NUREG-1433, Regulatory Audit in Support of Review of the License Amendment Request Concerning Technical Specification Conversion to NUREG-1433, Revision 5
| ML24361A149 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 01/07/2025 |
| From: | Bryant J Plant Licensing Branch 1 |
| To: | Mcfeaters C Public Service Enterprise Group |
| Kim J | |
| References | |
| EPID L-2024-LLI-0000 | |
| Download: ML24361A149 (1) | |
Text
January 7, 2025 Charles V. McFeaters President and Chief Nuclear Officer PSEG Nuclear LLC - N09 P.O. Box 236 Hancocks Bridge, NJ 08038
SUBJECT:
HOPE CREEK GENERATING STATION - REGULATORY AUDIT IN SUPPORT OF REVIEW OF THE LICENSE AMENDMENT REQUEST CONCERNING TECHNICAL SPECIFICATION CONVERSION TO NUREG-1433, REVISION 5 (EPID L-2024-LLI-0000)
Dear Charles McFeaters:
By letter dated May 20, 2024 (Agencywide Documents and Access Management System (ADAMS) Accession No. ML24142A428), as supplemented by letter dated October 17, 2024 (ML24291A058), PSEG Nuclear (PSEG, the licensee) submitted a license amendment request (LAR) for Hope Creek Generating Station (Hope Creek). The proposed LAR would revise the current technical specifications (TSs) to reflect adoption of NUREG-1433, Standard Technical Specifications - General Electric BWR/4 Plants, Revision 5 (ML21272A357).
The U.S. Nuclear Regulatory Commission (NRC) staff has identified the need for a regulatory audit to examine PSEGs non-docketed information with the intent to gain understanding, to verify information, or to identify information that will require docketing to support the basis of the licensing or regulatory decision.
The NRC staff will conduct the audit virtually via Microsoft Teams using a licensee-established electronic portal available to NRC staff from approximately January 11, through February 28, 2025, with formal audit meetings to be scheduled during this period as needed. The NRC staff reserves the right to extend the audit, if necessary. The detailed audit plan is enclosed with this letter.
C. McFeaters If you have any questions, please contact me at (301) 415-0610 or by email at jack.minzerbryant@nrc.gov Sincerely, Jack Minzer Bryant, Project Manager Plant Licensing Branch II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-354
Enclosure:
Audit Plan cc: Listserv JACK MINZER BRYANT Digitally signed by JACK MINZER BRYANT Date: 2025.01.07 09:10:11 -05'00'
Enclosure REGULATORY AUDIT PLAN BY THE OFFICE OF NUCLEAR REACTOR REGULATION TO SUPPORT THE REVIEW OF THE LICENSE AMENDMENT REQUEST CONVERSION TO IMPROVED STANDARD TECHNICAL SPECIFICATIONS PSEG NUCLEAR LLC HOPE CREEK GENERATING STATION DOCKET NO. 50-354 EPID L-2024-LLI-0000
1.0 BACKGROUND
By letter dated May 20, 2024 (Agencywide Documents and Access Management System (ADAMS) Accession No. ML24142A428) as supplemented by letter dated October 17, 2024 (ML24291A058), PSEG Nuclear LLC (PSEG, the licensee) submitted a license amendment request (LAR) for Hope Creek Generating Station (Hope Creek). The proposed LAR would revise the current technical specifications (TSs) to reflect adoption of NUREG-1433, Standard Technical Specifications - General Electric BWR/4 Plants, Revision 5 (ML21272A357).
The U.S. Nuclear Regulatory Commission (NRC) staff from the Office of Nuclear Reactor Regulation (NRR) has initiated its review of the LAR and identified the need for a regulatory audit to examine PSEGs non-docketed information with the intent to gain understanding, to verify information, or to identify information that will require docketing to support the basis of the licensing or regulatory decision.
2.0 REGULATORY AUDIT BASES A regulatory audit is a planned license-or regulation-related activity that includes the examination and evaluation of primarily non-docketed information associated with the LAR. An audit is conducted to gain understanding, to verify information, and to identify information that will require docketing to support the basis of a licensing or regulatory decision. An audit will assist the NRC staff in efficiently conducting its review and gaining insights to the licensees processes and procedures. Information that the NRC staff relies upon to make the safety determination must be submitted on the docket. This audit will be conducted in accordance with NRR Office Instruction LIC-111, Regulatory Audits, Revision 2, dated December 2024 (ML24309A281), with exceptions noted within this audit plan.
