ML21098A087

Issuance of Amendment No. 228 Adopt Technical Specifications Task Force TSTF-427, Allowance for Non Technical Specification Barrier Degradation on Supported System Operability

ML21098A087
Person / Time
Site:	Hope Creek
Issue date:	04/26/2021
From:	James Kim Plant Licensing Branch 1
To:	Carr E Public Service Enterprise Group
Kim J
References
EPID L-2020-LLA-0186
Download: ML21098A087 (22)

Text

April 26, 2021 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. 228 RE: ADOPTION OF TECHNICAL SPECIFICATIONS TASK FORCE TRAVELER TSTF-427, REVISION 2, ALLOWANCE FOR NON TECHNICAL SPECIFICATION BARRIER DEGRADATION ON SUPPORTED SYSTEM OPERABILITY (EPID L-2020-LLA-0186)

Dear Mr. Carr:

The U.S. Nuclear Regulatory Commission (NRC, the Commission) has issued the enclosed Amendment No. 228 to Renewed Facility Operating License No. NPF-57 for the Hope Creek Generating Station in response to your application dated August 19, 2020.

The amendment revises the technical specification requirements for unavailable barriers by adding Limiting Condition for Operation 3.0.9. This change is consistent with NRC approved Industry Technical Specifications Task Force (TSTF) Change Traveler TSTF-427, Revision 2, Allowance for Non Technical Specification Barrier Degradation on Supported System OPERABILITY. The availability of this TS improvement was published in the Federal Register on October 3, 2006, as part of the Consolidated Line Item Improvement Process (71 FR 58444).

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. 228 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. 228 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 August 19, 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. 228, 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 120 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: April 26, 2021 Jennifer C.

Tobin Digitally signed by Jennifer C. Tobin Date: 2021.04.26 09:37:07 -04'00'

ATTACHMENT TO LICENSE AMENDMENT NO. 228 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 pages of the Appendix A, Technical Specifications, with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Remove Insert 3/4 0-1 3/4 0-1 3/4 0-2 3/4 0-2

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. 228, 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. 228

3/4.0 APPLICABILITY LIMITING CONDITION FOR OPERATION 3.0.1 Compliance with the Limiting Conditions for Operation contained in the succeeding Specifications is required during the OPERATIONAL CONDITIONS or other conditions specified therein; except that upon failure to meet the Limiting Conditions for Operation, the associated ACTION requirements shall be met, and except as provided in LCO 3.0.8, and LCO 3.0.9.

3.0.2 Noncompliance with a Specification shall exist when the requirements of the Limiting Condition for Operation and associated ACTION requirements are not met within the specified time intervals. If the Limiting Condition for Operation is restored prior to expiration of the specified time intervals, completion of the Action requirements is not required.

3.0.3 When a Limiting Condition for Operation is not met, except as provided in the associated ACTION requirements, within one hour action shall be initiated to place the unit in an OPERATIONAL CONDITION in which the Specification does not apply by placing it, as applicable, in:

1.

At least STARTUP within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />,

2.

At least HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and

3.

At least COLD SHUTDOWN within the subsequent 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Where corrective measures are completed that permit operation under the ACTION requirements, the ACTION may be taken in accordance with the specified time limits as measured from the time of failure to meet the Limiting Condition for Operation. Exceptions to these requirements are stated in the individual Specifications.

This Specification is not applicable in OPERATIONAL CONDITIONS 4 or 5.

3.0.4 When an LCO is not met, entry into an OPERATIONAL CONDITION or other specified condition in the Applicability shall only be made:

a. When the associated ACTIONS to be entered permit continued operation in the OPERATIONAL CONDITION or other specified condition in the Applicability for an unlimited period of time; or

b. After performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the OPERATIONAL CONDITION or other specified condition in the Applicability, and establishment of risk management actions, if appropriate (exceptions to this Specification are stated in the individual Specifications); or

c. When an allowance is stated in the individual value, parameter, or other Specification.

This Specification shall not prevent changes in OPERATIONAL CONDITIONS or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

HOPE CREEK 3/4 0-1 Amendment No. 228

APPLICABILITY LIMITING CONDITION FOR OPERATION (Continued) 3.0.5 Equipment removed from service or declared inoperable to comply with ACTIONS may be returned to service under administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other equipment. This is an exception to LCO 3.0.2 for the system returned to service under administrative control to perform the testing required to demonstrate OPERABILITY.

