LR-N18-0038, License Amendment Request (LAR) to Amend the Salem Technical Specifications (TS) to Extend the Refueling Water Storage Tank (RWST) Allowed Outage Time

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License Amendment Request (LAR) to Amend the Salem Technical Specifications (TS) to Extend the Refueling Water Storage Tank (RWST) Allowed Outage Time
ML18183A025
Person / Time
Site: Salem  PSEG icon.png
Issue date: 06/29/2018
From: Mcfeaters C
Public Service Enterprise Group
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
LAR S18-03, LR-N18-0038
Download: ML18183A025 (21)
v • d • e


Text

PSEG Nuclear LLC P. 0. Box 236, Hancocks Bridge, New Jersey 08038-0236 0PSEG NuclearLLC 10 CFR 50.90 LR-N18-0038 LAR S18-03 JUN 2 9 2018 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

Subject:

License Amendment Request (LAR) to Amend the Salem Technical Specifications (TS) to Extend the Refueling Water Storage Tank (RWST)

Allowed Outage Time In accordance with the provisions of 10 CFR 50.90, PSEG Nuclear LLC (PSEG) is submitting a request for an amendment to the Technical Specifications (TS) for Salem Generating Station (Salem) Units 1 and 2.

The proposed change deletes duplicative TS requirements to the refueling water storage tank (RWST) in TS 3.1.2.6, "Borated Water Sources - Operating", and revises TS 3.5.5, "Refueling Water Storage Tank"; to ensure compliance with assumptions used in the design basis accident and containment response analyses and to make Salem TS requirements for the RWST consistent with NUREG 1431, Revision 4, "Standard Technical Specifications - Westinghouse Plants." PSEG concludes that the proposed change does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

The Enclosure provides a description and assessment of the proposed change. Attachment 1 provides the existing TS pages marked to show the proposed change.

PSEG requests approval of this LAR in accordance with standard NRC approval process and schedule. Once approved, the amendment will be implemented within 60 days from the date of issuance.

There are no regulatory commitments contained in this letter.

In accordance with 10 CFR 50.91, PSEG is notifying the State of New Jersey of this LAR by transmitting a copy of this letter and enclosure to the designated State Official.

JUN 2 9 2018 LR-N 18-0038 10 CFR 50.90 Page2 If there are any questions or if additional information is needed, please contact Mr. Michael Wiwel at 856-339-7907.

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

Executed on IL t//J r (Date)

Charles V. McFeaters Site Vice President Salem Generating Station

Enclosure:

Evaluation of the Proposed Change Attachment 1: Technical Specification Page Markups cc: Administrator, Region I, NRC Project Manager, NRC NRC Senior Resident Inspector, Salem Mr. P. Mulligan, Chief, NJBNE PSEG Corporate Commitment Tracking Coordinator Salem Commitment Tracking Coordinator

LR-N18-0038 LAR S18-03 Enclosure Evaluation of the Proposed Change

Subject:

License Amendment Request (LAR) to Amend the Salem Technical Specifications (TS) to Extend the Refueling Water Storage Tank (RWST) Allowed Outage Time Table of Contents 1.0

SUMMARY

DESCRIPTION .............................................................................................. 1 2.0 DETAILED DESCRIPTION ............................................................................................... 1 2.1 System Design and Operation .................................................................................. 1 2.2 Current Technical Specifications Requirements ....................................................... 1 2.3 Reason for the Proposed Change ............................................................................. 1 2.4 Description of the Proposed Change ........................................................................ 2

3.0 TECHNICAL EVALUATION

.............................................................................................. 5

4.0 REGULATORY EVALUATION

.......................................................................................... 7 4.1 Applicable Regulatory Requirements/Criteria ........................................................... 7 4.2 Precedent .................................................................................................................. 8 4.3 No Significant Hazards Consideration Analysis ........................................................ 8 4.4 Conclusion .............................................................................................................. 10

5.0 ENVIRONMENTAL CONSIDERATION

.......................................................................... 10

6.0 REFERENCES

................................................................................................................ 10 ATTACHMENTS:

