ML20281A613

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Issuance of Amendment No. 225 Revise Technical Specification Actions for Suppression Pool Cooling
ML20281A613
Person / Time
Site: Hope Creek PSEG icon.png
Issue date: 11/09/2020
From: James Kim
Plant Licensing Branch 1
To: Carr E
Public Service Enterprise Group
Kim J
References
EPID L 2020 LLA 0104
Download: ML20281A613 (13)


Text

November 9, 2020 Mr. Eric Carr President and Chief Nuclear Officer PSEG Nuclear LLC - N09 P.O. Box 236 Hancocks Bridge, NJ 08038

SUBJECT:

HOPE CREEK GENERATING STATION ISSUANCE OF AMENDMENT NO. 225 RE: REVISE TECHNICAL SPECIFICATION ACTIONS FOR SUPPRESSION POOL COOLING (EPID L-2020-LLA-0104)

Dear Mr. Carr:

The U.S. Nuclear Regulatory Commission (Commission) has issued the enclosed Amendment No. 225 to Renewed Facility Operating License No. NPF-57 for the Hope Creek Generating Station in response to your application dated May 7, 2020.

The amendment revises Technical Specification 3.6.2.3, Suppression Pool Cooling, to modify the action for one inoperable loop from 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to 7 days and modifies the action for both loops inoperable to add an 8-hour allowed outage time in accordance with Technical Specifications Task Force Traveler, TSTF-230, Revision 1, Add New Condition B to LCO [Limiting Condition for Operation] 3.6.2.3, RHR [Residual Heat Removal] Suppression Pool Cooling.

A copy of the related safety evaluation is also enclosed. Notice of Issuance will be included in the Commissions monthly Federal Register notice.

Sincerely,

/RA/

James S. Kim, Project Manager Plant Licensing Branch I Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-354

Enclosures:

1. Amendment No. 225 to Renewed License No. NPF-57
2. Safety Evaluation cc: Listserv

PSEG NUCLEAR LLC DOCKET NO. 50-354 HOPE CREEK GENERATING STATION AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 225 Renewed License No. NPF-57

1.

The U.S. Nuclear Regulatory Commission (the Commission) has found that:

A.

The application for amendment filed by PSEG Nuclear LLC dated May 7, 2020, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations set forth in 10 CFR Chapter I; B.

The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.

There is reasonable assurance: (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations set forth in 10 CFR Chapter I; D.

The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.

The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

2.

Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Renewed Facility Operating License No. NPF-57 is hereby amended to read as follows:

(2)

Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 225, and the Environmental Protection Plan contained in Appendix B, are hereby incorporated in the renewed license. PSEG Nuclear LLC shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3.

The license amendment is effective as of its date of issuance and shall be implemented within 60 days.

FOR THE NUCLEAR REGULATORY COMMISSION James G. Danna, Chief Plant Licensing Branch I Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Renewed Facility Operating License and Technical Specifications Date of Issuance: November 9, 2020 James G.

Danna Digitally signed by James G. Danna Date: 2020.11.09 17:16:55 -05'00'

ATTACHMENT TO LICENSE AMENDMENT NO. 225 HOPE CREEK GENERATING STATION RENEWED FACILITY OPERATING LICENSE NO. NPF-57 DOCKET NO. 50-354 Replace the following page of the Renewed Facility Operating License with the attached revised page. The revised page is identified by amendment number and contains a marginal line indicating the area of change.

Remove Insert 3

3 Replace the following page of the Appendix A, Technical Specifications, with the attached revised page. The revised page is identified by amendment number and contains marginal lines indicating the areas of change.

Remove Insert 3/4 6-16 3/4 6-16

reactor operation, as described in the Final Safety Analysis Report, as supplemented and amended; (4)

PSEG Nuclear LLC, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use at any time any byproduct, source and special nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required; (5)

PSEG Nuclear LLC, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use in amounts as required any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; and (6)

PSEG Nuclear LLC, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility. Mechanical disassembly of the GE14i isotope test assemblies containing Cobalt-60 is not considered separation.

(7)

PSEG Nuclear LLC, pursuant to the Act and 10 CFR Part 30, to intentionally produce, possess, receive, transfer, and use Cobalt-60.

C.

This renewed license shall be deemed to contain and is subject to the conditions specified in the Commissions regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

(1)

Maximum Power Level PSEG Nuclear LLC is authorized to operate the facility at reactor core power levels not in excess of 3902 megawatts thermal (100 percent rated power) in accordance with the conditions specified herein.

(2)

Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 225, and the Environmental Protection Plan contained in Appendix B, are hereby incorporated in the renewed license. PSEG Nuclear LLC shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

Renewed License No. NPF-57 Amendment No. 225

CONTAINMENT SYSTEMS SUPPRESSION POOL COOLING LIMITING CONDITION FOR OPERATION 3.6.2.3 The suppression pool cooling mode of the residual heat removal (RHR) system shall be OPERABLE with two independent loops, each loop consisting of:

a.

