LR-N17-0175, Response to Request for Additional Information Regarding License Amendment Request for Measurement Uncertainty Recapture Power Uprate

Response to Request for Additional Information Regarding License Amendment Request for Measurement Uncertainty Recapture Power Uprate

ML17353A744
Person / Time
Site:	Hope Creek
Issue date:	12/19/2017
From:	Carr E Public Service Enterprise Group
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
CAC MF9930, LAR H17-03, LR-N17-0175
Download: ML17353A744 (12)

Text

PSEG Nuclear LLC P.O. Box 236, Hancocks Bridge, NJ 08038-0236 P..

NuclearLLC 10 CFR 50.90

!DEC 19 2017 LR-N17-0175 LAR H17-03 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Hope Creek Generating Station Renewed Facility Operating License No. NPF-57 NRC Docket No. 50-354

Subject:

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST FOR MEASUREMENT UNCERTAINTY RECAPTURE POWER UPRATE (CAC NO. MF9930)

References 1. PSEG letter to NRC, "License Amendment Request for Measurement Uncertainty Recapture (MUR) Power Uprate," dated July 7, 2017 (ADAMS Accession No. ML17188A260)

2. NRC e-mail to PSEG, " Hope Creek MUR - Final Request for Additional Information - (MCCB)," dated November 17, 2017 (ADAMS Accession No. ML17348A628)

In the Reference 1 letter, PSEG Nuclear LLC (PSEG) submitted a license amendment request for Hope Creek Generating Station (HCGS). The proposed amendment will increase the rated thermal power (RTP) level from 3840 megawatts thermal (MWt) to 3902 MWt, and make TS changes as necessary to support operation at the uprated power level.

In Reference 2, the U.S. Nuclear Regulatory Commission staff provided PSEG a Request for Additional Information (RAI) to support the NRC staff's detailed technical review of Reference 1.

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

Page 2 10 CFR 50.90 LR-N17-0175 concluding that neither an environmental impact statement nor an environmental assessment needs to be prepared in connection with the proposed amendment.

No new regulatory commitments are established by this submittal. If you have any questions or require additional information, please do not hesitate to contact Mr. Brian Thomas at (856) 339-2022.

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

Executed on / 2,d1/l?

(Date)

Eric Carr Site Vice President Hope Creek Generating Station

DEC l & 2011 Page 3 10 CFR 50.90 LR*N17-0175 Attachment

1. Response to Request for Additional Information Regarding MUR Power Uprate cc: Mr. D. Dorman, Administrator, Region I, NRC Ms. L. Regner, Project Manager, NRC NRC Senior Resident Inspector, Hope Creek Mr. P. Mulligan, Chief, NJBNE Mr. L. Marabella, Corporate Commitment Tracking Coordinator Mr. T. MacEwen, Hope Creek Commitment Tracking Coordinator LAR H17-03 LRaN17-0175 Response to Request for Additional Information Regarding MUR Power Uprate

Attachment 1 LAR H17-03 LR-N17-0175 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST FOR MEASUREMENT UNCERTAINTY RECAPTURE POWER UPRATE Hope Creek Generating Station Docket No. 50-354 CAC No. MF9930 Protective Coatings in Containment:

Protective coating systems (paints) provide a means for protecting the surfaces of facilities and equipment from corrosion and contamination from radionuclides, and also provide wear protection during plant operation and maintenance activities. Coatings are also used due to their suitability for, and stability under, design basis LOCA accident conditions, considering radiation and chemical effects. The NRC's acceptance criteria for protective coating systems is based on: (1) 10 CFR Part 50, Appendix 8, which states quality assurance requirements for the design, fabrication, and construction of safety-related structures, systems, and components (SSCs); and (2) Regulatory Guide (RG) 1.54, Revision 3, Service Level l, II, and Ill Protective Coatings Applied to Nuclear Power Plants. Specific review criteria are contained in SRP Section 6.1.2, Protective Coating Systems (Paints) - Organic Materials Review Responsibilities.

