LR-N24-0024, Response to Request for Additional Information Associated with License Amendment Request (LAR) to Modify the Salem and Hope Creek Exclusion Area Boundary: Difference between revisions
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{{#Wiki_filter:Jason Jennings Director - Site Regulatory Compliance, PSEG PO Box 236 | {{#Wiki_filter:Jason Jennings Director - Site Regulatory Compliance, PSEG PO Box 236 Hancocks Bridge, New Jersey 08038-0221 856-339-1653 Jason.Jennings@PSEG.com 10 CFR 50.90 LAR S23-04 LAR H23-02 LR-N24-0024 April 26, 2024 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, 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 Hope Creek Generating Station Renewed Facility Operating License No. NPF-57 NRC Docket No. 50-354 | ||
10 CFR 50.90 LAR S23-04 LAR H23-02 LR-N24- 0024 April 26, 2024 | |||
U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, 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 | |||
Hope Creek Generating Station Renewed Facility Operating License No. NPF-57 NRC Docket No. 50 -354 | |||
==Subject:== | ==Subject:== | ||
Response to Request for Additional Information Associated with License Amendment Request (LAR) to Modify the Salem and Hope Creek Exclusion Area Boundary | Response to Request for Additional Information Associated with License Amendment Request (LAR) to Modify the Salem and Hope Creek Exclusion Area Boundary | ||
==References:== | ==References:== | ||
: 1. PSEG letter to NRC, License Amendment Request (LAR) to Modify the Salem and Hope Creek Exclusion Area Boundary, dated September 6, 2023 (ADAMS Accession No. ML23249A261) | : 1. PSEG letter to NRC, License Amendment Request (LAR) to Modify the Salem and Hope Creek Exclusion Area Boundary, dated September 6, 2023 (ADAMS Accession No. ML23249A261) | ||
: 2. NRC email to PSEG, Salem 1 and 2 - Final EXHB RAI for Hope Creek, Salem 1 and 2 Amendment to modify Exclusion Area Boundary (EPID L-2023-LLA-0125), dated February 28, 2024 (ADAMS Accession No. ML24060A049) | : 2. NRC email to PSEG, Salem 1 and 2 - Final EXHB RAI for Hope Creek, Salem 1 and 2 Amendment to modify Exclusion Area Boundary (EPID L-2023-LLA-0125), dated February 28, 2024 (ADAMS Accession No. ML24060A049) | ||
In the Reference 1 letter, PSEG Nuclear LLC (PSEG) submitted a license amendment request (LAR) to Renewed Facility Operating License Numbers DPR-70 and DPR-75 for Salem Generating Station (Salem) and NPF-57 for Hope Creek Generating Station (HCGS) to modify the Exclusion Area Boundary for the PSEG site. | In the Reference 1 letter, PSEG Nuclear LLC (PSEG) submitted a license amendment request (LAR) to Renewed Facility Operating License Numbers DPR-70 and DPR-75 for Salem Generating Station (Salem) and NPF-57 for Hope Creek Generating Station (HCGS) to modify the Exclusion Area Boundary for the PSEG site. | ||
In the Reference 2 email, the NRC provided PSEG a request for additional information (RAI) regarding the dose consequence analyses for both Salem and Hope Creek to support the NRC staffs detailed technical review of the Reference 1 submittal. The enclosure to this letter contains the responses to the RAI questions contained in Reference 2. | In the Reference 2 email, the NRC provided PSEG a request for additional information (RAI) regarding the dose consequence analyses for both Salem and Hope Creek to support the NRC staffs detailed technical review of the Reference 1 submittal. The enclosure to this letter contains the responses to the RAI questions contained in Reference 2. | ||
PSEG has determined that the information provided in this submittal does not alter the conclusions reached in the 10 CFR 50.92 no significant hazards determination previously submitted. In addition, the information provided in this submittal does not affect the bases for concluding that neither an environmental impact statement nor an environmental assessment needs to be prepared in connection with the proposed amendment. | PSEG has determined that the information provided in this submittal does not alter the conclusions reached in the 10 CFR 50.92 no significant hazards determination previously submitted. In addition, the information provided in this submittal does not affect the bases for concluding that neither an environmental impact statement nor an environmental assessment needs to be prepared in connection with the proposed amendment. | ||
o PSEG I NUCLEAR | |||
April 26, 2024 10 CFR 50.90 LR-N24-0024 LAR S23-04 Page 2 LAR H23-02 There are no regulatory commitments contained in this letter. If you have any questions or require additional information, please contact Mr. Michael Wiwel at Michael.Wiwel@pseg.com. | |||
I declare under penalty of perjury that the foregoing is true and correct. | I declare under penalty of perjury that the foregoing is true and correct. | ||
Executed on________________ | Executed on________________ | ||
Respectfully, Jason Jennings Director, Site Regulatory Compliance PSEG Nuclear LLC | |||
Respectfully, | |||
Jason Jennings Director, Site Regulatory Compliance PSEG Nuclear LLC | |||
==Enclosure:== | ==Enclosure:== | ||
Response to Final EXHB RAI for Hope Creek, Salem 1 and 2 Amendment to modify Exclusion Area Boundary (EPID L-2023-LLA-0125) | Response to Final EXHB RAI for Hope Creek, Salem 1 and 2 Amendment to modify Exclusion Area Boundary (EPID L-2023-LLA-0125) cc: | ||
Administrator, Region I, NRC Mr. J. Kim, Project Manager, NRC NRC Senior Resident Inspector, Salem NRC Senior Resident Inspector, Hope Creek Ms. Ann Pfaff, Manager, NJBNE PSEG Commitment Tracking Coordinator April 26, 2024 | |||
cc: Administrator, Region I, NRC Mr. J. Kim, Project Manager, NRC NRC Senior Resident Inspector, Salem NRC Senior Resident Inspector, Hope Creek Ms. Ann Pfaff, Manager, NJBNE PSEG Commitment Tracking Coordinator | : Jennings, Jason Digitally signed by Jennings, Jason Date: 2024.04.26 10:23:18 -04'00' | ||
LR-N24-0024 10 CFR 50.90 LAR S23-04 LAR H23-02 Enclosure Response to Final EXHB RAI for Hope Creek, Salem 1 and 2 Amendment to modify Exclusion Area Boundary (EPID L-2023-LLA-0125) | |||
LR-N24-0024 10 CFR 50.90 Enclosure LAR S23-04 LAR H23-02 1 | |||
BACKGROUND Pursuant to 10 CFR 50.90 and by {{letter dated|date=September 6, 2023|text=letter dated September 6, 2023}} (Agencywide Documents Access and Management System (ADAMS) Accession No. ML23249A260), Public Service Enterprise Group Nuclear LLC (PSEG, the Licensees) submitted a license amendment request (LAR) to change the licensing bases as described in the Salem and Hope Creek Updated Final Safety Analysis Reports (UFSARs) to account for proposed modifications to the Exclusion Area Boundary (EAB) for the Salem and Hope Creek nuclear generating stations at the PSEG site. | |||
The NRC staff reviewed the initial LAR submittal. Additional data and information needs pertaining to the accident-related, offsite atmospheric dispersion modeling for the respective EABs and the meteorological (Met) data input to that modeling were identified. These needs were provided to PSEG by email on September 28, 2023 (see ML23283A016) and discussed with the applicant on October 3, 2023. PSEG provided the supplemental data and information on October 30, 2023 (see ML21308A069). The NRC staff reviewed the supplemental submittal and determined that further clarification of the Met monitoring program and data processing was still necessary. PSEG responded by email on December 21, 2023 (see ML23355A273) to NRCs follow-up questions of December 11, 2023. | The NRC staff reviewed the initial LAR submittal. Additional data and information needs pertaining to the accident-related, offsite atmospheric dispersion modeling for the respective EABs and the meteorological (Met) data input to that modeling were identified. These needs were provided to PSEG by email on September 28, 2023 (see ML23283A016) and discussed with the applicant on October 3, 2023. PSEG provided the supplemental data and information on October 30, 2023 (see ML21308A069). The NRC staff reviewed the supplemental submittal and determined that further clarification of the Met monitoring program and data processing was still necessary. PSEG responded by email on December 21, 2023 (see ML23355A273) to NRCs follow-up questions of December 11, 2023. | ||
The requests for additional information (RAIs) here are based on the NRC staffs review of the various submittals and responses above because: (1) they may result in a need for PSEG to revise the atmospheric dispersion modeling the results of which are a direct input to the radiological dose evaluations in the original LAR, and (2) to reconcile noted discrepancies within the LAR and related submittals and/or the respective UFSARs. | The requests for additional information (RAIs) here are based on the NRC staffs review of the various submittals and responses above because: (1) they may result in a need for PSEG to revise the atmospheric dispersion modeling the results of which are a direct input to the radiological dose evaluations in the original LAR, and (2) to reconcile noted discrepancies within the LAR and related submittals and/or the respective UFSARs. | ||
REGULATORY BASIS The radiological dose analyses that accompany this LAR, as submitted under 10 CFR 50.90, require, as direct inputs, dispersion parameters (i.e., relative concentrations or X/Qs). These X/Qs are based on using an appropriate dispersion model that relies, in part, on the input of representative Met data. The dispersion analyses for this LAR consider the offsite impacts at the proposed EAB for the Salem and Hope Creek facilities due to potential accident releases from those plants. | |||
