ML26048A346
| ML26048A346 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  (NPF-057) |
| Issue date: | 03/02/2026 |
| From: | Marshall M Plant Licensing Branch 1 |
| To: | Mcfeaters C Public Service Enterprise Group |
| References | |
| EPID L-2026-LLA-0003 | |
| Download: ML26048A346 (0) | |
Text
March 2, 2026 Mr. Charles V. McFeaters President and Chief Nuclear Officer PSEG Nuclear LLC - N09 Hope Creek Generating Station P.O. Box 236 Hancocks Bridge, NJ 08038
SUBJECT:
HOPE CREEK GENERATING STATION - REGULATORY AUDIT PLAN IN SUPPORT OF LICENSE AMENDMENT REQUEST TO ADOPT TSTF-505, REVISION 2, PROVIDE RISK-INFORMED EXTENDED COMPLETION TIMES - RITSTF INITIATIVE 4B AND TSTF-591-A, REVISION 0 REVISE THE RISK INFORMED COMPLETION TIME PROGRAM (EPID L-2026-LLA-0003)
Dear Mr. McFeaters:
By letter dated December 31, 2025 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML25365A973), PSEG Nuclear, LLC (the licensee) submitted a license amendment request (LAR) to amend the license for Hope Creek Generating Station, Renewed Facility Operating License Nos. NPF-57. The proposed LAR would adopt Technical Specifications Task Force Traveler 505, Revision 2, Provide Risk-informed Extended Completion Times, RITSTF Initiative 4b (TSTF-505) and Technical Specifications Task Force Traveler 591-A, Revision 0, Revise the Risk Informed Completion Time (RICT) Program.
The U.S. Nuclear Regulatory Commission (NRC) staff has identified the need for a regulatory audit to examine the licensees non-docketed information with the intent to gain a better understanding, to verify information, or to identify information that will require docketing to support the basis of a regulatory decision.
The NRC staff will conduct the audit via video and audio conference using a licensee-established electronic portal available to NRC staff from March 9, 2026 through May 8, 2026 with formal audit meetings to be scheduled during this period, as needed. The detailed audit plan is enclosed with this letter.
If you have any questions, please contact me by telephone at 301-415-2871 or by email to Michael.Marshall@nrc.gov Sincerely,
/RA/
Michael L. Marshall, Jr., Senior Project Manager Plant Licensing Branch 1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-354
Enclosures:
- 1. Audit Plan
- 2. Audit Requests List cc: Listserv REGULATORY AUDIT PLAN TO SUPPORT THE REVIEW OF LICENSE AMENDMENT REQUEST TO ADOPT RISK INFORMED COMPLETION TIMES PSEG NUCLEAR, LLC HOPE CREEK GENERATING STATION DOCKET NO. 50-354
1.0 BACKGROUND
By letter dated December 31, 2025 [Reference 1], PSEG Nuclear, LLC (the licensee) submitted a license amendment request (LAR) for Hope Creek Generating Station (Hope Creek). The proposed amendment would modify the Hope Creek Technical Specifications (TSs) to permit the use of Risk-Informed Completion Times (RICTs) in accordance with Technical Specifications Task Force (TSTF)-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b [Reference 2].
The staff from the U.S. Nuclear Regulatory Commissions(NRCs) Office of Nuclear Reactor Regulation(NRR) has initiated its review of the LAR in accordance with NRR Office Instruction LIC-101, License Amendment Review Procedures [Reference 3].
2.0 REGULATORY AUDIT BASES A regulatory audit is a planned license, or regulation-related activity that includes the examination and evaluation of the licensees non-docketed information that provides the technical basis for 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 into 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 LIC-111, Regulatory Audits [Reference 4].
The NRC staff will perform the audit to support its evaluation of whether the licensees request 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. The staffs review will be informed by Standard Review Plan Section 19.2, Review of Risk Information Used to Support Permanent Plant-Specific Changes to the Licensing Basis [Reference 5].
The audit will assist the NRC staff with understanding the licensees proposed program for implementing RICTs for certain TSs.
