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

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

2 Agenda Introduction Purpose of Meeting Improved Technical Specifications (ITS)

Overview and Project Description Aspects of ITS LAR Development Current Status of ITS LAR NRC Review and Approval Support Upcoming Hope Creek LAR Submittals

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

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

5 Purpose of Meeting Given the complexity of ITS Conversions and 24 Month Fuel Cycle (24MFC) implementation, 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.

Upcoming Hope Creek LAR Submittals

6 Overview Hope Creek Current Technical Specifications are 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)
  • Based on NUREG-1433 Improved Technical Specifications

7 Project Description PSEG recognizes that TS Conversion provides several Key Benefits, which include:

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)

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

8 Project Phased Approach Phase 1 Initial Planning - Complete Phase 2 LAR Development - PSEG Schedule 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 Improved Technical Specifications

9 Aspects of LAR Development Development Approach -

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

10 Aspects of LAR Development Risk Informed Initiatives TSTF-425 - Incorporated as part of ISTS Rev. 5 Hope Creek has adopted the Surveillance Frequency Control Program (SFCP). Therefore, the ITS Conversion 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 LCO 3.0.9.

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

11 Aspects of LAR Development Risk Informed Initiatives TSTF-423 - Incorporated as part of ISTS Rev. 5 Hope Creek is proposing adoption of Technical Specifications End States in accordance with 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.

Improved Technical Specifications Hope Creek is proposing to adopt Technical Specifications End States.

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

12 Aspects of LAR Development Planned Adoption of Approved Travelers since ISTS NUREG Rev. 5 TSTF-584-A, Eliminate Automatic Reactor Water Clean Up System Isolation on Standby Liquid Control Initiation

- Approved by NRC TSTF-592, Revise Automatic Depressurization System (ADS) Instrumentation Requirements - Under NRC Review TSTF-598-T (Bases Traveler) Correct the SR 3.5.2.1 Bases Regarding the Residual Heat Removal Shutdown Cooling Being an Intact Closed System - Approved by TSTF Improved Technical Specifications Three TSTF Travelers approved or approval expected will be included in the Hope Creek ITS Conversion LAR.

13 Aspects of LAR Development Beyond Scope Changes PSEG does not believe any of the changes are beyond scope that will require Formal Technical Branch Review.

Sensitive or Proprietary Information None identified Improved Technical Specifications

14 NRC Review and Approval Support Acceptance Review LIC-601 process used Main Review Phase Anticipate Staff utilizing LIC-601 NRR Office Instruction 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 Improved Technical Specifications

15 NRC Review and Approval Support NRC Resources and 2024/2025 Schedule Support

  • PSEG is making a concerted effort to keep all changes in-scope and will provide an updated list at the time the LAR is submitted of those items that 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.

Improved Technical Specifications

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

17 Overview Hope Creek Generating Station (HCGS) is currently on 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.

24 Month Fuel Cycle and Surveillance Interval Extension

18 Project Description 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 to 24 months.

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.

24 Month Fuel Cycle and Surveillance Interval Extension

19 Project Phased Approach Phase 1: Study Phase - Complete Phase 2: Preliminary Engineering Phase -

Complete 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) 24 Month Fuel Cycle and Surveillance Interval Extension

20 24MFC LAR Development Approach 24MFC LAR Development Approach Consistent with recent NRC approved precedent, PSEG will utilize Generic Letter (GL) 91-04, Changes in Technical Specification Surveillance Intervals to Accommodate a 24-Month Fuel Cycle as the technical basis for surveillance interval extensions from 18 months to 24 months. GL 91-04 describes a non-risk-informed, deterministic method for justifying changing 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.

24 Month Fuel Cycle and Surveillance Interval Extension

21 24MFC LAR Development Approach 24MFC LAR Development Approach Extension of the surveillance requirements from 36 months to 48 months under the GL 91-04 technical basis are being done to be consistent with 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 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.