REGULATORY BASIS | |||
The radiological dose analyses that accompany this LAR, as submitted under 10 CFR 50.90, require, as direct inputs, dispersion parameters (i.e., relative concentrations or X/Qs). These X/Qs are based on using an appropriate dispersion model that relies, in part, on the input of representative Met data. The dispersion analyses for this LAR consider the offsite impacts at the proposed EAB for the Salem and Hope Creek facilities due to potential accident releases from those plants. | |||
Relevant guidance on modeling offsite dispersion parameters is given by: | Relevant guidance on modeling offsite dispersion parameters is given by: | ||
Regulatory Guide (RG) 1.145, Atmospheric Dispersion Models for Potential Accident Consequence Assessments at Nuclear Power Plants, Revision 1, November 1982 (Reissued February 1983 for correction), ADAMS Accession No. ML003740205; and NUREG/CR-2858, PAVAN: An Atmospheric Dispersion Program for Evaluating Design-Basis Accidental Releases of Radioactive Materials from Nuclear Power Plants, November 1982, ADAMS Accession No. ML12045A149. | |||
NUREG/CR-2260, Technical Basis for Regulatory Guide 1.145, Atmospheric Dispersion Models for Potential Accident Consequence Assessments at Nuclear Power Plants, October 1981, ADAMS Accession No. ML12045A197. | |||
LR-N24-0024 10 CFR 50.90 Enclosure LAR S23-04 LAR H23-02 2 | |||
Relevant guidance on meteorological monitoring is given by: | Relevant guidance on meteorological monitoring is given by: | ||
RG 1.23, Meteorological Monitoring Programs for Nuclear Power Plants, Revision 1, March 2007, ADAMS Accession No. ML070350028. | |||
REQUESTS FOR ADDITIONAL INFORMATION | |||
REQUESTS FOR ADDITIONAL INFORMATION | |||
===RAI-1=== | ===RAI-1=== | ||
According to Section 2.1 (Para. 2) and Section 2.2 of the original LAR submittal of Sept. 6, 2023 (ML23249A260), the EAB for Salem Units 1 and 2 and Hope Creek is said to be common on land and coextensive with the Salem and Hope Creek site boundary, see also LAR Figure 2.2-1. Section 2.2 (Para. 2) and Figure 2.2-1 identifies the minimum distance to the respective EABs in the Delaware River (i.e., 1270 m for Salem Units 1 and 2 and 901 m for Hope Creek). | According to Section 2.1 (Para. 2) and Section 2.2 of the original LAR submittal of Sept. 6, 2023 (ML23249A260), the EAB for Salem Units 1 and 2 and Hope Creek is said to be common on land and coextensive with the Salem and Hope Creek site boundary, see also LAR Figure 2.2-1. Section 2.2 (Para. 2) and Figure 2.2-1 identifies the minimum distance to the respective EABs in the Delaware River (i.e., 1270 m for Salem Units 1 and 2 and 901 m for Hope Creek). | ||
Is/are the proposed EAB(s) for Salem Units 1 and 2 and Hope Creek on land and/or in the Delaware River still common or separate? Note that LAR Figures 2.6-1 and 2.6-2 look much the same for both facilities on land, but different in the Delaware River. Please clarify in the LAR and the respective Updated Final Safety Analysis Reports (UFSARs). | Is/are the proposed EAB(s) for Salem Units 1 and 2 and Hope Creek on land and/or in the Delaware River still common or separate? Note that LAR Figures 2.6-1 and 2.6-2 look much the same for both facilities on land, but different in the Delaware River. Please clarify in the LAR and the respective Updated Final Safety Analysis Reports (UFSARs). | ||
Response to RAI-1 As described in Section 2.2 of the LAR, the current Exclusion Area Boundary (EAB) on land is common for both Salem and Hope Creek as depicted in LAR Figure 2.2-1. This common, on-land EAB is that area for which PSEG is responsible regarding the control of accident radiation exposure to plant personnel and members of the public. In LAR figures 2.6-1 and 2.6-2, the newly proposed EAB on-land continues to be depicted as common for both units, integrating the results of the revised dose consequence analyses for both stations. | Response to RAI-1 As described in Section 2.2 of the LAR, the current Exclusion Area Boundary (EAB) on land is common for both Salem and Hope Creek as depicted in LAR Figure 2.2-1. This common, on-land EAB is that area for which PSEG is responsible regarding the control of accident radiation exposure to plant personnel and members of the public. In LAR figures 2.6-1 and 2.6-2, the newly proposed EAB on-land continues to be depicted as common for both units, integrating the results of the revised dose consequence analyses for both stations. | ||
LAR Section 2.2 also describes the extension of each plants EAB into the Delaware River. | LAR Section 2.2 also describes the extension of each plants EAB into the Delaware River. | ||
Figure 2.2-1 of the LAR does not depict these EAB extensions into the river since control of river occupation/traffic and any evacuation of members of the public in response to a site release is solely the responsibility of the US Coast Guard and not PSEG. The depictions of the Salem and Hope Creek EABs over the Delaware River in LAR figures 2.6-1 and 2.6-2 respectively are intended to reflect the methodology used in the supporting analyses that establish the new boundary lines for each stations EAB. The approach for establishing the EAB boundaries on land and in the water is described in the response to RAI-2. | Figure 2.2-1 of the LAR does not depict these EAB extensions into the river since control of river occupation/traffic and any evacuation of members of the public in response to a site release is solely the responsibility of the US Coast Guard and not PSEG. The depictions of the Salem and Hope Creek EABs over the Delaware River in LAR figures 2.6-1 and 2.6-2 respectively are intended to reflect the methodology used in the supporting analyses that establish the new boundary lines for each stations EAB. The approach for establishing the EAB boundaries on land and in the water is described in the response to RAI-2. | ||
The Salem and Hope Creek UFSARs will be updated to reflect the common, on-land EAB as established by the methodology described in the response to RAI-2 and depicted in LAR Figures 2.6-1 and 2.6-2. Although the EAB is depicted over the Delaware River for each station, responsibility for restricting members of the public from the Delaware River remains with the US Coast Guard. | The Salem and Hope Creek UFSARs will be updated to reflect the common, on-land EAB as established by the methodology described in the response to RAI-2 and depicted in LAR Figures 2.6-1 and 2.6-2. Although the EAB is depicted over the Delaware River for each station, responsibility for restricting members of the public from the Delaware River remains with the US Coast Guard. | ||
LR-N24-0024 10 CFR 50.90 Enclosure LAR S23- 04 LAR H23-02 | LR-N24-0024 10 CFR 50.90 Enclosure LAR S23-04 LAR H23-02 3 | ||
===RAI-2=== | ===RAI-2=== | ||
For any given accident scenario at either Salem Units 1 and 2 or Hope Creek and evaluated in this LAR, will any of the releases to the ambient atmosphere occur simultaneously from multiple release points or locations such that the composite impacts may be additive? If not, why or why not and, if so, should more than one release location have been accounted for with such an accident? | For any given accident scenario at either Salem Units 1 and 2 or Hope Creek and evaluated in this LAR, will any of the releases to the ambient atmosphere occur simultaneously from multiple release points or locations such that the composite impacts may be additive? If not, why or why not and, if so, should more than one release location have been accounted for with such an accident? | ||
Response to RAI-2 Depending on the specific accident scenario (e.g., LOCA), releases to the ambient atmosphere can occur simultaneously from multiple release locations (i.e., release pathways). Each of these release pathways has a specific radionuclide release profile and timing sequence during the duration of the accident. The dose contribution from each of these release pathways is summed (additive) to determine the total dose at the dose receptor (i.e., new EAB). With respect to the new EAB relative concentration value (/Q) used for each release pathway, a single bounding /Q value is used for all release pathways, regardless of where the exact release location may be for that particular release pathway. A circle is defined which encompasses all release locations when measuring the nearest distance to the new EAB. The distance to the nearest point of the new EAB from the center of the circle is measured and the radius of the circle surrounding the release locations is subtracted to determine a new minimum distance for calculating the new EAB /Q value so that the /Q value would be bounding for all release locations (smaller distance equates to larger /Q). As indicated in the LAR, this approach is used for all accident dose analyses except in case of the Salem Unit 1 Steam Generator Tube Rupture (SGTR) accident. The most limiting distance from the Main Steam Safety Valves (MSSVs) to the new EAB is used to calculate a less conservative (yet still bounding for all release pathways) new EAB /Q value for the Salem Unit 1 SGTR accident analysis. Figure 3.1-1 for Hope Creek and Figures 3.1-2 and 3.1-3 for Salem are provided in the LAR to show these described distances and circles. | |||