1. Technical Specification Page Markups

LR-N18-0038 LAR S18-03 Enclosure 1.0

SUMMARY

DESCRIPTION The proposed change deletes specific operating limits for the refueling water storage tank (RWST) in TS 3.1.2.6, Borated Water Sources - Operating, Limiting Condition for Operation (LCO) b and replaces them with a reference to the LCO requirements in TS 3.5.5. A corresponding change is made to the associated Action statement in TS 3.1.2.6 b to reference the TS 3.5.5 Action statement. Similarly, the proposed change revises TS LCO 3.1.2.1.b to replace the reference to TS 3.1.2.6b with a reference to TS 3.5.5. The proposed change also revises TS 3.5.5, "Refueling Water Storage Tank", LCO a to remove the upper tank volume limit of 400,000 gallons and adds an upper temperature limit of 100°F to LCO c. A change is proposed to the Action statement for TS 3.5.5, to extend the allowed outage time for restoring the inoperable RWST to operable status from one hour to eight hours for inoperability stemming from boron concentration or temperature being outside of TS limits. The time permitted to enter at least HOT STANDBY if the RWST is not restored to OPERABLE status within the allowed outage time is changed from six hours to the next six hours. Finally, a change is proposed to Surveillance Requirement (SR) 4.5.5.b to add the applicability of outside air temperature being greater than 100°F for performance of the surveillance.

2.0 DETAILED DESCRIPTION 2.1 System Design and Operation The Refueling Water Storage Tank (RWST) is a passive component of the Emergency Core Cooling System (ECCS). Its primary function is to supply borated water for injection by the ECCS in the event of a design basis accident (DBA). During normal plant operation, the RWST serves no operating function. During a refueling outage, it provides an adequate borated water supply to fill the refueling cavity.

The RWST is designed to supply the Charging, Safety Injection (SI), and the Residual Heat Removal (RHR) Pumps following initiation of an SI actuation signal. Adequate volume also exists to supply the Containment Spray (CS) pumps if these pumps are actuated. This volume of stored borated water is also sufficient to fill the containment sump to a depth necessary to provide an adequate net positive suction head (NPSH) suction source for the RHR Pumps during long-term recirculation.

2.2 Current Technical Specification Requirements The current refueling water storage tank TS provides an upper limit of 400,000 gallons for RWST level, does not provide an upper limit for RWST temperature or an associated surveillance applicability and provides an action for the inoperable RWST, to restore the tank to operable status within one hour or be in at least hot standby within six hours and in cold shutdown within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

2.3 Reason for the Proposed Change TS 3.1.2.6 LCO b and associated Action statement b are redundant to the TS 3.5.5 LCO and Action statement for the RWST. PSEG considers that having identical RWST requirements appear under two different TS complicates the TS. Elimination of the duplicate requirement will reduce potential confusion without changing the requirements or adversely impacting the purpose and intent of the RWST requirements. Therefore, the RWST TS 3.1.2.6 LCO b and Action statement b will be revised to reference TS 3.5.5.

1

LR-N18-0038 LAR S18-03 Enclosure The change to TS 3.1.2.1, LCO b to replace the reference to TS 3.1.2.6b with a reference to TS 3.5.5 is required to align the TS to the correct LCO governing RWST operability.

The change to TS 3.5.5, LCO a to eliminate the upper limit of 400,000 gallons for RWST volume is proposed since the physical capacity of the RWST cannot exceed 400,000 gallons based on its vented design and the physical location of its overflow.

The change to TS 3.5.5, LCO c to add an upper limit of 100°F for RWST temperature ensures compliance with assumptions used in the design basis accident and containment response analyses.

The change to provide an eight hour allowed outage time for the RWST due to boron concentration or temperature being outside of TS limits will provide positive effects on plant safety by reducing the probability of unnecessary plant shutdowns and transients thus improving plant safety and increasing plant availability. The additional time provides a more reasonable time frame to determine the cause of a boron concentration or temperature deviation, identify and institute appropriate corrective actions, and conduct any needed confirmatory verification or testing.

A change to the time permitted to enter at least HOT STANDBY is required for consistency with the proposed change to the allowed outage time for boron concentration or temperature not within limits. The time permitted to enter at least HOT STANDBY if the RWST is not restored to OPERABLE status within the allowed outage time is currently six hours, which is less than the proposed eight hour allowed outage time for boron concentration or water temperature not within limits.

Additionally, the proposed changes are consistent with NUREG-1431, "Standard Technical Specifications, Westinghouse Plants."

2.4 Description of the Proposed Change The proposed change modifies TS 3.1.2.6, Borated Water Sources - Operating, LCO b LIMITING CONDITION FOR OPERATION 3.1.2.6 As a minimum, the following borated water source(s) shall be OPERABLE as required by Specifications 3.1.2.1 and 3.1.2.2:

a. A boric acid storage system with:
1. A contained volume of borated water in accordance with figure 3.1-2,
2. A Boron concentration in accordance with Figure 3.1-2, and
3. A minimum solution temperature of 63°F.
b. The refueling water storage tank with per Specification 3.5.5.
1. A contained volume of between 364,500 and 400,000 gallons of water
2. A boron concentration of between 2,300 and 2,500 ppm, and
3. A minimum solution temperature of 35°F.

