ML22132A004
| ML22132A004 | |
| Person / Time | |
|---|---|
| Site: | Salem, Hope Creek |
| Issue date: | 05/26/2022 |
| From: | Public Service Enterprise Group |
| To: | James Kim NRC/NRR/DORL/LPL1 |
| Kim J | |
| References | |
| Download: ML22132A004 (13) | |
Text
May 26, 2022 PSEG Pre-Submittal Meeting with NRC Extension of Technical Specification Allowed Outage Time (AOT) for Salem Emergency Diesel Generators (EDG)
PSEG Pre-Submittal Meeting with NRC, May 26, 2022 Meeting Purpose Describe upcoming license amendment request Establish common understanding of scope of request Establish a common understanding of schedule Obtain NRC feedback 2
PSEG Pre-Submittal Meeting with NRC, May 26, 2022 Current Salem Licensing Basis - TS 3.8.1.1 Action b:
- b. With one EDG of the above required A.C. electrical power sources inoperable:
1.
Demonstrate the OPERABILITY of the independent A.C. circuits by performing SR 4.8.1.1.1.a within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter; and 2.
Within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, declare required systems or components supported by the inoperable EDG inoperable when a required redundant system or component is inoperable, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> an in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />; and 3.
Determine the two remaining OPERABLE EDGs are not inoperable due to common cause failure or perform SR 4.8.1.1.2.a.2 within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. If the EDG is inoperable for PM, the two remaining OPERABLE EDGs need not be tested nor the OPERABILITY evaluated; and 4.
In any case restore the inoperable EDG 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 be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
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PSEG Pre-Submittal Meeting with NRC, May 26, 2022 Proposed Change - TS 3.8.1.1 Action b.4
- 4. In any case:
a) Restore the inoperable diesel generator 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 b) Verify the supplemental power source is available within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter# and restore the inoperable diesel generator to OPERABLE status within 14 days.
Otherwise, be in at least HOT SHUTDOWN within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
- After the initial verification period, the supplemental power source may be unavailable for a single period of up to 24-hours and once per 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> requirement to verify that the supplemental power source is available may be suspended during this period.
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PSEG Pre-Submittal Meeting with NRC, May 26, 2022 Background / Overview Major EDG maintenance performed during refueling outages Presents major challenge to Operations and Maintenance during RFO activities More effective allocation of craft and oversight resources to other risk significant areas of the refueling outage Greater focus and attention on EDG maintenance afforded for online outages LAR to request AOT extension from 72-hours to 14-days LAR will be deterministic in approach augmented with risk insights BTP 8-8 will be fully addressed Supplemental power source will consist of two portable, synchronized AOT diesel generators Same portable diesels used by Hope Creek Station for extended AOT on A & B EDGs They will not be credited simultaneously by both stations for extended EDG AOTs 5
PSEG Pre-Submittal Meeting with NRC, May 26, 2022 Paralleled AOT diesels provide 4550 kW at 4-kV Backfeed to 4kV vital buses via pre-engineered connection panels Same cable and connections used at Hope Creek Connection panels located on exterior of Circulating Water Switchgear Building
- Allows connection to any one of the three Class 1E 4KV busses for each Unit Static & dynamic load testing performed on diesels at factory simulating HC loads Hope Creek accident/safe shutdown load requirements exceed that for Salem PSEG proposes a 3-hour time frame to have the supplemental power source available in lieu of 1-hour as stipulated in BTP 8-8 3-hour time frame approved for Hope Creek to establish AAC Salem SBO coping analysis supports 4-hours without AC power - same as HC AOT diesel transport, connection and backfeed process similar to Hope Creek Hope Creek procedures and OE will be incorporated into Salem procedures.
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PSEG Pre-Submittal Meeting with NRC, May 26, 2022 7
AOT Diesel Staging/Connection Area
PSEG Pre-Submittal Meeting with NRC, May 26, 2022 8
U2 Connection Panel AOT Diesels in Storage Location U1 Connection Panel Circ Water Switchgear Building AOT Diesel Cutaway
PSEG Pre-Submittal Meeting with NRC, May 26, 2022 LAR Deterministic with Risk Insights Risk Insights Expect that the risk increase for the time spent in the AOT configuration will be small; well within the normal on-line risk compared to other activities treated in a(4)
The 3-hour time interval to provide AOT power to vital bus will be a primary parameter in PRA modeling Fire PRA not yet fully developed for Salem to support a risk-based LAR per Reg. Guide 1.174 The most recent LAR (Wolf Creek) on a similar subject used a deterministic approach with quantitative and qualitative risk insights, and does not have a modern fire PRA 9
PSEG Pre-Submittal Meeting with NRC, May 26, 2022 Additional TS Change Under Consideration
TS 3.8.1.1 Action b.3 requires determination that remaining EDGs are not inoperable due to CCF or perform SR 4.8.1.1.2.a.2 within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> SR 4.8.1.2.a.2 requires starting each OPERABLE EDG from standby and verifying it achieves the required voltage and frequency The SR also requires the EDG be synchronized and gradually loaded to 2340-2600kW and operate loaded for at least 60 minutes.
TS 3.8.1 Action B.3.2 in NUREG-1431 is the parallel to Salem TS 3.8.1.1 Action b.3 TS 3.8.1 Action B.3.2 requires performance of SR 3.8.1.2 SR 3.8.1.2 in NUREG-1431 only requires each EDG starts from a standby condition and achieves the required voltage and frequency - it does not require loading of the EDG however
PSEG proposes to align SR 4.8.1.2.a.2 with SR 3.8.1.2 of NUREG-1431 as an additional change in the proposed LAR 10
PSEG Pre-Submittal Meeting with NRC, May 26, 2022 Precedents:
- Wolf Creek LAR - Diesel Generator Completion Time Extension for Technical Specification 3.8.1, AC Sources - Operating, dated September 29, 2021 (ML21272A369)
- Watts Bar Nuclear Plant, Units 1 and 2 - Issuance of Amendments Regarding Extension of Completion Time for Inoperable Diesel Generator (CAC Nos. MF7147 and MF7148, dated January 13, 2017 (ML17006A271)
- Hope Creek Generating Station - Issuance of Amendment RE: Emergency Diesel Generators (EDG) A and B Allowed Outage Time (AOT) Extension (TAC No.
ME3597), dated March 25, 2011 (ML110610501)
- Hope Creek Generating Station - Issuance of Amendment No. 216 RE: Revise Technical Specification 3/4.8.1, A.C. Sources - Operating, Action for Inoperable Diesel Generator (EPID L-2018-LLA-0079), dated April 30, 2019 (ML19073A073) 11
PSEG Pre-Submittal Meeting with NRC, May 26, 2022 LAR submittal targeted for end of June, 2022 Requests one year review time frame
- Supports planned scope for future Salem refuel outages Request 100 day implementation time 12
Questions Feedback and Closing Remarks