Response to RAI-2 Depending on the specific accident scenario (e.g., LOCA), releases to the ambient atmosphere can occur simultaneously from multiple release locations (i.e., release pathways). Each of these release pathways has a specific radionuclide release profile and timing sequence during the duration of the accident. The dose contribution from each of these release pathways is summed (additive) to determine the total dose at the dose receptor (i.e., new EAB). With respect to the new EAB relative concentration value (/Q) used for each release pathway, a single bounding / Q value is used for all release pathways, regardless of where the exact release location may be for that particular release pathway. A circle is defined which encompasses all release locations when measuring the nearest distance to the new EAB. The distance to the nearest point of the new EAB from the center of the circle is measured and the radius of the circle surrounding the release locations is subtracted to determine a new minimum distance for calculating the new EAB / Q value so that the / Q value would be bounding for all release locations (smaller distance equates to larger / Q). As indicated in the LAR, this approach is used for all accident dose analyses except in case of the Salem Unit 1 Steam Generator Tube Rupture (SGTR) accident. The most limiting distance from the Main Steam Safety Valves (MSSVs) to the new EAB is used to calculate a less conservative (yet still bounding for all release pathways) new EAB / Q value for the Salem Unit 1 SGTR accident analysis. Figure 3.1-1 for Hope Creek and Figures 3.1-2 and 3.1-3 for Salem are provided in the LAR to show these described distances and circles. | |||
===RAI-3=== | ===RAI-3=== | ||
The NRC staff notes that the PAVAN dispersion model does not include a provision to account for plume rise and, if applicable to a given accident source, the plume rise would have to be determined separately. If any of the accident releases in this LAR are determined to be elevated due to plume rise for the duration of the accident (i.e., greater than 2.5 times the height of adjacent solid structures), then the applicability of determining stability class based on the delta-T between 150 ft and 33 ft would also need to be evaluated. | The NRC staff notes that the PAVAN dispersion model does not include a provision to account for plume rise and, if applicable to a given accident source, the plume rise would have to be determined separately. If any of the accident releases in this LAR are determined to be elevated due to plume rise for the duration of the accident (i.e., greater than 2.5 times the height of adjacent solid structures), then the applicability of determining stability class based on the delta-T between 150 ft and 33 ft would also need to be evaluated. | ||
a) For the Salem Units 1 and 2 accident scenarios, what is/are the temperature(s) relative to atmospheric conditions at the point(s) of release to the open environment due to a Loss of Coolant Accident (LOCA) and to the Steam Generator Tube Rupture (SGTR) accidents for Salem Unit 1 and, if applicable, any of the other accident scenarios listed in LAR Table 2.3-1 and Subsection 2.6.2.1 (Para. 3) (i.e., a Main Steam Line Break (MSLB), especially if still a high energy release at the point(s) the outside atmosphere is reached, and, if applicable, | |||
LR-N24-0024 10 CFR 50.90 Enclosure LAR S23-04 LAR H23-02 4 | |||
LR-N24-0024 10 CFR 50.90 Enclosure LAR S23- 04 LAR H23-02 | |||
any of the other accident scenarios (i.e., Locked Rotor Accident (LRA), Fuel Handling Accident (FHA), and Rod Ejection Accident (REA))? Also, for any applicable accident scenario, please indicate the orientation (e.g., vertical, horizontal) and characteristics (e.g., | any of the other accident scenarios (i.e., Locked Rotor Accident (LRA), Fuel Handling Accident (FHA), and Rod Ejection Accident (REA))? Also, for any applicable accident scenario, please indicate the orientation (e.g., vertical, horizontal) and characteristics (e.g., | ||
capped, uncapped) of any respective release location(s) as well as the corresponding exit velocities or alternatively the inside stack diameter(s) and flow rate(s). | capped, uncapped) of any respective release location(s) as well as the corresponding exit velocities or alternatively the inside stack diameter(s) and flow rate(s). | ||
This information is needed in order to confirm the reasonability of having assumed that ground-level releases in the PAVAN dispersion modeling apply to all accidents as opposed to an effective elevated release given that the proposed sector-specific distances to the EAB are being reduced (by about 500 m on land and about 400 m in the Delaware River) such that the maximum impact point could extend beyond one or more of these proposed sector-specific EAB distances. | This information is needed in order to confirm the reasonability of having assumed that ground-level releases in the PAVAN dispersion modeling apply to all accidents as opposed to an effective elevated release given that the proposed sector-specific distances to the EAB are being reduced (by about 500 m on land and about 400 m in the Delaware River) such that the maximum impact point could extend beyond one or more of these proposed sector-specific EAB distances. | ||
b) For the Hope Creek accident scenarios, what is/are the temperature(s) relative to atmospheric conditions at the point(s) of release to the open environment due to a LOCA (e.g., for the Main Steam Isolation Valves (MSIVs)), and a MSLB especially if either or both are still a high energy release at the point(s) the outside atmosphere is reached) and, if applicable, any of the other accident scenarios listed in LAR Table 2.4-1 and Subsection 2.6.2.2 (Para. 2) (i.e., FHA, Control Rod Drop Accident (CRDA), Instrument Line Pipe Break (ILPB), and Feedwater Line Break outside containment (FWLB))? Also, for any applicable accident scenario, please indicate the orientation (e.g., vertical, horizontal) and characteristics (e.g., capped, uncapped) of any respective release location(s) as well as the corresponding exit velocities or alternatively the inside stack diameter(s) and flow rate(s). | b) For the Hope Creek accident scenarios, what is/are the temperature(s) relative to atmospheric conditions at the point(s) of release to the open environment due to a LOCA (e.g., for the Main Steam Isolation Valves (MSIVs)), and a MSLB especially if either or both are still a high energy release at the point(s) the outside atmosphere is reached) and, if applicable, any of the other accident scenarios listed in LAR Table 2.4-1 and Subsection 2.6.2.2 (Para. 2) (i.e., FHA, Control Rod Drop Accident (CRDA), Instrument Line Pipe Break (ILPB), and Feedwater Line Break outside containment (FWLB))? Also, for any applicable accident scenario, please indicate the orientation (e.g., vertical, horizontal) and characteristics (e.g., capped, uncapped) of any respective release location(s) as well as the corresponding exit velocities or alternatively the inside stack diameter(s) and flow rate(s). | ||
This information is needed in order to confirm the reasonability of having assumed that ground-level releases in the PAVAN dispersion modeling apply to all accidents as opposed to an effective elevated release given that the proposed sector-specific distances to the EAB are being reduced (by about 450 m on land and in the Delaware River) such that the maximum impact point could extend beyond one or more of these proposed sector-specific EAB distances. | This information is needed in order to confirm the reasonability of having assumed that ground-level releases in the PAVAN dispersion modeling apply to all accidents as opposed to an effective elevated release given that the proposed sector-specific distances to the EAB are being reduced (by about 450 m on land and in the Delaware River) such that the maximum impact point could extend beyond one or more of these proposed sector-specific EAB distances. | ||
Response to RAI-3 Consistent with the existing design basis, the relative concentration values (/Q) for Salem and Hope Creek are determined using the ground level release mode in PAVAN. PAVAN allows the calculation of /Q values using a ground level release mode or an elevated release mode. | Response to RAI-3 Consistent with the existing design basis, the relative concentration values (/Q) for Salem and Hope Creek are determined using the ground level release mode in PAVAN. PAVAN allows the calculation of /Q values using a ground level release mode or an elevated release mode. | ||
For this scenario, assuming a ground level release (i.e., a release at a height of 10 meters) is considered conservative with respect to an elevated release because the ground level release mode provides bounding /Q values at the new EAB and at all distances beyond the new EAB. | For this scenario, assuming a ground level release (i.e., a release at a height of 10 meters) is considered conservative with respect to an elevated release because the ground level release mode provides bounding /Q values at the new EAB and at all distances beyond the new EAB. | ||
Since bounding /Q values for the new EAB and beyond are calculated, and since /Q values decrease as a function of downwind distance under the ground level release mode, using the ground level release mode provides maximum /Q values at the new EAB that can conservatively be used in downstream radiological accident analyses. | |||
decrease as a function of downwind distance under the ground level release mode, using the ground level release mode provides maximum /Q values at the new EAB that can conservatively be used in downstream radiological accident analyses. | |||
