chief Nuclear Officer PSEG Nuclear LLC - N09 Post Office Box 236 Hancocks Bridge, NJ 08038

SUBJECT:

SALEM NUCLEAR GENERATING STATION, UNIT NOS. 1 AND 2, ISSUANCE OF EXIGENT AMENDMENTS RE: SURVEILLANCE REQUIREMENTS FOR CONTAINMENT BUILDING PENETRATIONS (TAC NOS. MD8219 AND MD8220)

Dear Mr. Levis:

The Commission has issued the enclosed Amendment Nos. 288 and 272 to Facility Operating License Nos. DPR-70 and DPR-75 for the Salem Nuclear Generating Station (Salem), Unit Nos. 1 and 2. These amendments consist of changes to the Technical Specifications (TSs) and the facility operating licenses in response to your application dated March 5, 2008. The amendments revise the surveillance requirements for TS 3/4.9.4, Containment Building Penetrations.

A copy of the related Safety Evaluation (SE) is enclosed. The SE describes the exigent circumstances under which the amendments were issued and the final determination of no significant hazards. The Notice of Issuance, addressing the final no significant hazards determination and opportunity for a hearing, will be included in the Commission's next regular biweekly Federal Register notice.

Sincerely,

/ra/

Richard B. Ennis, Senior Project Manager Plant Licensing Branch I-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-272 and 50-311

Enclosures:

1. Amendment No. 288 to License No. DPR-70

2. Amendment No. 272 to License No. DPR-75

3. Safety Evaluation cc w/encls: See next page DISTRIBUTION:

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OFFICE LPL1-2/PM LPL1-2/LA SCVB/BC ITSB/BC (A) OGC LPL1-2/BC NAME REnnis ABaxter RDennig GWaig BMizuno HChernoff HWalker for DATE 3/10/08 3/10/08 3/7/08 3/7/08 3/7/08 3/13/08 OFFICIAL RECORD COPY

Salem Nuclear Generating Station, Unit Nos. 1 and 2 cc:

Mr. Thomas Joyce Senior Vice President - Operations Township Clerk PSEG Nuclear Lower Alloways Creek Township P.O. Box 236 Municipal Building, P.O. Box 157 Hancocks Bridge, NJ 08038 Hancocks Bridge, NJ 08038 Mr. Dennis Winchester Mr. Paul Bauldauf, P.E., Asst. Director Vice President - Nuclear Assessment Radiation Protection Programs PSEG Nuclear NJ Department of Environmental P.O. Box 236 Protection and Energy Hancocks Bridge, NJ 08038 CN 415 Trenton, NJ 08625-0415 Mr. Robert Braun Site Vice President - Salem Mr. Brian Beam PSEG Nuclear Board of Public Utilities P.O. Box 236 2 Gateway Center, Tenth Floor Hancocks Bridge, NJ 08038 Newark, NJ 07102 Mr. Carl Fricker Regional Administrator, Region I Vice President - Operations Support U.S. Nuclear Regulatory Commission PSEG Nuclear 475 Allendale Road P.O. Box 236 King of Prussia, PA 19406 Hancocks Bridge, NJ 08038 Senior Resident Inspector Mr. George Gellrich Salem Nuclear Generating Station Plant Manager - Salem U.S. Nuclear Regulatory Commission PSEG Nuclear Drawer 0509 P.O. Box 236 Hancocks Bridge, NJ 08038 Hancocks Bridge, NJ 08038 Mr. William Levis Mr. James Mallon President and Chief Nuclear Officer Manager - Licensing PSEG Nuclear, LLC PSEG Nuclear P.O. Box 236 P.O. Box 236 Hancocks Bridge, NJ 08038 Hancocks Bridge, NJ 08038 Mr. Steven Mannon Manager - Salem Regulatory Assurance PSEG Nuclear P.O. Box 236 Hancocks Bridge, NJ 08038 Mr. Jeffrie J. Keenan, Esquire PSEG Nuclear - N21 P.O. Box 236 Hancocks Bridge, NJ 08038

PSEG NUCLEAR LLC EXELON GENERATION COMPANY, LLC DOCKET NO. 50-272 SALEM NUCLEAR GENERATING STATION, UNIT NO. 1 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 288 License No. DPR-70

1. The 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 March 5, 2008, 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 Title 10 of the Code of Federal Regulations (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 set forth in 10 CFR Chapter I; 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 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 Appendices A and B, as revised through Amendment No. 288, are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications.