3.0 SCOPE The audit team will view the documentation and calculations that provide the technical support for the LAR. The scope of the NRC staffs audit will focus on the following subjects:
Understand how the licensees proposed program conforms to NRC-endorsed guidance in the Nuclear Energy Institute (NEI) report NEI 06-09, Revision 0-A, Risk-Informed Technical Specification Initiative 4b, Risk-Managed Technical Specification Guidelines [Reference 6].
Gain a better understanding of the detailed calculations, analyses, and bases underlying the LAR and confirm the 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 staffs evaluation of the technical acceptability of the probabilistic risk assessment (PRA) used for this application.
Identify any information needed to enable the 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 [Reference 7].
The NRC staff will audit the PRA methods that the licensee would use to determine the risk impact from which the revised completion times for TSTF-505 would be obtained. This will include the licensees assessment of internal events (including internal flooding) and fire as well as the treatment of uncertainties and evaluation of defense in depth. The NRC will also audit the licensees quantification of risk from significant external events, whether the licensee uses PRA or bounding methods. In addition, the audit team will discuss these topics with the licensees subject matter experts.
4.0 INFORMATION AND OTHER MATERIAL NECESSARY FOR THE REGULATORY AUDIT The NRC staff will request information and interviews throughout the audit period. The NRC staff will use an audit requests list to identify the information to be audited (e.g., methodology, process information, and calculations) and the subjects of requested interviews and meetings.
The NRC staff requests the licensee to have the information referenced in the audit request list available and accessible for the NRC staffs review via a web-based electronic portal within two weeks of the date of this audit plan. The NRC staff requests that any supplemental information requested be available and accessible for the NRC staffs review within 1 week of the date of the NRCs notification to the licensee of new requests. The NRC staff requests the licensee to notify the review team when an audit item is added to its electronic portal by sending an email to the NRC licensing project manager (or other arrangement agreed to by the NRC licensing project manager and the licensee).
The staff acknowledges and will observe appropriate handling and protection of proprietary information made available for the audit. Any information accessed through the licensees portal will not be held or retained in any way by NRC staff.
5.0 AUDIT TEAM The following table identifies the NRC audit team members, including contractors, and their respective focus areas:
Name E-mail Address Role Michael Marshall Michael.Marshall@nrc.gov Project Manager David McClain David.McClain@nrc.gov Audit Team Lead &
Reliability and Risk Analyst Jigar Patel Jigar.Patel@nrc.gov Reliability and Risk Analyst Naeem Iqbal Naeem.Iqbal@nrc.gov Fire Protection Engineer Jay Robinson Jay.Robinson@nrc.gov Fire Protection Engineer Daniel Silverstein Daniel.Silverstein@nrc.gov Reliability and Risk Analyst Sunwoo Park Sunwoo.Park @nrc.gov Reliability and Risk Analyst Khoi Nguyen Khoi.Nguyen@nrc.gov Electrical Engineer Liliana Ramadan Liliana.Ramadan@nrc.gov Electrical Engineer Jason English Jason.English@nrc.gov Electronics Engineer Ming Li Ming.Li@nrc.gov Electronics Engineer Rob Atienza Rob.Atienza@nrc.gov Reactor Systems Engineer Angelo Stubbs Angelo.Stubbs@nrc.gov Safety and Plant Systems Engineer Khadijah West Khadijah.West@nrc.gov Safety and Plant Systems Engineer 6.0 LOGISTICS The audit will be conducted using a secure, online electronic portal, established by the licensee to present supporting documentation and calculations and by meetings with the licensees subject matter experts via video or audio conference. The audit will begin within two weeks of the date of this audit plan.
The audit will take place between March 9, 2026 and May 8, 2026. The NRCs licensing project manager will inform the licensee of the entrance and exit meeting dates when they are established. The NRC project manager will coordinate with the licensee to set dates and times to discuss information needs and questions arising from the NRCs review of the audited items.
The NRC staff may change or add audit dates and times when deemed necessary. Audit meeting agenda and questions will be sent in advance of the audit meetings.
7.0 SPECIAL REQUESTS The following conditions associated with the online web-based electronic portal should be maintained while the NRC staff have access to the online portal:
The online electronic portal will be password-protected, and separate passwords will be assigned to each member of the audit team.
