ML17290B013

NRR E-mail Capture - Hope Creek Mur Request for Additional Information for Apla and Snpb

ML17290B013
Person / Time
Site:	Hope Creek
Issue date:	10/17/2017
From:	Lisa Regner Plant Licensing Branch IV
To:	Bernard Thomas Public Service Enterprise Group
References
EPID: L-2017-LLS-0002, MF9930
Download: ML17290B013 (5)

Text

NRR-PMDAPEm Resource From: Regner, Lisa Sent: Tuesday, October 17, 2017 11:39 AM To: Thomas, Brian J.

Cc: Paul.Duke@pseg.com

Subject:

Hope Creek MUR - Final Request for Additional Information (CAC: MF9930 EPID:

L-2017-LLS-0002)

Attachments: Final MUR RAI APLB SNPB.docx Final Request for Additional Information On September 22, 2017, the U.S. Nuclear Regulatory Commission (NRC) staff sent PSEG (the licensee) the draft Request for Additional Information (RAI) provided in the attached document. These RAI questions relates to a license amendment request (LAR) that proposes to increase the rated thermal power level from 3840 megawatts thermal to 3902 megawatts thermal, and make technical specification changes as necessary to support operation at the uprated power level. This is referred to as a measurement uncertainty recapture (MUR) uprate.

PSEG subsequently informed the NRC staff that questions APLA-1 and APLA-2 in the attached RAI were understood and an additional clarification was not necessary. Mr. Brian Thomas agreed to provide a response to this final RAI within 30 days from the date of this correspondence.

PSEG requested a clarification call for SNPB-1 and SNPB-2, which was held on October 10, 2017. At the conclusion of the call, the licensee stated it understood the questions. Mr. Brian Thomas agreed to provide a response to these final questions no later than December 8, 2017. Please note that if PSEG does not respond by this date, the requested completion date for the MUR decision may not be met by the NRC.

The NRC staff also informed the licensee that a publicly available version of this final RAI would be placed in the NRCs Agencywide Documents Access and Management System (ADAMS). Question No. SNPB-2 contains proprietary information that has been withheld.

By letter dated July 7, 2017, (ADAMS package Accession No. ML17188A259), the licensee requested an amendment to the Operating License for Hope Creek Generating Station. The proposed amendment requests a MUR uprate for Hope Creek. The NRC staff requires additional information to complete its review of this request as detailed in the attached document.

Lisa M. Regner Senior Project Manager Branch 4, Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Lisa.Regner@NRC.gov 301-415-1906 OWFN 9D14 1

Hearing Identifier: NRR_PMDA Email Number: 3775 Mail Envelope Properties (5fa6eae6fa9e4f8090b04b55f334fb4e)

Subject:

Hope Creek MUR - Final Request for Additional Information (CAC: MF9930 EPID: L-2017-LLS-0002)

Sent Date: 10/17/2017 11:39:11 AM Received Date: 10/17/2017 11:39:12 AM From: Regner, Lisa Created By: Lisa.Regner@nrc.gov Recipients:

"Paul.Duke@pseg.com" <Paul.Duke@pseg.com>

Tracking Status: None "Thomas, Brian J." <Brian.Thomas@pseg.com>

Tracking Status: None Post Office: HQPWMSMRS01.nrc.gov Files Size Date & Time MESSAGE 2161 10/17/2017 11:39:12 AM Final MUR RAI APLB SNPB.docx 33612 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

Recipients Received:

REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST FOR MEASUREMENT UNCERTAINTY RECAPTURE POWER UPRATE Hope Creek Generating Station Docket No. 50-354 CAC No. MF9930 APLB-1 The staff notes that Hope Creek Generating Station License Amendment Request, Enclosure 6, GE-Hitachi Nuclear Energy, Document NEDC-33871P, Revision 0, Safety Analysis Report for Hope Creek Generating Station, Thermal Power Optimization, April 2017, Section 6.7, Fire Protection, states that There is no change in the physical plant configuration and the potential for minor changes to combustible loading as result of TPO [thermal power optimization] Uprate are addressed by controlled design changes procedures Per Section 9.5.1.2, Administrative Controls, of NUREG-1048, the licensee should summarize any changes to the combustible loading, however minor, and discuss the impact of these changes on the plants compliance with the fire protection program licensing basis, Title 10 of the Code of Federal Regulations Part 50 (10 CFR 50.48), or applicable portions of 10 CFR 50, Appendix R. NUREG-1048, Safety Evaluation Report related to the operation of Hope Creek Generating Station, October 1984 and its Supplements 1 through 6 describe the approved fire protection program at Hope Creek Generating Station and explain how it complies with the requirements of 10 CFR 50.48, Fire protection, and the guidelines of Branch Technical Position (BTP) Chemical Engineering Branch (CMEB) 9.5-1 and Appendix A to BTP Auxiliary and Power Conversion Systems Branch (APCSB) 9.5-1. NUREG-1048 and its Supplement 1 through 6 are cited in the Hope Creek operating license condition 2.C.7.

APLB-2 Some nuclear power plants credit aspects of their fire protection system for other than fire protection activities for the increased power operating conditions and total decay heat. For example, utilizing the fire water pumps and water supply as backup cooling or inventory for non-primary reactor systems.