3.0.6 Not used.

3.0.7 Not used.

3.0.8 Inoperability of Snubbers When one or more required snubbers are unable to perform their associated support function(s), any affected supported LCO(s) are not required to be declared not met solely for this reason if risk is assessed and managed, and:

a. the snubbers not able to perform their associated support function(s) are associated with only one train or subsystem of a multiple train or subsystem supported system or are associated with a single train or subsystem supported system and are able to perform their associated support function within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />; or

b. the snubbers not able to perform their associated support function(s) are associated with more than one train or subsystem of a multiple train or subsystem supported system and are able to perform their associated support function within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

At the end of the specified period the required snubbers must be able to perform their associated support function(s), or the affected supported system LCO(s) shall be declared not met.

LCO 3.0.9 When one or more required barriers are unable to perform their related support function(s), any supported system LCO(s) are not required to be declared not met solely for this reason for up to 30 days provided that at least one train or subsystem of the supported system is OPERABLE and supported by barriers capable of providing their related support function(s),

and risk is assessed and managed. This specification may be concurrently applied to more than one train or subsystem of a multiple train or subsystem supported system provided at least one train or subsystem of the supported system is OPERABLE and the barriers supporting each of these trains or subsystems provide their related support function(s) for different categories of initiating events.

For the purposes of this specification, the High Pressure Coolant Injection system, the Reactor Core Isolation Cooling system, and the Automatic Depressurization System are considered independent subsystems of a single system.

If the required OPERABLE train or subsystem becomes inoperable while this specification is in use, it must be restored to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or the provisions of this specification cannot be applied to the trains or subsystems supported by the barriers that cannot perform their related support function(s).

At the end of the specified period, the required barriers must be able to perform their related support function(s) or the supported system LCO(s) shall be declared not met.

HOPE CREEK 3/4 0-2 Amendment No. 228

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 228 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 August 19, 2020 (Reference 1), PSEG Nuclear LLC (licensee), submitted a license amendment request regarding the renewed facility operating license and technical specifications (TS) for Hope Creek Generating Station (Hope Creek). The proposed amendment would modify the TS requirements for unavailable barriers by adding Limiting Condition for Operation (LCO) 3.0.9. This LCO establishes conditions under which TS systems would remain operable when required physical barriers are not capable of providing their related support function. The licensees application stated that the proposed changes are consistent with U.S. Nuclear Regulatory Commission (NRC) approved Technical Specifications Task Force (TSTF) Standard Technical Specification (STS) Change Traveler, TSTF-427, Revision 2, Allowance for Non Technical Specification Barrier Degradation on Supported System OPERABILITY, dated May 3, 2006 (Reference 2). The availability of this TS improvement was published in the Federal Register on October 3, 2006 (71 FR 58444), as part of the Consolidated Line Item Improvement Process.

On May 3, 2006, the industry owners group TSTF submitted a proposed change, TSTF-427, Revision 2, to the STSs (NUREGs 1430-1434) on behalf of the industry (TSTF-427, Revisions 0 and 1 were prior draft iterations). TSTF-427, Revision 2, is a proposal to add LCO 3.0.9, allowing a delay time for entering a supported system TS, when the inoperability is due solely to an unavailable barrier, if risk is assessed and managed. The postulated initiating events which may require a functional barrier are limited to those with low frequencies of occurrence, and the overall TS system safety function would still be available for the majority of anticipated challenges.

The proposed change adds a new LCO to the TS. This new LCO allows the licensee to delay declaring an LCO not met for equipment supported by barriers unable to perform their associated support function, when risk is assessed and managed.

For Hope Creek, this new LCO is LCO 3.0.9 and states:

When one or more required barriers are unable to perform their related support function(s), any supported system LCO(s) are not required to be declared not met solely for this reason for up to 30 days provided that at least one train or subsystem of the supported system is OPERABLE and supported by barriers capable of providing their related support function(s), and risk is assessed and managed. This specification may be concurrently applied to more than one train or subsystem of a multiple train or subsystem supported system provided at least one train or subsystem of the supported system is OPERABLE and the barriers supporting each of these trains or subsystems provide their related support function(s) for different categories of initiating events.

For the purposes of this specification, the High Pressure Coolant Injection system, the Reactor Core Isolation Cooling system, and the Automatic Depressurization System are considered independent subsystems of a single system.

If the required OPERABLE train or subsystem becomes inoperable while this specification is in use, it must be restored to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or the provisions of this specification cannot be applied to the trains or subsystems supported by the barriers that cannot perform their related support function(s).

At the end of the specified period, the required barriers must be able to perform their related support function(s), or the supported system LCO(s) shall be declared not met.

Consistent with TSTF-427, Revision 2, the licensee proposed conforming changes to add new LCO 3.0.9 as an exception to LCO 3.0.1.

2.0 REGULATORY EVALUATION

In Title 10 of the Code of Federal Regulations (10 CFR) Section 50.36, the Commission established its regulatory requirements related to the content of TS. Pursuant to 10 CFR 50.36, TS 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) LCOs; (3) surveillance requirements (SRs); (4) design features; and (5) administrative controls. The rule does not specify the particular requirements to be included in a plants TS.

As stated in 10 CFR 50.36(c)(2)(i), the Limiting conditions for operation are the lowest functional capability or performance levels of equipment required for safe operation of the facility. When a limiting condition for operational of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the technical specifications. TS Section 3.0, LCO and SR Applicability, provides details or ground rules for complying with the LCOs.

Barriers are doors, walls, floor plugs, curbs, hatches, installed structures or components, or other devices, not explicitly described in TS that support the performance of the functions of systems described in the TS. For purposes of this TS LCO, the term barrier refers to one or more devices which protect one train of a safety system from a given initiating event. A degraded barrier refers to a barrier that has been found to be degraded and must be repaired, or to a barrier that is purposefully removed or reconfigured to facilitate maintenance activities.

As stated in Nuclear Energy Institute (NEI) 04-08, Risk-Informed Technical Specifications Initiative 7a, Allowance for Non-Technical Specification Barrier Degradation on Supported System OPERATABILITY (TSTF-427), Industry Implementation Guidance, dated March 2006 (Reference 3), this new LCO 3.0.9 specifically does not apply to fire barriers, snubbers, barriers which support ventilation systems or non-TS systems, or barriers which support TS systems where the unavailability of the barrier does not render the supported system inoperable.

Some TS-required systems may require one or more functional barriers in order to perform their intended function(s) for certain initiating events for which the barriers provide some protective support function. For example, there are barriers to protect systems from the effects of internal flooding, such as floor plugs and retaining walls, and barriers are used to protect equipment from steam impingement in case of high-energy line breaks. Barriers are also used to protect systems against missiles, either internally generated, or generated by external events.

Barriers are not explicitly described in the TS but are required to be capable of performing their required support function by the definition of OPERABILITY for the supported system which is described in the TS. Therefore, under the current STS, the supported system must be declared inoperable when the related barrier(s) are unavailable. However, the magnitude of plant risk associated with the barrier which cannot perform its related support function is much less than the risk associated with direct unavailability of the supported system, since barriers are only required for specific, low frequency initiating events.

Some potential undesirable consequences of the current TS requirements include:

1.

When maintenance activities on the supported TS system require removal and restoration of barriers, the time available to complete maintenance and perform system restoration and testing is reduced by the time spent maneuvering the barriers within the time constraints of the supported system LCO;

2.

Restoration of barriers following maintenance may be given a high priority due to time restraints of the existing supported system LCO, when other activities may have a greater risk impact and should therefore be given priority; and

3.

Unnecessary plant shutdowns may occur due to discovery of degraded barriers which require more time than provided by the existing supported system LCO to complete repairs and restoration of the barrier.

To improve the treatment of unavailable barriers and enhance safety, the licensee proposed a risk-informed TS change that introduces a delay time before entering the actions for the supported equipment, when one or more barriers are found to be degraded, or are removed or reconfigured to support maintenance activities, if risk is assessed and managed. Such a time delay will provide needed flexibility in the performance of maintenance and at the same time will enhance overall plant safety by:

1.

Performing system maintenance and restoration activities, including post-maintenance testing, within the existing TS LCO time, and allowing barrier removal and restoration to be performed outside of the TS LCO, providing more time for the safe conduct of maintenance and testing activities on the supported TS system;

2.

Requiring barrier removal and restoration activities to be assessed and prioritized based on actual plant risk impacts; and

3.

Avoiding unnecessary unscheduled plant shutdowns and thus minimizing plant transition and realignment risks.

