LR-N24-0044, Relief Request VR-04
| ML24219A115 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 08/06/2024 |
| From: | Jurek S PSEG Power |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| LR-N24-0044 | |
| Download: ML24219A115 (1) | |
Text
Shane Jurek Regulatory Programs Manager - Licensing PO Box 236 o PSEG I NUCLEAR Hancocks Bridge, New Jersey 08038-0221 Shane.Jurek@pseg.com
10 CFR 50.55a LR-N2 4-0 044 August 6, 2024
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:
Hope Creek Relief Request VR-04
In accordance with 10 CFR 50.55a, PSEG Nuclear LLC (PSEG) requests NRC approval of attached Relief Request VR-04 for the fourth 120-month Inservice Testing (IST) interval at Hope Creek Generating Station (Hope Creek). The request is for a one-time deferral of a requirement of the ASME OM-2012 Code, Mandatory Appendix 1, I-1360 for periodic replacement of Class 3 non-reclosing pressure relief devices. Per the requirement, a Station Service Water (SSW)
Rupture Disc is required to be replaced every five years, with an additional six months of grace available. This puts the required replacement date for the Hope Creek A SSW Rupture Disc in May of 2025, during the operating cycle when the plant is expected to remain online.
Per the attached request, PSEG proposes an alternative wherein the interval for replacing this rupture disk would be extended by approximately six months to the next Hope Creek refueling outage. Details regarding justification of this extension are attached.
PSEG requests approval of the proposed request by April 30, 2025, based on the required due date for the A SSW Rupture Disc replacement.
There are no regulatory commitments contained in this letter. If you have any questions or require additional information, please contact Bernadette Cizin at Bernadette.Cizin@pseg.com.
Respectfully,
Shane Jurek Regulatory Programs Manager - Licensing PSEG Nuclear LLC
Attachments: - Relief Request VR-04 - Hope Creek Station Service Water Drawing August 6, 2024 10 CFR 50.55a LR-N24-0044 Page 2
cc: Administrator, Region I, NRC Project Manager, NRC NRC Senior Resident Inspector, Hope Creek Manager, NJBNE PSEG Commitment Tracking Coordinator LR-N24-0044 10 CFR 50.55a
Attachment 1
Relief Request VR-04 LR-N24-0044 10 CFR 50.55a
Hope Creek Unit 1 Inservice Test Program 10 CFR 50.55a Request VR-04
Proposed Alternative in Accordance with 10 CFR 50.55a(z)(2)
Hardship or Unusual Difficulty without Compensating Increase in Level of Quality or Safety
1.ASME Code Component(s) Affected
Component:
H1EA-1EAPSE-2210A - Safety Relief at Low Pressure A Exit
H1EA-1EAPSE-2210A (hereafter referred to as the A Station Service Water (SSW) Rupture Disc) is an American Society of Mechanical Engineers (ASME) Code Class 3 20 - 150#
American National Standards Institute (ANSI) Assembly. It is considered an ISTC-1300 Valve Category D that actuates by an energy source capable of only one operation. Per Mandatory Appendix I-1360 it is a Class 3 Non-reclosing Pressure Relief Device.
The A SSW Rupture Disc is the primary means of providing overpressure protection of SSW loop A piping and equipment in the event of a sudden blockage of the non-seismic Category I discharge line to the cooling tower.
2. Applicable Code Edition and Addenda
The Hope Creek Inservice Testing (IST) Program for Pumps and Valves was developed in accordance with the requirements of ASME Operations and Maintenance (OM) Code-2012, (Subsections ISTA, ISTB, ISTC, Mandatory Appendix I, Mandatory Appendix II, Mandatory Appendix III, and Mandatory Appendix V). Subsection ISTE, "Risk Informed Inservice Testing of Components in Light-Water Reactor Nuclear Plants" and Subsection ISTF, "Inservice Testing of Pumps in Light-Water Reactor Nuclear Plants - Post 2000 Plants" of OM Code 2012 are not applicable to Hope Creek.
The fourth 120-month IST interval at Hope Creek began on December 21, 2017, and is currently scheduled to end December 20, 2026.
3.Applicable Code Requirement
ASME OM-2012, Operation and Maintenance of Nuclear Power Plants, establishes the requirements for preservice and inservice testing and examination of certain components to assess their operational readiness in light-water nuclear power plants. For Category D valves such as the A SSW Rupture Disc, Section ISTC-5250, Rupture Disks, states: Rupture Disks shall meet the requirements for non-reclosing pressure relief devices of Mandatory Appendix I of this Division.
Per Mandatory Appendix I-1360:
Class 2 and 3 non-reclosing pressure relief devices shall be replaced every 5 yr, unless historical data indicates a requirement for more frequent replacement.
1 LR-N24-0044 10 CFR 50.55a
Additionally, ASME OM 2012 Code Case OMN-20 states:
(a) Components whose test frequencies are based on elapsed time periods shall be tested at the frequencies specified in Section IST with a specified time period between tests as shown in Table 1. The specified time period between tests may be reduced or extended as follows:
(1) For periods specified as fewer than 2 yr, the period may be extended by up to 25% for any given test.
(2) For periods specified as greater than or equal to 2 yr, the period may be extended by up to 6 mo for any given tests.
(3) All periods specified may be reduced at the discretion of the owner (i.e., there is no minimum period requirement).