2

LR-N18-0038 LAR S18-03 Enclosure The proposed change modifies TS 3.1.2.6, Borated Water Sources - Operating, Action statement b to reference the Action statement in Specification 3.5.5.:

ACTION

a. With the boric acid storage system inoperable and being used as one of the above required borated water sources, restore the storage system to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and borated to a SHUTDOWN MARGIN equivalent to at least 1% delta k/k at 200°F; restore the boric acid storage system to OPERABLE status within the next 7 days or be in COLD SHUTDOWN within the next 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
b. With the refueling water storage tank inoperable, restore the tank to OPERABLE status within one hour or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

perform the Action described in Specification 3.5.5.

The proposed change modifies SR 4.1.2.6.b to reference Surveillance Requirement 4.5.5:

SURVEILLANCE REQUIREMENT 4.1.2.6 Each borated water source shall be demonstrated OPERABLE:

a. For the boric acid storage system, when it is the source of borated water in accordance with the Surveillance Frequency Control Program by:
1. Verifying the boron concentration in each water source,
2. Verifying the water level of each water source, and
3. Verifying the boric acid storage system solution temperature
b. For the refueling water storage tank per Surveillance Requirement 4.5.5.

by:

1. Verifying the boron concentration in accordance with the Surveillance Frequency Control Program
2. Verifying the borated water volume in accordance with the Surveillance Frequency Control Program
3. Verifying the solution temperature in accordance with the Surveillance Frequency Control Program when the outside air temperature is less than 35°F 3

LR-N18-0038 LAR S18-03 Enclosure The proposed change revises TS 3.1.2.1, Boration Systems, Flow Paths - Shutdown LCO b to replace the reference to TS 3.1.2.6b with TS 3.5.5.

LIMITING CONDITION FOR OPERATION 3.1.2.1 As a minimum, one of the following boron injection flow paths shall be OPERABLE:

a. A flow path from the boric acid tanks via a boric acid transfer pump and a charging pump to the Reactor Coolant System if the boric acid storage system is OPERABLE, per Specification 3.1.2.6a while in MODE 4, or per Specification 3.1.2.5a while in MODE 5 or 6 or
b. A flow path from the refueling water storage tank via a charging pump to the Reactor Coolant System if the refueling water storage tank is OPERABLE per Specification 3.1.2.6b 3.5.5 while in MODE 4, or per Specification 3.1.2.5b while in MODE 5 or 6.

The proposed change revises TS 3.5.5, "Refueling Water Storage Tank" to remove the upper limit of 400,000 gallons for the RWST from LCO a and adds an upper temperature limit of 100°F to LCO c:

LIMITING CONDITION FOR OPERATION 3.5.5 The refueling water storage tank (RWST) shall be OPERABLE with:

a. A contained volume of between > 364,500 and 400,000 gallons of borated water.
b. A boron concentration of between 2300 and 2500 ppm, and
c. A minimum water temperature of 35°F RWST borated water temperature

>35°F and <100°F.

The proposed change revises TS 3.5.5, "Refueling Water Storage Tank" action to change the allowed outage time from one hour to eight hours if the tank is inoperable due to boron concentration or temperature being outside of TS limits and change the time permitted to enter at least HOT STANDBY when the RWST is not restored to OPERABLE status within the allowed outage time to "the next six hours."

ACTION With the refueling water storage tank inoperable, restore the tank to OPERABLE status within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or be in at least HOT STANDBY within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

a. With the RWST inoperable due to boron concentration or temperature not within limits, restore the tank to OPERABLE status within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

4

LR-N18-0038 LAR S18-03 Enclosure

b. With the RWST inoperable for reasons other than boron concentration or temperature not within limits, restore the tank to OPERABLE status within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> The proposed change modifies SR 4.5.5.b to add the 100°F upper temperature limit:

SURVEILLANCE REQUIRMENT:

4.5.5 The RWST shall be demonstrated OPERABLE:

a. In accordance with the Surveillance Frequency Control Program by:
1. Verifying the water level in the tank, and
2. Verifying the boron concentration of the water.
b. In accordance with the Surveillance Frequency Control Program by verifying the RWST temperature when the outside air temperature is

<35°F or >100°F

3.0 TECHNICAL EVALUATION

3.1 Background The RWST ensures that an adequate supply of borated water is available to cool and depressurize the containment in the event of a Design Basis Accident (DBA), to cool and cover the core in the event of a LOCA, to maintain the reactor subcritical following a DBA, and to ensure adequate level in the containment sump to support ECCS and Containment Spray System pump operation in the recirculation mode.