One OPERABLE RHR pump, and b.

An OPERABLE flow path capable of recirculating water from the suppression chamber through an RHR heat exchanger.

APPLICABILITY: OPERATIONAL CONDITIONS 1, 2 and 3.

ACTION:

a.

With one suppression pool cooling loop inoperable, restore the inoperable loop to OPERABLE status within 7 days or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTDOWN within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

b.

With both suppression pool cooling loops inoperable, restore one RHR suppression pool cooling loop 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 SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTDOWN*

within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

SURVEILLANCE REQUIREMENTS 4.6.2.3 The suppression pool cooling mode of the RHR system shall be demonstrated OPERABLE:

a.

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.

b.

By verifying that each of the required RHR pumps develops a flow of at least 10,160 gpm on recirculation flow through the RHR heat exchanger (after consideration of flow through the closed bypass valve) and the suppression pool when tested pursuant to the INSERVICE TESTING PROGRAM.

Whenever both RHR subsystems are inoperable, if unable to attain COLD SHUTDOWN as required by this ACTION, maintain reactor coolant temperature as low as practical by use of alternate heat removal methods.

HOPE CREEK 3/4 6-16 Amendment No. 225

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 225 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-57 PSEG NUCLEAR LLC HOPE CREEK GENERATING STATION DOCKET NO. 50-354

1.0 INTRODUCTION

By letter dated May 7, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20128J820), PSEG Nuclear LLC (the licensee) submitted a license amendment request for the Hope Creek Generating Station (Hope Creek). The amendment would revise Technical Specification (TS) 3.6.2.3, Suppression Pool Cooling, to adopt Technical Specifications Task Force Traveler, TSTF-230, Revision 1, Add New Condition B to LCO [Limiting Condition for Operation] 3.6.2.3, RHR [Residual Heat Removal] Suppression Pool Cooling (ADAMS Accession No. ML040570110).

The proposed change to Action b of LCO 3.6.2.3 would allow two RHR suppression pool cooling (SPC) subsystems to be inoperable for up to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. The licensee also proposed changes to Action a of LCO 3.6.2.3 to allow a single train of SPC to be out of service for 7 days, instead of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, which would be consistent with the currently approved Standard Technical Specifications (STS).

2.0 REGULATORY EVALUATION

2.1

System Description

The Hope Creek SPC function is performed by the RHR system, which contains two redundant loops. The system uses heat exchangers to remove decay heat from the reactor during shutdown and to maintain containment temperatures following design-basis accidents (DBAs) and transients. The SPC mode of operation controls containment temperature, which can also be controlled using the suppression pool spray mode. The heat exchangers allow the containment heat load to be transferred to the safety auxiliary cooling system.

Following a DBA (e.g., a loss-of-coolant accident (LOCA)), SPC is used to remove heat from the suppression pool. The suppression pool is designed to absorb the heat and energy that is released during a LOCA to ensure that the primary containment temperature remains within its design limits. The RHR system has two redundant loops to provide assurance that the function will be performed reliably. To cool the suppression pool, the water is pumped from the suppression pool through a heat exchanger and back to the suppression pool. Each individual loop can individually maintain suppression pool temperature within the required limits.

2.2 Proposed Changes to the Technical Specifications The LCO for TS 3.6.2.3 requires the SPC mode of RHR to be operable with two independent loops, each consisting of an operable RHR pump and a flow path capable of recirculating water from the suppression pool through an RHR heat exchanger.

Required Action a of TS 3.6.2.3 requires, with one SPC loop inoperable, that the loop be restored 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 the unit be brought to hot shutdown within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and cold shutdown within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Required Action b of TS 3.6.2.3 requires, with both SPC loops inoperable, that the unit immediately be brought to hot shutdown within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and cold shutdown within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

2.2.1 Proposed Revision to LCO 3.6.2.3 Action A The licensee requested that Action a be changed to allow a 7-day allowed outage time (AOT) for a single loop of SPC inoperable, replacing the current 72-hour AOT.

2.2.2 Proposed Revision to LCO 3.6.2.3 Action b The licensee requested that Action b be changed to allow an 8-hour AOT for both loops of SPC inoperable. This would establish an 8-hour AOT where there currently is none. Currently, actions to enter lower modes are started immediately. The new AOT would provide an 8-hour period before requiring action to move to a lower mode.

2.3 Applicable Regulatory Requirements and Guidance The regulation at Title 10 of the Code of Federal Regulations (10 CFR) 50.36(a)(1) requires an applicant for an operating license to include in the application proposed TSs in accordance with the requirements of 10 CFR 50.36. The applicant must include in the application, a summary statement of the bases or reasons for such specifications, other than those covering administrative controls. However, per 10 CFR 50.36(a)(1), these technical specification bases shall not become part of the technical specifications.