3.0 TECHNICAL EVALUATION

The industry submitted TSTF-427, Revision 2, in support of the proposed TS change. This submittal documents a risk-informed analysis of the proposed TS change. Probabilistic risk assessment (PRA) methods are used, in combination with deterministic and defense-in-depth arguments, to identify and justify delay times for entering the actions for the supported equipment associated with unavailable barriers at nuclear power plants. The industry also submitted implementation guidance NEI 04-08. This submittal provides detailed guidance on assessing and managing risk associated with unavailable barriers. This is in accordance with guidance provided in Regulatory Guide (RG) 1.174, An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis, dated July 1998 (Reference 4), and RG 1.177, An Approach for Plant-Specific, Risk-Informed Decisionmaking: Technical Specifications, dated August 1998 (Reference 5).

The risk impact associated with the proposed delay times for entering the TS actions for the supported equipment can be assessed using the same approach as for allowed completion time (CT) extensions. Therefore, the risk assessment was performed following the three-tiered approach recommended in RG 1.177 for evaluating proposed extensions in currently allowed CTs:

1.

The first tier involves the assessment of the change in plant risk due to the proposed TS change. Such risk change is expressed (1) by the change in the average yearly core damage frequency (CDF) and the average yearly large early release frequency (LERF) and (2) by the incremental conditional core damage probability (ICCDP) and the incremental conditional large early release probability (ICLERP).

The assessed CDF and LERF values are compared to acceptance guidelines, consistent with the Commission's Safety Goal Policy Statement as documented in RG 1.174, so that the plants average baseline risk is maintained within a minimal range. The assessed ICCDP and ICLERP values are compared to acceptance guidelines in RG 1.177, which provide assurance that the plant risk does not increase unacceptably during the period the equipment is taken out of service.

2.

The second tier involves the identification of potentially high-risk configurations that could exist if equipment in addition to that associated with the change were to be taken out of service simultaneously, or other risk-significant operational factors such as concurrent equipment testing were also involved. The objective is to ensure that appropriate restrictions are in place to avoid any potential high-risk configurations.

3.

The third tier involves the establishment of an overall configuration risk management program (CRMP) to ensure that potentially risk-significant configurations resulting from maintenance and other operational activities are identified. The objective of the CRMP is to manage configuration-specific risk by appropriate scheduling of plant activities and/or appropriate compensatory measures.

In TSTF-427, a simplified risk assessment was performed to justify the proposed addition of new LCO 3.0.9 to the licensees TS. This approach was necessitated by (1) the general nature of the proposed TS change (i.e., it applies to all plants and is associated with an undetermined number of barriers that are not able to perform their function), and (2) the lack of detailed modeling in most plant-specific PRAs which do not include passive structures such as barriers.

The simplified risk assessment considers three different parameters:

1. The length of time the affected barrier is unavailable,

2. The initiating event frequency for which the affected barrier is designed to mitigate, and

3. The importance to CDF (or LERF) of the TS equipment (train, subsystem, or component) for which the affected barrier is designed to protect, measured by the risk achievement worth (RAW) of the equipment.

The ICCDP can be calculated based on the following equation:

ICCDP T

IE IE RAW CDF CDF C

i T

j base base

8766 Where:

Tc is the time the barrier is unavailable (hours)

Tc/8766 is therefore the fraction of the year during which the barrier is unavailable, IEi/IET is the ratio of the initiating event frequency for which the affected barrier is designed to mitigate, IEi, and the total initiating event frequency, IET, RAWj is the risk achievement worth of the component(s) for which the barrier provides protection, and CDFbase is the baseline CDF (per year).

ICLERP also may be similarly determined, using baseline LERF and RAW values with respect to LERF. It is assumed that the magnitude of the LERF risk resulting from the barrier unable to perform its related support function would be generally at least one order of magnitude less than the corresponding CDF risk. Containment bypass scenarios, which are typically the significant contributors to LERF, would not be uniquely affected by application of the new LCO 3.0.9, and initiating events which would be significant LERF contributors, such as steam generator tube rupture and interfacing systems loss-of-coolant accident (LOCA), are not typically associated with barriers within the scope of this new LCO. Therefore, the assumption regarding LERF risk is reasonable and acceptable for the generic risk evaluation, provided that LERF risk impacts are considered on a plant-specific basis for unavailable barriers, as described in Section 3.1.3 of this safety evaluation (SE).