4.Reason for Request
During the most recent Hope Creek refueling outage, H1R25, a scheduling error was identified related to replacement intervals for the A and B SSW Rupture Disc assemblies resulting in an emergent need to replace both assemblies during the refuel outage. The B SSW Rupture Disc assembly was replaced, as it had a longer installed service life than the A disc. However, PSEG was unable to procure a replacement rupture disc assembly for the A SSW train and attempts to refurbish and recertify a previously used assembly were unsuccessful. Installation activities for the current A SSW Rupture Disc assembly were completed on November 11, 2019; therefore, the A SSW Rupture Disc requires replacement by May 11, 2025 (five years plus the additional six months allowed per Code Case OMN-20). The next planned refueling outage, H1R26, is not scheduled until fall 2025, approximately six months after the ASME Code-required replacement date.
Hope Creek Technical Specification (TS) 3.7.1, Service Water Systems, Limiting Condition for Operation (LCO) 3.7.1.2 requires that the SSW System loops are both operable in Operational Conditions 1, 2, and 3. Due to the piping configuration at Hope Creek, replacement of the A SSW Rupture Disc assembly involves a breach of the secondary containment boundary. TS 3.6.5, Secondary Containment, LCO 3.6.5.1 requires, for breaches of secondary containment in Operational Conditions 1, 2, and 3, that secondary containment be restored to an operable status within four hours or the unit must be shut down.
Based on historical schedules, it requires approximately 86 hours9.953704e-4 days <br />0.0239 hours <br />1.421958e-4 weeks <br />3.2723e-5 months <br /> to replace the A SSW Rupture Disc, including pre- and post-maintenance activities. A minimum of 28 hours3.240741e-4 days <br />0.00778 hours <br />4.62963e-5 weeks <br />1.0654e-5 months <br /> of this work is required to be performed while secondary containment is inoperable. Therefore, the replacement evolution for the A SSW Rupture Disc requires the unit to be in Operational Condition 4 or 5.
In order to preclude an otherwise unnecessary mid-cycle shutdown to replace the A SSW Rupture Disc, PSEG requests a one-time extension to the ASME Code-required replacement interval.
2 LR-N24-0044 10 CFR 50.55a
5.Proposed Alternative and Basis for Use
The proposed alternative is a one-time extension of the current replacement interval such that its end date would be extended from May 11, 2025 to the end of the H1R26 refueling outage scheduled for fall 2025.
The purpose of the A SSW Rupture Disc is to provide for emergency discharge of SSW into the plant yard following a sudden blockage of the non-seismic discharge piping to the cooling tower.
Emergency Discharge Valve (EDV) EA-HV-2356A (hereafter referred to as the EDV) is situated in parallel with the A SSW Rupture Disc and normally provides an SSW discharge path for a slow blockage of the non-seismic discharge piping (see Attachment 2). Under normal circumstances, actuation of the EDV is not fast enough to protect the SSW discharge piping from a sudden blockage. Plant procedures and TS 3.7.1.3 direct operators to preemptively open the EDV under specific circumstances, such as elevated river temperatures, to preserve the ability to discharge SSW into the plant yard following a sudden blockage and maintain the SSW system fully operable. The piping downstream of the EDV is sufficiently sized to accommodate the necessary flow rates in the event of blockage of the non-seismic piping in the SSW System.
To mitigate the potential consequences of having the A SSW Rupture Disc installed longer than allowed by the ASME Code, PSEG will preemptively open this normally closed EDV, and maintain it open throughout the duration of the extended replacement interval to ensure the availability of this discharge path.
In summary, PSEG will implement a compensatory measure to maintain the SSW System at a fully operable status by bypassing the A SSW Rupture Disc in the discharge lineup via opening of its parallel EDV. This compensatory measure is already used by PSEG to mitigate other degradations of the SSW System, including elevated river temperatures. The current A SSW Rupture Disc would remain installed until replacement during the fall 2025 refueling outage and provide an additional discharge path for SSW to the plant yard in the event it does burst, thereby providing further discharge capability. Thus, PSEG concludes that the ASME Code replacement of the A SSW Rupture Disc per its required schedule does not materially increase the level of safety or quality of Hope Creek commensurate with the hardship associated with performing a mid-cycle shutdown in support of disc replacement.
6.Duration of Proposed Alternative
As a result of the proposed alternative, the A SSW Rupture Disc will exceed its specified replacement interval by approximately six months. Replacement will take place no later than the fall H1R26 refueling outage. PSEG anticipates no additional challenges associated with acquisition of the required components and anticipates receipt well in advance of the refueling outage. The disc replacement will also be added to the forced outage worklist for performance if a forced outage of sufficient duration and scope occurs after completion of procurement activities but prior to the planned refueling outage.
7.Precedents
Hatch Nuclear Plant Units 1 and 2, Docket Nos, 50-321 and 50-366, had a rupture disc replacement interval extension approved for the Third, Fourth, and Fifth 10-year Inservice Testing intervals for both units [ML20212A664, ML051940481, ML15124A904]. Relief was
3 LR-N24-0044 10 CFR 50.55a
approved to replace four HPCI system rupture discs every 6 years (3rd refuel) versus every 5 years per ASME OM Code Mandatory Appendix 1.
Callaway Plant Unit 1, Docket 50-483 also had a somewhat similar Relief Request, VR-01
[ML12090A501], that was approved by the NRC [ML12258A045]. Callaway was pursuing a one-time,12-month extension of the replacement interval for four rupture discs associated with the actuators for the main steam isolation valves.
4 LR-N24-0044 10 CFR 50.55a
Attachment 2
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