ML17164A406

NRR E-mail Capture - Hope Creek - Final Request for Additional Information Concerning ILRT (MF8462)

ML17164A406
Person / Time
Site:	Hope Creek
Issue date:	06/13/2017
From:	Lisa Regner Plant Licensing Branch IV
To:	Duke P Public Service Enterprise Group
References
MF8462
Download: ML17164A406 (3)

Text

NRR-PMDAPEm Resource From: Regner, Lisa Sent: Tuesday, June 13, 2017 4:04 PM To: Paul.Duke@pseg.com Cc: Ennis, Rick; Ronewicz, Lynn

Subject:

Hope Creek - Final Request for Additional Information Concerning ILRT (MF8462)

Final Follow-up Request for Additional Information (RAI)

Regarding License Amendment Request (LAR) to Amend Technical Specifications (TS) 6.8.4.f for Permanent Extension of Type A and Type C Leak Rate Test Frequencies Hope Creek Generating Station (CAC NO. MF8462)

On May 26, 2017, the U.S. Nuclear Regulatory Commission (NRC) staff sent PSEG Nuclear LLC (PSEG) the draft RAI provided below. This RAI relates to a proposed amendment to revise HCGS Technical Specifications 6.8.4.f to allow extension of the Type A test interval up to one test in 15 years and extension of the Type C test interval up to 75 months.

Following a clarification call on June 1, 2017, PSEG subsequently informed the NRC staff that the information requested by the NRC staff was understood and additional clarification of the RAI was not necessary. Mr. Paul Duke agreed to provide a response to this final RAI within 30 days from the date of this correspondence. A publicly available version of this final RAI will be placed in the NRCs Agencywide Documents Access and Management System.

In a letter dated October 7, 2016, (Agencywide Documents Access and Management System

[ADAMS] Accession No. ML16281A139), as supplemented by letter dated March 27, 2017 (ADAMS Accession No. ML17086A096), PSEG requested an amendment to the facility operating license number NPF-57 for Hope Creek Generating Station (HCGS).

The Probabilistic Risk Assessment Licensing Branch (NRR/DRA/APLA) issued Requests for Additional Information (RAIs) by letter dated February 27, 2016 (ADAMS Accession No. ML17027A328) and the licensee provided responses to the RAIs in a letter dated March 27, 2017 (ADAMS Accession No. ML17086A096). The NRC staff reviewed the responses and determined that additional information is needed for the staff to complete its evaluation as follows:

In the response to RAI-1, the licensee concluded that the risk from external flooding is negligible based on the conclusions from the Individual Plant Examination for External Events (IPEEE) and the 2014 re-evaluated external flooding hazards (Accession Nos. ML080160320 and ML14071A505, respectively). The 2014 HCGS external flooding hazard re-evaluation demonstrates that several external flooding mechanisms, including substantial storm surges, are plausible for the site and may lead to flooding in excess of plant grade such that water impinges upon plant structures. Therefore, the external flooding hazard for HCGS does not appear to be negligible for the current application and may, in fact, significantly impact the risk assessment for this application. The licensees response to RAI-1 indicates that there is no impact of external flooding on the current application due the licensees compliance with the Current Design Basis (CDB). This is not a sufficient basis for concluding that the risk from the external flood hazard is negligible for the reasons discussed below.

1

The HCGS IPEEE used qualitative arguments, such as the effectiveness of watertight doors and seals, to analyze and screen the risk of external flooding hazards. Operational experience has revealed possible failure of flood barriers due to degraded or missing seals and other factors (NRC Information Notice 2015-01, ADAMS Accession No. ML14279A268). Furthermore, demonstrating that the flood hazard is bounded by the CDB flood hazard does not address the frequency of exposure to floods (including those lower than the design basis flood) that may impinge upon SSCs and challenge plant safety, the impact of associated effects and the temporal characteristics of the event (e.g., the period of site inundation), and the risk associated with those floods. Additionally, both the IPEEE and the mitigating strategies assessment for flooding (ADAMS Accession No. ML16364A217) reference procedures for detecting and protecting against the effects of external flooding. However, failure estimates for such procedures and operator actions do not appear to be considered.

Provide the impact of external flooding risk on the current application with justification using a bounding quantitative assessment or a detailed qualitative assessment. Either justification should include consideration of the following factors:

• The frequency of external flooding mechanisms,

• The impact of external flooding mechanisms on plant operation and structures including the ability to cope with upset conditions,

• The operating experience associated with reliability of flood protection measures, and

• The reliability of operator actions.

Regards, 2

Hearing Identifier: NRR_PMDA Email Number: 3563 Mail Envelope Properties (59f7f3fd45de44459b5465bdad3effbe)

Subject:

Hope Creek - Final Request for Additional Information Concerning ILRT (MF8462)

Sent Date: 6/13/2017 4:04:27 PM Received Date: 6/13/2017 4:04:28 PM From: Regner, Lisa Created By: Lisa.Regner@nrc.gov Recipients:

"Ennis, Rick" <Rick.Ennis@nrc.gov>

Tracking Status: None "Ronewicz, Lynn" <Lynn.Ronewicz@nrc.gov>

Tracking Status: None "Paul.Duke@pseg.com" <Paul.Duke@pseg.com>

Tracking Status: None Post Office: HQPWMSMRS01.nrc.gov Files Size Date & Time MESSAGE 4588 6/13/2017 4:04:28 PM Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

Recipients Received: