NUREG-1433, Regulatory Audit Report in Support of Review of the License Amendment Request Concerning Technical Specification Conversion to NUREG-1433, Revision 5
| ML25073A039 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 04/02/2025 |
| From: | Bryant J NRC/NRR/DORL/LPL1 |
| To: | Mcfeaters C Public Service Enterprise Group |
| Kim J | |
| References | |
| EPID L-2024-LLI-0000, NUREG-1433 | |
| Download: ML25073A039 (1) | |
Text
April 2, 2025 Charles V. McFeaters President and Chief Nuclear Officer PSEG Nuclear LLC - N09 P.O. Box 236 Hancocks Bridge, NJ 08038
SUBJECT:
HOPE CREEK GENERATING STATION - REGULATORY AUDIT REPORT IN SUPPORT OF REVIEW OF THE LICENSE AMENDMENT REQUEST CONCERNING TECHNICAL SPECIFICATION CONVERSION TO NUREG-1433, REVISION 5 (EPID L-2024-LLI-0000)
Dear Charles McFeaters:
By letter dated May 20, 2024 (Agencywide Documents and Access Management System (ADAMS) Accession No. ML24142A428), as supplemented by letter dated October 17, 2024 (ML24291A058), PSEG Nuclear (PSEG, the licensee) submitted a license amendment request (LAR) for Hope Creek Generating Station. The proposed LAR would revise the current technical specifications to reflect adoption of NUREG-1433, Standard Technical Specifications - General Electric BWR/4 Plants, Revision 5 (ML21272A357).
The U.S. Nuclear Regulatory Commission (NRC) staff conducted a virtual regulatory audit between January 11 and February 28, 2025, to examine PSEGs non-docketed information on the proposed LAR. This audit was conducted in accordance with the audit plan dated January 7, 2025 (ML24361A149). The purpose of this audit was to gain understanding, to verify information, or to identify information that will require docketing to support the basis of the licensing or regulatory decision.
The purpose of this letter is to provide the results of the regulatory audit. Documented in the enclosed report are the observations the NRC staff identified during the audit.
C. McFeaters If you have any questions, please contact me at (301) 415-0610 or by email at jack.minzerbryant@nrc.gov Sincerely,
/RA/
Jack Minzer Bryant, Project Manager Plant Licensing Branch II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-354
Enclosure:
Audit Report cc: Listserv
Enclosure REGULATORY AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION TO SUPPORT THE REVIEW OF THE LICENSE AMENDMENT REQUEST CONVERSION TO IMPROVED STANDARD TECHNICAL SPECIFICATIONS PSEG NUCLEAR LLC HOPE CREEK GENERATING STATION DOCKET NO. 50-354 EPID L-2024-LLI-0000 DATE: January 11 to February 28, 2025 LOCATION: Remote
1.0 BACKGROUND
By letter dated May 20, 2024 (Agencywide Documents and Access Management System (ADAMS) Accession No. ML24142A428) as supplemented by letter dated October 17, 2024 (ML24291A058), PSEG Nuclear LLC (PSEG, the licensee) submitted a license amendment request (LAR) for Hope Creek Generating Station (Hope Creek). The proposed LAR would revise the current technical specifications (TSs) to reflect adoption of NUREG-1433, Standard Technical Specifications - General Electric BWR/4 Plants, Revision 5 dated September 30, 2021 (ML21272A357).
The U.S. Nuclear Regulatory Commission (NRC) staff from the Office of Nuclear Reactor Regulation (NRR) initiated its review of the LAR and identified the need for a regulatory audit to examine PSEGs non-docketed information with the intent to gain understanding, to verify information, or to identify information that will require docketing to support the basis of the licensing or regulatory decision.
2.0 REGULATORY AUDIT BASES A regulatory audit is a planned license-or regulation-related activity that includes the examination and evaluation of primarily non-docketed information associated with the LAR. The purpose of this audit was to gain understanding, to verify information, or to identify information that will require docketing to support the basis of the licensing or regulatory decision. This audit was conducted in accordance with NRR Office Instruction LIC-111, Regulatory Audits, Revision 2, dated December 2024 (ML24309A281), with exceptions noted within the audit plan dated January 7, 2025 (ML24361A149). The NRC staff performed this audit to support its evaluation of whether the PSEG LAR 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 results of this audit are being used to enhance the NRC staffs understanding of the licensees proposed LAR.
3.0 REGULATORY AUDIT SCOPE AND METHODOLOGY NRCs objectives of the audit were the following:
Gain a better understanding of the detailed calculations, analyses, and bases underlying the LAR and confirm the NRC 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 NRC staffs evaluation of the technical basis used for this application.
Identify any information needed to enable the NRC 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, Revision 1, dated August 5, 2021 (ML21141A238).
The NRC staff audited the technical information and methods that the licensee used to determine the impact on the plant, and the licensees evaluation of defense-in-depth.
The audit gave the NRC staff the opportunity to:
Review and understand the licensees implementation of the footnotes that have been proposed for addition into Improved Technical Specifications (ITS) 3.3.1.1, Reactor Protection System (RPS) Instrumentation, ITS 3.3.2.1, Control Rod Block Instrumentation, ITS 3.3.4.1, End Of Cycle Recirculation Pump Trip (EOC-RPT)
System Instrumentation, ITS 3.3.5.1, Emergency Core Cooling System (ECCS)
Instrumentation, ITS 3.3.5.3, Reactor Core Isolation Cooling (RCIC) System Instrumentation, and to verify that limiting safety system settings (LSSS)-related instrument channels are functioning as required before returning the channel to service following a required surveillance. In particular, the staff reviewed how the instructions in the proposed ITS footnotes and the performance test acceptance criteria applied during surveillances are consistent with the plant setpoint methodology.