Additionally, 10 CFR 50.36(b) requires:

Each license authorizing operation of a utilization facility will include technical specifications. The technical specifications will be derived from the analyses and evaluation included in the safety analysis report, and amendments thereto, submitted pursuant to

[10 CFR] 50.34 [Contents of applications; technical information].

The Commission may include such additional technical specifications as the Commission finds appropriate.

The categories of items required to be in the TSs are provided in 10 CFR 50.36(c). As required by 10 CFR 50.36(c)(2)(i), the TSs will include LCOs, which are the lowest functional capability or performance levels of equipment required for safe operation of the facility. Per 10 CFR 50.36(c)(2)(i), when an LCO of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the TSs until the condition can be met.

The criteria for determining whether a TS LCO must be established for a particular item are provided in 10 CFR 50.36(c)(2)(ii).

The regulation at 10 CFR 50.36(c)(3) requires TSs to include items in the category of surveillance requirements (SRs), which are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the LCOs will be met. The SRs are not changed by this license amendment request and remain acceptable means to verify that the LCOs are met.

The NRC staffs guidance for the review of TSs is in Chapter 16.0, Technical Specifications, of NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR [Light-Water Reactor] Edition, Revision 3 (ADAMS Accession No. ML100351425), dated March 2010. As described therein, as part of the regulatory standardization effort, the NRC staff has prepared STS (NUREG-1430 to NUREG-1434) for each of the LWR nuclear designs. Accordingly, the NRC staffs review includes consideration of whether the proposed changes are consistent with the applicable reference STS (i.e., the current STS), as modified by NRC-approved travelers such as TSTF-230, Revision 1. In addition, the guidance states that comparing the change to previous STS can help clarify the intent of the TSs.

NUREG-1433, Revision 4, Standard Technical Specifications - General Electric BWR/4 Plants includes the STS applicable to Hope Creek (ADAMS Accession No. ML12104A192).

3.0 TECHNICAL EVALUATION

The licensee requested the proposed changes to the Hope Creek TSs to allow additional operational flexibility and to make the TSs consistent with the current STS. The NRC staff evaluated the licensees application to determine if the proposed changes are consistent with the guidance, regulations, and licensing information discussed in Section 2.3 of this safety evaluation, including NRC regulations, NRC-approved TSTF-230, Revision 1, and the current STS for General Electric BWR/4 plants (NUREG-1433, Revision 4). In determining whether an amendment to a license will be issued, the Commission is guided by the considerations that govern the issuance of initial licenses to the extent applicable and appropriate.

3.1 Proposed Technical Specification Changes 3.1.1 Proposed Changes to LCO 3.6.2.3, Action a The licensee requested that Action a be changed to allow a 7-day AOT instead of a 72-hour AOT when a single loop of SPC is inoperable. This would allow the plant to operate for 7 days with a single SPC loop inoperable. If the loop is not returned to operable within 7 days, the TS requires the plant to enter lower modes of operation.

The licensee stated that the change from a 72-hour to a 7-day AOT is consistent with the current STS, which allow a 7-day AOT. In addition, the longer AOT would allow online repairs that cannot be accomplished within the shorter AOT. The post-LOCA SPC mode is required to mitigate the consequences of an accident, which is mainly a standby function. However, during shutdown, the RHR system is used to provide shutdown cooling and is not in standby.

Providing the longer AOT allows greater maintenance flexibility for the RHR system.

The licensee stated that a single loop of SPC can maintain the suppression pool temperature within design limits. The ability of a single train to perform this function was evaluated to support an extended power uprate for Hope Creek. The evaluation found the design acceptable, and the NRC confirmed that adequate containment temperature and pressure control can be maintained by a single loop at the uprated conditions (Hope Creek License Amendment No. 174, dated May 14, 2008 (ADAMS Accession No. ML081230640)).

In addition, the licensee stated that extending the AOT for a single train of SPC from 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to 7 days is consistent with the STS for General Electric BWR/4 plants. When the STS were updated from those based on NUREG-0123, Standard Technical Specifications for General Electric Boiling Water Reactors (ADAMS Accession No. ML19343B588), to NUREG-1433, the AOT was increased from 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to 7 days. The licensee stated in its application that the justification for this change is as follows:

The restoration time is extended to 7 days. This time is consistent with the restoration time for an inoperable ECCS [emergency core cooling system]

subsystem. The redundancy and diversity of the ECCS design has justified a 7 day Completion Time for one subsystem being inoperable. The components of the LPCI [low-pressure coolant injection] ECCS subsystem also are required to be OPERABLE for various other functions (suppression pool cooling, containment spray, etc.) and the ITS [Improved Technical Specifications]

presents the ACTIONS for one inoperable subsystem in each of these Specifications with the same 7 day Completion Time. These functions (ultimately containment and decay heat removal functions) have designed diversity and redundancy in various suppression pool cooling, containment spray, and containment ventilation systems, supporting the engineering judgement that a 7 day AOT for one inoperable loop is sufficient.