Note that PAVAN does not include many of the provisions included in other dispersion codes such as XOQDOQ and ARCON96 (e.g., vent velocity and stack diameter). However, a provision for building wake area is included in PAVAN, and this area term is conservatively minimized in the PAVAN model used for Salem and Hope Creek. | LR-N24-0024 10 CFR 50.90 Enclosure LAR S23-04 LAR H23-02 5 | ||
Note that PAVAN does not include many of the provisions included in other dispersion codes such as XOQDOQ and ARCON96 (e.g., vent velocity and stack diameter). However, a provision for building wake area is included in PAVAN, and this area term is conservatively minimized in the PAVAN model used for Salem and Hope Creek. | |||
===RAI-4=== | ===RAI-4=== | ||
Section 3 (Sent. 2) of the original LAR submittal of Sept. 6, 2023 (ML23249A260) states [f]or the Salem SGTR event, the dose results for the Control Room and Low Population Zone were also recalculated. On the other hand, Section 3.1 (Para. 5) states [N]ote that the Control Room and Low Population Zone (LPZ) X/Qs are not revised for this activity, as the distances to the Control Rooms and LPZ are not impacted. Tables 3.3-2 and 3.3-3 for the pre-accident and concurrent iodine spike cases for the Salem Unit 1 SGTR accident and Tables 3.3-4 and 3.3-5 for the respective iodine spike cases for a Unit 2 SGTR accident provide, in addition to the EAB TEDE doses, TEDE dose values at the Control Room and LPZ. | Section 3 (Sent. 2) of the original LAR submittal of Sept. 6, 2023 (ML23249A260) states [f]or the Salem SGTR event, the dose results for the Control Room and Low Population Zone were also recalculated. On the other hand, Section 3.1 (Para. 5) states [N]ote that the Control Room and Low Population Zone (LPZ) X/Qs are not revised for this activity, as the distances to the Control Rooms and LPZ are not impacted. Tables 3.3-2 and 3.3-3 for the pre-accident and concurrent iodine spike cases for the Salem Unit 1 SGTR accident and Tables 3.3-4 and 3.3-5 for the respective iodine spike cases for a Unit 2 SGTR accident provide, in addition to the EAB TEDE doses, TEDE dose values at the Control Room and LPZ. | ||
a) The Control Room and LPZ X/Qs used for these dose calculations do not appear to be otherwise identified in the LAR. Please identify or cross-reference the X/Q values, meteorological data on which those X/Qs are based, and any other dispersion modeling-related assumptions (including the model used to estimate the Control Room X/Qs) that support these dose calculations. The LAR and respective UFSARs should be updated accordingly to explain this information. | a) The Control Room and LPZ X/Qs used for these dose calculations do not appear to be otherwise identified in the LAR. Please identify or cross-reference the X/Q values, meteorological data on which those X/Qs are based, and any other dispersion modeling-related assumptions (including the model used to estimate the Control Room X/Qs) that support these dose calculations. The LAR and respective UFSARs should be updated accordingly to explain this information. | ||
b) Please address the difference, if any, between a SGTR accident at Salem Unit 1 and Salem Unit 2 since the latter does not otherwise appear to be addressed and update the LAR and respective UFSARs accordingly. This includes explaining why only the SGTR accident for Salem Unit 1 was specified for modeling (i.e., in Table 2.6-1) while: (1) the total TEDE dose at the proposed EAB for Salem Unit 2 is slightly higher in Tables 3.3-4 and 3.3-5 compared to the total TEDE dose at the proposed EAB for Salem Unit 1 in Tables 3.3-2 and 3.3-3, (2) the distance to the proposed EAB is less from Salem Unit 2 versus Salem Unit 1 as shown in Table 2.6-1 considering that a ground-level release has been assumed and for such releases the X/Qs decrease with increasing distance, and (3) the X/Q attributed to Unit 2 as specified in Table 3.3-1 (second page) (i.e., 2.44 E-04) corresponds to the maximum X/Q in Table 3.1-7 (i.e., All Accidents except Salem SGTR Unit 1). - | b) Please address the difference, if any, between a SGTR accident at Salem Unit 1 and Salem Unit 2 since the latter does not otherwise appear to be addressed and update the LAR and respective UFSARs accordingly. This includes explaining why only the SGTR accident for Salem Unit 1 was specified for modeling (i.e., in Table 2.6-1) while: (1) the total TEDE dose at the proposed EAB for Salem Unit 2 is slightly higher in Tables 3.3-4 and 3.3-5 compared to the total TEDE dose at the proposed EAB for Salem Unit 1 in Tables 3.3-2 and 3.3-3, (2) the distance to the proposed EAB is less from Salem Unit 2 versus Salem Unit 1 as shown in Table 2.6-1 considering that a ground-level release has been assumed and for such releases the X/Qs decrease with increasing distance, and (3) the X/Q attributed to Unit 2 as specified in Table 3.3-1 (second page) (i.e., 2.44 E-04) corresponds to the maximum X/Q in Table 3.1-7 (i.e., All Accidents except Salem SGTR Unit 1). - | ||
c) Please update the LAR and UFSARs to explain the basis for applying the maximum X/Q for Salem Unit 1 (i.e., 2.44 E-04) from Table 3.1-7 to Salem Unit 2 for all of the accidents listed in Table 3.4-1 which include at least two accident scenarios (i.e., the LRA and REA) that are not shown in Table 2.4-1 for Unit 2. | |||
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Response to RAI-4 a) The original design basis CR and LPZ /Qs are not revised since the distances to the CR and LPZ are not impacted by this activity, and therefore the original design basis CR and LPZ /Qs continue to be used for the SGTR analysis. Per Section 2.6.2.1 of the LAR, the revised SGTR analysis also added a calculated flashing fraction for the primary coolant (rupture flow) entering the faulted steam generator and increased the iodine partition coefficient for both the faulted and intact steam generators. The details of these changes are described in Section 3.3 of the LAR. These changes to the SGTR analysis caused the dose results for the Control Room (CR) and Low Population Zone (LPZ) to change. | |||
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Response to RAI-4 | |||
a) The original design basis CR and LPZ /Qs are not revised since the distances to the CR and LPZ are not impacted by this activity, and therefore the original design basis CR and LPZ /Qs continue to be used for the SGTR analysis. Per Section 2.6.2.1 of the LAR, the revised SGTR analysis also added a calculated flashing fraction for the primary coolant (rupture flow) entering the faulted steam generator and increased the iodine partition coefficient for both the faulted and intact steam generators. The details of these changes are described in Section 3.3 of the LAR. These changes to the SGTR analysis caused the dose results for the Control Room (CR) and Low Population Zone (LPZ) to change. | |||
b) The intention of the text Salem - All RG 1.183 Accidents except S1 SGTR in Table 2.6-1 is to identify applicability of the EAB distance in that table row to all Salem accidents, including the Salem SGTR Unit 2 accident. The intention of the text S1 SGTR in Table 2.6-1 is to identify applicability of the EAB distance in that table row to only the Salem SGTR Unit 1 accident. | b) The intention of the text Salem - All RG 1.183 Accidents except S1 SGTR in Table 2.6-1 is to identify applicability of the EAB distance in that table row to all Salem accidents, including the Salem SGTR Unit 2 accident. The intention of the text S1 SGTR in Table 2.6-1 is to identify applicability of the EAB distance in that table row to only the Salem SGTR Unit 1 accident. | ||
The differences between the Salem SGTR Unit 1 accident and the Salem SGTR Unit 2 accident are many; reactor coolant volume, steam temperature, steam mass released, etc. | The differences between the Salem SGTR Unit 1 accident and the Salem SGTR Unit 2 accident are many; reactor coolant volume, steam temperature, steam mass released, etc. | ||
This is due to the fact that Unit 1 and Unit 2 have different steam generator designs (Westinghouse vs. Framatome). However, as related to this activity, the only difference between the Salem SGTR Unit 1 accident and the Salem SGTR Unit 2 accident is how the EAB /Q value is determined. For Unit 2, the minimum EAB distance used is taken as the distance from the perimeter of a circular accident release boundary with a radius of 85 meters. For Unit 1, the minimum EAB distance used is taken as the distance from the main steam safety valves (MSSVs) located in the Inner and Outer Penetration Areas. This approach is described in Section 2.6.1 of the LAR, and Figures 3.1-2 and 3.1-3 are provided in the LAR to show these described distances and circles. | This is due to the fact that Unit 1 and Unit 2 have different steam generator designs (Westinghouse vs. Framatome). However, as related to this activity, the only difference between the Salem SGTR Unit 1 accident and the Salem SGTR Unit 2 accident is how the EAB /Q value is determined. For Unit 2, the minimum EAB distance used is taken as the distance from the perimeter of a circular accident release boundary with a radius of 85 meters. For Unit 1, the minimum EAB distance used is taken as the distance from the main steam safety valves (MSSVs) located in the Inner and Outer Penetration Areas. This approach is described in Section 2.6.1 of the LAR, and Figures 3.1-2 and 3.1-3 are provided in the LAR to show these described distances and circles. | ||
