ML051870281

License Amendment, Containment Purge Valve Leak Rate Test Frequency

ML051870281
Person / Time
Site:	Susquehanna
Issue date:	08/04/2005
From:	Richard Guzman NRC/NRR/DLPM/LPD1
To:	Mckinney B Susquehanna
Guzman R, NRR/DLPM 415-1030
References
TAC MC4427, TAC MC4428
Download: ML051870281 (16)

Text

August 4, 2005 Mr. Britt T. McKinney Sr. Vice President and Chief Nuclear Officer PPL Susquehanna, LLC 769 Salem Blvd., NUCSB3 Berwick, PA 18603-0467

SUBJECT:

SUSQUEHANNA STEAM ELECTRIC STATION, UNITS 1 AND 2 - ISSUANCE OF AMENDMENTS RE: CONTAINMENT PURGE VALVE LEAK RATE TEST FREQUENCY (TAC NOS. MC4427 AND MC4428)

Dear Mr. McKinney:

The Nuclear Regulatory Commission has issued the enclosed Amendment No. 223 to Facility Operating License No. NPF-14 and Amendment No. 200 to Facility Operating License No.

NPF-22 for the Susquehanna Steam Electric Station, Units 1 and 2 (SSES 1 and 2). These amendments are in response to your application dated September 8, 2004.

The amendments revise the SSES 1 and 2 Technical Specification (TS) Surveillance Requirement 3.6.1.3.6 of TS 3.6.1.3, Primary Containment Isolation Valves, to reduce the frequency of performing leakage rate testing for each primary containment purge valve with resilient seals from 184 days to 24 months.

A copy of our safety evaluation is also enclosed. The Notice of Issuance will be included in the Commission's Biweekly Federal Register Notice.

Sincerely,

/RA/

Richard V. Guzman, Project Manager, Section 1 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-387 and 50-388

Enclosures:

1. Amendment No. 223 to License No. NPF-14

2. Amendment No. 200 to License No. NPF-22

3. Safety Evaluation cc w/encls: See next page

August 4, 2005 Mr. Britt T. McKinney Sr. Vice President and Chief Nuclear Officer PPL Susquehanna, LLC 769 Salem Blvd., NUCSB3 Berwick, PA 18603-0467

SUBJECT:

SUSQUEHANNA STEAM ELECTRIC STATION, UNITS 1 AND 2 - ISSUANCE OF AMENDMENTS RE: CONTAINMENT PURGE VALVE LEAK RATE TEST FREQUENCY (TAC NOS. MC4427 AND MC4428)

Dear Mr. McKinney:

The Nuclear Regulatory Commission has issued the enclosed Amendment No. 223 to Facility Operating License No. NPF-14 and Amendment No. 200 to Facility Operating License No.

NPF-22 for the Susquehanna Steam Electric Station, Units 1 and 2 (SSES 1 and 2). These amendments are in response to your application dated September 8, 2004.

The amendments revise the SSES 1 and 2 Technical Specification (TS) Surveillance Requirement 3.6.1.3.6 of TS 3.6.1.3, Primary Containment Isolation Valves, to reduce the frequency of performing leakage rate testing for each primary containment purge valve with resilient seals from 184 days to 24 months.

A copy of our safety evaluation is also enclosed. The Notice of Issuance will be included in the Commission's Biweekly Federal Register Notice.

Sincerely,

/RA/

Richard V. Guzman, Project Manager, Section 1 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-387 and 50-388

Enclosures:

1. Amendment No. 223 to DISTRIBUTION:

License No. NPF-14 PUBLIC PDI-1 R/F RLaufer

2. Amendment No. 200 to RGuzman MOBrien OGC License No. NPF-22 ACRS GHill (4) TBoyce

3. Safety Evaluation JPulsipher RDennig DLPM DPR MShanbaky, RGN-I cc w/encls: See next page

• SE input provided by memo. No substantive changes made.

