ML25072A013
| ML25072A013 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 04/02/2025 |
| From: | Hipolito Gonzalez NRC/NRR/DORL/LPL1 |
| To: | Mcfeaters C Public Service Enterprise Group |
| Lantigua R, NRR/DORL/LPL1 | |
| References | |
| EPID L-2024-LLR-0049 | |
| Download: ML25072A013 (1) | |
Text
April 2, 2025 HOPE CREEK STATION - AUTHORIZATION AND SAFETY EVALUATION FOR ALTERNATIVE REQUEST NO. VR-04 FOURTH INSERVICE TESTING INTERVAL PROGRAM (EPID L-2024-LLR-0049)
LICENSEE INFORMATION Recipients Name and Address:
Charles V. McFeaters President and Chief Nuclear Officer Shane.Jurek@pseg.com PSEG Nuclear LLC - N09 Hope Creek Generating Station P.O. Box 236 Hancocks Bridge, NJ 08038 Licensee:
Plant Name and Unit:
Hope Creek Generating Station (Hope Creek)
Docket No.
50-354 APPLICATION INFORMATION Submittal Date: August 6, 2024 Submittal Agencywide Documents Access and Management System (ADAMS) Accession No. ML24219A115 Applicable Inservice Testing (IST) Interval Program and Interval Start/End Dates:
The Fourth IST Interval Program at Hope Creek began on December 21, 2017, and is scheduled to end on December 20, 2026.
Applicable ASME OM Code Edition and Addenda:
The American Society of Mechanical Engineers (ASME) Operation and Maintenance of Nuclear Power Plants, Division 1, OM Code: Section IST (OM Code), 2012 Edition, as incorporated by reference in Title 10 of the Code of Federal Regulations (10 CFR) 50.55a, is the ASME OM Code of Record for the Fourth IST Interval Program at Hope Creek.
Applicable ASME OM Code Component:
H1EA-1EAPSE-2210A - Safety Relief at Low Pressure A Exit H1EA-1EAPSE-2210A (referred to as the A Station Service Water (SSW) Rupture Disc) is an ASME Boiler and Pressure Vessel Code Class 3 20 - 150# American National Standards Institute (ANSI) Assembly.
H1EA-1EAPSE-2210A actuates by an energy source capable of only one operation. 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.
10 CFR 50.55a Alternative Request:
The licensee (PSEG) submitted Alternative Request VR-04 for Hope Creek under 10 CFR, paragraph 50.55a(z)(2), on the basis that compliance with specific IST Program requirements in the ASME OM Code, as incorporated by reference in 10 CFR 50.55a, would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
Applicable IST Requirements:
The 2012 Edition of the ASME OM Code, as incorporated by reference in 10 CFR 50.55a, specifies the following:
ASME OM Code, Subsection ISTC, Inservice Testing of Valves in Water-Cooled Reactor Nuclear Power Plants, paragraph ISTC-5250, Rupture Disks, states:
Rupture Disks shall meet the requirements for nonreclosing pressure relief devices of Mandatory Appendix I of this Division.
ASME OM Code, Mandatory Appendix I, Inservice Testing of Pressure Relief Devices in Light-Water Reactor Nuclear Power Plants, paragraph I-1360, Test Frequency, Classes 2 and 3 Nonreclosing Pressure Relief Devices, states:
Classes 2 and 3 nonreclosing pressure relief devices shall be replaced every 5 years, unless historical data indicates a requirement for more frequent replacement.
ASME OM Code Case OMN-20, Inservice Test Frequency, paragraph 1, Test Frequency Grace, states in part:
(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 months for any given test.
(3) All periods specified may be reduced at the discretion of the owner (i.e., there is no minimum period requirement).
Period extension is to facilitate test scheduling and considers plant operating conditions that may not be suitable for performance of the required testing (e.g.,
performance of the test would cause an unacceptable increase in the plant risk profile due to transient conditions or other ongoing surveillance, test, or maintenance activities). Period extensions are not intended to be used repeatedly merely as an operational convenience to extend test intervals beyond those specified.
Proposed Duration of Alternative:
The licensee requested that this alternative for a one time 6-month extension of the ASME OM Code required replacement interval for the A SSW Rupture Disc be authorized until the Hope Creek fall 2025 refueling outage. The A SSW Rupture 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.
Brief Description of Proposed Alternative:
The proposed alternative is for a one-time extension of the ASME OM Code required replacement interval by 6 months for A SSW Rupture Disc. The replacement interval would be extended from May 11, 2025, to the end of the H1R26 refueling outage scheduled for fall 2025.
For additional details on the licensees request, please refer to the document located at the ADAMS Accession Number identified above.
NRC STAFF EVALUATION On August 6, 2024, the licensee submitted Alternative Request VR-04 proposing to defer the replacement of the A SSW Rupture Disc at Hope Creek. In its review of Alternative Request VR-04, the NRC staff evaluated (1) the licensees description of the Hope Creek A SSW Rupture Disc replacement to be deferred, (2) the hardship associated with and the reasons for a 6-month extension of the replacement interval, and (3) the compensating measure described in the alternative request.