c) Per Section 3.1.2 of the LAR, a new EAB /Q of 2.44E-04 s/m3 is conservatively calculated based on one (1) bounding distance that is used for all Salem accident analyses except for the Unit 1 SGTR accident. The value of 1.97E-04 s/m3 for the Unit-1 SGTR /Q is calculated based on the most limiting distance from the inboard and outboard MSSVs (i.e., | c) Per Section 3.1.2 of the LAR, a new EAB /Q of 2.44E-04 s/m3 is conservatively calculated based on one (1) bounding distance that is used for all Salem accident analyses except for the Unit 1 SGTR accident. The value of 1.97E-04 s/m3 for the Unit-1 SGTR /Q is calculated based on the most limiting distance from the inboard and outboard MSSVs (i.e., | ||
the release points) for that event. | the release points) for that event. | ||
===RAI-5=== | ===RAI-5=== | ||
Section 3.1 (Para. 4, Sent. 2) states [t]he 95th percentile EAB X/Q values were calculated to support accident analyses for Salem and Hope Creek using the PAVAN computer code for the updated distances. Please correct and clarify the phrase The 95th | Section 3.1 (Para. 4, Sent. 2) states [t]he 95th percentile EAB X/Q values were calculated to support accident analyses for Salem and Hope Creek using the PAVAN computer code for the updated distances. Please correct and clarify the phrase The 95th percentile EAB X/Q values to read The 0.5 percent sector-specific and 5 percent overall site EAB X/Q values, which is consistent with the methodology in Reg Guide 1.145 and NUREG/CR-2260. The NRC staff notes that correction of the phrase 95th percentile is also needed in Section 3.1.2 (Para. 1, Sent.1) and in Subsection 3.1.2.3 (Para. 2, Sent. 1) of the original LAR submittal of Sept. 6, 2023 (ML23249A260) by changing it to read 0.5 percent sector-specific. | ||
2260. The NRC staff notes that correction of the phrase 95th percentile is also needed in Section 3.1.2 (Para. 1, Sent.1) and in Subsection 3.1.2.3 (Para. 2, Sent. 1) of the original LAR submittal of Sept. 6, 2023 (ML23249A260) by changing it to read 0.5 percent sector-specific. | Similar corrections may also be needed in the supplemental LAR submittal dated October 30, 2023 (ML23303A144) and in the respective UFSARs. Finally, the NRC staff notes that the | ||
Similar corrections may also be needed in the supplemental LAR submittal dated October 30, 2023 (ML23303A144) and in the respective UFSARs. Finally, the NRC staff notes that the | |||
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summary tables in the Hope Creek and Salem Units 1 and 2 PAVAN output files provided by PSEG correctly label the controlling X/Q, in those cases, as the 0.5 percent X/Q limiting value. | summary tables in the Hope Creek and Salem Units 1 and 2 PAVAN output files provided by PSEG correctly label the controlling X/Q, in those cases, as the 0.5 percent X/Q limiting value. | ||
Response to RAI-5 It is agreed that the 95th percentile value represents the larger of the 0.5% maximum sector value and the 5% overall site value (as determined internally within the PAVAN software). The Salem and Hope Creek /Q PAVAN calculations describe this detail in the calculation body text and state that this value is commonly referred to as the 95th percentile /Q. This terminology is then carried over to the LAR. The intent of using 95th percentile /Q is strictly for nomenclature purposes. | |||
Response to RAI-5 It is agreed that the 95th percentile value represents the larger of the 0.5% maximum sector value and the 5% overall site value (as determined internally within the PAVAN software). The Salem and Hope Creek /Q PAVAN calculations describe this detail in the calculation body text and state that this value is commonly referred to as the 95th percentile /Q. This terminology is then carried over to the LAR. The intent of using 95th percentile / Q is strictly for nomenclature purposes. | |||
===RAI-6=== | ===RAI-6=== | ||
| Line 177: | Line 115: | ||
Please correct the LAR submittal in Section 3.1.1 and elsewhere as needed to read Additionally, hourly T based on 46 m - 10 m (150 ft. - 33 ft.), 60 m - 10 m (197 ft. - 33 ft.), | Please correct the LAR submittal in Section 3.1.1 and elsewhere as needed to read Additionally, hourly T based on 46 m - 10 m (150 ft. - 33 ft.), 60 m - 10 m (197 ft. - 33 ft.), | ||
and 91 m - 10 m (300 ft. - 33 ft.) temperature differences was included and stability class based on the 46 m - 10 m (150 ft. - 33 ft.) T, respectively. If the upper measurement level used to determine stability class changes based on one or both of the earlier RAI questions, please revise Para. 3 (Sent. 1) as appropriate. The NRC staff notes that Subsection 3.1.1.1 (Para. 1, Sent. 2) correctly states, although inconsistent with the previously indicated text, that T is determined between 46 meters and 10 meters (150 ft. - 33 ft.). The NRC staff further notes that similar discrepancies exist in the PAVAN input and output files provided by PSEG for this LAR. | and 91 m - 10 m (300 ft. - 33 ft.) temperature differences was included and stability class based on the 46 m - 10 m (150 ft. - 33 ft.) T, respectively. If the upper measurement level used to determine stability class changes based on one or both of the earlier RAI questions, please revise Para. 3 (Sent. 1) as appropriate. The NRC staff notes that Subsection 3.1.1.1 (Para. 1, Sent. 2) correctly states, although inconsistent with the previously indicated text, that T is determined between 46 meters and 10 meters (150 ft. - 33 ft.). The NRC staff further notes that similar discrepancies exist in the PAVAN input and output files provided by PSEG for this LAR. | ||
Response to RAI-6 The LAR text in question identified in RAI-6 describes the elevations from which hourly T values were obtained for developing updated joint frequency distributions (JFDs). The referenced LAR text expresses the two meteorological tower elevations from which a set of T data are derived. For instance, the expression 10 m - 46 m (33 ft. - 150 ft.) means the T was determined between the temperature sensor located at 10 m (33 ft.) and the sensor located at 46 m (150 ft.). The T value is an absolute value derived from the difference in sensed temperatures at each of the listed meteorological tower elevations. The order in which the elevations are expressed have no bearing on the numerical value of T since the dash between each elevation is intended to mean to and not a minus sign (i.e., a negative elevation). As such, the resultant value of the Ts determined for each of the listed ranges of elevations are the same regardless of the order in which the elevations are described in each range of Ts. | |||
The upper elevation measurement used to determine the stability class identified in the LAR is not changed as a result of the responses to any of the questions in this RAI and is therefore still applicable. | |||
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===RAI-7=== | ===RAI-7=== | ||
Subsection 3.1.1.1 (Para. 1, Sent. 2) states, in part, the updated JFDs were constructed using hourly wind speed and direction recorded at the 10 meter (33 ft.) level. If the upper measurement level used to determine stability class changes based on one or both of the earlier RAI questions, the use of wind data from a higher measurement level for the Salem Units 1 and 2 and/or the Hope Creek dispersion modeling analyses with PAVAN also needs to be evaluated. If so, considering the comparison between the joint frequency distributions (JFDs) in the LAR and those used to support a previous Early Site Permit application, please revise Para. 1 and any other affected text accordingly. More importantly, the JFDs in Tables 3.1-1 and 3.1-2 of the original LAR submittal of Sept. 6, 2023 (ML23249A260) and in Attachments 2 and 3 of the supplemental LAR submittal dated October 30, 2023 (ML23303A144) may also need to be revised as well as the affected PAVAN dispersion modeling, radiological doses, and related text. | Subsection 3.1.1.1 (Para. 1, Sent. 2) states, in part, the updated JFDs were constructed using hourly wind speed and direction recorded at the 10 meter (33 ft.) level. If the upper measurement level used to determine stability class changes based on one or both of the earlier RAI questions, the use of wind data from a higher measurement level for the Salem Units 1 and 2 and/or the Hope Creek dispersion modeling analyses with PAVAN also needs to be evaluated. If so, considering the comparison between the joint frequency distributions (JFDs) in the LAR and those used to support a previous Early Site Permit application, please revise Para. 1 and any other affected text accordingly. More importantly, the JFDs in Tables 3.1-1 and 3.1-2 of the original LAR submittal of Sept. 6, 2023 (ML23249A260) and in Attachments 2 and 3 of the supplemental LAR submittal dated October 30, 2023 (ML23303A144) may also need to be revised as well as the affected PAVAN dispersion modeling, radiological doses, and related text. | ||
Response to RAI-7 Based on the RAI responses above, there is no change to the upper measurement level used for determination of stability class, nor is there a change to the assumed release elevations. | |||
Response to RAI-7 | Therefore, there is no impact to the meteorological data/analyses and associated PAVAN analyses or resulting dose consequences at the proposed EAB. | ||
Based on the RAI responses above, there is no change to the upper measurement level used for determination of stability class, nor is there a change to the assumed release elevations. | |||
Therefore, there is no impact to the meteorological data/analyses and associated | |||
===RAI-8=== | ===RAI-8=== | ||