The NRC staff will perform the audit to support its evaluation of whether PSEGs LAR can be approved per Title 10 of the Code of Federal Regulations (10 CFR), Section 50.90, Application for amendment of license, construction permit, or early site permit.
3.0 REGULATORY AUDIT SCOPE AND METHODOLOGY NRCs objectives of the audit are the following:
Gain a better understanding of the detailed calculations, analyses, and bases underlying the LAR and confirm the NRC staffs understanding of the LAR.
Gain a better understanding of plant design features and their implications for the LAR.
Identify any information needed to enable the NRC staffs evaluation of the technical basis used for this application.
Identify any information needed to enable the NRC staffs evaluation of whether the proposed changes challenge design-basis functions or adversely affect the capability or capacity of plant equipment to perform design-basis functions.
Identify questions and requests that may become formal requests for additional information (RAIs) per NRR Office Instruction LIC-115, Processing Requests for Additional Information (ML21141A238).
The NRC staff will audit the technical information and methods that the licensee used to determine the impact on the plant, and the licensees evaluation of defense-in-depth.
The audit will give the NRC staff the opportunity to:
Review and understand the licensees implementation of the footnotes that have been proposed for addition into Improved Technical Specifications (ITS) 3.3.1.1, Reactor Protection System (RPS) Instrumentation, ITS 3.3.2.1, Control Rod Block Instrumentation, ITS 3.3.4.2, End-Of-Cycle Recirculation Pump Trip System Instrumentation, ITS 3.3.5.1, Emergency Core Cooling System (ECCS)
Instrumentation, ITS 3.3.5.3, Reactor Core Isolation Cooling (RCIC) System Instrumentation, and to verify that limiting safety system settings (LSSS)-related instrument channels are functioning as required before returning the channel to service following a required surveillance. In particular, the staff needs to understand how the instructions in the proposed ITS footnotes and the performance test acceptance criteria applied during surveillances are consistent with the plant setpoint methodology. The NRC staff may need to review other documents associated with this ITS LAR.
Understand the methodology for determining the as-found/as-left acceptance criteria bands and other surveillance-related criteria discussed in the plant setpoint methodology and applied in the surveillance procedures. The NRC staff requests the licensee to locate the setpoint methodology in its licensing and/or design basis, to clarify the terminology inconsistencies between the licensee-controlled document HC.DE-TS.ZZ-1001, Instrument Setpoint Calculations for Hope Creek Generating Station, Revision 0, March 3, 2006, and the proposed footnotes in this ITS LAR.
Walk through one or more examples of how LSSS are established, and how they relate to its setpoint methodology. In addition, the staff needs to understand how performance test acceptance criteria used in required surveillance tests are determined.
4.0 INFORMATION AND OTHER MATERIAL NECESSARY FOR THE AUDIT The NRC staff will request information and an audit meeting(s) throughout the audit period.
section 9.0 of this audit plan includes the NRC staffs initial audit questions (AQs). The NRC staff requests the licensee to have the requested information responsive to the AQs to be readily available and accessible for the NRC staffs review via a Web-based portal.
5.0 TEAM ASSIGNMENTS The audit will be conducted by NRC staff from the NRR, Division of Engineering and External Hazards Branch (DEX), and Instrumentation and Controls Branch (EICB) who are knowledgeable in instrument setpoint calculations and calibrations, and associated surveillance procedures. The audit will be led by staff from the NRR, Division of Operating Reactor Licensing (DORL). Additionally, staff from the Technical Specifications Branch (STSB) within the Division of Safety Systems (DSS) will participate in the audit. NRC staff from other organizations may be assigned to the team as appropriate and others may participate as observers. Observers at the audit may include NRR project managers and various Regional NRC staff.