In Alternative Request VR-04, the licensee stated that during the most recent refueling outage, H1R25, a scheduling error related to the replacement intervals for the A and B SSW Rupture Disc assemblies resulted in an emergent need to replace both assemblies during the refueling outage at Hope Creek. The licensee replaced the B SSW Rupture Disc assembly as it had a longer installed service life than the A SSW Rupture Disc assembly. However, the licensee 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 during the refueling outage.
The current A SSW Rupture Disc assembly was installed on November 11, 2019, at Hope Creek. Therefore, the A SSW Rupture Disc requires replacement by May 11, 2025, based on an interval of 5 years plus the additional 6 months allowed by ASME OM Code Case OMN-20.
The next planned refueling outage H1R26 at Hope Creek is not scheduled until fall 2025, approximately 6 months after the ASME OM Code required replacement date. The licensee specified that the A SSW Rupture Disc replacement will 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.
The licensee described the hardship associated with the request and reason to delay the A SSW Rupture Disc replacement by 6 months. 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.
The licensee stated that approximately 86 hours9.953704e-4 days <br />0.0239 hours <br />1.421958e-4 weeks <br />3.2723e-5 months <br /> including pre-and post-maintenance activities are required for the replacement of the A SSW Rupture Disc based on historical work schedules. The licensee indicated that 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 needs to be performed while the 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. Therefore, the licensee requested a one-time extension to the ASME OM Code-required replacement interval to preclude a mid-cycle shutdown to replace the A SSW Rupture Disc.
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. In Alternative Request VR-04, the licensee proposes a compensatory measure for the duration of the request. As shown in Attachment 2 of Alternative Request VR-04, Emergency Discharge Valve (EDV) EA-HV-2356A 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. 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 temperature, 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 a 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 OM Code, the licensee 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 for the SSW System. 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.
Based on its review, the NRC staff finds that the licensee has justified that a hardship exists without a compensating increase in the level of quality and safety to meet the ASME OM Code interval requirement for the replacement of the A SSW Rupture Disc in Hope Creek at this time. The staff also finds that the alternative request is supported by a compensatory measure that preemptively opens the normally closed EDV and maintains it open throughout the duration of the proposed extended replacement interval for the A SSW Rupture Disc to ensure the availability of this discharge path for SSW to discharge to the yard in the event of a blockage of the non-seismic piping in the SSW System. With the compensatory measure specified by the licensee, the staff finds that the licensees proposed alternative for a one-time deferral by 6 months compared to ASME Code requirement for the replacement of the A SSW Rupture Disc is acceptable. In addition, the licensee specified that replacement of the A SSW Rupture Disc will be added to the forced outage worklist if a forced outage of sufficient duration and scope occurs after completion of procurement activities but prior to the planned refueling outage. Therefore, the NRC staff finds that Alternative Request VR-04 meets the regulatory requirements in accordance with 10 CFR 50.55a(z)(2) for the requested extension of the replacement interval for the A SSW Rupture Disc at Hope Creek.
CONCLUSION Based on its review of Alternative Request VR-04, the NRC staff determined that the licensee provided adequate justification that a hardship exists without a compensating increase in the level of quality and safety to meet the ASME OM Code interval requirement for the replacement of the A SSW Rupture Disc in Hope Creek at this time. With the specified compensatory measure, the licensees proposed alternative for a one-time deferral by 6 months compared to ASME Code requirement for the replacement of the A SSW Rupture Disc provides an acceptable level of quality and safety. Therefore, the NRC staff concludes that Alternative Request VR-04 satisfies 10 CFR 50.55a(z)(2) and may be authorized until the fall 2025 refueling outage at Hope Creek, or until a forced outage of sufficient duration and scope to perform the replacement of A SSW Rupture Disc after procurement activities, whichever occurs first.
All other ASME OM Code requirements as incorporated by reference in 10 CFR 50.55a for which relief or an alternative was not specifically requested, and granted or authorized (as appropriate), in the subject request remain applicable.
Principal Contributors: Chakrapani Basavaraju, NRR/DEX/EMIB Thomas Scarbrough, NRR/DEX/EMIB Date: April 2, 2025 Hipólito González, Chief Plant Licensing Branch 1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation cc: Listserv HIPOLITO GONZALEZ Digitally signed by HIPOLITO GONZALEZ Date: 2025.04.02 10:06:22
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ML25072A013 NRR-028 OFFICE NRR/DORL/LPL1/PMiT NRR/DORL/LPL1/PM NRR/DORL/LPL1/LA NAME RLantigua MMarshall KEntz DATE 3/12/25 3/12/2025 3/14/2025 OFFICE NRR/DEX/EMIB/BC NRR/DORL/LPL1/BC NRR/DORL/LPL1/PM NAME SBailey HGonzález MMarshall DATE 2/26/25 4/2/2025 4/2/2025