ML15071A139
| ML15071A139 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 03/11/2015 |
| From: | Davison P Public Service Enterprise Group |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| EA-12-049, LR-N 15-0055 | |
| Download: ML15071A139 (8) | |
Text
PSEG Nuclear LLC P.O. Box 236, Hancocks Bridge, NJ 08038-0236 MAR 11 2015 Order EA-12-049 LR-N15-0055 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Hope Creek Generating Station Renewed Facility Operating License No. NPF-57 NRC Docket No. 50-354
Subject:
PSEG Nuclear LLC's Request for Relaxation from Schedule Requirements of NRC Order EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events " - Hope Creek Generating Station
References:
- 1. NRC Order EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Effective Immediately)," dated March 12, 2012
- 2. PSEG Letter LR-N13-0031, "PSEG Nuclear LLC's Overall Integrated Plan for the Hope Creek Generating Station in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)," dated February 27, 2013
- 3. PSEG Letter LR-N14-0093, "PSEG Nuclear LLC's Request for Relaxation from NRC Order EA-12-049, 'Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events' - Hope Creek Generating Station," dated April 16, 2014
MAR 11 2015 Order EA-12-049 Page 2 LR-N15-0055
- 4. NRC Letter to PSEG, "Hope Creek Generating Station - Relaxation of the Schedule Requirements for Order EA-12-049 'Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events,"' dated May 20,2014
- 5. NRC Order EA-13-109, "Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Effective Immediately)," dated June 6, 2013 On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued Order EA-12-049 (Reference 1) to PSEG Nuclear LLC (PSEG). NRC Order EA-12-049 requires the Hope Creek Generating Station (HCGS) to develop, implement, and maintain guidance and strategies to maintain or restore core cooling, containment,and spent fuel pool cooling capabilities in the event of a beyond-design-basis external event.
The HCGS Overall Integrated Plan for the diverse and flexible (FLEX) strategies to comply with NRC Order EA-12-049 was provided in Reference 2.
The original schedule for HCGS compliance with NRC Order EA-12-049 is prior to startup from the spring 2015 refueling outage. In response to PSEG's request in Reference 3, the NRC granted schedule relaxation (Reference 4) in order to enable PSEG to integrate full compliance with NRC Order EA-12-049 with completion of the design and installation of the severe accident capable torus vent required by NRC Order EA-13-109 (Reference 5), prior to startup from the fall 2016 refueling outage. The basis for NRC approval of the schedule relaxation in Reference 4 included PSEG's expected completion of the activities required to implement the mitigation strategies required by NRC Order EA-12-049, other than those activities associated with the severe accident capable vent, prior to startup from the spring 2015 refueling outage. PSEG has subsequently encountered additional challenges to implementing the activities supporting HCGS mitigation strategies prior to startup from the spring 2015 refueling outage. PSEG therefore proposes to complete activities required for compliance with NRC Order EA-12-049, other than those activities associated with the severe accident capable vent, by December 18, 2015. Attachment 1 contains details of the request for schedule relaxation to address the proposed deferral of activities that are not directly associated with compliance with the severe accident capable torus vent requirements of NRC Order EA-13-109. The fall 2016 refueling outage milestone for full compliance with NRC Order EA-12-049 as approved in Reference 4 is not affected by this request.
In accordance with Section IV of NRC Order EA-12-049, PSEG requests the Director, Office of Nuclear Reactor Regulation to relax the schedule requirement for full implementation prescribed by Condition IV.A.2 of the Order for the reasons provided in Attachment 1 to this letter.
MAR 11 2015 Order EA-12-049 Page 3 LR-N15-0055 PSEG considers that the requested relaxation would constitute a change in the implementation schedule requirements of NRC Order EA-12-049 for HCGS. There are no regulatory commitments contained in this letter.
If you have any questions or require additional information, please do not hesitate to contact Mr. Brian Thomas at 856-339-2022.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on ------
3- \\- J..o \5 (Date)
Sincerely, J\.U Paul J. 8avison Site Vice President Hope Creek Generating Station : Hope Creek Generating Station Request for Relaxation from NRC Order EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events "
cc: Mr. William Dean, Director of Office of Nuclear Reactor Regulation Mr. Daniel Dorman, Administrator, Region I, NRC Ms. Carleen Sanders-Parker, Project Manager, NRC NRC Senior Resident Inspector, Hope Creek Mr. Patrick Mulligan, Manager IV, NJBNE Mr. Thomas MacEwen, Hope Creek Commitment Tracking Coordinator Mr. Lee Marabella, PSEG Commitment Coordinator - Corporate
LR-N15-0055 Attachment 1 Hope Creek Generating Station Request for Relaxation from NRC Order EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events"
LR-N15-0055 1 Order Requirement from Which Relaxation is Requested Condition IV.A.2 of NRC Order EA-12-049 (Reference 1) requires full implementation of the Order requirements by no later than two refueling cycles after submittal of the overall integrated plan required by Condition C.1.a, or December 31, 2016, whichever comes first.
2 Relaxation Request In accordance with Section IV of NRC Order EA-12-049, PSEG requests relaxation of the Order requirement for HCGS to complete full implementation by no later than two refueling cycles after submittal of the Overall Integrated Plan required by Condition C.1.a of the Order, or December 31, 2016, whichever comes first. As described in the HCGS Overall Integrated Plan for diverse and flexible (FLEX) strategies (Reference 2),
the original milestone for full compliance with NRC Order EA-12-049 is prior to startup from HCGS Refueling Outage 19 (H1R19) in spring 2015.