The relevant initiating events (i.e., events for which barriers subject to LCO 3.0.9 provide protection) are: internal and external floods, high-energy line breaks, feedwater line breaks, LOCAs (small, medium, and large), tornados and high winds, and turbine missiles. Generic frequencies for most of these initiating events were obtained from NUREG/CR-5750, Rates of Initiating Events at U.S. Nuclear Power Plants: 1987-1995, dated February 1999 (Reference 6). For external floods, turbine missiles, and tornados, other industry source documents were referenced. The most limiting (highest frequency) initiating event was obtained for a high-energy line break from NUREG/CR-5750, with a frequency of 9.1E-3 per year. The risk assessment is, therefore, based on this limiting frequency, and the proposed methodology to apply this new LCO is similarly restricted to barriers protecting against initiating events whose total frequency is no more than 9.1E-3 per year.

3.1 Risk Assessment Results and Insights The results and insights from the implementation of the three-tiered approach of RG 1.177 to support the proposed addition of this new LCO to the licensees TS are summarized and evaluated in the following Sections 3.1.1 to 3.1.3 of this SE.

3.1.1 Risk Impact The bounding risk assessment approach, described in Section 3.0 of this SE, was developed for a range of plant baseline CDF values and for a range of protected component RAW values.

The maximum allowable 30-day outage time was used. The results are summarized in Table 1.

Table 1. Risk Assessment Results for a Postulated 30-Day Barrier Outage.

Baseline CDF = 1E-6 per year RAW ICCDP ICLERP 2

7.5E-10 7.5E-11 10 6.7E-09 6.7E-10 50 3.7E-08 3.7E-09 100 7.4E-08 7.4E-09 Baseline CDF = 1E-5 per year RAW ICCDP ICLERP 2

7.5E-09 7.5E-10 10 6.7E-08 6.7E-09 50 3.7E-07 3.7E-08 100 7.4E-07 7.4E-08 Baseline CDF = 1E-4 per year RAW ICCDP ICLERP 2

7.5E-08 7.5E-09 10 6.7E-07 6.7E-08 50 3.7E-06 3.7E-07 100 7.4E-06 7.4E-07 The above results represent a sensitivity analysis covering the expected range of plant baseline CDF values and component RAW values. The most limiting configurations involving very high risk components (RAW > 10) would not be anticipated to occur for most planned maintenance activities.

The calculations conservatively assume the most limiting (highest frequency) initiating event and the longest allowable outage time (30 days). Occurrence of the initiating event during unavailability of the barrier is conservatively assumed to directly fail the protected equipment; no credit is taken for event-specific circumstances which may result in the equipment remaining functional even with the barrier unavailable. (For example, a barrier required to protect equipment from steam impingement for high-energy line breaks may only be required for breaks occurring in specific locations and orientations relative to the protected equipment, and only for large size breaks.) No credit is taken for avoided risk identified in Section 2.0 of this SE.

The risk assessment results of Table 1 were compared to guidance provided in the revised Section 11 of NUMARC 93-01, Revision 4f, Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, dated April 2018 (Reference 7), endorsed by RG 1.160, Revision 4, Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, dated August 2018 (Reference 8), for implementing the requirements of paragraph (a)(4) of the Maintenance Rule, 10 CFR 50.65. Such guidance is summarized in Table 2. Guidance regarding the acceptability of conditional risk increase in terms of CDF for a planned configuration is provided. This guidance states that a specific configuration that is associated with a CDF higher than 1E-3 per year should not normally be entered voluntarily. The NRC staff notes that the higher risk configurations documented in Table 1 would exceed this guidance and would therefore not be permitted to be entered voluntarily. For example, with a baseline CDF of 1E-4 per year, a component with a RAW greater than 10 would exceed the 1E-3 per year criteria. Therefore, the sensitivity analyses presented in Table 1 are understood to include higher risk configurations which would not be permitted under the guidance of NUMARC 93-01.

Table 2. Guidance for Implementing 10 CFR 50.65(a)(4)

RCDF Guidance Greater than 1E-3/year Configuration should not normally be entered voluntarily ICCDP Guidance ICLERP Greater than 1E-5 Configuration should not normally be entered voluntarily Greater than 1E-6 1E-6 to 1E-5 Assess non-quantifiable factors Establish risk management actions 1E-7 to 1E-6 Less than 1E-6 Normal work controls Less than1E-7 Guidance regarding the acceptability of ICCDP and ICLERP values for a specific planned configuration and the establishment of risk management actions is also provided in NUMARC 93-01. This guidance, as shown in Table 2, states that a specific plant configuration that is associated with ICCDP and ICLERP values below 1E-6 and 1E-7, respectively, is considered to require normal work controls. Table 1 shows that for the majority of barrier outage configurations, the conservatively assessed ICCDP and ICLERP values are within the limits for what is recommended as the threshold for the normal work controls region.

