ML24253A194

NRR E-mail Capture - Final Eeeb RAI - Hope Creek Amendment to Revise TS to Change Surveillance Interval to Accommodate 24-Month Fuel Cycle

ML24253A194
Person / Time
Site:	Hope Creek
Issue date:	09/09/2024
From:	James Kim NRC/NRR/DORL/LPL1
To:	Jurek S Public Service Enterprise Group
References
L-2024-LLA-0065
Download: ML24253A194 (5)

Text

From: James Kim Sent: Monday, September 9, 2024 2:01 PM To: Jurek, Shane Cc: Thomas, Brian J.

Subject:

Final EEEB RAI regarding Hope Creek Amendment to Revise TS to Change Surveillance Interval to Accommodate 24-Month Fuel Cycle (EPID: L-2024-LLA-0065)

Attachments: Final EEEB RAI - Hope Creek 24-Month SR Interval.docx

SUBJECT:

Hope Creek - Final EEEB RAI regarding Amendment to Revise TS to Change

Surveillance Interval to Accommodate 24-Month Fuel Cycle (EPID: L-2024-LLA-0065)

Mr. Jurek,

By letter dated May 20, 2024 (Agencywide Documents Access and Management System (ADAMS) Accession ML24141A136), Public Service Enterprise Group Nuclear LLC (PSEG, the licensee) requested to amend the Technical Specifications (TSs) for Hope Creek Generating Station (Hope Creek) to implement a 24 Month Fuel Cycle (24MFC). Hope Creeks license amendment request (LAR) would revise certain Surveillance Requirements (SRs) intervals from 18 months to 24 months. The proposed SR intervals are in accordance with NRC Generic Letter (GL) 91-04.

The NRC staff has determined that additional information is needed to complete its review of the amendment. On August 27, 2024, the NRC staff sent PSEG the draft Request for Additional Information (RAI) from the Electrical Engineering Branch (EEEB). On September 9, 2024, the NRC staff and the licensee held a conference call to clarify the draft RAI questions. At the conclusion of teleconference, PSEG agreed to provide the RAI responses within 30 days. A publicly available version of this final RAI (attached) will be placed in the NRCs ADAMS.

Jim Kim Project Manager NRR/DORL/LPL1 301-415-4125

Hearing Identifier: NRR_DRMA Email Number: 2601

Mail Envelope Properties (DM6PR09MB4711CA1132F8465DDC679F21E4992)

Subject:

Final EEEB RAI regarding Hope Creek Amendment to Revise TS to Change Surveillance Interval to Accommodate 24-Month Fuel Cycle (EPID L-2024-LLA-0065)

Sent Date: 9/9/2024 2:01:01 PM Received Date: 9/9/2024 2:00:00 PM From: James Kim

Created By: James.Kim@nrc.gov

Recipients:

"Thomas, Brian J." <Brian.Thomas@pseg.com>

Tracking Status: None "Jurek, Shane" <Shane.Jurek@pseg.com>

Tracking Status: None

Post Office: DM6PR09MB4711.namprd09.prod.outlook.com

Files Size Date & Time MESSAGE 1335 9/9/2024 2:00:00 PM Final EEEB RAI - Hope Creek 24-Month SR Interval.docx 35259

Options Priority: Normal Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

REQUEST FOR ADDITIONAL INFORMATION

BY THE OFFICE OF NUCLEAR REACTOR REGULATION

LICENSE AMENDMENT REQUEST TO REVISE TECHNICAL SPECIFICATIONS TO CHANGE

SURVEILLANCE INTERVALS TO ACCOMMODATE 24-MONTH FUEL CYCLE

(EPID L-2024-LLA-0065)

By letter dated May 20, 2024 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML24141A136), Public Service Enterprise Group Nuclear LLC (PSEG, the licensee) requested to amend the Technical Specifications (TSs) for Hope Creek Generating Station (Hope Creek) to implement a 24 Month Fuel Cycle (24MFC). Hope Creeks license amendment request (LAR) would revise certain Surveillance Requirements (SRs) intervals from 18 months to 24 months. The proposed SR intervals are in accordance with NRC Generic Letter (GL) 91-04.

The following regulatory requirements and General Design Criteria are applicable to the Hope Creek electrical power systems.