3. This license amendment is effective as of its date of issuance and shall be implemented within 1 day.

FOR THE NUCLEAR REGULATORY COMMISSION

/ra/

Harold K. Chernoff, Chief Plant Licensing Branch I-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Facility Operating License and the Technical Specifications Date of Issuance: March 13, 2008

ATTACHMENT TO LICENSE AMENDMENT NO. 288 FACILITY OPERATING LICENSE NO. DPR-70 DOCKET NO. 50-272 Replace the following page of 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 Insert Page 4 Page 4 Replace the following page of the Appendix A, Technical Specifications, with the attached revised page as indicated. The revised page is identified by amendment number and contains marginal lines indicating the areas of change.

Remove Insert 3/4 9-4 3/4 9-4

PSEG NUCLEAR LLC EXELON GENERATION COMPANY, LLC DOCKET NO. 50-311 SALEM NUCLEAR GENERATING STATION, UNIT NO. 2 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 272 License No. DPR-75

1. The 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 March 5, 2008, 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 Title 10 of the Code of Federal Regulations (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 set forth in 10 CFR Chapter I; 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 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 Appendices A and B, as revised through Amendment No. 272, are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications.

3. This license amendment is effective as of its date of issuance and shall be implemented within 1 day.

FOR THE NUCLEAR REGULATORY COMMISSION

/ra/

Harold K. Chernoff, Chief Plant Licensing Branch I-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Facility Operating License and the Technical Specifications Date of Issuance: March 13, 2008

ATTACHMENT TO LICENSE AMENDMENT NO. 272 FACILITY OPERATING LICENSE NO. DPR-75 DOCKET NO. 50-311 Replace the following page of 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 Insert Page 4 Page 4 Replace the following page of the Appendix A, Technical Specifications, with the attached revised page as indicated. The revised page is identified by amendment number and contains marginal lines indicating the areas of change.

Remove Insert 3/4 9-4 3/4 9-4

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NOS. 288 AND 272 TO 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 application dated March 5, 2008 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML080660205) PSEG Nuclear LLC (PSEG or the licensee) submitted an amendment request for Salem Nuclear Generating Station (Salem), Unit Nos. 1 and 2. The proposed amendments would revise the surveillance requirements (SRs) for Technical Specification (TS) 3/4.9.4, Containment Building Penetrations. Specifically, SR 4.9.4.2 would be revised to make this SR applicable to the equipment hatch inside door or an installed equivalent closure device consistent with the current requirements in limiting condition for operation (LCO) 3.9.4.a.

As a result of Nuclear Regulatory Commission (NRC or the Commission) inspection activities associated with the upcoming Salem Unit No. 2 refueling outage 2R16, it was determined that the current wording in SR 4.9.4.2 does not address the equivalent closure device option permitted by LCO 3.9.4.a. This LCO provides the TS requirements for closure of the containment equipment hatch penetration. The containment equipment hatch penetration provides a means for moving large equipment and components into and out of containment.

During movement of irradiated fuel in containment, LCO 3.9.4.a requires that the equipment hatch inside door is capable of being closed and held in place by a minimum of four bolts, or an equivalent closure device is installed and capable of being closed. SR 4.9.4.2 provides the TS requirements to demonstrate that the containment equipment hatch penetration can be closed.

Currently, the SR reads as follows:

Once per refueling prior to the start of movement of irradiated fuel assemblies within the containment building, verify the capability to install, within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, the equipment hatch. Applicable only when the equipment hatch is open during movement of irradiated fuel in the containment building.

Enclosure

The current wording in SR 4.9.4.2 can only be complied with through the use of the equipment hatch inside door and not with an equivalent closure device. Since LCO 3.9.4.a provides that the equipment hatch penetration can be closed with the equipment hatch inside door or an equivalent closure device, the licensee proposed to revise SR 4.9.4.2 to read as follows:

Once per refueling prior to the start of movement of irradiated fuel assemblies within the containment building, verify the capability to close, within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, the equipment hatch inside door or an equivalent closure device. Applicable only when the equipment hatch is open during movement of irradiated fuel in the containment building.

As discussed in the licensees application dated March 5, 2008, PSEG requested that the proposed amendments be processed by the NRC on an exigent basis in accordance with the provisions in Title 10 of the Code of Federal Regulations (10 CFR) Section 50.91(a)(6). The NRCs evaluation regarding the exigent circumstances is discussed below in Safety Evaluation (SE) Section 4.0.