The RWST supplies borated water to the Chemical and Volume Control System (CVCS) during abnormal operating conditions, to the refueling cavity during refueling, and to the ECCS and the Containment Spray System during accident conditions. The RWST supplies both trains of the ECCS and the Containment Spray System through separate supply headers during the injection phase of a loss of coolant accident (LOCA) recovery. During normal operation in MODES 1, 2, and 3, the safety injection (SI) and residual heat removal (RHR) pumps are aligned to take suction from the RWST.

The LCOs affected by this amendment ensure that:

a. The RWST contains sufficient borated water within the required temperature range to support the ECCS during the injection phase,
b. Sufficient water volume exists in the containment sump to support continued operation of the ECCS and Containment Spray System pumps at the time of transfer to the recirculation mode of cooling, and
c. The reactor remains subcritical following a LOCA.

5

LR-N18-0038 LAR S18-03 Enclosure 3.2 RWST Temperature Providing a maximum limit of 100°F to RWST temperature ensures that the conditions of the RWST water inventory is maintained within the explicit assumptions used in the small break Loss of Coolant Accident (LOCA) and post-DBA containment response safety analyses.

RWST temperature is typically logged once per shift by the control room operators per the Surveillance Frequency Control Program.

Temperature variations of the RWST inventory occur very slowly due to the thermal inertia of the large volume of water. The average daily variation of tank temperature over the course of 2017 was nominally less than 1°F. Larger daily temperature variations were less than 10°F and were typically attributed to manual operations associated with chemistry sampling and adjustment or abrupt weather conditions.

Operational procedures are in place to prevent operation of the RWST outside of allowed temperature limits. In the event a temperature reading is found below its limit, the RWST heating recirculation pump would be placed in start to heat the RWST inventory. To restore a temperature reading that is above its limit, cooler inventory can be added to the tank.

Increasing the allowed outage time from one hour to eight hours provides a reasonable amount of time to complete these corrective actions to restore temperature within limits.

3.3 RWST Boron Concentration The limits on boron concentration ensures the reactor will remain subcritical in the cold condition following a small and large break LOCA assuming complete mixing of the RWST, RCS and ECCS water volumes. The boron concentration limits also ensure a pH value of between 7.0 and 10.0 for the solution recirculated within containment after a LOCA to minimize the evolution of iodine and effects of chloride and caustic stress corrosion on mechanical systems and components.

Boron concentration of the RWST can be affected by addition of water (makeup or leakage) that is at a different boron concentration. Since the RWST is a passive, isolated component, the boron concentration is not expected to change due to changing plant conditions. The RWST boron concentration for both Salem units over the course of 2017 ranged from a low of 2412 ppm to a high of 2484 ppm. Boron concentration is established within the proper range, and tank valves are closed to isolate the tank inventory. Some closed lines may be administratively opened if required to provide recirculation for in service testing of ECCS pumps or to allow operation of the purification system. In those cases, the water from the tank is returned to the tank with little or no change to the boron concentration.

The procedure to provide makeup to the RWST includes a number of checks for proper setup and function. Boric acid from the boric acid storage tanks and primary water are blended to the correct boron concentration in the chemical and volume control system (CVCS) and added to the RWST. Makeup is a manual operation requiring setting of flow rates to the blender, determining the amount of water to be blended, and operation of various valves. Based on the number of actions required to make up to the RWST, inadvertent makeup to the RWST through a single incorrect action or equipment malfunction that could change boron concentration is unlikely.

6

LR-N18-0038 LAR S18-03 Enclosure By procedure, the RWST is isolated after makeup is completed. The boron concentration in the RWST is then sampled. If the sample indicates the boron concentration is outside the acceptable range, the boron concentration is adjusted. Since the RWST is not normally used outside of refueling operations, any makeup to the tank is typically small. Weekly samples are also taken to comply with TS Surveillance Requirements.

3.4 Temperature and Boron Action Bases The purpose of the action statement for RWST boron concentration or temperature being outside of limits is to require rapid correction of conditions that affect both trains of ECCS. The change in the allowed outage time (AOT) from one hour to eight hours is acceptable because the completion time of eight hours is consistent with safe operation considering the low likelihood of a DBA occurring during the AOT, the time to assess and correct RWST chemistry or temperature conditions and the fact that the contents of the tank are still available for injection if a DBA were to occur during the AOT.

