LR-N20-0051, Supplement to License Amendment Request to Adopt 10 CFR 50.69, Risk-informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors

Supplement to License Amendment Request to Adopt 10 CFR 50.69, Risk-informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors

ML20203M297
Person / Time
Site:	Hope Creek
Issue date:	07/21/2020
From:	Casulli E Public Service Enterprise Group
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
LAR H19-07, LR-N20-0051
Download: ML20203M297 (5)

Text

PSEG Nuclear LLC P.O. Box 236, Hancocks Bridge, NJ 08038-0236 10 CFR 50.90 LR-N20-0051 LAR H19-07 July 21, 2020 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 HOPE CREEK GENERATING STATION RENEWED FACILITY OPERATING LICENSE NO. NPF-57 NRC DOCKET NO. 50-354

Subject:

Supplement to License Amendment Request to Adopt 10 CFR 50.69, "Risk-informed categorization and treatment of structures, systems and components for nuclear power reactors

References:

1. PSEG letter to NRC, "Application to Adopt 10 CFR 50.69, Risk-informed categorization and treatment of structures, systems and components for nuclear power reactors," dated November 25, 2019 (ADAMS Accession No. ML19330C961)

2. NRC email to PSEG, Hope Creek - Final RAI RE: Adopt 10 CFR 50.69 LAR (L-2019-LLA-0265), dated June 15, 2020 (ADAMS Accession No. ML20167A330)

3. PSEG letter to NRC, "Response to Request for Additional Information, Re:

Adopt 10 CFR 50.69 LAR," dated June 25, 2020 (ADAMS Accession No. ML20177A535)

In the Reference 1 letter, PSEG Nuclear LLC (PSEG) submitted a license amendment request for Hope Creek Generating Station (Hope Creek). The proposed amendment would modify the Hope Creek licensing basis by the addition of a License Condition, to allow for the implementation of the provisions of Title 10 of the Code of Federal Regulations (10 CFR), Part 50.69, "Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors." In Reference 2, the Nuclear Regulatory Commission (NRC) requested PSEG to provide additional information in order to evaluate the proposed License Amendment Request.

July 21, 2020 10 CFR 50.90 Page 2 LR-N20-0051 In Reference 3, PSEG submitted its response to the NRC request for additional information.

PSEG proposed in its response to APLA RAI 06 an addition to the license condition provided in the original LAR application that includes all applicable implementation items with a statement that they will be completed prior to implementation of the 10 CFR 50.69 categorization process.

The updated proposed license condition is provided in the enclosure to this letter. Attachment 1 to the enclosure to this letter contains the implementation items that are referenced in the proposed license condition.

The information contained in the enclosure does not affect the Technical Analysis or No Significant Hazards Consideration conclusions contained in the LAR. 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.

There are no regulatory commitments contained in this letter.

If you have any questions or require additional information, please contact Mr. Lee Marabella at (856) 339-1208 I declare under penalty of perjury that the foregoing is true and correct.

Executed on __ /2_,_0_r__,/._i-"--

(Dat)

&lfb Respectfully, Site Vice President Hope Creek Generating Station

Enclosure:

1. 10 CFR 50.69 License Condition cc: Administrator, Region I, NRC Project Manager, NRC NRC Senior Resident Inspector, Hope Creek Mr. P. Mulligan, Chief, NJBNE Mr. L. Marabella, Corporate Commitment Tracking Coordinator Mr. T. Cachaza, Site Compliance Commitment Tracking Coordinator

LR-N20-0051 Enclosure 10 CFR 50.69 License Condition 1

LR-N20-0051 LAR H19-07 Enclosure PSEG proposes the following license condition:

PSEG is approved to implement 10 CFR 50.69 using the processes for categorization of Risk-Informed Safety Class (RISC)-1, RISC-2, RISC-3, and RISC-4 Structures, Systems, and Components (SSCs) using: Probabilistic Risk Assessment (PRA) models to evaluate risk associated with internal events, including internal flooding, and internal fire; the shutdown safety assessment process to assess shutdown risk; the Arkansas Nuclear One, Unit 2 (ANO-2) passive categorization method to assess passive component risk for Class 2 and Class 3 SSCs and their associated supports; the results of the non-PRA evaluations that are based on the IPEEE Screening Assessment for External Hazards updated using the external hazard screening significance process identified in ASME/ANS PRA Standard RA-Sa-2009 for other external hazards except seismic; and the alternative seismic approach as described in PSEG submittal letter dated November 25, 2019, and all its subsequent associated supplements, as specified in License Amendment No. [XXX] dated

[DATE].

PSEG will complete the implementation items listed in Attachment 1 of PSEG's letter to the NRC dated July 21, 2020, prior to crediting portable FLEX equipment for 10 CFR 50.69 categorization.

Prior NRC approval, under 10 CFR 50.90, is required for a change to the categorization process specified above (e.g., change from the alternate seismic approach (referenced above) to a seismic probabilistic risk assessment approach).

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LR-N20-0051 LAR H19-07 Enclosure Attachment 1 10 CFR 50.69 Implementation Items No. Implementation Item

1. PSEG will not credit portable FLEX equipment in the PRA models used for 10 CFR 50.69 categorization until focused-scope peer reviews are performed on the model changes associated with incorporating mitigating strategies, and associated Findings and Observations are resolved to Capability Category II in accordance with the current revision of Regulatory Guide 1.200.

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