ML25169A316
| ML25169A316 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 05/08/2025 |
| From: | Richard Guzman NRC/NRR/DORL/LPL1 |
| To: | Jurek S Public Service Enterprise Group |
| References | |
| EPID L-2025-LLA-0021, EPID L-2025-LLA-0022 | |
| Download: ML25169A316 (1) | |
Text
{{#Wiki_filter:From: Richard Guzman To: Jurek, Shane
Subject:
Salem Generating Station, Units 1 and 2 - Risk-Informed Completion Time TSTF-505/TSTF-591 and 10 CFR 50.69 Audit Questions (EPIDs L-2025-LLA-0021, L-2025-LLA-0022) Date: Thursday, May 8, 2025 9:52:33 AM
- Shane,
By letters dated January 31, 2025 (Agencywide Documents Access and Management System (ADAMS) Accession Nos. ML25031A416 and ML25031A371), PSEG Nuclear, LLC (PSEG, the licensee) submitted two license amendment requests (LARs) for Salem Generating Station, Units 1 and 2 (Salem). The proposed amendments would modify Salem licenses DPR-70 and DPR-75 and the Technical Specifications (TSs) to adopt Technical Specifications Task Force (TSTF) Traveler 505 (TSTF-505), Provide Risk-informed Extended Completion Times, RITSTF Initiative 4b, TSTF-591, Revise the Risk Informed Completion Time (RICT) Program, and the provisions of Title 10 of the Code of Federal Regulations (10 CFR), Section 50.69, Risk-informed categorization and treatment of structures, systems and components for nuclear power reactors.
On April 14, 2025, the NRC staff issued an audit plan (ML25096A002) that conveyed intent to conduct a regulatory audit to support its review of the subject licensing actions. Based on the commonalities between the LARs and subsequent overlap in technical content and review personnel, the staff is conducting a combined audit that addresses both LARs. In the audit plan, the NRC staff requested an electronic portal setup and provided a list of documents to be added to the online portal. The audit plan also indicated that the NRC may request information and audit meetings/interviews throughout the audit period. The NRC staff has performed an initial review of the list of documents and is developing a list of audit questions.
The first set of audit questions are provided below. Please post the response(s) for the questions to the online portal as the response is completed (but no later than one week before the date of the scheduled audit meeting). The dates and times for the audit meetings have not been set; however, the staff is targeting June 2025 to conduct the initial audit discussions via MS Team teleconference call. The proposed agenda for the audit discussions will also be provided on a later date. Please contact me at any time prior if a clarification discussion is needed. We look forward to discussing these questions and PSEGs responses during the virtual audit meeting.
Thank you,
Rich Guzman Sr. PM, Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Phone: (301) 415-1030 Richard.Guzman@nrc.gov
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AUDIT QUESTIONS
LICENSE AMENDMENT REQUESTS TO REVISE TECHNICAL SPECIFICATIONS TO ADOPT
TSTF-505, REVISION 2, RISK-INFORMED EXTENDED COMPLETION TIMES INITIATIVE 4B;
TSTF-591, REVISION 0, RISK-INFORMED COMPLETION TIME PROGRAM; AND
10 CFR 50.69, RISK-INFORMED CATEGORIZATION AND TREATMENT
OF STRUCTURES, SYSTEMS, AND COMPONENTS
PSEG NUCLEAR, LLC
SALEM GENERATING STATION, UNITS 1 AND 2
DOCKET NOS. 50-272 AND 50-311
By letters dated January 31, 2025 (Agencywide Documents Access and Management System (ADAMS) Accession Nos. ML25031A416 and ML25031A371), PSEG Nuclear LLC submitted license amendment requests (LARs) to amend the licenses for Salem Generating Station, Units 1 and 2, Renewed Facility Operating License Nos. DPR-70 and DPR-75, respectively. The proposed LARs would adopt Technical Specifications Task Force Traveler 505 (TSTF-505), Revision 2, Provide Risk-informed Extended Completion Times, RITSTF Initiative 4b, TSTF-591, Revise the Risk Informed Completion Time (RICT) Program, and the provisions of Title 10 of the Code of Federal Regulations (10 CFR), Section 50.69, Risk-informed categorization and treatment of structures, systems and components for nuclear power reactors.