As stated in the implementation guidance for STS LCO 3.0.9 (TSTF-427, Revision 2), plants are required to commit to the guidance of NUMARC 93-01, Section 11; therefore, the above limits would be applicable. Plant configurations including out-of-service barriers may, therefore, be entered voluntarily if supported by the results of the risk assessment required by 10 CFR 50.65(a)(4), and by the new LCO 3.0.9.

RG 1.177 provides guidance of 5E-7 ICDP and 5E-8 ILERP as the limit for TS allowed outage time. As shown in Table 1, the guidance is met for the typically anticipated configurations, unless either the baseline CDF for the plant approaches 1E-4 per year or the RAW of the protected components is well above 10. Such configurations may exceed the criteria described in NUMARC 93-01 (Table 2) and would not be voluntarily entered. Such configurations are not expected to be frequently encountered and may be addressed on a case-by-case plant-specific basis by limiting the allowed outage time and by implementing plant-specific risk management actions, as per the implementing guidance (TSTF-427, Revision 2).

RG 1.174 provides guidance of 1E-5 per year CDF and 1E-6 per year LERF. The ICCDP calculations demonstrated that each individual 30-day barrier outage is anticipated to be low risk. Although there is no explicit limit on the number of times per year this new LCO 3.0.9 may be applied, even assuming barrier outages occurred continuously over the entire year, the risk incurred would still be anticipated to be below the limits of the guidance.

The NRC staff finds that the risk assessment results support the proposed addition of the new LCO 3.0.9 to Hope Creeks TS. The risk increases associated with this TS change will be insignificant based on guidance provided in RGs 1.174 and 1.177 and within the range of risks associated with normal maintenance activities.

3.1.2 Identification of High-Risk Configurations The second tier of the three-tiered approach recommended in RG 1.177 involves the identification of potentially high-risk configurations that could exist if equipment, in addition to that associated with the TS change, were to be taken out of service simultaneously. Insights from the risk assessments, in conjunction with important assumptions made in the analysis and defense-in-depth considerations, were used to identify such configurations. To avoid these potentially high-risk configurations, specific restrictions to the implementation of the proposed TS changes were identified.

When the proposed new LCO is applied, at least one train or subsystem is required to be operable with required barriers in place, such that this train or subsystem would be available to provide mitigation of the initiating event. The new LCO 3.0.9 may be applied to multiple trains of the same system only for barriers which provide protection for different initiating events, such that at least one train or subsystem is available to provide mitigation of the initiating event. The use of this new LCO for barriers which protect all trains or subsystems from a particular initiating event is not permitted. Therefore, potentially high-risk configurations involving a loss of function required for mitigation of a particular initiating event are avoided by the restrictions imposed on applicability of the new LCO 3.0.9.

This new LCO 3.0.9 also addresses potential emergent conditions where unplanned failures or discovered conditions may result in the unavailability of a required train or subsystem for a particular initiating event. Such conditions may result during application of the new LCO from equipment failure on the operable train, such that all trains of a TS system are not protected from the same initiating event. In such cases, a 24-hour allowed time is provided to restore the conditions to permit continued operation with unavailable barriers, after which the applicability of the new LCO ends, and the supported system LCO becomes effective. This allowed time is provided so that emergent conditions with low risk consequences may be effectively managed, rather than requiring immediate exit of the new LCO and the potential for an unplanned plant shutdown.

A limit of 30 days is applied to the new LCO 3.0.9 allowed outage time for each barrier, after which the barrier must be restored to an available status, or the supported system TS must be applied. This 30-day backstop applies regardless of the risk level calculated and provides assurance that installed plant barriers will be maintained available over long periods of time, and that the application of the new LCO will not result in long-term degradation of plant barriers.

The NRC staff finds that the restrictions on the applicability of new LCO 3.0.9 that one safety train remains available to mitigate the initiating event, along with the 30-day limit applicable to each barrier, assure that potentially high-risk configurations are avoided in accordance with the guidance provided in RGs 1.174 and 1.177.

