ML23291A139

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PSEG Presentation Slides for Pre Submittal Meeting on 10-24-2023
ML23291A139
Person / Time
Site: Hope Creek PSEG icon.png
Issue date: 10/18/2023
From: James Kim
Plant Licensing Branch 1
To: Carr E
Public Service Enterprise Group
Kim J
References
EPID L-2023-LRM-0080
Download: ML23291A139 (1)
v • d • e


Text

Improved Technical Specifications Conversion, 24 Month Fuel Cycle and Surveillance Interval Extension, SRV Lift Setpoint Change October 24, 2023

Upcoming Hope Creek LAR Submittals Introduction Purpose of Meeting Agenda Improved Technical Specifications (ITS)

Overview and Project Description Aspects of ITS LAR Development Current Status of ITS LAR NRC Review and Approval Support 2

Upcoming Hope Creek LAR Submittals 24 Month Fuel Cycle and Surveillance Interval Extension Agenda Overview and Project Description Project Description 24MFC LAR Development Approach 24MFC LAR Interface with ITS LAR NRC Review and Approval Support 3

Upcoming Hope Creek LAR Submittals Safety Relief Valve Lift Setpoint Change Agenda Overview and Project Description Aspects of LAR Development NRC Review and Approval Support Hope Creek LAR Parallel Submittal Schedule Questions and Closing Remarks 4

Upcoming Hope Creek LAR Submittals Given the complexity of ITS Conversions and Purpose of 24 Month Fuel Cycle (24MFC) implementation, Meeting this meeting is intended to ensure common understanding of the process for their development, thereby, allowing for a more efficient use of both NRC and PSEG Nuclear resources. The meeting will also present another initiative to improve plant performance by changing SRV lift setpoints.

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Improved Technical Specifications Hope Creek Current Technical Specifications are Overview based on pre-ITS Standard Technical Specifications

  • Hope Creek Current TS, originally licensed in 1986, is based on NUREG-0123 ITS Conversion to Revision 5 (latest revision) of the Improved Standard Technical Specifications (ISTS)

Improved Technical Specifications PSEG recognizes that TS Conversion provides several Key Project Benefits, which include:

Description Industry Standardization, enhanced safety, operational, and regulatory performance Significantly improved TS Bases, including alignment of the TS Bases with Hope Creek Current Licensing Bases Adoption of the TS Rules of Usage Sections in Chapter 1 of the Improved Standard Technical Specifications (ISTS)

Key Benefits include enhanced safety performance and enhanced bases for the TS requirements.

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Improved Technical Specifications Phase 1 Initial Planning - Complete Project Phased Phase 2 LAR Development - PSEG Schedule Approach May 2023 to May 2024 Phase 3 NRC Review and Approval - PSEG Schedule May 2024 to June 2025 Phase 4 Implementation - PSEG Schedule May 2024 to August 2025 8

Improved Technical Specifications Development Approach -

  • TSTF-GG-13-01 ITS Conversion Guidance Aspects of
  • ITS Submittal Contains LAR Current Tech Spec markup Development Discussion of Changes ISTS and ISTS Bases markup Justification for Deviation from the ISTS No Significant Hazard Consideration Supporting Information as required ITS Conversions Packages are arranged consistent with previous ITS Conversion submittals.

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Improved Technical Specifications Risk Informed Initiatives TSTF-425 - Incorporated as part of ISTS Rev. 5 Aspects of

  • Hope Creek has adopted the Surveillance Frequency LAR Control Program (SFCP). Therefore, the ITS Conversion Development reflects the CTS adoption of this program with one exception:

o ITS proposes to relocate periodic frequencies specified in Section 5.5 programs to the SFCP consistent with several other plants.

TSTF-427 - Incorporated as part of ISTS Rev. 5

Hope Creek has previously adopted a Surveillance Frequency Control Program and LCO 3.0.9 - Hazards Barrier Rule of Usage.

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Improved Technical Specifications Risk Informed Initiatives TSTF-423 - Incorporated as part of ISTS Rev. 5 Aspects of

  • Hope Creek is proposing adoption of Technical LAR Specifications End States in accordance with Development NEDC-32988-A.

TSTF-505 - Incorporated as part of ISTS Rev. 5

  • Hope Creek is not proposing adoption of Risk Informed Completion Time (RICT) Program at this time. Therefore, the ITS Conversion LAR will not include any RICTs or associated program requirements.

Hope Creek is proposing to adopt Technical Specifications End States.

Hope Creek is not proposing adoption of Risk Informed Completion Times. 11

Improved Technical Specifications Planned Adoption of Approved Travelers since ISTS NUREG Rev. 5 Aspects of

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Improved Technical Specifications Beyond Scope Changes

  • PSEG does not believe any of the changes are beyond Aspects of scope that will require Formal Technical Branch Review.