The online web-based electronic portal will be sufficiently secure to prevent the NRC staff and contractors from printing, saving, downloading, or collecting any information from the web portal.
Conditions of use of the online electronic portal will be displayed on the login screen and will require acknowledgment by each user.
The licensee should provide username and password information directly to the NRC staff and contractors on the audit team, listed above. The NRC project manager will provide the licensee the names and contact information of the NRC staff and contractors who are added to the audit team. All other communications should be coordinated with the NRC licensing project manager.
The NRCs project manager will inform the licensee via routine communications when the NRC staff no longer needs access to the electronic portal. No data accessed by the audit team members will be taken by the NRC staff.
8.0 DELIVERABLES The NRC staff will develop any RAIs, as needed, in accordance with NRR LIC-115 [Reference 7] and issue such RAIs separate from audit-related correspondence. The NRC staff will issue an audit summary within 90 days after the end of the audit.
9.0 REFERENCES
[1] Larson, Eric A., PSEG Nuclear, LLC, Hope Creek Generating Station - letter to U.S.
Nuclear Regulatory Commission, "License Amendment Request - Revise Technical Specifications to Adopt Risk Informed Completion Times TSTF-505-A, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b and TSTF-591-A, Revision 0, Revise the Risk Informed Completion Time (RICT) Program" December 31, 2025 (Agencywide Documents access and management system Accession No. ML25365A973).
[2] Technical Specifications Task Force (TSTF) - A Joint Owners Group Activity, "TSTF Comments on Draft Safety Evaluation for Traveler TSTF 505, Provide Risk-Informed Extended Completion Times, and Submittal of TSTF-505, Revision2," July 2, 2018 (Package, ML18183A493).
[3] U.S. Nuclear Regulatory Commission, Office of Nuclear Reactor Regulation, LIC-101, Revision 6, "License Amendment Review Procedures," July 31, 2020 (ML19248C539).
[4] U.S. Nuclear Regulatory Commission, Office of Nuclear Reactor Regulation, LIC-111, Revision 2, "Regulatory Audits," December 19, 2024 (ML24309A281).
[5] U.S. Nuclear Regulatory Commission, NUREG-0800 - Standard Review Plan:
Section 19.2, "Review of Risk Information Used to Support Permanent Plant-Specific Changes to the Licensing Basis: General Guidance," June 2007 (ML071700658).
[6] Nuclear Energy Institute (NEI), NEI 06-09, Revision 0-A, "Risk-Informed Technical Specifications Initiative 4b, Risk-Managed Technical Specifications (RMTS) Guidelines -
Industry Guidance Document," October 2012 (Package,ML122860402).
[7] U.S. Nuclear Regulatory Commmission, Office of Nuclear Reactor Regulation, LIC-115, Revision 1, "Licensing Processes," August 5, 2021 (ML21141A238).
Audit Requests List Item Audit Requests (Documents and Questions)
Branch Identifier
- 1.
Reports cited in Enclosure 2 of the license amendment request (LAR) to adopt Technical Specifications Task Force (TSTF) 505 from full-scope and focused-scope peer reviews, self-and gap assessments (including findings, observations, and dispositions), and closure reviews of facts and observations (F&Os).
APLA
- 2.
For the probabilistic risk assessments (PRAs) identified under Item #1 above, plant-specific documentation (e.g., uncertainty notebooks) related to:
- a. The review of the PRA model assumptions and sources of uncertainty (generic and plant-specific assumptions/uncertainties) for the TSTF-505 LAR.
APLA
- 3.
PRA notebooks for the modeling of diverse and flexible coping strategies (FLEX) equipment and FLEX human error probabilities credited in the PRAs.
APLA
- 4.
PRA notebooks for the modeling of digital control systems, including basis for the representative failure probabilities.
APLA
- 5.
If modeled, PRA notebooks associated with the modeling of open phase condition (OPC) in electrical switchyards and the open phase isolation system (OPIS).
APLA
- 6.
Documentation of how shared or cross-tied systems are modeled in the PRA.
APLA
- 7.
Fire PRA notebooks containing the results of the fire PRA, including risk importance measures.
APLA
- 8.
If not included in #7 above, fire PRA F&O closure reports.