The following are members of the NRC audit team:
Team Member Title Organization Jack Minzer Bryant Jack.minzerbryant@nrc.gov Project Manager NRR/DORL/LPLII-1 Richard Guzman Richard.guzman@nrc.gov Senior Project Manager NRR/DORL/LPLI Ming Li Ming.li@nrc.gov Electronics Engineer NRR/DEX/EICB Frederick OBrien Frederick.obrien@nrc.gov Electronics Engineer NRR/DEX/EICB Andrea Russell Andrea.russell@nrc.gov Safety and Plant Systems Engineer NRR/DSS/STSB Khadijah West Khadijah.west@nrc.gov Safety and Plant Systems Engineer NRR/DSS/STSB Tarico Sweat Tarico.sweat@nrc.gov Reactor System Engineer NRR/DSS/STSB 6.0 LOGISTICS To support the review schedule communicated to PSEG when the NRC staff accepted the LAR for technical review, audit activities will be performed virtually using Microsoft Teams, Web-based portal or other virtual meeting space created by the licensee. The NRC staff information requests and communications with licensee staff will be coordinated through the NRCs licensing project manager.
The virtual audit window will be between January 11 through February 28, 2025. The NRCs licensing project manager will coordinate with the licensee to establish virtual audit meetings via Microsoft Teams on mutually agreeable dates and times, to discuss information needs and questions arising from the NRCs review of the audited items. The NRC staff may change and/or add audit dates and times, or extend the audit, if necessary. Audit meeting agenda and questions, if needed, will be sent in advance of the audit meeting.
The NRC staff intends to conduct the initial virtual audit meetings with PSEGs staff in the late January/early February 2025 timeframe to discuss items addressing the determination of the as-found/as-left acceptance criteria bands and other surveillance acceptance-related criteria and their applications in the plant surveillance processes. The NRC staff requests the licensee to have the information responsive to the items listed in section 9.0 of this audit plan available and accessible for the NRC staffs review via an internet-based portal. The NRCs licensing project manager will inform the licensee via routine communications when the NRC staff no longer needs access to the portal. The NRC staff requests the licensee to notify the NRCs licensing project manager when an audit item is added to its portal by sending an e-mail to the NRC licensing project manager.
7.0 SPECIAL REQUESTS The NRC requests access to requested documents and information through a Web-based portal that allows the NRC staff and contractors to access documents over the Internet. The following conditions associated with the online portal must be maintained while the NRC staff and contractors have access to the online portal:
The online portal will be password-protected. A separate password will be assigned to each member of the NRC staff and NRC contractors participating in the audit.
The online portal will prevent the NRC participants from printing, saving, downloading, or collecting any information directly from the online portal.
Conditions of use of the online portal will be displayed on the login screen and will require acknowledgment by each user.
Username and password and/or other Web-based portal access information should be provided directly to members of the NRC staff and contractors as needed. The NRC licensing project manager will provide the licensee with names and contact information of the NRC staff and contractors participating in the audit. All other communications should be coordinated through the NRC project manager.
8.0 DELIVERABLES The NRC staff will develop any RAIs, as needed, via NRR Office Instruction LIC-115 and issue such RAIs separately from audit-related correspondence. The NRC staff will issue an audit summary report prior to completing its review of the LAR.
9.0 AUDIT QUESTIONS AQ-1 The licensee proposed to not adopt the footnotes (a) and (b) from ITS/LCO table 3.3.1.1-1 Function Unit 1.a, (Reactor Protection System Instrumentation, Intermediate Range Monitors (IRMs), Neutron Flux - High.). In Attachment 2 of the LAR, the licensee stated in ITS 3.3.1.1 Justification for Deviation #4 that:
- 1. HCGS [Hope Creek Generating Station] will control the as-left and as-found tolerances for the Intermediate Range Monitors Neutron Flux - High Function in station procedures,
- 2. the Rod Worth Minimizer [RWM] provides protection against unacceptable neutron flux excursions during reactor startup, and
- 3. NRC staff has a position that if a licensee did not propose to add the TSTF-493 footnotes in a license amendment request (LAR) to revise Allowable Values, their practice is to not request that they be added as long as control of as-left and as-found tolerances is being addressed in plant procedures. The licensee concluded that specifying footnotes for the IRM Neutron Flux - High is not necessary.