24 Month Fuel Cycle and Surveillance Interval Extension

22 24MFC LAR Development Approach 24MFC LAR Development Approach The Fermi 2 application was submitted on November 8, 2019

[ML21218093]. 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.

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.

24 Month Fuel Cycle and Surveillance Interval Extension

23 24MFC LAR Development Approach 24MFC LAR Development Approach The strategy proposed for a one-time exception to using the SFCP will be a new License Condition rather than a modification of the SFCP Technical Specification. The use of the License Condition will result in 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.

24 Month Fuel Cycle and Surveillance Interval Extension

24 24MFC LAR Interface with ITS LAR 24MFC LAR Interface with ITS LAR PSEG is pursuing a 24MFC transition concurrently with an ITS Conversion 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.

24 Month Fuel Cycle and Surveillance Interval Extension

25 24MFC LAR Interface with ITS LAR 24MFC LAR Interface with ITS LAR A review of the CTS has been performed to identify any refueling cycle based requirements that may fall under the scope of revision as part of the conversion from 18 months to 24 months.

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.

24 Month Fuel Cycle and Surveillance Interval Extension

26 24MFC LAR Interface with ITS LAR 24MFC LAR Interface with ITS LAR The following Specifications were identified (contd):

4. SR 4.6.1.2.h - All containment isolation valves in hydrostatically tested lines which penetrate the primary containment shall be tested once per 18 months.
5. SR 4.8.2.1.f - Performance discharge testing of battery capacity that shows 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.

24 Month Fuel Cycle and Surveillance Interval Extension

27 24MFC LAR Interface with ITS LAR 24MFC LAR Interface with ITS LAR An analysis of the aforementioned impacted CTS surveillance requirements indicates a need for a markup of the following CTS pages:

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

24 Month Fuel Cycle and Surveillance Interval Extension

28 24MFC LAR Interface with ITS LAR 24MFC LAR Interface with ITS LAR

4. SR 4.6.1.2.h - 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.
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.

24 Month Fuel Cycle and Surveillance Interval Extension

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

30 24MFC LAR Interface with ITS LAR 24MFC LAR Interface with ITS LAR With an ITS Conversion, it is typical to incorporate approved, but unadopted Technical Specification Task Force (TSTF) travelers. It is likely that certain new SRs will be added, some which will have SR Frequencies that are aligned with the refueling cycle. In most cases, these new SRs would have 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.

24 Month Fuel Cycle and Surveillance Interval Extension

31 NRC Review and Approval Support NRC Review and Approval Support

  • LAR Submittal Targeted for May 2024
  • 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.

24 Month Fuel Cycle and Surveillance Interval Extension

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

33 Overview

  • 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.

Safety Relief Valve Lift Setpoint Change

34 Project Description 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 +/-

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

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.

The TS 3.4.2.2 Low-Low Set functions and TS 3.5.1 Automatic Depressurization System (ADS) related functions of these valves remain unchanged by the proposed activities.

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

Safety Relief Valve Lift Setpoint Change

35 Aspects of LAR Development Development Approach -

  • GEH is revising Hope Creek specific topical Task Reports to evaluate impact on plant systems/design.
  • Station Overpressure-Related Safety Limits, ASME Limits, and ATWS Limits are met and unchanged

Safety Relief Valve Lift Setpoint Change

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

  • LAR Submittal Targeted for June 2024
  • 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

37 Hope Creek LAR Parallel Submittal Schedule No linked submittals planned.

Hope Creek Near Term LAR Submittals None are currently expected.

Parallel LAR Submittals

  • 24 Month Fuel Cycle LAR

38 Hope Creek LAR Parallel Submittal Schedule ITS Conversion LAR Scheduled May 2024 with approval requested for June 2025 (to support Implementation PRIOR to the Fall outage) 24 Month Fuel Cycle LAR 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)

Upcoming Hope Creek LAR Submittals

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

40

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