APLB
- 9.
If not included in #7 above, ordered list of top fire scenarios (i.e., those contributing 1 percent or more of the calculated fire risk).
APLB
- 10.
If not included in #7 above, risk summary (i.e., core damage frequency (CDF) and large early release frequency (LERF)) for each fire area.
APLB
- 11.
If not included in #7 above, fire area to physical analysis unit (PAU) crosswalk APLB
- 12.
Seismic PRA notebooks containing the results of the individual plant examination for external events (IPEEE) seismic PRA APLC
- 13.
Documentation supporting example screening of high winds from risk-informed completion times (RICT).
APLC
- 14.
Documentation supporting the example risk-informed completion times (RICT) calculations presented in LAR Enclosure 1, Table E1-2.
APLA Audit Requests List Item Audit Requests (Documents and Questions)
Branch Identifier
- 15.
Documentation supporting the development of the real-time risk tool and benchmarking it against the PRA.
APLA
- 16.
PRA configuration control and update procedures, including when the PRA is updated (i.e., unscheduled and scheduled PRA updates).
APLA
- 17.
If available, final RICT program procedures (e.g., for risk management actions, PRA functionality determination, and recording limiting conditions for operation).
or If available, draft RICT program procedures if final procedures are not available.
APLA
- 18.
For all cases where manual initiation is the sole diverse instrumentation, provide justification that this diversity under the given event does not overly rely on programmatic methods by including:
a) A timeline from the accident analysis demonstrating that the operator has sufficient time to initiate the manual scram b) Confirmation that this operation is prescribed in the operators manuals.
EICB
- 19.
Provide a logic block diagram that illustrates the average power range monitor (APRM) System and its tripping logic.
EICB
- 20.
In Table 5-2, the sole diverse instrumentation for Reactor Vessel Water Level High is manual trip. Provide justification that this diverse approach under CRDA event does not overly rely on programmatic methods by including: a) A timeline from the accident analysis demonstrating that the operator has sufficient time to initiate the manual scram, and b)
Confirmation that this operation is prescribed in the operators manuals.
EICB
- 21.
In Table 5-5, the Diverse Instrumentation is labeled as N/A for Function 1.c/d/e/f/g, 2.c/d/e, and 3.c/d/e/f. Justify why no diverse instrumentations are needed, and the defense-in-depth is preserved, for events credited in Updated Final Safety Analysis Report during the extended completion time.
EICB
- 22.
Single line diagrams of alternating circuit and direct circuit electrical power distribution systems.
EEEB
- 23.
Load lists for safety-related loads per division/train.
EEEB
- 24.
Latest Hope Creek Technical Specifications Basis sections for the electrical power systems.
EEEB
- 25.
List of shared electrical structure, system, and components and cross-ties between divisions, subsystems, or trains (and associated manual actions).
For each manual action, if any, associated with electrical power systems, identify whether it is modeled in PRA.
APLA EEEB Audit Requests List Item Audit Requests (Documents and Questions)
Branch Identifier
- 26.
If available, plant procedures (or other documents) related to risk management actions (RMA) for the electrical power systems, including RMA associated with TS 3.8.7 and TS 3.8.9 conditions (the LAR only provides RMA examples for TS 3.8.1 and TS 3.8.4).
EEEB
ML26048A346 NRR-106 OFFICE NRR/DORL/LPL1/PM NRR/DORL/LPL1/LA NRR/DEX/EEEB/BC NAME MMarshall SLent WMorton DATE 2/18/2026 2/19/2026 2/26/2026 OFFICE NRR/DEX/EICB/BC (A)
NRR/DSS/STSB/BC NRR/DSS/SCPB/BC NAME SDarbali SMehta MValentin DATE 2/28/2026 2/20/2026 2/27/2026 OFFICE NRR/DRA/APLA/BC (A)
NRR/DRA/APLB/BC NRR/DRA/APLC/BC (A)
NAME MGonzalez EDavidson RPascarelli DATE 2/19/2026 2/19/2026 2/19/2026 OFFICE NRR/DORL/LPL1/BC (A)
NRR/DORL/LPL1/PM NAME UShoop MMarshall DATE 2/26/2026 3/2/2026