2.0 REGULATORY EVALUATION

On February 26, 1999, the NRC staff issued Amendment Nos. 217 and 199 for Salem Unit Nos. 1 and 2, respectively (ADAMS Accession No. ML011730414), which, in part, revised LCO 3.9.4 to allow use of an equivalent closure device to satisfy the closure requirements for the equipment hatch penetration. Following issuance of these amendments, the Salem TSs required, during core alterations or movement of irradiated fuel within containment, that the equipment hatch inside door be closed and held in place by a minimum of four bolts, or an equivalent closure device be installed. The TSs did not contain any provisions to allow the equipment hatch penetration to be open during core alterations or movement of irradiated fuel within containment. As such, the associated SRs only required verification that this penetration was in the closed condition.

On September 16, 2004, the NRC staff issued Amendment Nos. 263 and 245 for Salem Unit Nos. 1 and 2, respectively (ADAMS Accession No. ML042610308), which, in part, revised LCO 3.9.4 to allow the equipment hatch penetration to be open under administrative controls during movement of irradiated fuel within containment. LCO 3.9.4.a was revised to read as follows:

The equipment hatch inside door is capable of being closed and held in place by a minimum of four bolts, or an equivalent closure device installed and capable of being closed, These amendments also added new SR 4.9.4.2 to demonstrate that containment equipment hatch penetration can be closed within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. This SR reads as follows:

Once per refueling prior to the start of movement of irradiated fuel assemblies within the containment building, verify the capability to install, within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, the equipment hatch. Applicable only when the equipment hatch is open during movement of irradiated fuel in the containment building.

The TS changes made via Amendment Nos. 263 and 245, as discussed above, reflect the current TS 3/4.9.4 requirements for Salem Unit Nos. 1 and 2.

The changes approved by the NRC in Amendment Nos. 263 and 245 for Salem Unit Nos. 1 and 2 were based on a revised analysis of a Fuel Handling Accident (FHA) using selective implementation of alternate source term (AST) methodology in accordance with 10 CFR 50.67, Accident source term, and the guidance in Regulatory Guide 1.183, Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors. The selective implementation of an AST methodology for the Salem FHA radiological analysis had previously been approved by the NRC in Amendments Nos. 251 and 232 for Salem Unit Nos. 1 and 2, respectively, on October 10, 2002 (ADAMS Accession No. ML022880130). As discussed in the NRC staffs SE for Amendments Nos. 251 and 232, the licensees FHA radiological consequences analysis assumed that fission products were released to the environment for a 2-hour period via the open containment equipment hatch, as well as other release paths. The licensee subsequently revised the FHA analysis in support of Salem Unit No. 2 Amendment No. 271, (ADAMS Accession No. ML080320411) which was issued on March 5, 2008. The current FHA analysis also assumes that fission products are released to the environment for a 2-hour period via the open containment equipment hatch, as well as other release paths.

The NRCs regulatory requirements related to the content of the TSs are set forth in 10 CFR 50.36, ATechnical specifications.@ This regulation requires that the TSs include items in five specific categories. These categories include: (1) safety limits, limiting safety system settings and limiting control settings; (2) LCOs; (3) SRs; (4) design features; and (5) administrative controls. With respect to SRs, 10 CFR 50.36(d)(3) states that: Surveillance requirements 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 limiting conditions for operation will be met.

3.0 TECHNICAL EVALUATION

The current FHA radiological consequences analysis, applicable to both Salem Unit Nos. 1 and 2, is shown in PSEG Calculation S-C-ZZ-MDC-1920, Revision 4IR0, which was provided in to PSEGs letter dated October 17, 2007 (ADAMS Accession No. ML073470363).

This calculation was provided to the NRC staff in support of Salem Unit No. 2 Amendment No. 271, which modified the TS requirements for fuel decay time in LCO 3.9.3. As discussed in Section 3.1.1 of the NRC staffs SE dated March 5, 2008, for Salem Unit No. 2 Amendment No. 271, [t]he licensees analysis assumes no containment closure during fuel movement with the activity released to the environment through either the open containment equipment hatch or the plant vent. SE Section 3.1.1 also states that for a postulated FHA occurring in the containment building that the activity is assumed to be released to the environment through the opened containment equipment hatch or plant vent over a 2-hour time period. The licensees FHA analysis is based on a fuel decay time of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Salem Unit Nos. 1 and 2 LCO 3.9.3, Decay Time, ensures that the reactor is sub-critical for a decay time greater than the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> value assumed in the FHA analysis prior to any movement of irradiated fuel in the reactor pressure vessel. The Salem FHA analysis demonstrates that offsite and control room dose consequences of a design-basis FHA remain within the applicable dose criteria, provided sufficient decay has occurred prior to the movement of irradiated fuel without taking credit for closure of the containment equipment hatch.