The primary function of the RWST is to provide large volumes of water to the RCS following a Loss of Coolant Accident. This large volume of water continues to be available during the eight hour out of service time for temperature and boron being outside of limits. As a result, the most important safety function of the RWST can still be provided. Because of the volume of the RWST, changes to the boron concentration or temperature occur slowly. Given the weekly sampling of the RWST boron concentration and the daily monitoring of the RWST temperature per the Surveillance Frequency Control Program, the volume of the RWST, and the relatively few plant evolutions that impact the RWST inventory, it is unlikely that the boron concentration or temperature would significantly be outside of the limits prior to discovery. Following discovery, a significant change in concentration or temperature prior to restoration during the eight hour period is similarly unlikely.

If one of these parameters was out of limit, more than one hour would likely be required to restore the parameter. Given the remaining abilities of the RWST, requiring a plant shutdown after one hour is not warranted. If boron concentration or temperature limits cannot be returned within specification within eight hours, action will be initiated for controlled shutdown activities per the TS 3.5.5 Action statement

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria In 10 CFR 50.36, "Technical specification," the Commission established its regulatory requirements related to the content of the TSs. Pursuant to 10 CFR 50.36, TSs are required to include items in the following five specific categories related to station operation: (1) safety limits, limiting safety system settings, and limiting control settings; (2) Limiting conditions for operation (LCOs); (3) surveillance requirements; (4) design features; and (5) administrative controls. Based on the assessments presented herein, the proposed change to the Salem TS has no significant impact on the continued conformance with the requirements of 10 CFR 50.36.

7

LR-N18-0038 LAR S18-03 Enclosure 10 CFR 50.65, "Requirements for monitoring the effectiveness of maintenance at nuclear power plants, requires that preventive maintenance activities must be sufficient to provide reasonable assurance that structures, systems, and components (SSCs) are capable of fulfilling their intended functions. Maintenance and testing activities will be controlled in accordance with the operability requirements for the affected equipment contained within the TS. Extending the allowed outage time for restoring boron or temperature conditions for an inoperable refueling water storage tank does not alter the stations approach to ensuring operability of TS required systems, subsystems, trains, components, and devices is maximized.

10 CFR 50.90, "Application for amendment of license or construction permit," addresses the requirements for a licensee desiring to amend its license and the TS incorporated therein. This license amendment request to Salem TS 3.1.2.6, 4.1.2.6 and 3.5.5 has been prepared to meet the requirements of 10 CFR 50.90.

Following implementation of the proposed changes, Salem will remain in compliance with the above regulations and guidance.

4.2 Precedent The proposed change is consistent with NUREG 1431, Standard Technical Specifications -

Westinghouse Plants, Revision 4 as well as the following NRC-approved license amendments:

Pacific Gas and Electric Company on April 14, 1995 (Amendment Numbers 101 and 100) for Diablo Canyon Nuclear Power Plant, Units 1 and 2 (NRC ADAMS Accession No. ML022340263). The approved TS changes are similar to the change proposed in this request.

Wolf Creek Nuclear Operating Corporation on November 13, 1995, (Amendment No.

91) for Wolf Creek Generating Station (NRC ADAMS Accession No. ML022040111).

4.3 No Significant Hazards Consideration In accordance with 10 CFR 50.90, PSEG Nuclear LLC (PSEG) requests an amendment to the Salem Unit 1 and Unit 2 Operating Licenses. The proposed change:

Revises TS 3.1.2.1 Boration Systems, Flow Paths - Shutdown LCO b to replace reference to Specification 3.1.2.6b with a reference to Specification 3.5.5.

Revises TS 3.1.2.6, Borated Water Sources - Operating, Limiting Condition of Operation and associated Action statement b to reference Specification 3.5.5.

Revises Surveillance Requirement (SR) 4.1.2.6.b for the RWST to reference TS Surveillance Requirement 4.5.5.

Revises TS 3.5.5, "Refueling Water Storage Tank"; Limiting Condition of Operation to remove the upper volume limit for the RWST, adds an upper temperature limit to the LCO, changes the associated action statement to extend the allowed outage time for restoring the inoperable RWST to operable status from 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> for inoperability due to boron concentration or temperature and changes SR 4.5.5.b to add the upper temperature limit.