3.1.3 Configuration Risk Management The third tier of the three-tiered approach recommended in RG 1.177 involves the establishment of an overall CRMP to ensure that potentially risk-significant configurations resulting from maintenance and other operational activities are identified. The objective of the CRMP is to manage configuration-specific risk by appropriate scheduling of plant activities and/or appropriate compensatory measures. This objective is met by licensee programs to comply with the requirements of paragraph (a)(4) of the Maintenance Rule (10 CFR 50.65) to assess and manage risk resulting from maintenance activities, and by the new LCO 3.0.9 requiring risk assessments and management using (a)(4) processes if no maintenance is in progress. These programs can support licensee decision making regarding the appropriate actions to manage risk whenever a risk-informed TS is entered.

The implementation guidance for this new LCO (TSTF-427, Revision 2) requires that the allowed outage time determination for an unavailable barrier be performed using the plant-specific configuration. Further, the risk determinations are to be updated whenever emergent conditions occur. These requirements assure that the configuration-specific risk associated with unavailable barriers is assessed and managed prior to entry into the new LCO 3.0.9 and during its applicability as conditions change.

These evaluations for the unavailable barrier are performed as part of the assessment of plant risk required by 10 CFR 50.65(a)(4). The numerical guidance identified in Table 2 is applicable to implementation of the new LCO 3.0.9, using the results of the configuration-specific risk assessment which addresses the risk impact of the unavailable barrier along with all other out of service components and plant alignments.

Risk management actions are required to be considered when the calculated risk exceeds specific thresholds per NUMARC 93-01, Section 11, as identified in Table 2. Additional guidance on risk management actions are provided in the implementation guidance for the new LCO.

The allowed outage time for a barrier is calculated based on an ICCDP limit of 1E-6. This is the NUMARC 93-01, Section 11, guidance for applicability of normal work controls and is conservatively lower than the guidance of 1E-5 for voluntary maintenance activities. The use of 1E-6 will result in conservatively short allowed outage times for barriers compared to allowed times for other maintenance activities.

If the scope of the PRA model used to support the plant-specific CRMP does not include the initiating event for which a barrier provides protection, then the new LCO 3.0.9 applicability is limited to one barrier on a single train. Multiple barriers for such initiating events may not be unavailable under the new LCO 3.0.9, and in such situations the LCO(s) associated with the protected components would be applicable. Applicability of the new LCO to the single barrier for an initiating event that is not modeled in the plant PRA is acceptable based on the generic risk analysis provided by TSTF-427, as described in Section 3.1 of this SE.

Assessment of the LERF risk impact on an unavailable barrier is required to be performed in accordance with NUMARC 93-01, Section 11. If an unavailable barrier provides protection to equipment which is relevant to the containment function, or which protects equipment from the effects of an initiating event which is a contributor to LERF, then applicability of the new LCO must be limited to that one barrier unless a quantified assessment of LERF is performed.

The NRC staff finds that the risk evaluations necessary to support the applicability of the new LCO 3.0.9 appropriately consider the risk from unavailable barriers in an integrated manner based on the overall plant configuration. Therefore, potentially high-risk configurations can be identified and managed in accordance with the guidance provided in RGs 1.174 and 1.177.

3.2 Summary and Conclusions The unavailability of barriers which protect TS-required components from the effects of specific initiating events is typically a low-risk configuration which should not require that the protected components be immediately declared inoperable. The current TS require that when such barriers are unavailable, the protected component LCO is immediately entered. Some potential undesirable consequences of the current TS requirements include:

1. When maintenance activities on the supported TS system requires removal and restoration of barriers, the time available to complete maintenance and perform system restoration and testing is reduced by the time spent maneuvering the barriers within the time constraints of the supported system LCO;

2. Restoration of barriers following maintenance must be given a high priority due to time restraints of the existing supported system LCO, when other more risk-important activities may have a greater risk impact and should therefore be given priority; and

3. Unnecessary plant shutdowns may occur due to discovery of degraded barriers which may require more than the existing supported system LCO time to complete repairs and restoration.

To remove the overly restrictive requirements in the treatment of barriers, the licensee is proposing a risk-informed TS change which introduces a delay time before entering the actions for the supported equipment when one or more barriers are found degraded or removed to facilitate planned maintenance activities. Such a delay time will provide needed flexibility in the performance of maintenance during power operation and at the same time will enhance overall plant safety by (1) performing system maintenance and restoration activities, including post-maintenance testing, within the existing TS LCO time, and allowing barrier removal and restoration to be performed outside of the TS LCO, providing more time for the safe conduct of maintenance and testing activities on the supported system; (2) requiring barrier removal and restoration activities to be assessed and prioritized based on actual plant risk impacts; and (3) avoiding unnecessary unscheduled plant shutdowns, thus minimizing plant transition and realignment risks.

