ML22194A817

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Issuance of Amendment No. 232 Revise Surveillance Requirements for Electric Power Monitor Channels for Reactor Protection System and Power Range Neutron Monitoring System
ML22194A817
Person / Time
Site: Hope Creek PSEG icon.png
Issue date: 08/10/2022
From: James Kim
NRC/NRR/DORL/LPL1
To: Carr E
Public Service Enterprise Group
Kim J, NRR/DORL/LPL1
References
EPID L-2021-LLA-0202
Download: ML22194A817 (14)


Text

August 10, 2022 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. 232 RE: REVISED SURVEILLANCE REQUIREMENTS FOR ELECTRIC POWER MONITOR CHANNELS FOR REACTOR PROTECTION SYSTEM AND POWER RANGE NEUTRON MONITORING SYSTEM (EPID L-2021-LLA-0202)

Dear Mr. Carr:

The U.S. Nuclear Regulatory Commission (NRC, the Commission) has issued the enclosed Amendment No. 232 to Renewed Facility Operating License No. NPF-57 for the Hope Creek Generating Station in response to your application dated November 3, 2021.

The amendment revises Technical Specifications (TS) Surveillance Requirement (SR) 4.8.4.4.a and SR 4.8.4.6.a, which describe performance of a channel functional test for the Reactor Protection System and Power Range Neutron Monitoring System Electric Power Monitoring Channels, respectively. The amendment relocates the Mode requirements for performance of the SR to a separate Note in the TS and relocates the surveillance frequency to the licensee control. The proposed change controls the frequency of performance of the SR via the Surveillance Frequency Control Program.

E. Carr A copy of the related safety evaluation is also enclosed. A 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. 232 to Renewed License No. NPF-57
2. Safety Evaluation cc w/encls: Listserv

PSEG NUCLEAR LLC DOCKET NO. 50-354 HOPE CREEK GENERATING STATION AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 232 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 November 3, 2021, 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.

Enclosure 1

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. 232, 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 of the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Digitally signed by Hipolito Hipolito J. J. Gonzalez Date: 2022.08.10 Gonzalez 12:39:53 -04'00' Hipolito J. Gonzalez, 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: August 10, 2022

ATTACHMENT TO LICENSE AMENDMENT NO. 232 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 8-40 3/4 8-40 3/4 8-44 3/4 8-44

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. 232, 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. 232

ELECTRICAL POWER SYSTEMS REACTOR PROTECTION SYSTEM ELECTRICAL POWER MONITORING LIMITING CONDITION FOR OPERATION 3.8.4.4 Two RPS electric power monitoring channels for each inservice RPS MG set or alternate power supply shall be OPERABLE.

APPLICABILITY: At all times.

ACTION:

a. With one RPS electric power monitoring channel for an inservice RPS MG set or alternate power supply inoperable, restore the inoperable power monitoring channel 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 remove the associated RPS MG set or alternate power supply from service.
b. With both RPS electric power monitoring channels for an inservice RPS MG set or alternate power supply inoperable, restore at least one electric power monitoring channel to OPERABLE status within 30 minutes or remove the associated RPS MG set or alternate power supply from service.

SURVEILLANCE REQUIREMENTS 4.8.4.4 The above specified RPS electric power monitoring channels shall be determined OPERABLE:

NOTE SR 4.8.4.4.a only required to be performed prior to entering MODE 2 or 3 from MODE 4, when in MODE 4 for > 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

a. By performance of a CHANNEL FUNCTIONAL TEST in accordance with the Surveillance Frequency Control Program.
b. In accordance with the Surveillance Frequency Control Program by demonstrating the OPERABILITY of over-voltage, under-voltage, and under-frequency protective instrumentation by performance of a CHANNEL CALIBRATION including simulated automatic actuation of the protective relays, tripping logic and output circuit breakers and verifying the following setpoints.
1. Over-voltage 132 VAC, (Bus A), 132 VAC (Bus B)
2. Under-voltage 108 VAC, (Bus A), 108 VAC (Bus B)
3. Under-frequency 57 Hz. (Bus A and Bus B)

HOPE CREEK 3/4 8-40 Amendment No. 232

ELECTRICAL POWER SYSTEM POWER RANGE NEUTRON MONITORING SYSTEM ELECTRICAL POWER MONITORING LIMITING CONDITION FOR OPERATION 3.8.4.6 The power range neutron monitoring system (NMS) electric power monitoring channels for each inservice power range NMS power supply shall be OPERABLE.

APPLICABILITY: At all times.

ACTION:

a. With one power range NMS electric power monitoring channel for an inservice power range NMS power supply inoperable, restore the inoperable power monitoring channel 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 deenergize the associated power range NMS power supply feeder circuit.
b. With both power range NMS electric power monitoring channels for an inservice power range NMS power supply inoperable, restore at least one electric power monitoring channel to OPERABLE status within 30 minutes or deenergize the associated power range NMS power supply feeder circuit.