Subsection 3.1.1.1 (Para. 3, Sent. 2) states Wind speeds were grouped into nominal 0.5 meters per second (m/s) steps from 0.0 m/s to 10.0 m/s and above 10.0 m/s. This statement only partially matches the maximum wind speeds listed in the Salem and Hope Creek PAVAN model input / output files and the individual yearly and composite 3-year (i.e., 2019-2021) wind speed groupings in the JFDs presented in the original and supplemental LAR submittals (ML23249A260 and ML23303A144, respectively). Please correct the statement in Subsection 3.1.1.1 of the LAR, and elsewhere, for consistency with the JFDs and model input / output files. | Subsection 3.1.1.1 (Para. 3, Sent. 2) states Wind speeds were grouped into nominal 0.5 meters per second (m/s) steps from 0.0 m/s to 10.0 m/s and above 10.0 m/s. This statement only partially matches the maximum wind speeds listed in the Salem and Hope Creek PAVAN model input / output files and the individual yearly and composite 3-year (i.e., 2019-2021) wind speed groupings in the JFDs presented in the original and supplemental LAR submittals (ML23249A260 and ML23303A144, respectively). Please correct the statement in Subsection 3.1.1.1 of the LAR, and elsewhere, for consistency with the JFDs and model input / output files. | ||
Response to RAI-8 The wind speed groupings in the JFDs presented in the original and supplemental LAR submittals (ML23249A260 and ML23303A144, respectively) vary in step speed range from calm to maximum wind speeds. The 0.5 m/s was described as nominal to characterize that the actual values are approximate and may vary. The actual speed ranges are provided in the following table: | |||
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Speed Groupings (M/S) | |||
Group Step Speed Range Delta (M/S) | |||
CALM N/A 0.00<WS< 0.50 0.5 0.50<WS< 1.05 0.55 1.05<WS< 1.55 0.5 1.55<WS< 2.05 0.5 2.05<WS< 3.05 1.0 3.05<WS< 4.05 1.0 4.05<WS< 5.05 1.0 5.05<WS< 6.05 1.0 6.05<WS< 8.05 2.0 8.05<WS< 10.00 1.95 WS> 10.00 N/A}} | |||
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Speed Groupings | |||
CALM N/A 0.00<WS< 0.50 0.5 | |||
0.50<WS< 1.05 0.55 | |||
1.05<WS< 1.55 0.5 1.55<WS< 2.05 0.5 | |||
2.05<WS< 3.05 1.0 3.05<WS< 4.05 1.0 | |||
4.05<WS< 5.05 1.0 | |||
5.05<WS< 6.05 1.0 6.05<WS< 8.05 2.0 | |||
8.05<WS< 10.00 1.95 | |||
WS> 10.00 N/A | |||
Latest revision as of 18:31, 24 November 2024
| ML24117A128 | |
| Person / Time | |
|---|---|
| Site: | Salem, Hope Creek  |
| Issue date: | 04/26/2024 |
| From: | Jennings J Public Service Enterprise Group |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| LR-N24-0024, LAR S23-04, LAR H23-02 | |
| Download: ML24117A128 (1) | |
Text
Jason Jennings Director - Site Regulatory Compliance, PSEG PO Box 236 Hancocks Bridge, New Jersey 08038-0221 856-339-1653 Jason.Jennings@PSEG.com 10 CFR 50.90 LAR S23-04 LAR H23-02 LR-N24-0024 April 26, 2024 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, 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 Hope Creek Generating Station Renewed Facility Operating License No. NPF-57 NRC Docket No. 50-354
Subject:
Response to Request for Additional Information Associated with License Amendment Request (LAR) to Modify the Salem and Hope Creek Exclusion Area Boundary
References:
- 1. PSEG letter to NRC, License Amendment Request (LAR) to Modify the Salem and Hope Creek Exclusion Area Boundary, dated September 6, 2023 (ADAMS Accession No. ML23249A261)
- 2. NRC email to PSEG, Salem 1 and 2 - Final EXHB RAI for Hope Creek, Salem 1 and 2 Amendment to modify Exclusion Area Boundary (EPID L-2023-LLA-0125), dated February 28, 2024 (ADAMS Accession No. ML24060A049)
In the Reference 1 letter, PSEG Nuclear LLC (PSEG) submitted a license amendment request (LAR) to Renewed Facility Operating License Numbers DPR-70 and DPR-75 for Salem Generating Station (Salem) and NPF-57 for Hope Creek Generating Station (HCGS) to modify the Exclusion Area Boundary for the PSEG site.
In the Reference 2 email, the NRC provided PSEG a request for additional information (RAI) regarding the dose consequence analyses for both Salem and Hope Creek to support the NRC staffs detailed technical review of the Reference 1 submittal. The enclosure to this letter contains the responses to the RAI questions contained in Reference 2.
PSEG has determined that the information provided in this submittal does not alter the conclusions reached in the 10 CFR 50.92 no significant hazards determination previously submitted. In addition, the information provided in this submittal does not affect the bases for concluding that neither an environmental impact statement nor an environmental assessment needs to be prepared in connection with the proposed amendment.
o PSEG I NUCLEAR
April 26, 2024 10 CFR 50.90 LR-N24-0024 LAR S23-04 Page 2 LAR H23-02 There are no regulatory commitments contained in this letter. If you have any questions or require additional information, please contact Mr. Michael Wiwel at Michael.Wiwel@pseg.com.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on________________
Respectfully, Jason Jennings Director, Site Regulatory Compliance PSEG Nuclear LLC
Enclosure:
Response to Final EXHB RAI for Hope Creek, Salem 1 and 2 Amendment to modify Exclusion Area Boundary (EPID L-2023-LLA-0125) cc:
Administrator, Region I, NRC Mr. J. Kim, Project Manager, NRC NRC Senior Resident Inspector, Salem NRC Senior Resident Inspector, Hope Creek Ms. Ann Pfaff, Manager, NJBNE PSEG Commitment Tracking Coordinator April 26, 2024
- Jennings, Jason Digitally signed by Jennings, Jason Date: 2024.04.26 10:23:18 -04'00'
LR-N24-0024 10 CFR 50.90 LAR S23-04 LAR H23-02 Enclosure Response to Final EXHB RAI for Hope Creek, Salem 1 and 2 Amendment to modify Exclusion Area Boundary (EPID L-2023-LLA-0125)
LR-N24-0024 10 CFR 50.90 Enclosure LAR S23-04 LAR H23-02 1
BACKGROUND Pursuant to 10 CFR 50.90 and by letter dated September 6, 2023 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML23249A260), Public Service Enterprise Group Nuclear LLC (PSEG, the Licensees) submitted a license amendment request (LAR) to change the licensing bases as described in the Salem and Hope Creek Updated Final Safety Analysis Reports (UFSARs) to account for proposed modifications to the Exclusion Area Boundary (EAB) for the Salem and Hope Creek nuclear generating stations at the PSEG site.
The NRC staff reviewed the initial LAR submittal. Additional data and information needs pertaining to the accident-related, offsite atmospheric dispersion modeling for the respective EABs and the meteorological (Met) data input to that modeling were identified. These needs were provided to PSEG by email on September 28, 2023 (see ML23283A016) and discussed with the applicant on October 3, 2023. PSEG provided the supplemental data and information on October 30, 2023 (see ML21308A069). The NRC staff reviewed the supplemental submittal and determined that further clarification of the Met monitoring program and data processing was still necessary. PSEG responded by email on December 21, 2023 (see ML23355A273) to NRCs follow-up questions of December 11, 2023.
The requests for additional information (RAIs) here are based on the NRC staffs review of the various submittals and responses above because: (1) they may result in a need for PSEG to revise the atmospheric dispersion modeling the results of which are a direct input to the radiological dose evaluations in the original LAR, and (2) to reconcile noted discrepancies within the LAR and related submittals and/or the respective UFSARs.
REGULATORY BASIS The radiological dose analyses that accompany this LAR, as submitted under 10 CFR 50.90, require, as direct inputs, dispersion parameters (i.e., relative concentrations or X/Qs). These X/Qs are based on using an appropriate dispersion model that relies, in part, on the input of representative Met data. The dispersion analyses for this LAR consider the offsite impacts at the proposed EAB for the Salem and Hope Creek facilities due to potential accident releases from those plants.
Relevant guidance on modeling offsite dispersion parameters is given by:
Regulatory Guide (RG) 1.145, Atmospheric Dispersion Models for Potential Accident Consequence Assessments at Nuclear Power Plants, Revision 1, November 1982 (Reissued February 1983 for correction), ADAMS Accession No. ML003740205; and NUREG/CR-2858, PAVAN: An Atmospheric Dispersion Program for Evaluating Design-Basis Accidental Releases of Radioactive Materials from Nuclear Power Plants, November 1982, ADAMS Accession No. ML12045A149.
NUREG/CR-2260, Technical Basis for Regulatory Guide 1.145, Atmospheric Dispersion Models for Potential Accident Consequence Assessments at Nuclear Power Plants, October 1981, ADAMS Accession No. ML12045A197.
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Relevant guidance on meteorological monitoring is given by:
RG 1.23, Meteorological Monitoring Programs for Nuclear Power Plants, Revision 1, March 2007, ADAMS Accession No. ML070350028.
REQUESTS FOR ADDITIONAL INFORMATION
RAI-1
According to Section 2.1 (Para. 2) and Section 2.2 of the original LAR submittal of Sept. 6, 2023 (ML23249A260), the EAB for Salem Units 1 and 2 and Hope Creek is said to be common on land and coextensive with the Salem and Hope Creek site boundary, see also LAR Figure 2.2-1. Section 2.2 (Para. 2) and Figure 2.2-1 identifies the minimum distance to the respective EABs in the Delaware River (i.e., 1270 m for Salem Units 1 and 2 and 901 m for Hope Creek).
Is/are the proposed EAB(s) for Salem Units 1 and 2 and Hope Creek on land and/or in the Delaware River still common or separate? Note that LAR Figures 2.6-1 and 2.6-2 look much the same for both facilities on land, but different in the Delaware River. Please clarify in the LAR and the respective Updated Final Safety Analysis Reports (UFSARs).