Consistent with the regulatory requirements stated above, the license amendment request (LAR) dated July 7, 2017 (Agencywide Documents Access Management System (ADAMS)

Accession No. ML17188A260), TSAR Section 4.1.5, "Containment Coatings" stated that the i-service level 1 coatings in containment are qualified to 340 degrees Fahrenheit (F), 70 pounds 1I per square inch (psig), and 1.1 x 106 absorbed radiation dose (rads). I MCCB RAI-1:

In order for the NRC staff to determine whether the coatings will continue to perform their safety function and not be adversely impacted by the power uprate conditions, the staff requests the licensee confirm the qualification limit for radiological dose. The current radiological dose qualification appears to be low for service in containment compared to similar epoxy coatings at other plants. In addition, provide the maximum post-accident primary containment conditions for temperature, pressure, and radiation at the measurement uncertainty recapture (MUR) power uprate conditions.

Response

The design basis accident containment temperature and pressure conditions were determined for EPU using a core thermal power of 4031 MWt (1.02 x 3952 MWt), with the exception of peak bulk suppression pool temperature, which was determined at 3917 MWt (1.02 x 3840 MWt).

The results are documented in Table 4-1 of NEDC-33076P, "Safety Analysis Report for Hope Creek Constant Pressure Power Uprate," submitted as Attachment 4 to the Hope Creek EPU license amendment request (ADAMS Accession No. ML062680447) and are shown below.

1 of 8

Attachment 1 LAR H17-03 LR-N17-0175 Peak Drywell Airspace 50.6 Pressure (psig)

Peak Drywell Airspace 298 Temperature (°F)

Peak Bulk Pool 212.3 Temperature (°F)

Peak Wetwell Airspace 27.7 Pressure (psig)

Peak Wetwell Airspace 212.2 Temperature (°F)

These results bound operation at TPO conditions, and are bounded by the qualifications of the containment coatings.

Hope Creek's normal and accident dose analyses were performed for the EPU uprate at a bounding power level of 3952 MWt for normal doses and 4031 MWt (3952 x 1.02) for accident dose. The radiation dose applicable to containment coatings is:

Total 60-year Normal 7.90E+07 Integrated Dose Total Post-LOCA EQ Dose 6.29E+08 Total Integrated Dose 7.08E+08 (TID)

Qualified Dose of 1.00E+09 Coatings During the review of the requested information, PSEG identified that the Service Level1 qualification for integrated dose stated in TSAR Section 4.1.5 contained a typographical error. The statement is corrected to:

9 The Service Leve/1 coatings are qualified to 340°F, 70 psig, and 1x1 0 rads.

Therefore, the containment coatings continue to bound the DBA temperature, pressure, and radiation at TPO conditions.

Flow-Accelerated Corrosion (FAC):

FAC is a corrosion mechanism occurring in carbon steel components exposed to single-phase or two-phase water flow. Components made from stainless steel are immune to FAC, and FAC is significantly reduced in components containing even small amounts of chromium or molybdenum. The rates of material loss due to FAC depend on the system flow velocity, component geometry, fluid temperature, steam quality, oxygen content, and pH. During plant operation, it is not normally possible to maintain all of these parameters in a regime that minimizes FAC; therefore, loss of material by FAC can occur and the rate of material loss needs to be predicted so that repair or replacement of damaged components could be made before reaching a critical thickness. The NRC's acceptance criteria are based on the structural evaluation of the minimum acceptable wall thickness for the components undergoing degradation by FAC.

2 of 8 LAR H17-03 LR*N17-0175 MCCB RAI-2:

The MUR power uprate will affect several process variables that influence FAC. The licensee states that for the TPO the evaluation of predicted wall thinning of the balance of plant piping will be minimal. However, the licensee also states that the TPO will change some parameters affecting FAC in systems associated with the turbine cycle and appropriate changes to piping inspection frequency will be made. Provide the areas where changes may be made to the piping inspection frequency and discuss the impacts of operating parameters (e.g. planned changes in water chemistry, power level, steam cycle data, etc.) that lead to the changes in inspection frequency.

Response

The table and flow chart below provide the results of the CHECWOR KS' SFA Model Update for MUR at HCGS. The model was updated to predict changes in FAC wear rate at various plant locations when operating at the MUR power level. The CHECWORKS' model is updated after every refueling outage with inspection information, plant conditions, and water treatment data (dissolved oxygen and pH) from the chemistry department.

3 of 8 LAR H17-03 LR-N17-0175 4 of 8 LAR H17-03 LR-N17-0175 5 of 8 LAR H17-03 LR-N17-0175 6 of 8 LAR H17-03 LR-N17-0175 7 of 8 LAR H17-03 LR-N17-0175 8 of 8