As for arguments #1 and #3, the Technical Specification Task Force (TSTF)-19-07 Elimination of the Requirement to Adopt TSTF-493, "Clarify Application of Setpoint Methodology for LSSS Functions," suggests a license commitment such as The practices described in the notes of TSTF-493 Option A, will be retained in [Licensees] surveillance procedures, to align with the NRC staff position. Please provide the technical basis as to why the Intermediate Range Monitors Neutron FluxHigh Function needs to be treated differently from the other functions in the table. Please confirm if the licensee plans to insert such kind of commitment (i.e., controlled within surveillance procedures) to its proposed ITS.
As for #2, the TSTF-493 footnotes or similar administrative controls are required for the LSSS safety functions. TSTF-493, Revision 4, suggests a comprehensive list of LSSS safety functions, which includes the IRM trip function. The determination of the LSSS function is not based on whether that function has diversity. Therefore, the RWM provides the same protection as the IRM trip does not de-categorize the IRM trip from the LSSS functions. Please clarify the assertion that IRM trip is not one of the LSSS functions as STS Revision 5 suggested.
AQ-2 Describe the current process or provide the procedure of evaluating both operability and functioning as required for I&C functions during the routine surveillance as described in the TSTF-493 Option A footnotes.
AQ-3 The licensee states in the LAR Attachment 2 that The terms recalibration tolerance and calibration tolerance are equivalent, respectively, to the terms As-Found Tolerance [AFT] and As-Left Tolerance [ALT] specified in NUREG-1433, and then demonstrates example applications of the HCGS setpoint methodology. Confirm what terms the plant engineers use during the surveillance as described by the TSTF-493 footnotes. If the plant TS and surveillance procedures use different sets of terms, clarify what management measures are in place to address this inconsistency and potential confusion that plant engineers might have.
AQ-4 HC.DE-TS.ZZ-1001, Instrument Setpoint Calculations for Hope Creek Generating Station, Revision 0, March 3, 2006, defines LSSS as Reactor trip/protection system instrumentation setpoints included in station technical specifications. Per 10 CFR 50.36(c)(1), TS shall include LSSS. As such the licensee is not allowed to remove LSSS setpoint out of its TS. Please justify the regulatory basis of proposal of the setpoint removal from the ITS.
AQ-5 Provide the list of technical documents in the portal that includes definitions and the calculation details for ALT, AFT, Allowable Value (AV), limiting trip setpoint (LTSP)/nominal trip setpoint (NTSP).
AQ-6 The licensee proposed to change in ITS Section 3.3 the term Limiting Trip Setpoint (LTSP) to Nominal Trip Setpoint (NTSP). These two terms are defined differently in RIS 2006-17. Please clarify the definition of NTSP and its location in the plant licensing basis.
AQ-7 In attachment 2 to the LAR, ITS table 3.3.1.1-1, the licensee proposed to add calibration surveillance requirement footnotes (similar to TSTF-493, Revision 4, Option A) to Function 3 (Reactor Vessel Steam Dome Pressure - High), Function 4 (Reactor Vessel Steam Dome Pressure - Low), Function 6 (Drywell Pressure - High), and Function 9 (Turbine Control Valve Fast Closure, Trip Oil Pressure - Low). The footnotes are not applied to these functions in the Hope Creek current TS. Also, in proposed ITS 3.3.4.1, End of Cycle Recirculation Pump Trip (EOC-RPT) Instrumentation, Surveillance Requirement 3.3.4.1.2 (Channel Calibration) contains similar notes that are not in current TS. Please provide Discussion of Changes for these proposed changes in ITS 3.3.1.1 and 3.3.4.1.
ML24361A149 NRR-106 OFFICE NRR/DORL/LPL1/PM NRR/DORL/LPL2-1/PM NRR/DORL/LPL1/LA NRR/DSS/STSB/BC NAME RGuzman JMinzerBryant KEntz SMehta DATE 12/23/2024 12/23/2024 1/6/2025 1/3/2025 OFFICE NRR/DEX/EICB/BC NRR/DORL/LPL1/BC NRR/DORL/LPL2-1/PM NAME FSacko HGonzález JMinzerBryant DATE 1/3/2025 1/7/2025 1/7/2025