Accession No.: Package No.: TSs:

OFFICE PDI-1/PM PDI-2/LA SPSB/SC* OGC PDI-1/SC NAME RGuzman MO'Brien RDennig TSmith RLaufer DATE 7/29/05 7/29/05 6/3/05 SE DTD 8/2/05 8/2/05 OFFICIAL RECORD COPY

Susquehanna Steam Electric Station, Unit Nos. 1 and 2 cc:

Robert A. Saccone Steven M. Cook General Manager - Nuclear Operations Manager - Quality Assurance PPL Susquehanna, LLC PPL Susquehanna, LLC 769 Salem Blvd., NUCSB3 769 Salem Blvd., NUCSB2 Berwick, PA 18603-0467 Berwick, PA 18603-0467 Aloysius J. Wrape, III Luis A. Ramos General Manager - Performance Community Relations Manager, Improvement and Oversight Susquehanna PPL Susquehanna, LLC PPL Susquehanna, LLC Two North Ninth Street, GENPL4 634 Salem Blvd., SSO Allentown, PA 18101-1179 Berwick, PA 18603-0467 Terry L. Harpster Bryan A. Snapp, Esq General Manager - Plant Support Assoc. General Counsel PPL Susquehanna, LLC PPL Services Corporation 769 Salem Blvd., NUCSA4 Two North Ninth Street, GENTW3 Berwick, PA 18603-0467 Allentown, PA 18101-1179 Richard D. Pagodin Supervisor - Document Control Services General Manager - Nuclear PPL Susquehanna, LLC Engineering (Acting) Two North Ninth Street, GENPL4 PPL Susquehanna, LLC Allentown, PA 18101-1179 769 Salem Blvd., NUCSB3 Berwick, PA 18603-0467 Richard W. Osborne Allegheny Electric Cooperative, Inc.

Rocco R. Sgarro 212 Locust Street Manager - Nuclear Regulatory Affairs P.O. Box 1266 PPL Susquehanna, LLC Harrisburg, PA 17108-1266 Two North Ninth Street, GENPL4 Allentown, PA 18101-1179 Director - Bureau of Radiation Protection Pennsylvania Department of Walter E. Morrissey Environmental Protection Supervising Engineer P.O. Box 8469 Nuclear Regulatory Affairs Harrisburg, PA 17105-8469 PPL Susquehanna, LLC 769 Salem Blvd., NUCSA4 Senior Resident Inspector Berwick, PA 18603-0467 U.S. Nuclear Regulatory Commission P.O. Box 35, NUCSA4 Michael H. Crowthers Berwick, PA 18603-0035 Supervising Engineer Nuclear Regulatory Affairs Regional Administrator, Region 1 PPL Susquehanna, LLC U.S. Nuclear Regulatory Commission Two North Ninth Street, GENPL4 475 Allendale Road Allentown, PA 18101-1179 King of Prussia, PA 19406

Susquehanna Steam Electric Station, Unit Nos. 1 and 2 cc:

Board of Supervisors Salem Township P.O. Box 405 Berwick, PA 18603-0035 Dr. Judith Johnsrud National Energy Committee Sierra Club 443 Orlando Avenue State College, PA 16803

PPL SUSQUEHANNA, LLC ALLEGHENY ELECTRIC COOPERATIVE, INC.

DOCKET NO. 50-387 SUSQUEHANNA STEAM ELECTRIC STATION, UNIT 1 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 223 License No. NPF-14

1. The Nuclear Regulatory Commission (the Commission or the NRC) having found that:

A. The application for the amendment filed by PPL Susquehanna, LLC, dated September 8, 2004, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the regulations of the Commission; C. There is reasonable assurance: (I) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations set forth in 10 CFR Chapter I; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment and paragraph 2.C.(2) of the Facility Operating License No. NPF-14 is hereby amended to read as follows:

(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 223 and the Environmental Protection Plan contained in Appendix B, are hereby incorporated in the license. PPL Susquehanna, LLC shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3. This license amendment is effective as of its date of issuance and shall be implemented within 60 days.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

Richard J. Laufer, Chief, Section 1 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications Date of Issuance: August 4, 2005

ATTACHMENT TO LICENSE AMENDMENT NO.223 FACILITY OPERATING LICENSE NO. NPF-14 DOCKET NO. 50-387 Replace the following page of the Appendix A Technical Specifications with the attached revised page. The revised page is identified by amendment number and contains marginal lines indicating the areas of change.