On April 14, 2025, the U.S. Nuclear Regulatory Commission (NRC) staff issued an audit plan (ML25096A002) that conveyed intent to conduct a regulatory audit to support its review of the subject LARs. Based on the commonalities between the LARs and subsequent overlap in technical content and review personnel, the NRC staff is conducting a combined audit that addresses both LARs. The NRC staff has determined that the additional information is needed to support the audit as shown in the following audit questions. The questions are ordered by number and identified by technical review branch/area.
Audit Question-01 (EEEB) of the LAR cites the Browns Ferry license amendment (ML23073A290) as precedence for a RICT variation for one inoperable diesel generator (DG). The NRC staff recognizes there are differences between the Improved Standard TS format for Browns Ferry and the custom TS format for Salem. However, the proposed RICT for Salem TS 3.8.1.1 Actions b.4.a)2.a. and b.4.a)2.b. appears inconsistent with the requirements of
TSTF-505 as described below.
As stated in the exclusion criteria listed in TSTF-505, Revision 2, the traveler will only modify Required Actions that specify that a system be restored to OPERABLE status, that require an instrument channel to be placed in trip, or that require isolating an inoperable isolation valve. Accordingly, a RICT cannot be applied to Required Actions that specify that a system be restored to a status other than OPERABLE (e.g., available).
The proposed changes, as currently structured, would apply RICT to Actions b.4.a)2.a. and b.4.a)2.b. that specify, in part, that a system (i.e., Supplemental Power Source (SPS)) be restored to available status, and thereby does not meet the requirements of TSTF-505. Please address this variation from TSTF-505, Revision 2 for TS 3.8.1.1 Actions b.4.a)2.a. and b.4.a)2.b. including the corresponding TS Bases and Action Item in Table E1-1.
Audit Question-02 (EEEB)
It appears that the LAR Table E1-1 does not include the design success criteria and probabilistic risk assessment (PRA) success criteria for TS 3.8.1.1 Action b.4.a)2.a. If the resolution for audit question 1 above is to remove the proposed RICTs for Actions b.4.a)2.a. and b.4.a)2.b., this concern is no longer applied. Otherwise, please clarify.
Audit Question-03 (EEEB)
In Attachment 3.1 of the LAR, the markup for TS 3.8.1.1 would add an option to apply a RICT to Action b.4.a)2.b., which currently has a front-stop completion time (CT) of 24 hours. In Attachment 3.2 of the LAR, the associated TS Bases markup states, in part (proposed text is emphasized in bold font):
In the event TS Action statement 3.8.1.1.b is entered for an inoperable emergency diesel generator (EDG) for greater than or equal to 48 hours, then only 24 hours is allowed to return the SPS to available status or the EDG to OPERABLE status. The 24-hour allowance for an unavailable SPS can be entered more than once to address unanticipated conditions associated with the SPS. Alternatively, restoration to an OPERABLE status can be in accordance with the Risk Informed Completion Time Program.
However, the NRC Branch Technical Position (BTP) 8-8, Onsite (Emergency Diesel Generators) and Offsite Power Sources Allowed Outage Time Extensions, Section B, Branch Technical Position, (ML113640138), states, in part:
If the AAC or supplemental power source becomes unavailable any time during extended AOT, the unit shall enter the LCO and start shutting down within 24 hours. This 24-hour period will be allowed only once within any given extended EDG AOT.
It appears that the TS Bases for TS 3.8.1.1, Action b.4.a)2.b. is inconsistent with guidance in BTP 8-8 regarding the limitation of the use of 24-hour allowance for an unavailable SPS. Please address this inconsistency.
Audit Question-04 (EEEB)
In the LAR Table E1-1 (Page 23 of 43), TS 3.8.1.1, the design success criteria (DSC) for Action b.4.a)1. and Action b.4.a)2. stated, 1 of 2 AC [Alternating Current] electrical power sources and 1 diesel generator. AC electrical power sources can be either AC circuits or diesel generator. It is not clear what the 1 of 2 AC electrical power sources refer to. Please clarify.
Audit Question-05 (EEEB)
In the LAR Table E1-1, the PRA success criteria for TS 3.8.1.1 Actions a.3, c., d.3., and d.4.; TS 3.8.2.1 Action a. and b.; TS 3.8.2.3 Actions a. and b.; and TS 3.8.2.5 Actions a. and b. stated, As needed to supply supported functions. However, there is no description of what the PRA success criteria are. Please explain.