As discussed in the Section 3.3.4.1 of the NRC staffs SE dated September 16, 2004, for Amendment Nos. 263 and 245, even though containment closure is not credited in the Salem FHA analysis, the LCO 3.9.4.a requirement to have the equipment hatch inside door or equivalent closure device capable of being closed is an important element of defense-in-depth and serves to manage the consequences of an FHA, further reducing the release.

As part of the changes approved by the NRC in Salem Amendment Nos. 263 and 245, new SR 4.9.4.2 was added to ensure that the requirements in LCO 3.9.4.a would be met. As discussed in the licensees application dated March 5, 2008, due to an oversight, the original SR wording failed to reference the equivalent closure device. As such, the licensee has proposed to revise the SR as discussed above in SE Section 1.0. The NRC staff finds that the proposed changes to SR 4.9.4.2 are: (1) consistent with ensuring that the associated requirements in LCO 3.9.4.a are met; and (2) meet the intent of the requirements in 10 CFR 50.36(d)(3).

Therefore, the NRC staff concludes that the proposed amendments are acceptable.

=

Background===

The Commissions regulations in 10 CFR 50.91 contain provisions for issuance of amendments when the usual 30-day public comment period cannot be met. One of these provisions is an exigency. An exigency is a case where the licensee and the NRC staff must act quickly and there is insufficient time to process the license amendment request within the normal time frame.

Pursuant to the provisions in 10 CFR 50.91(a)(6), the licensee requested the proposed amendments on an exigent basis.

Under the provisions in 10 CFR 50.91(a)(6), the Commission notifies the public in one of two ways: (1) by issuing a Federal Register notice providing an opportunity for hearing and allowing at least 2 weeks from the date of the notice for prior public comments; or (2) by using local media to provide reasonable notice to the public in the area surrounding the licensees facility.

In this case, the Commission used the second approach and published a public notice in the local newspaper, Todays Sunbeam, on March 11, 2008.

As discussed in the licensees application dated March 5, 2008, PSEG requested that the proposed amendments be processed by the NRC on an exigent basis based on the recent identification of this issue and the significant impact it has on the schedule for the upcoming refueling outage 2R16 at Salem Unit No. 2. Further details regarding the exigent circumstances are provided below.

Identification of the Issue The issue necessitating the need for the proposed amendments (i.e., current wording in SR 4.9.4.2 does not address the equivalent closure device option permitted by LCO 3.9.4.a) was identified by the NRC staff as a result of inspection activities associated with the upcoming refueling outage 2R16 at Salem Unit No. 2. The NRC staff held conference calls with PSEG on February 28, and March 3, 2008, to gather information regarding the licensees plans for the upcoming outage and to discuss the requirements in SR 4.9.4.2. Based on these calls, the

licensee determined that a license amendment request was needed to support the 2R16 outage activities. PSEG submitted the amendment request to the NRC on March 5, 2008.

Impact on the Outage Schedule PSEG developed the outage schedule for the replacement of the Salem Unit No. 2 steam generators based on the use of an equivalent closure device to meet the requirements of SR 4.9.4.2. Since SR 4.9.4.2 is only applicable to the equipment hatch inside door, the equipment hatch inside door would need to be verified capable of being closed within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, prior to movement of irradiated fuel inside containment with the containment equipment hatch penetration open. PSEG stated that without the proposed change to SR 4.9.4.2, the outage schedule would need to be revised to maintain the equipment hatch inside door closed, during movement of irradiated fuel inside containment as a result of the, inability to move equipment in support of steam generator replacement from the hatch and close the equipment hatch within one hour. While the inability to move equipment in support of steam generator replacement from the hatch and close the hatch within one hour does not, in and of itself, require the equipment hatch inside door to be installed during movement of irradiated fuel in containment, it would require scheduling movement of the referenced support equipment in series with movement of irradiated fuel in containment. PSEG had planned to conduct these activities in parallel. The licensee stated that the impact of not using the equivalent closure device on the current 2R16 outage schedule would be approximately 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> of critical path time; therefore, extending the start-up from the refueling outage by 2-1/2 days. PSEG requested approval of the proposed amendments by March 14, 2008, to support Salem Unit No. 2 refueling outage 2R16, which is scheduled to commence on March 11, 2008.

NRC Staff Conclusion Based on the above circumstances, the NRC staff finds that the licensee made a timely application for the proposed amendments following identification of the issue. In addition, the NRC staff finds that the licensee could not avoid the exigency without significant impact to the 2R16 outage schedule, thereby extending the start-up from the refueling outage by 2-1/2 days.