SURVEILLANCE REQUIREMENTS 4.8.4.6 The above specified power range NMS electric power monitoring channels shall be determined OPERABLE:

NOTE SR 4.8.4.6.a only required to be performed prior to entering MODE 2 or 3 from MODE 4, when in MODE 4 for > 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

a. By performance of a CHANNEL FUNCTIONAL TEST in accordance with the Surveillance Frequency Control Program.
b. In accordance with the Surveillance Frequency Control Program by demonstrating the OPERABILITY of over-voltage, under-voltage, and under-frequency protective instrumentation by performance of a CHANNEL CALIBRATION including simulated automatic actuation of the protective relays, tripping logic and output circuit breakers and verifying the following setpoints.
1. Over-voltage 132 VAC (BUS A), 132 VAC (BUS B)
2. Under-voltage 108 VAC (BUS A), 108 VAC (BUS B)
3. Under-frequency 57 Hz. -0, +2%

HOPE CREEK 3/4 8-44 Amendment No. 232

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 232 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 November 3, 2021 (Agencywide Documents Access and Management System Accession No. ML21307A405), PSEG Nuclear LLC, (PSEG, the licensee), requested changes to the technical specifications (TS) for the Hope Creek Generating Station (Hope Creek).

The proposed amendment revises TS Surveillance Requirement (SR) 4.8.4.4.a and SR 4.8.4.6.a, which describe performance of a Channel Functional Test for the reactor protection system (RPS) and Power Range Neutron Monitoring System (PRNMS) Electric Power Monitoring Channels, respectively. The amendment would relocate the Mode requirements for performance of the SR to a separate Note in the TS and relocate the surveillance frequency to licensee control. The frequency of performance of the SR would be controlled via the Surveillance Frequency Control Program (SFCP). The proposed change also relocates the frequency of performance of the Channel Functional Test from the TS to the SFCP.

2.0 REGULATORY EVALUATION

The regulations in Title 10 of the Code of Federal Regulations (10 CFR) paragraph 50.36(c)(3) require that TSs include 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 limiting conditions for operation will be met.

The following criterion from 10 CFR Part 50, Appendix A, General Design Criteria for Nuclear Power Plants, applies to Hope Creek:

CRITERION 18 - Inspection and testing of electric power systems. Electric power systems important to safety shall be designed to permit appropriate periodic inspection and testing of important areas and features, such as wiring, insulation, connections, and switchboards, to assess the continuity of the systems and the condition of their components. The systems shall be designed with a capability to test periodically (1) the operability and functional performance of the components Enclosure 2

of the systems, such as onsite power sources, relays, switches, and buses, and (2) the operability of the systems as a whole and, under conditions as close to design as practical, the full operation sequence that brings the systems into operation, including operation of applicable portions of the protection system, and the transfer of power among the nuclear power unit, the offsite power system, and the onsite power system.

The U.S. Nuclear Regulatory Commission (NRC or Commission) staffs guidance for the review of TSs is in Chapter 16, Technical Specifications, of NUREG-0800, Revision 3, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants (SRP), dated March 2010 (ML100351425). As described therein, as part of the regulatory standardization effort, the NRC staff has prepared Standard Technical Specifications (STSs) for each of the light-water reactor nuclear designs. The NRC staffs review includes consideration of whether the proposed changes are consistent with the Standard Technical Specifications, General Electric, BWR/4 Plants, NUREG-1433, Volume 1, Specifications, and Volume 2, Bases, Revision 5.0, September 2021 (ML21272A357 and ML21272A358), respectively, as modified by NRC-approved travelers.

3.0 TECHNICAL EVALUATION

3.1 Proposed TS Changes

The proposed amendment revises Hope Creek TS SR 4.8.4.4.a and SR 4.8.4.6.a for performance of a Channel Functional Test of the RPS and PRNMS Electric Power Monitoring Channels. The proposed change relocates the embedded requirement regarding performance of the Channel Functional Test each time the plant is in Cold Shutdown for a period of more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, unless performed in the previous six months, to a separate Note specific to this SR.

The proposed change also relocates the frequency of performance of the Channel Functional Test from the TS to the SFCP.

The proposed TS changes are as follows with proposed deletions shown as strike-through and proposed additions shown in bold italics:

SURVEILLANCE REQUIREMENTS 4.8.4.4 The above specified RPS electric power monitoring channels shall be determined OPERABLE:

NOTE SR 4.8.4.4.a only required to be performed prior to entering MODE 2 or 3 from MODE 4, when in MODE 4 for > 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

a. By performance of a CHANNEL FUNCTIONAL TEST each time the plant is in COLD SHUTDOWN for a period of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, unless performed in the previous 6 months in accordance with the Surveillance Frequency Control Program.

SURVEILLANCE REQUIREMENTS 4.8.4.6 The above specified power range NMS electric power monitoring channels shall be determined OPERABLE:

NOTE SR 4.8.4.6.a only required to be performed prior to entering MODE 2 or 3 from MODE 4, when in MODE 4 for > 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

a. By performance of a CHANNEL FUNCTIONAL TEST each time the plant is in COLD SHUTDOWN for a period of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, unless performed in the previous 6 months in accordance with the Surveillance Frequency Control Program.