Audit Question-06 (EEEB)
Salem updated final safety analysis report (UFSAR), Section 8.3.1.5, Standby Power Supplies, states, Any two of the diesel generators and their associated vital buses can supply sufficient power for operation of the required safeguards equipment for a design basis LOCA [loss-of-coolant accident] coincident with a loss of offsite power. In the LAR Table E1-1, TS 3.8.1.1, the PRA success criteria for Action b.4.a)1. (Page 23 of 43), Action b.4.a)2. (Page 23 of 43), Action b.4.a)2.b. (Page 24 of 43), and Action e. state, 1 of 3 DGs per unit. Please explain the following:
- a. Why these PRA success criteria are different from the associated DSC, and
- b. How these PRA success criteria do not result in a loss of function.
Audit Question-07 (EEEB)
LAR Table E1-1, TS 3.8.1.1 uses two different terms: AC electrical power sources and AC distribution power sources. For consistency, please clarify the intended term for TS 3.8.1.1, Actions c., d.3., and d.4.
Audit Question-08 (EEEB)
In the LAR Table E1-1, the DSC for TS 3.8.1.1 Actions d.3. is 1 of 2 AC distribution power source. Action d. relates to two of the AC circuits inoperable. With both AC circuits inoperable, it is not clear how the DSC for Action d.3., as currently constructed, do not result in a loss of function. Please explain.
Audit Question-09 (EEEB)
TS 3.8.2.3 states:
The following D.C. bus trains shall be OPERABLE and energized :
TRAIN 2A
consisting of 125-volt D.C. bus No. 2A, 125-volt D.C. battery No. 2A and battery charger 2A1.
TRAIN 2B
TRAIN 2C consisting of 125-volt D.C. bus No. 2B, 125-volt D.C. battery No. 2B and battery charger 2B1.
consisting of 125-volt D.C. bus No. 2C, 125-volt D.C. battery No. 2C* and battery charger 2C1.
It appears that there is one battery charger for each train. In the LAR Table E1-1, the design success criteria for TS 3.8.2.3 Action b states, 1 of 2 battery chargers per required DC bus. Please clarify how many battery chargers per DC bus.
Audit Question-10 (EEEB)
TS 3.8.2.5 states:
The following D.C. bus trains shall be energized and OPERABLE:
TRAIN 2A
TRAIN 2B
consisting of 28-volt D.C. bus No. 2A, 28-volt D.C. battery No. 2A and battery charger 2A1.
consisting of 28-volt D.C. bus No. 2B, 28-volt D.C. battery No. 2B, and battery charger 2B1. It appears that there is one battery charger for each train. LAR Table E1-1, design success criteria for TS 3.8.2.5 Action b. states, 1 of 2 battery chargers per required DC bus. Please clarify how many battery chargers per DC bus?
Audit Question-11 (EEEB)
LAR Attachment 4 provides cross-reference of TSTF-505 and Salem TS. In this attachment, the technical variation justification for TS 3.8.1.1 Actions b.4.a)2., b.4.a)2.a., and b.4.a)2.b. is that This variation has been approved by the NRC previously; for example, at the Browns Ferry Nuclear Plant [ML23073A290]. However, both Browns Ferry LAR (ML22090A287) and its NRC approval do not describe the Browns Ferry corresponding TS 3.8.1 Required Action B.5. as a technical variation from TSTF-505. Please clarify.
The technical variation justification for TS 3.8.1.1 Actions b.4.a)2., b.4.a)2.a., and b.4.a)2.b. also states that, However, a failed DG is used as a suitable surrogate for an inoperable SPS. Therefore, the calculated RICT for Action b.4.a)2 [b.4.a)2.a., and b.4.a)2.b.] will be equivalent to Action b.4.a)1. It is not clear what the intent of this statement is. Please explain.
Audit Question-12 (EEEB)
For AC and DC distributions, provide number of busses required for safe shutdown.
Audit Question-13 (EEEB)
Provide the list of electrical shared Structures, Systems, and Components (SSCs) (if any) and their associated cross-tie(s).
Technical Review Branch/Review Area EEEB - Electrical Engineering
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