Based on these findings, the NRC staff has determined that a valid need exists for issuance of the license amendment using the exigent provisions of 10 CFR 50.91(a)(6).

5.0 FINAL NO SIGNIFICANT HAZARDS CONSIDERATION

DETERMINATION The Commissions regulations in 10 CFR 50.92(c) state that the Commission may make a final determination that a proposed license amendment involves no significant hazards considerations if operation of the facility in accordance with the proposed amendment would not:

(1) involve a significant increase in the probability or consequences of an accident previously evaluated; or (2) create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) involve a significant reduction in a margin of safety.

As required by 10 CFR 50.91(a), an evaluation of the issue of no significant hazards consideration is presented below:

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

Response: No.

An AST calculation has been performed for Salem Unit Nos. 1 and 2 that demonstrates that offsite and control room dose consequences of a postulated FHA remain within the applicable dose criteria, provided sufficient decay has occurred prior to the movement of irradiated fuel without taking credit for containment closure. Fuel movement is allowed, provided that irradiated fuel has undergone the required decay time. This AST calculation for an FHA inside containment is already part of the current Salem licensing basis.

The proposed amendments would revise SR 4.9.4.2 to state that this SR is applicable to the equipment hatch inside door or an equivalent closure device allowed by LCO 3.9.4.a.

SR 4.9.4.2 demonstrates the ability to close the equipment hatch penetration within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> when this penetration remains open during the movement of irradiated fuel within containment. An equivalent closure device is already specifically allowed by the Salem Unit Nos. 1 and 2 TSs. That allowance was incorporated into the Salem TSs by Amendment Nos. 217 and 199 for Salem Unit Nos. 1 and 2, respectively and, therefore, is already part of the current Salem licensing basis. This amendment request requires that if an equivalent closure device is installed in lieu of the equipment hatch inside door, the verification requirement of SR 4.9.4.2 must be performed for the equivalent closure device to ensure that closure of the equipment hatch penetration will take place within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> following an FHA inside containment.

The proposed amendments do not alter the methodology of the FHA or equipment used directly in fuel handling operations. The equipment hatch is not an accident initiator.

Actual fuel handling operations are not affected by the proposed changes. Therefore, the probability of an FHA is not affected with the proposed amendments. No other accident initiator is affected by the proposed changes.

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

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

Response: No.

The proposed change does not involve the addition or modification to any plant system, structure, or component. Having the equipment hatch penetration open during movement of irradiated fuel in containment does not create the possibility of a new accident. Closure of the equipment hatch penetration can be accomplished by either the equipment hatch inside door, or an equivalent closure device already specifically allowed by the Salem Unit Nos. 1 and 2 TSs. If an equivalent closure device is installed in lieu of the equipment hatch inside door, the verification requirement of SR 4.9.4.2 must be

performed for the equivalent closure device to ensure that closure of the equipment hatch penetration will take place within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> following an FHA inside containment.

Therefore, the proposed amendments do not create the possibility of a new or different kind of accident than any previously evaluated.

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

Response: No.

An AST calculation has been performed for Salem Unit Nos. 1 and 2 that demonstrates that offsite and control room dose consequences of a postulated FHA remain within the applicable dose criteria, provided sufficient decay has occurred prior to the movement of irradiated fuel without taking credit for containment closure. Fuel movement is allowed, provided that irradiated fuel has undergone the required decay time. This AST calculation for an FHA inside containment is already part of the current Salem licensing basis.

The proposed change to SR 4.9.4.2 does not alter the current FHA analysis. This amendment request simply clarifies that if an equivalent closure device is installed in lieu of the equipment hatch inside door, the verification requirement of SR 4.9.4.2 must be performed for the equivalent closure device to ensure that closure of the equipment hatch penetration will take place within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> following an FHA inside containment Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above evaluation, the NRC staff concludes that the three standards of 10 CFR 50.92(c) are satisfied. Therefore, the NRC staff has made a final determination that no significant hazards consideration is involved for the proposed amendments and that the amendments should be issued as allowed by the criteria contained in 10 CFR 50.91.

6.0 STATE CONSULTATION

In accordance with the Commission's regulations, the New Jersey State official was notified of the proposed issuance of the amendments. The State official had no comments.

7.0 ENVIRONMENTAL CONSIDERATION

The amendments change a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and changes 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 made a final determination that no significant hazards consideration is involved for the proposed amendments as discussed above in SE Section 5.0.

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.

8.0 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) 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: R. Ennis Date: March 13, 2008