In addition, the licensees application referenced the following discussion from the bases of NUREG-1433:

With one RHR suppression pool cooling subsystem inoperable, the inoperable subsystem must be restored to OPERABLE status within 7 days. In this Condition, the remaining RHR suppression pool cooling subsystem is adequate to perform the primary containment cooling function. However, the overall reliability is reduced because a single failure in the OPERABLE subsystem could result in reduced primary containment cooling capability. The 7 day Completion Time is acceptable in light of the redundant RHR suppression pool cooling capabilities afforded by the OPERABLE subsystem and the low probability of a DBA occurring during this period.

The NRC staff has reviewed the Hope Creek design and determined that approval of the 7-day AOT for a single loop of SPC inoperable provides reasonable assurance that the plant can operate safely. The design of the RHR system, including the SPC mode, is consistent with the assumptions and considerations that were applied in the development of the STS (NUREG-1433). As determined during the development of the STS, it is appropriate to assign the same AOT to the SPC mode as the other ECCS functions. The bases for the STS discuss the redundancy available and the reduction in reliability when a single loop of SPC is inoperable. After considering these attributes, the bases conclude that the 7-day AOT is acceptable because the operable loop is available and can perform the necessary function independent of the inoperable loop, and there is a low probability of DBA occurrence during the AOT window. Therefore, the NRC staff finds the 7-day AOT for a single loop of SPC inoperable is acceptable.

3.1.2 Proposed Changes to LCO 3.6.2.3, Action b The licensee requested that Action b be changed to allow an 8-hour AOT in place of requiring immediate action if both loops of SPC are inoperable. If neither loop of SPC is returned to operable within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, the TSs would require the plant to enter lower modes of operation.

Currently the TSs require the licensee to immediately begin the process of entering lower modes of operation. As noted in its application, the licensees basis for the change was NRC-approved TSTF-230, Revision 1, which was developed specifically to allow this change for all BWR/4 plants that demonstrate that their plant design supports the change.

The licensee stated that allowing an 8-hour AOT for two loops inoperable is appropriate since an immediate plant shutdown has the potential in resulting in a plant scram that could result in steam being discharged to the suppression pool. With both loops of SPC inoperable, the heat rejected to the suppression pool could not be removed. The licensee stated that the 8-hour AOT would provide some time to restore a loop of SPC prior to requiring a unit shutdown.

The licensee stated that it had reviewed TSTF-230, Revision 1, and determined that it is applicable to Hope Creek. The licensee also noted that the 8-hour AOT is consistent with Hope Creek TS 3.6.2.2, Action b, for both loops of suppression pool spray inoperable.

The NRC staff reviewed the licensees submittal and plant design and concluded that TSTF-230, Revision 1, is applicable to Hope Creek and that the change in AOT is acceptable.

The 8-hour time is considered acceptable due to the low probability of a DBA occurring within this short period. Thus, the NRC staff concludes that the licensees proposal is consistent with the intent of TSTF-230, Revision 1. Based on the above, the NRC staff finds the proposed change is acceptable and that incorporation of the new AOT in LCO 3.6.2.3, Action b, retains reasonable assurance that the plant can be operated safely.

3.1.3 Technical Evaluation Summary The NRC staff finds that the proposed changes in AOT for both the single loop and both loops of SPC inoperable will allow operation of the plant with reasonable assurance of safety. The AOT for a single loop of SPC inoperable is changed from 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to 7 days. The AOT of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> is established for both SPC loops inoperable. The license amendment request does not change the design or function of any safety or non-safety-related systems. The existing SRs are unchanged and provide adequate assurance that the LCOs will be met.

The staff reviewed the licensees request and determined that it is consistent with the current STS for BWR/4 plants, including changes evaluated and approved by TSTF-230, Revision 1.

Therefore, the NRC staff concludes that the proposed TS changes are acceptable.

4.0 STATE CONSULTATION

In accordance with the Commissions regulations, the New Jersey State official was notified of the proposed issuance of the amendment on October 7, 2020. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendment changes requirements with respect to the installation or use of facility components located within the restricted area as defined in 10 CFR Part 20 and changes SRs.

The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration, as published in the Federal Register (85 FR 36436; June 16, 2020), and there has been no public comment on such finding.

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

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that 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.

Principal Contributors: S. Smith D. Scully Date: November 9, 2020

ML20281A613

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