Response to RAI-1 As described in Section 2.2 of the LAR, the current Exclusion Area Boundary (EAB) on land is common for both Salem and Hope Creek as depicted in LAR Figure 2.2-1. This common, on-land EAB is that area for which PSEG is responsible regarding the control of accident radiation exposure to plant personnel and members of the public. In LAR figures 2.6-1 and 2.6-2, the newly proposed EAB on-land continues to be depicted as common for both units, integrating the results of the revised dose consequence analyses for both stations.
LAR Section 2.2 also describes the extension of each plants EAB into the Delaware River.
Figure 2.2-1 of the LAR does not depict these EAB extensions into the river since control of river occupation/traffic and any evacuation of members of the public in response to a site release is solely the responsibility of the US Coast Guard and not PSEG. The depictions of the Salem and Hope Creek EABs over the Delaware River in LAR figures 2.6-1 and 2.6-2 respectively are intended to reflect the methodology used in the supporting analyses that establish the new boundary lines for each stations EAB. The approach for establishing the EAB boundaries on land and in the water is described in the response to RAI-2.
The Salem and Hope Creek UFSARs will be updated to reflect the common, on-land EAB as established by the methodology described in the response to RAI-2 and depicted in LAR Figures 2.6-1 and 2.6-2. Although the EAB is depicted over the Delaware River for each station, responsibility for restricting members of the public from the Delaware River remains with the US Coast Guard.
LR-N24-0024 10 CFR 50.90 Enclosure LAR S23-04 LAR H23-02 3
RAI-2
For any given accident scenario at either Salem Units 1 and 2 or Hope Creek and evaluated in this LAR, will any of the releases to the ambient atmosphere occur simultaneously from multiple release points or locations such that the composite impacts may be additive? If not, why or why not and, if so, should more than one release location have been accounted for with such an accident?
Response to RAI-2 Depending on the specific accident scenario (e.g., LOCA), releases to the ambient atmosphere can occur simultaneously from multiple release locations (i.e., release pathways). Each of these release pathways has a specific radionuclide release profile and timing sequence during the duration of the accident. The dose contribution from each of these release pathways is summed (additive) to determine the total dose at the dose receptor (i.e., new EAB). With respect to the new EAB relative concentration value (/Q) used for each release pathway, a single bounding /Q value is used for all release pathways, regardless of where the exact release location may be for that particular release pathway. A circle is defined which encompasses all release locations when measuring the nearest distance to the new EAB. The distance to the nearest point of the new EAB from the center of the circle is measured and the radius of the circle surrounding the release locations is subtracted to determine a new minimum distance for calculating the new EAB /Q value so that the /Q value would be bounding for all release locations (smaller distance equates to larger /Q). As indicated in the LAR, this approach is used for all accident dose analyses except in case of the Salem Unit 1 Steam Generator Tube Rupture (SGTR) accident. The most limiting distance from the Main Steam Safety Valves (MSSVs) to the new EAB is used to calculate a less conservative (yet still bounding for all release pathways) new EAB /Q value for the Salem Unit 1 SGTR accident analysis. Figure 3.1-1 for Hope Creek and Figures 3.1-2 and 3.1-3 for Salem are provided in the LAR to show these described distances and circles.
RAI-3
The NRC staff notes that the PAVAN dispersion model does not include a provision to account for plume rise and, if applicable to a given accident source, the plume rise would have to be determined separately. If any of the accident releases in this LAR are determined to be elevated due to plume rise for the duration of the accident (i.e., greater than 2.5 times the height of adjacent solid structures), then the applicability of determining stability class based on the delta-T between 150 ft and 33 ft would also need to be evaluated.
a) For the Salem Units 1 and 2 accident scenarios, what is/are the temperature(s) relative to atmospheric conditions at the point(s) of release to the open environment due to a Loss of Coolant Accident (LOCA) and to the Steam Generator Tube Rupture (SGTR) accidents for Salem Unit 1 and, if applicable, any of the other accident scenarios listed in LAR Table 2.3-1 and Subsection 2.6.2.1 (Para. 3) (i.e., a Main Steam Line Break (MSLB), especially if still a high energy release at the point(s) the outside atmosphere is reached, and, if applicable,
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any of the other accident scenarios (i.e., Locked Rotor Accident (LRA), Fuel Handling Accident (FHA), and Rod Ejection Accident (REA))? Also, for any applicable accident scenario, please indicate the orientation (e.g., vertical, horizontal) and characteristics (e.g.,
capped, uncapped) of any respective release location(s) as well as the corresponding exit velocities or alternatively the inside stack diameter(s) and flow rate(s).
This information is needed in order to confirm the reasonability of having assumed that ground-level releases in the PAVAN dispersion modeling apply to all accidents as opposed to an effective elevated release given that the proposed sector-specific distances to the EAB are being reduced (by about 500 m on land and about 400 m in the Delaware River) such that the maximum impact point could extend beyond one or more of these proposed sector-specific EAB distances.
b) For the Hope Creek accident scenarios, what is/are the temperature(s) relative to atmospheric conditions at the point(s) of release to the open environment due to a LOCA (e.g., for the Main Steam Isolation Valves (MSIVs)), and a MSLB especially if either or both are still a high energy release at the point(s) the outside atmosphere is reached) and, if applicable, any of the other accident scenarios listed in LAR Table 2.4-1 and Subsection 2.6.2.2 (Para. 2) (i.e., FHA, Control Rod Drop Accident (CRDA), Instrument Line Pipe Break (ILPB), and Feedwater Line Break outside containment (FWLB))? Also, for any applicable accident scenario, please indicate the orientation (e.g., vertical, horizontal) and characteristics (e.g., capped, uncapped) of any respective release location(s) as well as the corresponding exit velocities or alternatively the inside stack diameter(s) and flow rate(s).
This information is needed in order to confirm the reasonability of having assumed that ground-level releases in the PAVAN dispersion modeling apply to all accidents as opposed to an effective elevated release given that the proposed sector-specific distances to the EAB are being reduced (by about 450 m on land and in the Delaware River) such that the maximum impact point could extend beyond one or more of these proposed sector-specific EAB distances.
Response to RAI-3 Consistent with the existing design basis, the relative concentration values (/Q) for Salem and Hope Creek are determined using the ground level release mode in PAVAN. PAVAN allows the calculation of /Q values using a ground level release mode or an elevated release mode.
For this scenario, assuming a ground level release (i.e., a release at a height of 10 meters) is considered conservative with respect to an elevated release because the ground level release mode provides bounding /Q values at the new EAB and at all distances beyond the new EAB.
Since bounding /Q values for the new EAB and beyond are calculated, and since /Q values decrease as a function of downwind distance under the ground level release mode, using the ground level release mode provides maximum /Q values at the new EAB that can conservatively be used in downstream radiological accident analyses.
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Note that PAVAN does not include many of the provisions included in other dispersion codes such as XOQDOQ and ARCON96 (e.g., vent velocity and stack diameter). However, a provision for building wake area is included in PAVAN, and this area term is conservatively minimized in the PAVAN model used for Salem and Hope Creek.
RAI-4
Section 3 (Sent. 2) of the original LAR submittal of Sept. 6, 2023 (ML23249A260) states [f]or the Salem SGTR event, the dose results for the Control Room and Low Population Zone were also recalculated. On the other hand, Section 3.1 (Para. 5) states [N]ote that the Control Room and Low Population Zone (LPZ) X/Qs are not revised for this activity, as the distances to the Control Rooms and LPZ are not impacted. Tables 3.3-2 and 3.3-3 for the pre-accident and concurrent iodine spike cases for the Salem Unit 1 SGTR accident and Tables 3.3-4 and 3.3-5 for the respective iodine spike cases for a Unit 2 SGTR accident provide, in addition to the EAB TEDE doses, TEDE dose values at the Control Room and LPZ.
a) The Control Room and LPZ X/Qs used for these dose calculations do not appear to be otherwise identified in the LAR. Please identify or cross-reference the X/Q values, meteorological data on which those X/Qs are based, and any other dispersion modeling-related assumptions (including the model used to estimate the Control Room X/Qs) that support these dose calculations. The LAR and respective UFSARs should be updated accordingly to explain this information.
b) Please address the difference, if any, between a SGTR accident at Salem Unit 1 and Salem Unit 2 since the latter does not otherwise appear to be addressed and update the LAR and respective UFSARs accordingly. This includes explaining why only the SGTR accident for Salem Unit 1 was specified for modeling (i.e., in Table 2.6-1) while: (1) the total TEDE dose at the proposed EAB for Salem Unit 2 is slightly higher in Tables 3.3-4 and 3.3-5 compared to the total TEDE dose at the proposed EAB for Salem Unit 1 in Tables 3.3-2 and 3.3-3, (2) the distance to the proposed EAB is less from Salem Unit 2 versus Salem Unit 1 as shown in Table 2.6-1 considering that a ground-level release has been assumed and for such releases the X/Qs decrease with increasing distance, and (3) the X/Q attributed to Unit 2 as specified in Table 3.3-1 (second page) (i.e., 2.44 E-04) corresponds to the maximum X/Q in Table 3.1-7 (i.e., All Accidents except Salem SGTR Unit 1). -
c) Please update the LAR and UFSARs to explain the basis for applying the maximum X/Q for Salem Unit 1 (i.e., 2.44 E-04) from Table 3.1-7 to Salem Unit 2 for all of the accidents listed in Table 3.4-1 which include at least two accident scenarios (i.e., the LRA and REA) that are not shown in Table 2.4-1 for Unit 2.