LAR Sensitive or Proprietary Information Development

  • None identified 13

Improved Technical Specifications Acceptance Review

  • LIC-601 process used NRC Review Main Review Phase and Approval
  • Anticipate Staff utilizing LIC-601 NRR Office Instruction Support
  • RAI Communications and Use of Dedicated Reading Room and RAI Portal Issue Resolution and Submission of Revisions by Licensee Safety Evaluation Preparation, Document Routing, and Issuance 14

Improved Technical Specifications NRC Resources and 2024/2025 Schedule Support

  • PSEG is making a concerted effort to keep all NRC Review changes in-scope and will provide an updated list and Approval at the time the LAR is submitted of those items that Support may require formal technical branch review. As stated, none are anticipated at this time.
  • ITS implementation date anticipated to occur within 6 months following issuance of the ITS Amendment and prior to the Fall 2025 outage.

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24 Month Fuel Cycle and Surveillance Interval Extension 24 Month Fuel Cycle and Surveillance Interval Extension 16

24 Month Fuel Cycle and Surveillance Interval Extension Hope Creek Generating Station (HCGS) is currently on Overview an 18 month operating cycle and surveillance testing interval.

PSEG Nuclear, LLC is pursuing an extension of the operating cycle length and surveillance testing interval from 18 to 24 months at HCGS under the auspices of Generic Letter 91-04.

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24 Month Fuel Cycle and Surveillance Interval Extension PSEG Nuclear, LLC plans to transition HCGS from the current 18-month fuel cycle to 24 months. This transition necessitates corresponding changes to surveillance intervals from 18 months Project to 24 months.

Description The transition to a 24MFC is expected to increase plant availability by eliminating one refueling outage every six years:

reduce cumulative radiological occupational exposure due to fewer refueling outages; and increase lead times for outage planning and preparations.

Additional benefits include:

  • Enhance fuel reliability and operating margins.
  • Reduce the frequency of required surveillances and PMs.
  • Reduced operating costs.

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24 Month Fuel Cycle and Surveillance Interval Extension Phase 1: Study Phase - Complete Project Phase 2: Preliminary Engineering Phase -

Phased Complete Approach Phase 3: License Amendment Preparation Phase - PSEG Schedule: April 2023 to May 2024 Phase 4: Implementation Phase - PSEG Schedule: June 2024 to November 2025 (end of fall outage) 19

24 Month Fuel Cycle and Surveillance Interval Extension 24MFC LAR Development Approach Consistent with recent NRC approved precedent, PSEG will utilize Generic Letter (GL) 91-04, Changes in Technical Specification Surveillance Intervals 24MFC LAR to Accommodate a 24-Month Fuel Cycle as the technical basis for Development surveillance interval extensions from 18 months to 24 months. GL 91-04 describes a non-risk-informed, deterministic method for justifying changing Approach surveillance intervals from 18 to 24 months that is acceptable to the NRC.

Since the issuance of the HCGS TSTF-425 license amendment in 2011, a number of Surveillance Requirement periodicities have been extended from 18 months to 36 months under the HCGS Surveillance Frequency Control Program (SFCP), in part to promote outage efficiency by implementing channelized alternating outages. Since the 36-month SRs must be performed during Modes 4 or 5, this LAR proposes to extend the SR periodicities from 36 months to 48 months using the methodology of GL 91-04, rather than additional extensions under the HCGS SFCP.

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24 Month Fuel Cycle and Surveillance Interval Extension 24MFC LAR Development Approach Extension of the surveillance requirements from 36 months to 48 months 24MFC LAR under the GL 91-04 technical basis are being done to be consistent with Development the 24-month fuel cycle interval. The use of the GL 91-04 methodology is fundamentally the same whether the SR is being extended from 18 to 24 Approach months or 36 to 48 months. A detailed evaluation is performed with respect to the change of the SR frequency that should support the conclusion that extending the testing interval will have a minimal impact, if any, on safety.

A precedent for PSEGs strategy for utilizing GL 91-04 as the technical basis for surveillance interval extensions from 18 months to 24 months in lieu of extension via the SFCP has been previously established by two separate nuclear sites, Fermi 2 and Prairie Island Units 1 and 2, as accepted by the NRC.

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24 Month Fuel Cycle and Surveillance Interval Extension 24MFC LAR Development Approach The Fermi 2 application was submitted on November 8, 2019 24MFC LAR [ML21218093]. This was preceded by a pre-application meeting with the Development NRC that resulted in the NRC accepting the proposed approach to apply Approach the GL 91-04 analysis methodology. The NRC review consisted of an audit with associated RAIs that similarly resulted in acceptance of this approach.

