NUREG-1433, Draft Audit Questions Technical Specification Conversion to NUREG-1433, Revision 5
| ML24358A100 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 12/16/2024 |
| From: | Richard Guzman NRC/NRR/DORL/LPL1 |
| To: | Bernard Thomas Public Service Enterprise Group |
| References | |
| EPID L-2024-LLI-0000 | |
| Download: ML24358A100 (1) | |
Text
{{#Wiki_filter:From: Richard Guzman To: Thomas, Brian J. Cc: Jurek, Shane; Jack Minzer Bryant
Subject:
DRAFT Audit Questions for Regulatory Audit re: Hope Creek Improved Standard Technical Specifications Conversion Date: Monday, December 16, 2024 5:07:51 PM
- Brian, Please see below draft Audit Questions for the proposed regulatory audit. We can discuss the proposed schedule/timeline for the audit on our call tomorrow.
- Thanks, Rich Guzman Sr. PM, Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Office: O-10H17 l Phone: (301) 415-1030 Richard.Guzman@nrc.gov
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REGULATORY AUDIT QUESTIONS 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 Introduction 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 (ML21272A357). The NRC staff has 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.
Regulatory Requirements and Guidance The requirements for plant TSs are stated in 10 CFR 50.36, Technical Specifications: Section 50.36(a) states: Each applicant for a license authorizing operation of a production or utilization facility shall include in his application proposed technical specifications in accordance with the requirements of this section. Section 50.36(c)(1)(i)(A) states: Safety limits for nuclear reactors are limits upon important process variables that are found to be necessary to reasonably protect the integrity of certain of the physical barriers that guard against the uncontrolled release of radioactivity. Section 50.36(c)(1)(ii)(A) states: Limiting safety system settings for nuclear reactors are settings for automatic protective devices related to those variables having significant safety functions. Where a limiting safety system setting is specified for a variable on which a safety limit has been placed, the setting must be so chosen that automatic protective action will correct the abnormal situation before a safety limit is exceeded. If, during operation, it is determined that the automatic safety system does not function as required, the licensee shall take appropriate action, which may include shutting down the reactor. Section 50.36(c)(3) states: Surveillance requirements are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met. Regulatory Guide (RG) 1.105, Revision 3, Setpoints for Safety-Related Instrumentation, describes a method acceptable to the NRC staff for complying with the NRCs regulations for ensuring that setpoints for safety-related instrumentation are initially within and remain within the TS limits. RIS 2006-17 discusses issues that could occur during testing of LSSSs and which, therefore, may have an adverse effect on equipment operability. This RIS also presents an approach, found acceptable to the NRC staff, for addressing these issues for use in licensing actions that require prior NRC staff approval. TSTF-493, Revision 4, addresses NRC concerns that the Technical Specification (TS) requirements for Limiting Safety System Settings (LSSS) may not be fully in compliance with the intent of 10 CFR 50.36. Specifically, the NRC is concerned that the existing Surveillance Requirements (SRs) do not provide adequate assurance that instruments will always actuate safety functions at the point assumed in the applicable safety analysis. Audit Questions
AQ-1 The licensee proposed to not adopt the footnotes (a) and (b) from ITS/LCO table 3.3.1.1-1 Function Unit 1.a, (Reactor Protection System Instrumentation, Intermediate Range Monitors, Neutron Flux - High.) In Attachment 2 of the LAR, the licensee stated in ITS 3.3.1.1 Justification for Deviation #4 that:
- 1. HCGS will control the as-left and as-found tolerances for the Intermediate Range Monitors Neutron Flux - High Function in station procedures,
- 2. the Rod Worth Minimizer provides protection against unacceptable neutron flux excursions during reactor startup, and
- 3. NRC staff has a position that if a licensee did not propose to add the TSTF-493 footnotes in a license amendment request (LAR) to revise Allowable Values, their practice is to not request that they be added as long as control of as-left and as-found tolerances is being addressed in plant procedures. The licensee concluded that specifying footnotes for the IRM Neutron Flux - High is not necessary.
As for the argument #1 and #3, the TSTF-19-07 Elimination of the Requirement to Adopt TSTF-493, "Clarify Application of Setpoint Methodology for LSSS Functions," suggests a license commitment such as The practices described in the notes of TSTF-493 Option A, will be retained in [Licensees] surveillance procedures, to align with the NRC staff position. Please provide the technical basis as to why the Intermediate Range Monitors Neutron FluxHigh Function needs to be treated differently from the other functions in the table. Please confirm if the licensee plans to insert such kind of commitment (i.e., controlled within surveillance procedures) to its proposed ITS. As for #2, the TSTF-493 footnotes or similar administrative controls are required for the LSSS safety functions. TSTF-493, Revision 4, suggests a comprehensive list of LSSS safety functions, which includes the IRM trip function. The determination of the LSSS function is not based on whether that function has diversity. Therefore, the RWM provides the same protection as the IRM trip does not de-categorize the IRM trip from the LSSS functions. Please clarify the assertion that IRM trip is not one of the LSSS functions as STS Revision 5 suggested. AQ-2 Describe the current process or provide the procedure of evaluating both operability and functioning as required for I&C functions during the routine surveillance as described in the TSTF-493 Option A footnotes. Provide these documents in the audit portal. AQ-3 The licensee states in the LAR Attachment 2 that The terms recalibration tolerance and calibration tolerance are equivalent, respectively, to the terms AFT and ALT specified in NUREG-1433, and then demonstrates example applications of the HCGS setpoint methodology. Confirm what terms the plant engineers use during the surveillance as described by the TSTF-493 footnotes. If the plant TS and surveillance procedures use
different sets of terms, clarify what management measures are in place to address this inconsistency and potential confusion that plant engineers might have. AQ-4 HC.DE-TS.ZZ-1001, Instrument Setpoint Calculations for Hope Creek Generating Station, Revision 0, March 3, 2006, defines LSSS as Reactor trip/protection system instrumentation setpoints included in station technical specifications. Per 10 CFR 50.36(c) (1), TS shall include LSSS. As such the licensee is not allowed to remove LSSS setpoint out of its TS. Please justify the regulatory basis of proposal of the setpoint removal from the ITS. AQ-5 Provide the list of technical documents in the portal that includes definitions and the calculation details for ALT, AFT, AV, LTSP/NTSP. AQ-6 The licensee proposed to change in ITS Section 3.3 the term Limiting Trip Setpoint (LTSP) to Nominal Trip Setpoint (NTSP). These two terms are defined differently in RIS 2006-17. Please clarify the definition of NTSP and its location in the plant licensing basis. AQ-7 In attachment 2 to the LAR, ITS table 3.3.1.1-1, the licensee proposed to add calibration surveillance requirement footnotes (similar to TSTF-493, Revision 4, Option A) to Function 3 (Reactor Vessel Steam Dome Pressure - High), Function 4 (Reactor Vessel Steam Dome Pressure - Low), Function 6 (Drywell Pressure - High), and Function 9 (Turbine Control Valve Fast Closure, Trip Oil Pressure - Low). The footnotes are not applied to these functions in the Hope Creek current TS. Also, in proposed ITS 3.3.4.1, End of Cycle Recirculation Pump Trip (EOC-RPT) Instrumentation, Surveillance Requirement 3.3.4.1.2 (Channel Calibration) contains similar notes that are not in CTS. Please provide Discussion of Changes for these proposed changes in ITS 3.3.1.1 and 3.3.4.1.
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