REMOVE INSERT TS/3.6-14 TS/3.6-14

PPL SUSQUEHANNA, LLC ALLEGHENY ELECTRIC COOPERATIVE, INC.

DOCKET NO. 50-388 SUSQUEHANNA STEAM ELECTRIC STATION, UNIT 2 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 200 License No. NPF-22

1. The Nuclear Regulatory Commission (the Commission or the NRC) having found that:

A. The application for the amendment filed by PPL Susquehanna, LLC, dated September 8, 2004, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the regulations of the Commission; C. There is reasonable assurance: (I) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations set forth in 10 CFR Chapter I; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment and paragraph 2.C.(2) of the Facility Operating License No. NPF-22 is hereby amended to read as follows:

(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 200 and the Environmental Protection Plan contained in Appendix B, are hereby incorporated in the license. PPL Susquehanna, LLC shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3. This license amendment is effective as of its date of issuance and shall be implemented within 60 days.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

Richard J. Laufer, Chief, Section 1 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications Date of Issuance: August 4, 2005

ATTACHMENT TO LICENSE AMENDMENT NO. 200 FACILITY OPERATING LICENSE NO. NPF-22 DOCKET NO. 50-388 Replace the following page of the Appendix A Technical Specifications with the attached revised page. The revised page is identified by amendment number and contains marginal lines indicating the areas of change.

REMOVE INSERT TS/3.6-14 TS/3.6-14

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 223 TO FACILITY OPERATING LICENSE NO. NPF-14 AND AMENDMENT NO. 200 TO FACILITY OPERATING LICENSE NO. NPF-22 PPL SUSQUEHANNA, LLC ALLEGHENY ELECTRIC COOPERATIVE, INC.

SUSQUEHANNA STEAM ELECTRIC STATION, UNITS 1 AND 2 DOCKET NOS. 50-387 AND 388

1.0 INTRODUCTION

By application dated September 8, 2004 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML042590450), PPL Susquehanna, LLC (PPL, the licensee),

requested changes to the Technical Specifications (TSs) for Susquehanna Steam Electric Station, Units 1 and 2 (SSES 1 and 2).

The proposed changes would revise the SSES 1 and 2 TS Surveillance Requirement (SR) 3.6.1.3.6 of TS 3.6.1.3, Primary Containment Isolation Valves, to reduce the frequency of performing leakage rate testing for each primary containment purge valve with resilient seals from 184 days to 24 months.

2.0 REGULATORY EVALUATION

The Nuclear Regulatory Commission (NRC) finds that PPL, in its September 8, 2004, submittal, identified the applicable regulatory requirements. The regulatory requirements and guidance which the NRC staff considered in its review of the application are as follows:

1. Title 10 of the Code of Federal Regulations (10 CFR) establishes the fundamental regulatory requirements with respect to fluid systems at nuclear power plants.

Specifically, Appendix J to Part 50, "Primary Reactor Containment Leakage Testing For Water-Cooled Power Reactors," provides the containment leakage test requirements to assure that (a) leakage through the primary reactor containment and systems and components penetrating primary containment shall not exceed allowable leakage rate values as specified in the TSs or associated bases, and (b) periodic surveillance of reactor containment penetrations and isolation valves is performed so that the proper maintenance and repairs are made during the service life of the containment, and systems and components penetrating primary containment.

2. Section 50.36, Technical specifications, provides the regulatory requirements for the content required in a licensees TSs. Section 50.36 states, in part, that the TSs will

include SRs to assure that the quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation (LCO) will be met.

4. Regulatory Guide (RG) 1.163, Performance-Based Containment Leak Test Program, provides methods, procedures, and analyses that are acceptable to the NRC for containment leakage rate testing.

3.0 TECHNICAL EVALUATION

3.1 Background At the time that SSES 1 and 2 received their operating licenses, 10 CFR, Part 50, Appendix J, "Primary Reactor Containment Leakage Testing For Water-Cooled Power Reactors," required containment isolation valves, including containment purge and vent valves, to be subjected to local leakage rate tests at every refueling outage, but not to exceed 2-year intervals.