8

LR-N18-0038 LAR S18-03 Enclosure PSEG has evaluated whether a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, Issuance of amendment, as discussed below:

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

Response: No The proposed changes do not adversely affect accident initiators or precursors or alter the design assumptions, conditions, or configuration of the facility or the manner in which the plant is operated and maintained. The proposed changes do not alter or prevent the ability of structures, systems, and components (SSCs) to perform their intended function to mitigate the consequences of an initiating event within the acceptance limits. The proposed changes do not affect the source term, containment isolation, or radiological release assumptions used in evaluating the radiological consequences of an accident previously evaluated. The proposed change is consistent with and continues to support the safety analysis assumptions and resultant consequences.

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 changes do not alter or involve any design basis accident initiators. The changes to the Technical Specifications regarding RWST operational limits are primarily administrative in nature and do not affect the design or operation of the plant. Increasing the allowable out of service time (AOT) for the RWST does not cause any plant systems to become initiators of a new or different type of accident. Systems and equipment will be operated in the same configuration and manner that is currently allowed and for which the systems were designed.

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

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

Response: No The proposed change does not alter the permanent plant design, including instrument set points, nor does it change the assumptions contained in the safety analyses.

The RWST continues to meet the design requirements relative to core and containment cooling and reactivity control; there is no reduction in capability or change in design configuration. Increasing the RWST AOT for reasons directly related to boron concentration or temperature does not affect any accident analysis assumptions, initial conditions, or results. Adding an upper temperature limit to the LCO for TS 3.5.5 ensures the RWST remains within temperature ranges assumed in the plants safety analyses. Removing the 9

LR-N18-0038 LAR S18-03 Enclosure upper limit on RWST volume does not alter the RWST design and the limit is not used as an input or assumption in any plant safety analysis. The proposed changes do not alter a design basis or safety limit.

Therefore, it is concluded that the proposed changes do not involve a significant reduction in a margin of safety.

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

4.4 Conclusion In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

5.0 ENVIRONMENTAL CONSIDERATION

A review has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure.

Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

6.0 REFERENCES

None 10

LR-N18-0038 LAR S18-03 Attachment 1 Technical Specification Page Markups The following Technical Specifications pages for Renewed Facility Operating License DPR-70 are affected by this change request:

Technical Specification Page 3/4.1.2.1, Boration Systems - Flow Paths Shutdown 3/4 1-7 3/4.1.2.6, Borated Water Sources - Operating 3/4 1-16 & 3/4 1-17 3/4.5.5, Refueling Water Storage Tank 3/4 5-7 The following Technical Specifications pages for Renewed Facility Operating License DPR-75 are affected by this change request:

Technical Specification Page 3/4.1.2.1, Boration Systems - Flow Paths Shutdown 3/4 1-7 3/4.1.2.6, Borated Water Sources - Operating 3/4 1-12 3/4.5.5, Refueling Water Storage Tank 3/4 5-9 1

REACTIVITY CONTROL SYSTEMS 3/4.1.2 BORATION SYSTEMS FLOW PATHS - SHUTDOWN LIMITING CONDITION FOR OPERATION 3.1.2.1 As a minimum, one of the following boron injection flow paths shall be OPERABLE:

a. A flow path from the boric acid tanks via a boric acid transfer pump and a charging pump to the Reactor Coolant System if the boric acid storage system is OPERABLE, per Specification 3. 1.2.6a while in MODE 4, or per Specification 3.1.2.Sa while in MODE 5 or 6, or
b. A flow path from the refueling water storage tank via a charging pump to the Reactor Coolant System if the refueling water storage tank is OPERABLE per Specification 3.1.2.6b while in MODE 4, or per Specification 3.1.2.Sb while in MODE 5 or 6.

3.5.5 APPLICABILITY

MODES 4, 5 and 6.

ACTION:

With none of the above flow paths OPERABLE. suspend all operations involving CORE ALTERATIONS or positive reactivity changes until at least one injection path is restored to OPERABLE status.

SURVEILLANCE REQUIREMEN TS 4.1. 2.1 At least one of the above required flow paths shall be demonstrated OPERABLE:

a. When the boric acid tank is a required water source, by verifying in accordance with the Surveillance Frequency Control Program that:

(1) The flow path from the boric acid tank to the boric acid transfer pump, the boric acid transfer pump, and the recirculation path from the boric acid transfer pump to the boric acid tank is 63°F, and (2) The flow path between the boric acid transfer pump recirculation line to the charging pump suction line is S0°F,

b. In accordance with the Surveillance Frequency Control Program by verifying that each valve (manual, power operated or automatic) in the flow path that is not locked, sealed, or otherwise secured in position, is in its correct position.