• Title 10 of the Code of Federal Regulations (10 CFR), Section 50.36(c)(3), "Surveillance requirements," state that surveillance requirements 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.

• General Design Criterion (GDC) 17, Electric power systems, of Appendix A, General Design Criteria for Nuclear Power Plants, to 10 CFR Part 50, states in part that an onsite electric power system and an offsite electric power system shall be provided to permit functioning of structures, systems, and components important to safety. The safety function for each system (assuming the other system is not functioning) shall be to provide sufficient capacity and capability to assure that (1) specified acceptable fuel design limits and design conditions of the reactor coolant pressure boundary are not exceeded as a result of anticipated operational occurrences and (2) the core is cooled and containment integrity and other vital functions are maintained in the event of postulated accidents.

• GDC 18, Inspection and Testing of Electric Power Systems, requires that electric power systems that are important to safety must be designed to permit appropriate periodic inspection and testing.

Guidance:

• Generic Letter (GL) 91-04, Changes in Technical Specification Surveillance Intervals to Accommodate a 24-Month Fuel Cycle, provides, in part, guidance on preparation of a license amendment request for changes in surveillance intervals to accommodate a 24-month fuel cycle.

The NRC staff has determined that the following information is needed for the staff to complete the review and to reach the regulatory safety finding.

Request Additional Information (RAI)

RAI #1 In the LAR, the licensee stated that the proposed change follows the guidance of NRC Generic Letter (GL) 91-04 to increase the SR intervals from 18 months to 24 months.

For non-calibration SRs, GL 91-04 recommends, in part, that the licensees should perform the following to support surveillance intervals to accommodate a 24-month fuel cycle:

a) Evaluate the effect on safety of the change in surveillance intervals to support a conclusion that the effect on safety is small.

b) Confirm that historical maintenance and surveillance data do not invalidate the conclusion that the effect on safety is small.

c) Confirm that the performance of surveillances at the bounding surveillance interval limit provided to accommodate a 24-month fuel cycle would not invalidate any assumption in the plant licensing basis.

For Recommendation (a) above, LAR Section 4.1.1, Non-Calibration Change, states, in part:

Each non-calibration SR frequency being changed has been evaluated with respect to the effect on plant safety. The methodology utilized to justify the conclusion that extending the testing interval has a minimal effect on safety was based on the fact that the function/feature is:

(1) Tested on a more frequent basis during the operating cycle by other plant programs;

(2) Designed to have redundant counterparts or be single failure proof; or

(3) Highly reliable.

A summary of the evaluation of the effect on safety for each non-calibration SR Frequency being changed is presented in Attachment 3.

The staff notes that Attachment 3, Section 2.1.1 of the LAR further describes the evaluation to justify the conclusion that changing the non-calibration SR intervals from an 18-month to a 24-month frequency has a minimal effect on safety. However, the LAR does not specify the more-frequent testing (Item (1) above). For each of SRs 4.8.1.1.2, 4.8.4.1, and 4.8.4.2.1 please specify the more frequent testing(s) to support the justification. For each such test, the response to this RAI should include the type of test and what surveillance or program it is under.

RAI # 2

Hope Creek TS 3/4.8.1.1.2.k.2 states, in part:

-OR-

Operate the diesel generator between 4000 kW and 4400 kW for two hours. Within 5 minutes of shutting down the diesel generator, verify each diesel generator starts and achieves 3950 volts and 58.8 Hz in 10 seconds after receipt of the start signal, and subsequently achieves steady state voltage 3828 and 4580 volts and frequency of 60 +/-

1.2 Hz. This test shall continue for at least five minutes.

LAR Attachment 3, Pages 30 and 31 of 70, state (bold emphasize added):

-OR-

Operate the diesel generator between 4000 kW and 4400 kW for two hours. Within 5 minutes of shutting down the diesel generator, verify each diesel generator starts and achieves 3950 volts and 58.8 Hz in 10 seconds after receipt of the start signal, and subsequently achieves steady state voltage 3828 and 4580 volts and frequency of 60 +/-

1.2 Hz. This test shall continue for at least five minutes.

Please explain the discrepancy between the TS and LAR ( 10 seconds and 10 seconds, respectively) with regards to the time required to verify each diesel generator starts and achieves 3950 volts and 58.8 Hz after receipt of its start signal.