The Prairie Island Unit 1 and 2 application was submitted on August 6, 2021 [ML19312A110]. This was preceded by a pre-application meeting with the NRC that resulted in the NRC accepting the proposed approach to apply the GL 91-04 analysis methodology. The NRC review consisted of an audit with associated RAIs that similarly resulted in acceptance of this approach.

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24 Month Fuel Cycle and Surveillance Interval Extension 24MFC LAR Development Approach The strategy proposed for a one-time exception to using the SFCP will 24MFC LAR be a new License Condition rather than a modification of the SFCP Development Technical Specification. The use of the License Condition will result in Approach fewer Technical Specification Markups and retyped pages with the 24MFC LAR owing to SR Frequencies already referencing SFCP Frequencies.

There will however be marked-up CTS pages to reflect the necessary changes to SRs from CTS to ITS that will be addressed in the 24MFC LAR Interface with ITS LAR section of this presentation.

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24 Month Fuel Cycle and Surveillance Interval Extension 24MFC LAR Interface with ITS LAR PSEG is pursuing a 24MFC transition concurrently with an ITS 24MFC LAR Conversion LAR.

Interface with ITS LAR The 24MFC LAR will be submitted concurrently with the ITS Conversion LAR. While the latter LAR will be wide sweeping, there will be no anticipated intersecting changes since the 24MFC approach to obtaining the one-time exception to the SFCP will be in a new Licensing Condition for the HCGS Operating License rather than any TS changes.

Additionally, there should be no technical conflicts between the two LARs.

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24 Month Fuel Cycle and Surveillance Interval Extension 24MFC LAR Interface with ITS LAR A review of the CTS has been performed to identify any refueling cycle 24MFC LAR based requirements that may fall under the scope of revision as part of the Interface conversion from 18 months to 24 months.

with ITS LAR The following CTS Specifications were identified:

1. Table 1.1 - contains the annotation R which correlates to at least once every 18 months (550 days)
2. SR 4.6.1.2.f - Testing of main steam line isolation valves once per 18 months.
3. SR 4.6.1.2.g - Hydrostatically testing of containment isolation valves which form the boundary of the long-term seal of the feedwater lines shall be tested once per 18 months.

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24 Month Fuel Cycle and Surveillance Interval Extension 24MFC LAR Interface with ITS LAR The following Specifications were identified (contd):

24MFC LAR

4. SR 4.6.1.2.h - All containment isolation valves in hydrostatically tested lines Interface which penetrate the primary containment shall be tested once per 18 months.

with ITS 5. SR 4.8.2.1.f - Performance discharge testing of battery capacity that shows LAR sign of degradation or has reached 85% of the service life expectation shall be performed once every 18 months during shutdown.

6. SR 6.16.d - Measurement of the CRE pressure relative to all external areas adjacent to the CRE boundary during the pressurization mode of operation by one train of the CREF shall be tested every 36 months on a STAGGERED TEST BASIS.

All aforementioned impacted CTS SRs (except item 1 for Table 1-1) will be evaluated for extension under the GL 91-04 process.

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24 Month Fuel Cycle and Surveillance Interval Extension 24MFC LAR Interface with ITS LAR An analysis of the aforementioned impacted CTS surveillance requirements indicates a 24MFC need for a markup of the following CTS pages:

LAR 1. There are no places in the CTS where the designator R is utilized with the Interface exception of Table 1.1 and there is no equivalent table in NUREG-1433. This with ITS frequency designator is anticipated to be relocated to the SFCP during ITS conversion.

LAR 2. SR 4.6.1.2.f - There is no equivalent SR in NUREG-1433. This SR is expected to be relocated to the Containment Leakage Rate Testing Program during ITS conversion.

The program currently allows a frequency of 30 months for Type C testing.

3. SR 4.6.1.2.g - There is no equivalent SR in NUREG-1433. This SR is expected to be relocated to the Containment Leakage Rate Testing Program during ITS conversion.

The program currently allows a frequency of 30 months for Type C testing.

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24 Month Fuel Cycle and Surveillance Interval Extension 24MFC LAR Interface with ITS LAR

4. SR 4.6.1.2.h - There is no equivalent SR in NUREG-1433. This SR is 24MFC LAR expected to be relocated to the Containment Leakage Rate Testing Interface Program during ITS conversion. The program currently allows a with ITS LAR frequency of 30 months for Type C testing.
5. SR 4.8.2.1.f - The ITS Conversion is expected to transfer this SR to NUREG-1433 SR 3.8.6.6 and will modify the SR Frequencies to 12 and 24 months consistent with IEEE-450.
6. 6.16.d - This is specified in NUREG-1433 as 18 months on a STAGGERED TEST BASIS (equivalent to HCGS 36 months due to the difference in the definition). The Staggered Frequency will be relocated to the SFCP and the text regarding 36 month assessment will be revised during ITS conversion.