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Response to RAI-4 a) The original design basis CR and LPZ /Qs are not revised since the distances to the CR and LPZ are not impacted by this activity, and therefore the original design basis CR and LPZ /Qs continue to be used for the SGTR analysis. Per Section 2.6.2.1 of the LAR, the revised SGTR analysis also added a calculated flashing fraction for the primary coolant (rupture flow) entering the faulted steam generator and increased the iodine partition coefficient for both the faulted and intact steam generators. The details of these changes are described in Section 3.3 of the LAR. These changes to the SGTR analysis caused the dose results for the Control Room (CR) and Low Population Zone (LPZ) to change.
b) The intention of the text Salem - All RG 1.183 Accidents except S1 SGTR in Table 2.6-1 is to identify applicability of the EAB distance in that table row to all Salem accidents, including the Salem SGTR Unit 2 accident. The intention of the text S1 SGTR in Table 2.6-1 is to identify applicability of the EAB distance in that table row to only the Salem SGTR Unit 1 accident.
The differences between the Salem SGTR Unit 1 accident and the Salem SGTR Unit 2 accident are many; reactor coolant volume, steam temperature, steam mass released, etc.
This is due to the fact that Unit 1 and Unit 2 have different steam generator designs (Westinghouse vs. Framatome). However, as related to this activity, the only difference between the Salem SGTR Unit 1 accident and the Salem SGTR Unit 2 accident is how the EAB /Q value is determined. For Unit 2, the minimum EAB distance used is taken as the distance from the perimeter of a circular accident release boundary with a radius of 85 meters. For Unit 1, the minimum EAB distance used is taken as the distance from the main steam safety valves (MSSVs) located in the Inner and Outer Penetration Areas. This approach is described in Section 2.6.1 of the LAR, and Figures 3.1-2 and 3.1-3 are provided in the LAR to show these described distances and circles.
c) Per Section 3.1.2 of the LAR, a new EAB /Q of 2.44E-04 s/m3 is conservatively calculated based on one (1) bounding distance that is used for all Salem accident analyses except for the Unit 1 SGTR accident. The value of 1.97E-04 s/m3 for the Unit-1 SGTR /Q is calculated based on the most limiting distance from the inboard and outboard MSSVs (i.e.,
the release points) for that event.
RAI-5
Section 3.1 (Para. 4, Sent. 2) states [t]he 95th percentile EAB X/Q values were calculated to support accident analyses for Salem and Hope Creek using the PAVAN computer code for the updated distances. Please correct and clarify the phrase The 95th percentile EAB X/Q values to read The 0.5 percent sector-specific and 5 percent overall site EAB X/Q values, which is consistent with the methodology in Reg Guide 1.145 and NUREG/CR-2260. The NRC staff notes that correction of the phrase 95th percentile is also needed in Section 3.1.2 (Para. 1, Sent.1) and in Subsection 3.1.2.3 (Para. 2, Sent. 1) of the original LAR submittal of Sept. 6, 2023 (ML23249A260) by changing it to read 0.5 percent sector-specific.
Similar corrections may also be needed in the supplemental LAR submittal dated October 30, 2023 (ML23303A144) and in the respective UFSARs. Finally, the NRC staff notes that the
LR-N24-0024 10 CFR 50.90 Enclosure LAR S23-04 LAR H23-02 7
summary tables in the Hope Creek and Salem Units 1 and 2 PAVAN output files provided by PSEG correctly label the controlling X/Q, in those cases, as the 0.5 percent X/Q limiting value.
Response to RAI-5 It is agreed that the 95th percentile value represents the larger of the 0.5% maximum sector value and the 5% overall site value (as determined internally within the PAVAN software). The Salem and Hope Creek /Q PAVAN calculations describe this detail in the calculation body text and state that this value is commonly referred to as the 95th percentile /Q. This terminology is then carried over to the LAR. The intent of using 95th percentile /Q is strictly for nomenclature purposes.
RAI-6
Section 3.1.1 (Para. 2, Sent. 5 and Para. 3, Sent. 1) read Additionally, hourly T from 10 m -
46 m (33 ft. - 150 ft.), 10 m - 60 m (33 ft. - 197 ft.), and 10 m - 91 m (33 ft. - 300 ft.) was included and stability class based on 10 m - 46 m (33 ft. - 150 ft.) T, respectively.
Please correct the LAR submittal in Section 3.1.1 and elsewhere as needed to read Additionally, hourly T based on 46 m - 10 m (150 ft. - 33 ft.), 60 m - 10 m (197 ft. - 33 ft.),
and 91 m - 10 m (300 ft. - 33 ft.) temperature differences was included and stability class based on the 46 m - 10 m (150 ft. - 33 ft.) T, respectively. If the upper measurement level used to determine stability class changes based on one or both of the earlier RAI questions, please revise Para. 3 (Sent. 1) as appropriate. The NRC staff notes that Subsection 3.1.1.1 (Para. 1, Sent. 2) correctly states, although inconsistent with the previously indicated text, that T is determined between 46 meters and 10 meters (150 ft. - 33 ft.). The NRC staff further notes that similar discrepancies exist in the PAVAN input and output files provided by PSEG for this LAR.
Response to RAI-6 The LAR text in question identified in RAI-6 describes the elevations from which hourly T values were obtained for developing updated joint frequency distributions (JFDs). The referenced LAR text expresses the two meteorological tower elevations from which a set of T data are derived. For instance, the expression 10 m - 46 m (33 ft. - 150 ft.) means the T was determined between the temperature sensor located at 10 m (33 ft.) and the sensor located at 46 m (150 ft.). The T value is an absolute value derived from the difference in sensed temperatures at each of the listed meteorological tower elevations. The order in which the elevations are expressed have no bearing on the numerical value of T since the dash between each elevation is intended to mean to and not a minus sign (i.e., a negative elevation). As such, the resultant value of the Ts determined for each of the listed ranges of elevations are the same regardless of the order in which the elevations are described in each range of Ts.
The upper elevation measurement used to determine the stability class identified in the LAR is not changed as a result of the responses to any of the questions in this RAI and is therefore still applicable.
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RAI-7
Subsection 3.1.1.1 (Para. 1, Sent. 2) states, in part, the updated JFDs were constructed using hourly wind speed and direction recorded at the 10 meter (33 ft.) level. If the upper measurement level used to determine stability class changes based on one or both of the earlier RAI questions, the use of wind data from a higher measurement level for the Salem Units 1 and 2 and/or the Hope Creek dispersion modeling analyses with PAVAN also needs to be evaluated. If so, considering the comparison between the joint frequency distributions (JFDs) in the LAR and those used to support a previous Early Site Permit application, please revise Para. 1 and any other affected text accordingly. More importantly, the JFDs in Tables 3.1-1 and 3.1-2 of the original LAR submittal of Sept. 6, 2023 (ML23249A260) and in Attachments 2 and 3 of the supplemental LAR submittal dated October 30, 2023 (ML23303A144) may also need to be revised as well as the affected PAVAN dispersion modeling, radiological doses, and related text.
Response to RAI-7 Based on the RAI responses above, there is no change to the upper measurement level used for determination of stability class, nor is there a change to the assumed release elevations.
Therefore, there is no impact to the meteorological data/analyses and associated PAVAN analyses or resulting dose consequences at the proposed EAB.
RAI-8
Subsection 3.1.1.1 (Para. 3, Sent. 2) states Wind speeds were grouped into nominal 0.5 meters per second (m/s) steps from 0.0 m/s to 10.0 m/s and above 10.0 m/s. This statement only partially matches the maximum wind speeds listed in the Salem and Hope Creek PAVAN model input / output files and the individual yearly and composite 3-year (i.e., 2019-2021) wind speed groupings in the JFDs presented in the original and supplemental LAR submittals (ML23249A260 and ML23303A144, respectively). Please correct the statement in Subsection 3.1.1.1 of the LAR, and elsewhere, for consistency with the JFDs and model input / output files.
Response to RAI-8 The wind speed groupings in the JFDs presented in the original and supplemental LAR submittals (ML23249A260 and ML23303A144, respectively) vary in step speed range from calm to maximum wind speeds. The 0.5 m/s was described as nominal to characterize that the actual values are approximate and may vary. The actual speed ranges are provided in the following table:
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Speed Groupings (M/S)
Group Step Speed Range Delta (M/S)
CALM N/A 0.00<WS< 0.50 0.5 0.50<WS< 1.05 0.55 1.05<WS< 1.55 0.5 1.55<WS< 2.05 0.5 2.05<WS< 3.05 1.0 3.05<WS< 4.05 1.0 4.05<WS< 5.05 1.0 5.05<WS< 6.05 1.0 6.05<WS< 8.05 2.0 8.05<WS< 10.00 1.95 WS> 10.00 N/A