The risk impact of the proposed TS changes was assessed following the three-tiered approach recommended in RG 1.177. A simplified bounding risk assessment was performed to justify the proposed TS changes. This bounding assessment was selected due to the lack of detailed plant-specific risk models for most plants which do not include failure modes of passive structures such as barriers. The impact from the addition of the proposed new LCO 3.0.9 to the TS on defense-in-depth was also evaluated in conjunction with the risk assessment results.

Based on this integrated evaluation, which is bounding for the licensee, the NRC staff concludes that the proposed addition of the new LCO 3.0.9 to the licensees TS would lead to insignificant risk increases as stipulated by RG 1.177 and depicted on Table 1 above. This conclusion is true without taking any credit for the removal of potential undesirable consequences associated with the current conservative treatment of barriers. Therefore, the proposed change provides adequate protection of public health and safety and is acceptable provided the conditions set forth below are satisfied.

Consistent with the NRC staffs approval and inherent in the implementation of TSTF-427, the licensee agreed to implement the new LCO 3.0.9 by operating in accordance with the following stipulations:

1. The licensee committed to the guidance of NUMARC 93-01, Section 11, and

2. The licensee stated that procedures would be revised to ensure that the guidance on the risk assessment and management process described in NEI 04-08 is used whenever a barrier is considered unavailable and the requirements of the new LCO 3.0.9 are to be applied. This would be done in accordance with an overall CRMP to ensure that potentially risk-significant configurations resulting from maintenance and other operational activities are identified and avoided.

The licensees application made regulatory commitments in Section 3.2, Verification and Commitments, to implement this new LCO 3.0.9 with the above stipulations; the NRC staff finds the licensees regulatory commitments 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 April 9, 2021. 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. 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 59563; September 22, 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.

7.0 REFERENCES

1.

Casulli, Edward T., PSEG Nuclear LLC, letter to U.S. Nuclear Regulatory Commission, Hope Creek Generating Station, Application to Adopt TSTF-427, Revision 2, Allowance for Non Technical Specification Barrier Degradation on Supported System OPERABILITY, dated August 19, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20232D120).

2.

Technical Specifications Task Force, letter to U.S. Nuclear Regulatory Commission, TSTF-427, Revision 2, Allowance for Non Technical Specification Barrier Degradation on Supported System OPERABILITY, dated May 3, 2006 (ADAMS Accession No. ML061240055).

3.

Pietrangela, Anthony R., Nuclear Energy Institute, letter to U.S. Nuclear Regulatory Commission, transmitting NEI 04-08, Risk-Informed Technical Specifications Initiative 7a, Allowance for Non-Technical Specification Barrier Degradation on Supported System OPERABILITY (TSTF-427), Industry Implementation Guidance, March 2006, dated April 4, 2006 (ADAMS Accession No. ML061220426).

4.

U.S. Nuclear Regulatory Commission, Regulatory Guide 1.174, An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis, dated July 1998 (ADAMS Accession No. ML003740133).

5.

U.S. Nuclear Regulatory Commission, Regulatory Guide 1.177, An Approach for Plant-Specific, Risk-Informed Decisionmaking: Technical Specifications, dated August 1998 (ADAMS Accession No. ML003740176).

6.

U.S. Nuclear Regulatory Commission, NUREG/CR-5750, Rates of Initiating Events at U.S. Nuclear Power Plants: 1987 - 1995, Idaho National Engineering and Environmental Laboratory, dated February 1999 (ADAMS Accession No. ML070580080).

7.

Vaughan, Stephen, Nuclear Energy Institute, letter to U.S. Nuclear Regulatory Commission, Submittal of NUMARC 93-01, Rev 4f, Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, dated April 27, 2018 (ADAMS Accession No. ML18120A069).

8.

U.S. Nuclear Regulatory Commission, Regulatory Guide 1.160, Revision 4, Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, dated August 2018 (ADAMS Accession No. ML18220B281).

Principal Contributor: C. Tilton Date: April 26, 2021

ML21098A087

• by email OFFICE NRR/DORL/LPL1/PM NRR/DORL/LPL1/LA NRR/DSS/STSB/BC*

NAME JKim JBurkhardt VCusumano DATE 4/12/2021 4/12/2021 3/31/2021 OFFICE OGC NRR/DORL/LPL1/BC NRR/DORL/LPL1/PM NAME N/A (Per OGC Memo, ML072980209)

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