If the Hope Creek Generating Station credits its fire protection system in this way, the licensee should identify the specific situations and discuss to what extent, if any, the MUR power uprate affects these non-fire-protection aspects of the plant fire protection system. In your response discuss how any non-fire suppression use of fire protection water will impact the ability to meet the fire protection system design demands per NUREG-1048, Section 9.5.1.5, Fire Detection and Suppression. If the Hope Creek Generating Station does not take such credit, the licensee needs to verify this as its response to this question.

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The PROPRIETARY INFORMATION in Question SNPB-2 has been removed. The Proprietary information was enclosed within double-brackets. ((This sentence is an example of the proprietary portion marking)).

SNPB-1 Title 10 of the U.S. Code of Federal Regulations (10 CFR), part 50, appendix A, General Design Criteria for Nuclear Power Plants, criterion 10 (i.e., GDC 10) states, The reactor core and associated coolant, control, and protection systems shall be designed with appropriate margin to assure that specified acceptable fuel design limits are not exceeded during any condition of normal operation, including the effects of anticipated operational occurrences.

In order to provide assurance that 99.9 percent of the fuel rods in the core do not enter transition boiling in the event of an anticipated operational occurrence, the safety limit (SL) minimum critical power ratio (MCPR) is established as a specified acceptable fuel design limit. The SLMCPR is a limit placed on the critical power ratio (CPR). If a fuel rod has a CPR of 1.0, it would be predicted to enter transition boiling. The SLMCPR provides a margin to account for uncertainties associated with the correlation used to estimate the critical power ratio (CPR),

small variations in the pin- and bundle-radial power distribution in the core, and instrument monitoring.

The uncertainties associated with the methods used to estimate the effect of small variations in the radial power distribution in the core are sensitive to the void conditions in the fuel bundles. This sensitivity is evaluated for plants operating in high-bundle-power, high-exit-void-fraction conditions in General Electric - Hitachi (GEH) Licensing Topical Report (LTR) NEDC-33173P-A, Revision 4, Applicability of GE Methods to Expanded Operating Domains (ADAMS Package No. ML123130130). This report, which is approved for use by the NRC staff, is also known as the Interim Methods LTR (IMLTR).

Figures 2-1, 2-3, and 2-4 of the Thermal Power Optimization (TPO) Safety Analysis Report (TSAR) indicate that challenging void conditions may exist at HCNGS upon implementation of the measurement uncertainty recapture uprate (MUR) (ADAMS Accession Nos. ML17188A263 (publicly available) and ML17188A270 (proprietary)). First, HCNGS is predicted to have bundle power levels that are higher than the other plants shown in the experiential database. Second, the bundle exit void fractions are similarly high, approaching 90 percent.

• Justify the application of the nuclear and thermal-hydraulic design uncertainties in the GESTAR-II analytic process without the IMLTR penalties that are required of plants that operate in the high bundle power, high maximum channel exit void fraction conditions that appear to be associated with the HCNGS MUR. In particular, the plots shown indicate that HCNGS will be operating with bundle exit void conditions that would require the application of the penalty suggested by Limitation 5 as contained in the IMLTR. A comparison of the attributes, displayed in the figures listed above, to other plants operating with qualitatively similar characteristics (e.g., domestically licensed, Maximum Extended Load Line Limit Analysis, Extended Power Uprate, Thermal Power Optimization) would suffice for this purpose.

• Provide evidence that, in light of the significantly different operating conditions between extended power uprate implementation and MUR, the dispositions contained in the TPO LTR (TLTR, i.e., NEDC-32938P-A, Generic Guidelines and Evaluations for General Electric Boiling Water Reactor Thermal Power Optimization (ADAMS Package No.

ML17076A207)) relative to fuel design, operation, and thermal margin assessment, are applicable. Analytic results of two or several potentially limiting anticipated operational occurrences in the MUR operating conditions may provide such evidence.

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SNPB-2 GDC 10 requires that the reactor core be designed with appropriate margin to assure that specified acceptable fuel design limits (SAFDLs) are not exceeded during any condition of normal operation, including the effects of anticipated operational occurrences. GDC 12 requires that the reactor core be designed to assure that power oscillations, which can result in conditions exceeding SAFDLs, are not possible or can be reliably and readily detected and suppressed. 10 CFR 50.36 defines limiting system safety settings (LSSS) and requires their inclusion in facility Technical Specifications. At HCNGS, the LSSS that protect the core from conditions that would challenge conformance to GDC 10 and 12 are required to be operable above a threshold value for monitoring margin to the thermal limits that assure compliance with these GDC.

The thermal limits monitoring threshold is based on ((

.))

HCNGS provided an evaluation, in section 2.2 of the TSAR, demonstrating that ((

- )). Then, in Section 2.4.2 of the TSAR, the license states that HCNGS will maintain its thermal limits monitoring threshold at 24 percent for operational convenience, and based on a judgment of adequacy. This is inconsistent with the basis ((

- )) for the TLTR.

In light of not (( )), provide a detailed analysis or evaluation supporting a thermal limits monitoring threshold that exceeds the ((

- )) value.

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