Compliance with Appendix J provides assurance that the leakage rate of the containment, including those systems and components which penetrate the containment, does not exceed the allowable leakage rate specified in the TSs and bases. The allowable leakage rate is determined so that the leakage rate assumed in the safety analyses is not exceeded.

However, in the 1970s, the NRC staff had determined that containment purge and vent valves were, as a class, a special problem in terms of leakage rate. Experience had shown that containment purge and vent valves with resilient seals were more susceptible than other containment isolation valves to degradation caused by environmental factors (such as temperature extremes, and changes in humidity and barometric pressure) and mechanical factors (such as wear and tear, and hardening of resilient seals due to aging and exposure to radiation). This degradation not only could cause high and rapidly increasing leakage rates, but the radiological consequences of such leaks were more significant than for other valves because of the large diameter of the containment purge and vent valves and the direct connection that it provides between the containment atmosphere and the outside environment.

As part of the resolution of Generic Issue B-20 (also known as Multi-Plant Action MPA-B020),

Containment Leakage Due to Seal Deterioration, the NRC staff decided to increase the frequency of local leakage rate testing of containment purge and vent valves, beyond the frequency required by Appendix J (additional background may be found in IE Circular 77-11, "Leakage of Containment Isolation Valves with Resilient Seals," issued September 6, 1977).

This would limit the time during which the valves might be inoperable due to excessive leakage, and make it more likely that a licensee would catch and correct advancing degradation before it became extreme. Although there was some variation, a typical testing arrangement was to have passive valves (those not opened during plant operation) tested every 6 months, and active valves (those opened during plant operation) tested every 3 months. This is similar to the current testing arrangement at SSES 1 and 2, where the test interval is 184 days.

Note that the NRC did not implement the increased testing frequencies through regulations, but rather through plant TSs. Although Appendix J does not contain any special requirements for containment purge and vent valves, and the 3- and 6-month tests are not entirely the same as Appendix J tests, the same tests are usually used to fulfill Appendix J requirements when they come due.

In 1995, the NRC revised Appendix J to add a new, performance-based option for testing, called Option B. The NRC also published RG 1.163, "Performance-Based Containment Leak Test Program," dated September 1995, which was developed as a method acceptable to the NRC staff for implementing Option B. This RG states that the Nuclear Energy Institute (NEI) guidance document, NEI 94-01, Rev. 0, "Industry Guideline for Implementing Performance-Based Option of 10 CFR Part 50, Appendix J," dated July 26, 1995, provides methods acceptable to the NRC staff for complying with Option B, with four exceptions which are described therein. Virtually all of the plants that have adopted Option B, including SSES 1 and 2, have adopted TSs which require compliance with the provisions of RG 1.163.

RG 1.163 allows an extension in the Type A (integrated leakage rate) test interval to 10 years based upon two consecutive successful tests. Type B tests (local leakage rate tests of containment penetrations such as electrical penetrations) may be extended up to a maximum interval of 10 years based upon completion of two consecutive successful tests. Type C tests (local leakage rate tests of containment isolation valves) may have intervals extended to 5 years based on two consecutive successful tests. However, despite the fact that most other containment isolation valves may have test intervals of up to 5 years, RG 1.163 does not allow the containment purge and vent valves go onto an extended interval; they must remain on the nominal 30-month interval. This is in consideration of their past poor operating experience and the safety significance of their large diameter and direct connection between the containment atmosphere and the outside environment. Also, although RG 1.163 indicates a 30-month interval, this still does not directly affect the more frequent (3- and 6-month) tests contained in plant TSs, which, as before, go beyond the requirements of Appendix J.

Subsequent to the problems observed in the 1970s, the industry has made considerable strides in correcting the deficiencies of containment purge and vent valves with resilient seals.