Understand the methodology for determining the acceptance criteria for as-found/as-left measurements and other surveillance-related criteria discussed in the plant setpoint methodology and applied in the surveillance procedures. The NRC staff reviewed the setpoint methodology in its licensing and/or design basis, to clarify the terminology inconsistencies between the licensee-controlled document HC.DE-TS.ZZ-1001, Instrument Setpoint Calculations for Hope Creek Generating Station, Revision 0, March 3, 2006, and the proposed footnotes in this ITS LAR.
Walk through examples of how LSSS are established, and how they relate to its setpoint methodology. In addition, the staff reviewed how performance test acceptance criteria used in required surveillances are determined.
4.0 REGULATORY AUDIT ACTIVITES Audit Call, February 4, 2025 The NRC staff discussed the following topics during the February 4 teleconference:
Audit questions 1 through 7 as described in audit plan dated January 7, 2025 (ML24361A149).
The technical basis as to why the Intermediate Range Monitor Neutron FluxHigh Function is not categorized as one of the LSSS functions as the standard technical specifications suggests.
Walked through calibration processes and channel testing procedures.
The definitions and use of various terms such as: recalibration tolerance, calibration tolerance, As-Found Tolerance, As-Left Tolerance, Allowable Value, Limiting Trip Setpoint, and Nominal Trip Setpoint, in various licensee documents.
Audit Call, February 5, 2025 The NRC staff discussed the following topics during the February 5 teleconference:
Continued discussion regarding audit questions 1 through 7 as described in audit plan.
Walked through additional examples of channel calibration procedures and the corresponding setpoint calculation.
As a result of the audit discussions on February 4 and 5, the NRC staff generated requests for additional information (RAIs) KNW001 through KNW005 (which capture audit questions 2, 3, 4, 6, and 7) in the Hope Creek ITS RAI [request for additional information] portal for the licensee to place on the docket.
February 7, 2025 The NRC staff asked two additional audit questions: (1) The Special Analysis in Appendix 15B of the UFSAR states: Consequently, credit is taken for either the IRM or APRM 15 percent power scram in meeting the consequences of this event [referring to a continuous control rod withdrawal casualty in the startup range]. The transients for this response were initiated at 1 percent of power and were performed using the APRM 15 percent power scram. - The CTS list the APRM trip setpoint for Neutron Flux-Upscale (Setdown) at 17 percent. We would like to discuss the discrepancy, and (2)
Both the CTS and proposed ITS bases state No specific safety analyses take credit for the Average Power Range Monitor Neutron Flux - High (or Upscale), Setdown Function.
As stated in item 1, the UFSAR appears to contradict this statement.
As a result of the two additional audit questions above, the NRC staff generated RAI-KNW006, which is associated with AQ-1, and placed it in the Hope Creek ITS RAI portal for the licensee to place on the docket.
February 28, 2025 The NRC staff closed the audit with the licensee. There were no open items from the audit discussions and no deviations from the audit plan. The audit questions were converted to RAIs (except for AQ-5) and placed in the Hope Creek ITS RAI portal under KNW001 through KNW006.
5.0 TEAM ASSIGNMENTS The audit was conducted by NRC staff from the NRR, Division of Engineering and External Hazards Branch (DEX), and Instrumentation and Controls Branch (EICB) who are knowledgeable in instrument setpoint calculations and calibrations, and associated surveillance procedures. The audit was led by staff from the NRR, Division of Operating Reactor Licensing (DORL). Additionally, staff from the Technical Specifications Branch (STSB) within the Division of Safety Systems (DSS) participated in the audit.
The following were members of the NRC audit team:
Team Member Title Organization Jack Minzer Bryant Jack.minzerbryant@nrc.gov Project Manager NRR/DORL/LPLII-1 Richard Guzman Richard.guzman@nrc.gov Senior Project Manager NRR/DORL/LPLI Ming Li Ming.li@nrc.gov Electronics Engineer NRR/DEX/EICB Fredrick OBrien Fredrick.obrien@nrc.gov Electronics Engineer NRR/DEX/EICB Andrea Russell Andrea.russell@nrc.gov Safety and Plant Systems Engineer NRR/DSS/STSB Khadijah West Khadijah.west@nrc.gov Safety and Plant Systems Engineer NRR/DSS/STSB Tarico Sweat Tarico.sweat@nrc.gov Reactor System Engineer NRR/DSS/STSB
Package: ML25073A043 Audit Plan: ML24361A149 Audit Summary: ML25073A039 OFFICE NRR/DORL/LPL2-1/PM NRR/DORL/LPL1/LA NRR/DEX/EICB/BC NRR/DSS/STSB/BC NAME JMinzerBryant KEntz FSacko SMehta DATE 03/14/2024 3/17/2025 03/24/2025 03/24/2025 OFFICE NRR/DORL/LPL1/BC NRR/DORL/LPL2-1/PM NAME HGonzález JMinzerBryant DATE 04/02/2025 04/02/2025