ML25062A111
| ML25062A111 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 02/28/2025 |
| From: | Marshall M Plant Licensing Branch 1 |
| To: | Jurek S Public Service Enterprise Group |
| Kim J | |
| References | |
| EPID L-2025-LLA-0037 | |
| Download: ML25062A111 (3) | |
Text
From:
Michael Marshall To:
Jurek, Shane
Subject:
HOPE CREEK, UNIT 1 - REQUEST FOR ADDITIONAL INFORMATION REGARDING EMERGENCY LICENSE AMENDMENT FOR ONE-TIME CHANGE TO EXTEND ALLOWED OUTAGE TIME FOR DIESEL GENERATOR (EPID L-2025-LLA-0037)
Date:
Friday, February 28, 2025 10:46:00 PM Hello Shane,
By application dated February27, 2025, as supplemented by letter dated February27, 2025 (Agencywide Documents Access and Management System Accession Nos.
ML25058A095 and ML25058A312, respectively), PSEG Nuclear LLC (the licensee or PSEG) submitted a license amendment request (LAR) requesting temporary changes to the technical specifications (TSs) for Hope Creek Generating Station (Hope Creek). The proposed TS changes would revise the allowed outage time (AOT) for TS Action 3.8.1.1.b.3 from 14-days to 18-days, one-time, to allow time to complete repairs on the D emergency diesel generator (EDG).
The U.S. Nuclear Regulatory Commission (NRC) staff has determined that additional information is needed to complete our review of the Hope Creek emergency LAR. This request was discussed with PSEG on February28, 2025. The licensee agreed to provide its response to these requests for additional information (RAIs) by March2, 2025.
RAI 1
Branch Technical Position (BTP) 8-8, "Onsite (Emergency Diesel Generators) and Offsite Power Sources Allowed Outage Time Extensions," in NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR Edition (ML113640138) provides guidance, from a deterministic perspective, for reviewing an EDGs AOT extension request up to 14 days. Although the requested extension for the Hope Creek TS 3.8.1 Action b.3 AOT exceeds 14 days, for defense-in-depth review purpose, the NRC staff uses the guidance in BTP 8-8 to review the proposed change.
Section 3.2, Compliance with Branch Technical Position 8-8, of the LAR states that Hope Creek complies with BTP 8-8 guidance criteria.
BTP 8-8 states, in part, that the system load dispatcher will be contacted once per day to ensure no significant grid perturbations (high grid loading unable to withstand a single contingency of line or generation outage) are expected during the extended AOT.In addressing the above-mentioned statement ofBTP 8-8, Section 3.2 of the LAR states See Section 3.4. However, it appears that Section 3.4 of the LAR does not clearly address the above-mentioned statement ofBTP 8-8. Compensatory measures 12 and 20 in Section 3.4 of the LAR mention that electrical system operator will be notified or contacted, but do not state whether PSEG will check once per day to ensure there are no grid perturbations. No other compensatory measure discusses contacting the electrical system operator.
Under which compensatory measure listed in Section 3.4 of the LAR does PSEG plan to notify/contact the electrical system operator to ensure no significant grid perturbations and what language in that compensatory measure clearly indicates the action will be taken once per day?
RAI 2
BTP 8-8 states, in part, that the availability of supplemental power source should be verified within the last 30 days before entering extended AOT by operating or bringing the power source to its rated voltage and frequency for 5 minutes and ensuring all its auxiliary support systems are available or operational.
In Section 3.4, Compensatory measures, of the LAR, compensatory measures 15, 16, 18, and 19 state that the associated compensatory actions (related to the supplemental power source (i.e., AOT diesels) verification actions) will be performed after exceeding 14 days.
The NRC staff notes that per BTP 8-8, the verification of the AOT diesels availability should be performed prior to exceeding the plant current EDG AOT and during the requested extended AOT entry.
Please explain how performing compensatory measures 15, 16, 18 and 19 after exceeding 14 days satisfy the above-mentioned BTP 8-8 criterion.
RAI 3
BTP 8-8 states, in part, that the availability of supplemental power source should be verified within the last 30 days before entering extended AOT by operating or bringing the power source to its rated voltage and frequency for 5 minutes and ensuring all its auxiliary support systems are available or operational. In Section 3.2 of the LAR, PSEG states that it complies with the guidance in BTP 8-8.
Item 9 in Section 3.4 of the LAR PSEG states The AOT diesels are available and are not being credited for Salem Generating Station. In LAR Section 3.2, item e, PSEGstates:
The availability of AAC or supplemental power source should be verified within the last 30 days before entering extended AOT by operating or bringing the power source to its rated voltage and frequency for 5 minutes and ensuring all its auxiliary support systems are available or operational.
See Amendment 216 for verification of the availability of the supplement power source.
Hope Creeks TS 3.8.1.1 action b.3 does not require verification of the supplemental power source for the current 14-day AOT for restoration of D EDG. It is unclear in the LAR which compensatory measure(s) referenced in the proposed TS footnote include actions, prior to exceeding the D EDG 14-day AOT, to verify the supplemental power source will be tested as described in Amendment 216.
Clarify which compensatory measure(s) ensure that the supplemental power source (i.e.,
AOT diesels) will be verified as described in Amendment 216 prior to exceeding the 14-day AOT. If none of the compensatory measures ensure that the supplemental power source (i.e., AOT diesels) will be verified as described in Amendment 216 prior to exceeding the 14-day AOT, please describe how PSEG will ensure the actions described in Amendment 216 will be completed prior to exceeding the 14-day AOT, thus ensuring the AOT diesel will operate properly.
RAI 4
BTP 8-8 states, in part, that
The EDG or offsite power AOT should be limited to 14 days to perform maintenance activities. This time period is based on industry operating experience; for example, a maximum of 216 hours0.0025 days <br />0.06 hours <br />3.571429e-4 weeks <br />8.2188e-5 months <br /> (13.5 days, consisting of two shifts, each shift working 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />) is considered to be sufficient for a major EDG overhaul or offsite power major maintenance. The licensee must provide justification for the duration of the requested AOT (actual hours plus margin based on plant-specific past operating experience).
[emphasis added]
LAR Section 2.3, Reason for the Proposed Change, states, in part:
The request to extend the D EDG AOT to 18 days includes additional contingency time to address delays that may arise during restoration and testing of the electrical, instrumentation and mechanical equipment removed to perform work on the lube oil heat exchanger and additional time for restoration of the EDG (e.g., longer time needed for lube oil heat up). As stated in the TS mark up in Enclosure 2, the one-time extension shall expire upon completion of the maintenance to restore the D EDG to OPERABLE status or by 0200 on March9, 2025, whichever occurs first.
The Table 1, Projected D EDG Maintenance Schedule, in the LAR provides an itemized maintenance activities with associated projected time for the 14-day AOT.
The NRC staff notes that both the paragraph in Section2.3 of the LAR and Table 1 do not provide sufficient justification satisfying the BTP 8-8 guidance quoted above. Please provide the itemized contingency activities with associated estimated time (with margin) needed to support the requested additional 4 days.
Best Regards, Michael L. Marshall, Jr.
Senior Project Manager
Plant Licensing Branch I Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
301-415-2871
Docket No. 050-354