PSEG previously requested schedule relaxation for HCGS compliance with NRC Order EA-12-049 in Reference 3. The schedule relaxation was approved by NRC via Reference 4, specifically to enable the integration of FLEX implementation with related requirements for a severe accident capable torus vent in compliance with NRC Order EA-13-109 (Reference 5) prior to startup from the H1R20 refueling outage in fall 2016.
NRC approval of the schedule relaxation was based, in part, on the condition that HCGS FLEX activities unrelated to the severe accident capable torus vent would be implemented prior to startup from H1R19 in spring 2015.
The relaxation request proposed herein would allow deferral of FLEX implementation activities unrelated to the NRC Order EA-13-109 severe accident capable vent requirements until December 18, 2015. These activities include completion of plant modifications, testing and commissioning of FLEX equipment, approval and issuance of procedure changes, and training.
3 Justification for Relaxation Request HCGS FLEX strategies include consideration of applicable external hazards as defined in NEI 12-06 (Reference 6). Following the initial development of the HCGS FLEX Overall Integrated Plan, PSEG's further consideration of applicable external hazards and evaluation of the feasibility of possible FLEX equipment storage locations prompted PSEG to change the strategy for storage and deployment of FLEX equipment. Included among these changes is the storage of two FLEX diesel generators on the roof of the HCGS Unit 2 reactor building in lieu of locations closer to the plant grade elevation.
Page 1 of 4
LR-N15-0055 While storage on the reactor building roof provides protection against storm surge flood levels, this change resulted in the following challenges:
- 1. Placement of the FLEX diesel generators at a higher elevation affected the seismic design, necessitating iterative interactions with the equipment supplier to complete the structural design.
- 2. The relocation affected the design and layout of the motor control centers (MCCs) associated with the FLEX diesel generators. This impact includes the seismic design of the MCCs.
The completion schedule for HCGS FLEX implementation activities is also affected by ongoing evaluation of the structural adequacy of the HCGS Unit 2 reactor building to support temporary storage of FLEX equipment in the event of an impending hurricane.
During final, independent third party design reviews, PSEG identified an incorrect assumption regarding concrete strength in the cancelled HCGS Unit 2 reactor building, which requires further evaluation and possible re-design of the planned storage area.
In order to meet the requested schedule, PSEG is scheduling the plant modifications which require unit shutdown, including connections to HCGS mechanical systems, to be completed during the spring 2015 refueling outage. PSEG is continuing the completion of design and installation of plant modifications, and procurement and receipt of FLEX equipment. The critical path schedule activities are related to electrical modification work. In addition to changes in equipment storage locations, electrical modification challenges resulted from recent unsatisfactory results during circuit breaker acceptance testing, which resulted in the need for breaker adjustment or replacement of parts, and re-testing.
A significant amount of the remaining field work is capable of being performed during power operation using standard work control and risk management processes. Post modification activities required to support NRC Order EA-12-049 compliance include testing, procedure approval and issuance, strategy validation, and just-in-time gap training for station personnel. Completion of the remaining activities prior to startup from the spring 2015 refueling outage would significantly increase the outage duration absent the requested relaxation.
In view of the challenges summarized above, PSEG considers that completion of all FLEX implementation activities unrelated to the severe accident capable torus vent prior to startup from the spring 2015 refueling outage would constitute undue hardship.
Considering the existing plant capabilities and the extremely low likelihood of having a beyond-design-basis external event during the approximate seven-month period of the requested relaxation, there is no significant safety impact or significant increase in risk associated with this request. PSEG therefore requests schedule relaxation to allow completion of FLEX activities unrelated to the severe accident capable torus vent by December 18, 2015.
Page 2 of 4
LR-N15-0055 The overall schedule milestone for HCGS to fully comply with NRC Order EA-12-049 would remain prior to startup from the H1R20 refueling outage in fall 2016. The proposed date for full implementation of NRC Order EA-12-049 remains within the December 31, 2016 date in Order Condition IV.A.2. Based on current regulatory requirements and plant capabilities, a sequence of events similar to those encountered at the Fukushima Dai-ichi station is considered to be unlikely to occur in the United States. Therefore, the proposed schedule relaxation for full compliance with NRC Order EA-12-049 would avoid undue hardship without significantly affecting nuclear safety or resulting in any significant increase in risk.
4 Conclusion Full compliance with the mitigation strategy implementation schedule requirements of NRC Order EA-12-049 at HCGS would result in hardship or unusual difficulty without a compensating increase in the level of safety. Therefore, in accordance with Section IV of NRC Order EA-12-049, PSEG requests relaxation of the schedule requirement described in Condition IV.A.2 of NRC Order EA-12-049, to allow completion of activities that are needed to achieve compliance with NRC Order EA-12-049, and that are unrelated to the severe accident capable torus vent requirements of NRC Order EA-13-109, by December 18, 2015. The schedule milestone for full compliance with NRC Order EA-12-049 as approved by the schedule relaxation in Reference 4 would remain prior to restart from the H1R20 refueling outage in fall 2016.
5 References
- 1. NRC Order Number EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated March 12, 2012
- 2. PSEG Letter LR-N13-0031, "PSEG Nuclear LLC's Overall Integrated Plan for the Hope Creek Generating Station in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)," dated February 27, 2013
- 3. PSEG Letter LR-N14-0093, "PSEG Nuclear LLC's Request for Relaxation from NRC Order EA-12-049, 'Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events' - Hope Creek Generating Station," dated April 16, 2014
- 4. NRC Letter to PSEG, "Hope Creek Generating Station - Relaxation of the Schedule Requirements For Order EA-12-049 'Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond Design-Basis External Events,"' dated May 20, 2014 Page 3 of 4
LR-N15-0055
- 5. NRC Order EA-13-109, "Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Effective Immediately)," dated June 6, 2013