ML24053A128

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24 Month Fuel Cycle Pre-Submittal Meeting Presentation
ML24053A128
Person / Time
Site: Hope Creek PSEG icon.png
Issue date: 02/27/2024
From: Carr E
Public Service Enterprise Group
To: James Kim
Plant Licensing Branch 1
Kim J
References
EPID L-2024-LRM-0021
Download: ML24053A128 (1)
v • d • e


Text

February 27, 2024 24 Month Fuel Cycle and Surveillance Interval Extension Pre-Submittal Meeting

2 Agenda 24 Month Fuel Cycle and Surveillance Interval Extension Introduction Overview 24MFC LAR Development Approach 24MFC LAR Interface with ITS LAR NRC Review and Approval Support Hope Creek LAR Parallel Submittal Schedule Questions and Closing Remarks 24 Month Fuel Cycle and Surveillance Interval Extension

3 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

4 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

5 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

6 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

7 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

8 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

9 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

10 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

11 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

12 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

13 24MFC LAR Development Approach 24MFC LAR Development Approach 24 Month Fuel Cycle and Surveillance Interval Extension

14 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

15 NRC Review and Approval Support NRC Review and Approval Support

  • LAR Submittal Targeted for May 2024
  • 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

16 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

17 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) 24 Month Fuel Cycle and Surveillance Interval Extension

18 Questions and Closing Remarks 24 Month Fuel Cycle and Surveillance Interval Extension We look forward to working with you and your Review Teams.

19 you Thank

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