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24 Month Fuel Cycle and Surveillance Interval Extension 24MFC LAR Development Approach 24MFC LAR Development Approach 29

24 Month Fuel Cycle and Surveillance Interval Extension 24MFC LAR Interface with ITS LAR With an ITS Conversion, it is typical to incorporate approved, but unadopted 24MFC LAR Technical Specification Task Force (TSTF) travelers. It is likely that certain new SRs will be added, some which will have SR Frequencies that are Interface aligned with the refueling cycle. In most cases, these new SRs would have with ITS LAR an SR Frequency of In accordance with the Surveillance Frequency Control Program. For these cases, the LAR would not have to specifically address the transition to a 24MFC. If there were any new SRs that for some reason did not meet the SFCP inclusion criteria provided by the NRC in the TSTF-425 Federal Register Note, the 24-month SR Frequency would have to be addressed within the ITS Conversion LAR.

It is anticipated that both the ITS and 24MFC LARs be approved to enable the implementation of ITS in August 2025 and 24MFC during the Fall 2025 Outage.

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24 Month Fuel Cycle and Surveillance Interval Extension NRC Review and Approval Support NRC Review

  • LAR Submittal Targeted for May 2024 and Approval
  • Dose impact may require NRC review for the 24MFC LAR
  • Periodic Communications During NRC Review
  • Use of NRC Audit Process to Facilitate Communication
  • 24MFC Amendment to be issued after ITS Conversion 24MFC implementation anticipated to occur no later than the Fall 2025, with the refueling outage scheduled to begin in October 2025.

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Safety Relief Valve Lift Setpoint Change Safety Relief Valve Setpoint Change 32

Safety Relief Valve Lift Setpoint Change

  • Hope Creek has changed 14 Target Rock 2-Stage Overview Safety Relief Valves with Target Rock 3-Stage 0867F model valves
  • Hope Creek station and other BWR operating experience with these newer model valves supports that increased station reliability can be achieved with higher simmer margin, along with other initiatives
  • Increasing lift setpoints is expected to result in a minimal change in safety margins; all parameters remain within existing safety limits.

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Safety Relief Valve Lift Setpoint Change

  • Project will revise Technical Specification 3/4.4.2, Safety/Relief Valves, current specified code safety valve function as-found lift settings from staggered settings (4 valves @1108 psig +/-

Project 3%, 5 valves @1120 psig +/- 3%, and 5 valves @1130 psig +/-

Description psig +/-3%) to 1130 psig +/-3% for all fourteen (14) valves.

The LAR may include a -5% lower band consistent with changes submitted by Fitzpatrick, Columbia, Susquehanna and River Bend.

  • As-left setpoint of the Safety/Relief Valves remain at +/- 1%

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Safety Relief Valve Lift Setpoint Change Development Approach -

Aspects of

  • GEH is revising Hope Creek specific topical Task LAR Reports to evaluate impact on plant systems/design.

Development

  • Station Overpressure-Related Safety Limits, ASME Limits, and ATWS Limits are met and unchanged

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Safety Relief Valve Lift Setpoint Change NRC Review and Approval Support SRV Lift Setpoint change implementation anticipated to occur in the Fall NRC Review 2025 refueling outage scheduled to begin in October 2025.

and Approval

  • LAR Submittal Targeted for June 2024 Support
  • Mark up of TS based on CTS
  • Periodic Communications During NRC Review
  • Use of NRC Audit Process to Facilitate Communication
  • SRV Amendment to be issued after ITS Conversion
  • Supplemental submittal to address ITS mark ups 36

Upcoming Hope Creek LAR Submittals No linked submittals planned.

Hope Creek Near Term LAR Submittals Hope Creek LAR Parallel

  • None are currently expected.

Submittal Parallel LAR Submittals Schedule

  • 24 Month Fuel Cycle LAR

Upcoming Hope Creek LAR Submittals ITS Conversion LAR

  • Scheduled May 2024 with approval requested for June Hope Creek 2025 (to support Implementation PRIOR to the Fall LAR Parallel outage)

Submittal 24 Month Fuel Cycle LAR Schedule

  • Scheduled May 2024 with approval requested for July 2025 (to support implementation in the Fall 2025 outage)

Safety Relief Valve Setpoint Change LAR

  • Scheduled June 2024 with approval requested for August 2025 (to support Fall 2025 outage) 38

Upcoming Hope Creek LAR Submittals Questions and Closing Remarks We look forward to working with you and your Review Teams.

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