SALEM - UNIT 1 3/4 1-7 Amendment No. 299

REACTIVITY CONTROL SYSTEMS BORATED WATER SOURCES - OPERATING LIMITING CONDITION FOR OPERATION 3.1.2.6 As a minimum, the following borated water source(s) shall be OPERABLE as required by specifications 3.1.2.1 and 3.1.2.2:

a. A boric acid storage system with:
1. A contained volume of borated water in accordance with figure 3.1.2,
2. A boron concentration in accordance with figure 3.1-2, and
3. A minimum solution temperature of 63°F.
b. The refueling water storage tank with: per Specification 3.5.5.
1. A contained volume of between 364,500 and 400,000 gallons of water,
2. A boron concentration of between 2,300 and 2,500 ppm, and
3. A minimum solution temperature of 35°F.

APPLICABILITY: MODES 1, 2, 3 and 4.

ACTION:

a. With the boric acid storage system inoperable and being used as one of the above required boration water systems, restore the storage system to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and borated to a SHUTDOWN MARGIN equivalent to at least 1%

delta K/k at 200°F; restore the boric acid storage system to OPERABLE status within the next 7 days or be in COLD SHUTDOWN within the next 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

b. With the refueling water storage tank inoperable, restore the tank to OPERABLE status within one hour or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

perform the Action described in Specification 3.5.5.

SALEM - UNIT 1 3/4 1-16 Amendment No 299

REACTIVITY CONTROL SYSTEMS SURVEILLAf\JCE REQUIREMENTS 4.1. 2. 6 Each borated water source shall be demonstrated OPERABLE:

a. For the boric acid storage system, when it is the source of borated water in accordance with the Surveillance Frequency Control Program by:
1. Verifying the boron concentration in each water source,
2. Verifying the water level of each water source, and
3. Verifying the boric acid storage system solution temperature.
b. For the refueling water storage tank by: per Surveillance Requirement 4.5.5.
1. Verifying the boron concentration in accordance with the Surveillance Frequency Control Program,
2. Verifying the borated water volume in accordance with the Surveillance Frequency Control Program, and
3. Verifying the solution temperature in accordance with the Surveillance Frequency Control Program when the outside air temperature is less than 35°F.

SALEM - UNIT 1 3/4 1-17 Amendment No. 299

EMERGENCY CORE COOLING SYSTEMS REFUELING WATER STORAGE TANK LIMITING CONDlILON FOR OPERATION 3.5.5 The refueling water storage tank (RWST) shall be OPERABLE with:

a. A contained volume of between 364,500 and 400,000 gallons of borated water.
b. A boron concentration of between 2300 and 2500 ppm, and RWST borated water temperature 35°F
c. A minimum water temperature of 35°F.

and 100°F.

APPLICABILITY: MODES 1, 2, 3 and 4.

ACTION:

With the refueling water storage tank inoperable, restore the tank to OPERABLE status within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or be in at least HOT STANDBY within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

S.URVEI LLANCE REQUIREMENTS 4.5.5 The RWST shall be demonstrated OPERABLE:

a. In accordance with the Surveillance Frequency Control Program by:
1. Verifying the water level in the tank, and
2. Verifying the boron concentration of the water.
b. In accordance with the Surveillance Frequency Control Program by verifying the RWST temperature when the outside air temperature is < 35 F. <35°F or >100°F.

°

a. With the RWST inoperable due to boron concentration or temperature not within limits, restore the tank to OPERABLE status within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
b. With the RWST inoperable for reasons other than boron concentration or temperature not within limits, restore the tank to OPERABLE status within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

SALEM - UNIT 1 3/4 5-7 Amendment No. 299

REACTIVITY CONTROL SYSTEMS 3/4.1.2 BORATION SYSTEMS FLOW PATHS - SHUTDOWN LIMITING CONDITION FOR OPERATION 3.1.2.1 As a minimum, one of the following boron injection flow paths shall be OPERABLE:

a. A flow path from the boric acid tanks via a boric acid transfer pump and a charging pump to the Reactor Coolant System if the boric acid storage system is OPERABLE, per Specification 3.1.2.6a while in MODE 4, or per Specification 3.1.2.Sa while in MODE 5 or 6, or
b. A flow path from the refueling water storage tank via a charging pump to the Reactor Coolant System if the refueling water storage tank is OPERABLE per Specification 3.1.2.6b while in MODE 4, or per Specification 3.1.2.Sb while in MODE 5 or 6.

