ML22290A220

NRR E-mail Capture - Final RAI - Salem 1 and 2 LAR to Revise TS to Extend Allowed Outage Time for Inoperable EDG

ML22290A220
Person / Time
Site:	Salem
Issue date:	10/17/2022
From:	James Kim NRC/NRR/DORL/LPL1
To:	Bernard Thomas Public Service Enterprise Group
References
L-2022-LLA-0095
Download: ML22290A220 (3)

Text

From: James Kim Sent: Monday, October 17, 2022 3:05 PM To: Thomas, Brian J.

Cc: Wiwel, Michael; Hipo Gonzalez

Subject:

Final RAI for Salem LAR to Revise TS to Extend Allowed Outage Time for Inoperable EDG (EPID L-2022-LLA-0095)

Attachments: APLC Final RAI - Salem EDG.docx

SUBJECT:

Salem 1 and 2 - Final RAI for Salem LAR to Revise TS to Extend Allowed Outage Time for Inoperable EDG (EPID L-2022-LLA-0095)

Mr. Thomas, By application dated June 29, 2022 (Agencywide Documents Access and Management System Accession No. ML22180A268), PSEG Nuclear LLC, the licensee, submitted a license amendment request to revise the Salem Unit 1 and Unit 2 Technical Specifications Action 3.8.1.1.b.4 to extend the allowed outage time (AOT) for an inoperable emergency diesel generator (EDG) from 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to 14 days.

The NRC staff has determined that additional information is needed to complete its review of the request. On October 3, 2022, the NRC staff sent PSEG the draft Request for Additional Information (RAI). On October 17, 2022, the NRC staff and the licensee held conference call to clarify the draft RAI questions. Subsequently, PSEG agreed to respond to this request by November 23, 2022. A publicly available version of this final RAI (attached) will be placed in the NRCs ADAMS.

James Kim Project Manager -Salem NRR/DORL/LPL1 301-415-4125

Hearing Identifier: NRR_DRMA Email Number: 1811 Mail Envelope Properties (DM6PR09MB4711471DAD7A287A58A72E74E4299)

Subject:

Final RAI for Salem LAR to Revise TS to Extend Allowed Outage Time for Inoperable EDG (EPID L-2022-LLA-0095)

Sent Date: 10/17/2022 3:05:07 PM Received Date: 10/17/2022 3:05:00 PM From: James Kim Created By: James.Kim@nrc.gov Recipients:

"Wiwel, Michael" <Michael.Wiwel@pseg.com>

Tracking Status: None "Hipo Gonzalez" <Hipolito.Gonzalez@nrc.gov>

Tracking Status: None "Thomas, Brian J." <Brian.Thomas@pseg.com>

Tracking Status: None Post Office: DM6PR09MB4711.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 1092 10/17/2022 3:05:00 PM APLC Final RAI - Salem EDG.docx 23386 Options Priority: Normal Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

BACKGROUND By application dated June 29, 2022 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML22180A268), PSEG Nuclear (the licensee) requested a change to the Technical Specifications (TSs) for Salem Generating Station, Units 1 and 2 (Salem). The proposed change would modify TS Action 3.8.1.1.b.4 to extend the allowed out of service time for an inoperable emergency diesel generator (EDG) from 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to 14 days.

NRC CONSIDERATION OF RISK INSIGHTS The proposed amendment is not a risk-informed amendment submitted in accordance with Regulatory Guide 1.174. Therefore, the NRC staff does not review the licensees probabilistic risk assessment models to determine their technical acceptability. The NRC staff does not rely on the quantitative risk information provided by the licensee in the license amendment request (LAR). However, the NRC staff considers the licensee-provided qualitative risk insights and associated compensatory measures in its decision on the proposed change.

RAI APLC-1: Risk Insights Identified During the Risk Assessment The licensee states that the proposed amendment is deterministic and was developed using the guidelines in Branch Technical Position 8-8, Onsite (Emergency Diesel Generators) and Offsite Power Sources Allowed Outage Time Extensions. The licensee also states that additional risk insights reflecting the change in the allowed outage time (AOT) are provided.

Section 1.0, Summary Description, of the enclosure to the LAR provides an overview of the proposed change. It states that the proposed extended AOT is based on a deterministic justification and a summary of probabilistic risk insights.

Section 3.8, Risk Assessment of Increasing the EDG AOT to 14 Days, of the enclosure to the LAR describes the results of the risk assessment performed in support of this LAR. It states that a quantitative and qualitative analysis of risk was performed to support the conclusion that the change in risk associated with the proposed 14-day AOT extension for the emergency diesel generators is acceptable. In addition, the notes for tables 3.8-1 and 3.8-2 state that risk contributions from fire, seismic, and other external hazards were evaluated qualitatively in the risk assessment.

Since the proposed amendment is not a risk-informed amendment submitted in accordance with Regulatory Guide 1.174, the NRC staff considers the licensee-provided qualitative risk insights and associated compensatory measures, but the NRC staff does not rely on the quantitative risk information provided in the LAR. The NRC staff did not find a discussion of the risk insights mentioned in the LAR and section 1.0 of the enclosure to the LAR and how these insights support the request.

Please address the following:

a. Discuss the risk insights mentioned in the LAR and section 1.0 of the enclosure to the LAR for the proposed request to increase the EDG AOT to 14 days and justify how those insights support this application. The discussion should include the qualitative risk insights associated with fire, seismic, and other external hazards and their impact on this application.