3.2 Relocating Mode Requirement to Note Performance of the Channel Functional Test SR for the RPS electric power monitoring channels involves tripping of each RPS breaker that provides power to an entire division of RPS and Nuclear Steam Supply Shutoff System (NSSSS) logics in order to functionally test its associated electrical protective assemblies. De-energization of all the downstream loads fed from that RPS power division, in turn, results in a trip of that RPS division (i.e., a half scram) and partial actuation logic inputs to the NSSSS.

Performance of the PRNMS electrical power monitoring involves tripping one of the two 120 Vac sources supplying the PRNMS. Tripping one of the PRNMS supplies results in a half scram via de-energization of two of the four two-out-of-four logic modules associated with an RPS division.

As stated in the license amendment request, currently, Hope Creek SRs 4.8.4.4.a and 4.8.4.6.a require the Channel Functional Test be performed in Cold Shutdown to ensure the test is not performed when the reactor is in startup or during power operations. Restricting the performance of the SR outside of Modes 1 and 2 removes the potential risk of a plant transient during performance of the test that may occur due to an inadvertent failure in the opposite RPS division while performing the test or due to human error in performing the test.

The licensee proposed to make SR 4.8.4.4.a and SR 4.8.4.6.a consistent with the format in NUREG-1433, General Electric Plants, BWR/4, Rev. 5 Standard Technical Specifications, by relocating the requirement regarding performance of the Channel Functional Test each time the plant is in Cold Shutdown for a period of more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, unless performed in the previous six months, to a separate Note specific to this SR, as described in Section 3.1 of this Safety Evaluation.

NUREG-1433 SR 3.3.8.2.1, which is the equivalent of Hope Creek SR 4.8.4.4.a., currently requires a Channel Functional Test be performed with a Note that states:

only required to be performed prior to entering MODE 2 or 3 from MODE 4, when in MODE 4 for > 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

There is no TS in NUREG-1433 that is equivalent to Hope Creek SR 4.8.4.6.a, but SR 4.8.4.6.a has the same format and transient avoidance rationale for performance of SR 4.8.4.4.a. Hope

Creek SR 4.8.4.4.a and SR 4.8.4.6.a currently require performance of a Channel Functional Test each time the plant is in Cold Shutdown for a period of more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, unless performed in the previous 6 months.

SR 3.3.8.2.1 in NUREG-1433 provides the Mode in which the SR is required to be performed within a specific Note associated with the SR, whereas the current Hope Creek TS includes the Mode requirement in the SR.

Relocating the Hope Creek SR Mode requirement to a Note, as described in Section 3.1 of this Safety Evaluation, does not change the modes in which SRs 4.8.4.4.a and 4.8.4.6.a are required to be performed, is consistent with NUREG-1433, and therefore continues to meet the requirements of 10 CFR 50.36(c)(3) and General Design Criteria 18. Accordingly, the NRC staff finds the proposed change acceptable.

3.3 Relocation of SRs 4.8.4.4.a and 4.8.4.6.a to the SFCP Hope Creek has implemented TSTF-425, as approved by the NRC through TS Amendment 187 (ML103410243). Amendment 187 relocated periodic frequencies of TS surveillances to a licensee-controlled document and allows Hope Creek to programmatically change the frequencies of relocated SRs based on the guidance within NEI 04-10, Risk-Informed Technical Specifications Initiative 5B, Risk Informed Method for Control of Surveillance Frequencies (ML071360456).

The relocation of the Frequency for the RPS electric power monitoring Channel Functional Test and for the power range NMS electric power monitoring Channel Functional Test to the SFCP is consistent with TSTF-425, Revision 3, and with the NRC staff's model safety evaluation in the Federal Register on July 6, 2009 (74 FR 31996), Notice of Availability of Technical Specification Improvement to Relocate Surveillance Frequencies to Licensee Control-Risk-Informed Technical Specification Task Force (RITSTF) Initiative 5b, Technical Specification Task Force-425 Revision 3, because the subject SRs involve a fixed periodic Frequency.

Changes to the Frequency for the RPS electric power monitoring channel and power range NMS electric power monitoring channel Surveillances would be controlled under the SFCP. The requirements for the SFCP have been added to TS 6.8.4.j, Surveillance Frequency Control Program in the Administrative Controls section through TS Amendment 187. The NRC staff determined that the SFCP provides the necessary administrative controls to require that Surveillances related to testing, calibration, and inspection are conducted at a frequency to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met.

Therefore, the staff finds relocating SRs 4.8.4.4.a and 4.8.4.6.a to the SFCP is 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 July 14, 2022. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendment 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 on December 28, 2021 (86 FR 73819), 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 Contributor: T. Sweat, NRR Date: August 10, 2022

ML22194A817 OFFICE NRR/DORL/LPL1/PM NRR/DORL/LPL1/LA NRR/DSS/STSB/BC NRR/DEX/EICB/BC NAME JKim KEntz VCusumano MWaters DATE 7/21/2022 7/21/2022 7/12/2022 7/8/2022 OFFICE OGC - NLO NRR/DORL/LPL1/BC NRR/DORL/LPL1/PM NAME BAyersman HGonzalez JKim DATE 8/5/2022 8/10/2022 8/10/2022