3.5.5 APPLICABILITY

MODES 4, 5 and 6.

ACTION:

With none of the above flow paths OPERABLE, suspend all operations involving CORE ALTERATIONS or positive reactivity changes until at least one injection path is restored to OPERABLE status.

SUREILLANCE REQUIREMENTS 4.1 .2.1 At least one of the above required flow paths shall be demonstrated OPERABLE:

a.

(1) The flow path from the boric acid tank to the boric acid transfer pump, the boric acid transfer pump, and the recirculation path from the boric acid transfer pump to the boric acid tank is 63°F, and (2) The flow path between the boric acid transfer pump recirculation line to the charging pump suction line is S0°F,

b. In accordance with the Surveillance Frequency Control Program by verifying that each valve (manual, power operated or automatic) in the flow path that is not locked, sealed, or otherwise secured in position, is in its correct position.

SALEM - UNIT 2 3/4 1-7 Amendment No. 282

REACTIVITY CONTROL SYSTEMS BORATED WATER SOURCES - OPERATING LIMITING CQNQITION FQR OPERATION 3.1.2.6 As a minimum, the following borated water source(s) shall be OPERABLE as required by Specifications 3. 1.2.1 and 3. 1.2. 2:

a. A boric acid storage system with:
1. A contained volume of borated water in accordance with figure 3. 1-2,
2. A Boron concentration in accordance with Figure 3.1-2, and
3. A minimum solution temperature of 63°F.
b. The refueling water storage tank with: per Specification 3.5.5.
1. A contained volume of between 364,500 and 400,000 gallons of water,
2. A boron concentration of between 2,300 and 2, 500 ppm, and
3. A minimum solution temperature of 35°F.

APPLIC ABILITY: MODES 1, 2, 3 and 4.

ACTIOl\J:

a. With the boric acid storage system inoperable and being used as one of the above required borated water sources, restore the storage system to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT ST AN OBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and borated to a SHUTDOWN MARGIN equivalent to at least 1% delta k/k at 200°F; restore the boric acid storage system to OPERABLE status within the next 7 days or be in COLD SHUTDOWN within the next 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
b. With the refueling water storage tank inoperable, restore the tank to OPERABLE status within one hour or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

perform the Action in Specification 3.5.5.

S!lfill_EILLANCE REQUIREMENTS 4.1. 2.6 Each borated water source shall be demonstrated OPERABLE:

a. For the boric acid storage system, when it is the source of borated water in accordance with the Surveillance Frequency Control Program by:
1. Verifying the boron concentration in each water source.
2. Verifying the water level of each water source, and
3. Verifying the boric acid storage system solution temperature.
b. For the refueling water storage tank by: per Surveillance Requirement 4.5.5.
1. Verifying the boron concentration in accordance with the Surveillance Frequency Control Program,
2. Verifying the borated water volume in accordance with the Surveillance Frequency Control Program, and
3. Verifying the solution temperature in accordance with the Surveillance Frequency Control Program when the outside air temperature is less than 35°F.

SALEM - UNIT 2 3/4 1-12 Amendment No. 282

EMERGENCY CORE COOLING SYSTEMS REFUELING WATER STORAGE TAl\IK LIMITING CONDITION FOR OPERATION 3.5.5 The refueling water storage tank (RWST) shall be OPERABLE with:

a. A contained volume of between 364,500 and 400,000 gallons of borated water.
b. A boron concentration of between 2,300 and 2,500 ppm , and RWST borated water temperature 35°F
c. A minimum water temperature of 35°F.

and 100°F.

APPLICABILITY: MODES 1, 2, 3 and 4.

ACTION:

With the refueling water storage tank inoperable, restore the tank to OPERABLE status within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or be in at least HOT STANDBY within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

SURVEILLANCE REQUIREMENTS 4.5.5 The RWST shall be demonstrated OPERABLE:

a. In accordance with the Surveillance Frequency Control Program by:
1. Verifying the water level in the tank, and
2. Verifying the boron concentration of the water.
b. In accordance with the Surveillance Frequency Control Program by verifying the RWST temperature when the outside air temperature is < 35"F. <35°F or >100°F.
a. With the RWST inoperable due to boron concentration or temperature not within limits, restore the tank to OPERABLE status within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
b. With the RWST inoperable for reasons other than boron concentration or temperature not within limits, restore the tank to OPERABLE status within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

SALEM - UNIT 2 314 5-9 Amendment No. 282

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