Improved seal materials, quality control, and modifications of equipment and environmental conditions have largely corrected valve deficiencies in many plants. Several plants have requested, and the NRC staff has granted, TS changes to eliminate the more-frequent testing requirements, allowing testing at what is essentially a refueling outage interval (References 1 through 6). The NRC staff has granted these reliefs on the basis of good valve performance demonstrated by plant-specific historical leakage rate testing results. Each plant must show that their containment purge and vent valves have had consistently good performance and are thus unlikely to experience significant degradation between tests when the test interval is lengthened.

3.2 PPLs Proposed Change The proposed amendment revises the SSES 1 and 2 TSs SR 3.6.1.3.6 to reduce the frequency of performing leakage rate testing for each primary containment purge valve with resilient seals from 184 days to 24 months.

The associated mark-up page, TS/3.6-14, for Unit 2, was incorrectly marked by PPL as page TS/3.6-15. However, the final proposed TS page for Unit 2 was correctly paginated.

3.3 Technical Evaluation PPL has provided information on purge valve test results between March 1982 and February 2004. This results in a total of 892 individual tests. Of these, there were 17 failed tests. There have been only four test failures since 1995; three of those failures were not seal-related.

There has been only one failure since 1999, and it was not seal-related. PPL credits the recent good performance to the evolution of the preventive maintenance program.

Considering a low overall test failure rate, and an even lower failure rate in recent years, with no seal-related failures since 1999, the NRC staff finds it acceptable for PPL to extend the interval between leakage rate tests of the containment purge and vent valves to 24 months.

4.0 STATE CONSULTATION

In accordance with the Commissions regulations, the Pennsylvania State Official was notified of the proposed issuance of the amendments. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendments change a surveillance requirement. The NRC staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration, and there has been no public comment on such finding (70 FR 9995). Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.

6.0 CONCLUSION

The Commission has concluded based on the considerations discussed above that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.

7.0 REFERENCES

1. Letter to Robert E. Link (Point Beach) from Allen G. Hansen (NRC),

Subject:

Amendment Nos. 169 and 173 to Facility Operating License Nos. DPR-24 and DPR Point Beach Nuclear Plant, Unit Nos. 1 and 2 (TAC Nos. M95668 and M95669), dated October 9, 1996.

2. Letter to Ted C. Feigenbaum (Seabrook) from Albert W. De Agazio (NRC),

Subject:

Amendment No. 49 to Facility Operating License NPF-86: Implementation of 10 CFR 50 Appendix J, Option B - License Amendment Request 96-05 (TAC No. M95312), dated February 24, 1997 (ADAMS Accession No. ML011830237).

3. Letter to H. B. Barron (McGuire) from Robert E. Martin (NRC),

Subject:

McGuire Nuclear Station, Units 1and 2 Re: Issuance of Amendments Regarding Option B of Appendix J for Local Leakage Rate Testing (TAC Nos. MB3565 and MB3566), dated September 4, 2002 (ADAMS Accession No. ML022540005).

4. Letter to William T. Cottle (South Texas) from Mohan Thadani (NRC),

Subject:

South Texas Project, Units 1 and 2 - Issuance of Amendments Re: Extension of the Intervals Between Operability Tests of the Normal and Supplementary Containment Purge Valves (TAC Nos. MB4048 and MB4049), dated January 7, 2003 (ADAMS Accession No. ML030140325).

5. Letter to Gregory M. Rueger (Diablo Canyon) from Girija S. Shukla (NRC),

Subject:

Diablo Canyon Power Plant, Unit Nos. 1 and 2 - Issuance of Amendment Re: Extension of Local Leakage Rate Testing Intervals for Containment Purge and Vent Valves (TAC Nos. MC1208 and MC1209), dated October 6, 2004 (ADAMS Accession No. ML042860073).

6. Letter to M. R. Blevins (Comanche Peak) from Mohan Thadani (NRC),

Subject:

Comanche Peak Steam Electric Station, Units 1 and 2 - Issuance of Amendments to Extend Surveillance Frequency for Containment Purge, Hydrogen Purge, and Containment Pressure Relief Valves (TAC Nos. MC0911 and MC0912), dated April 13, 2005 (ADAMS Accession No. ML051180530).

Principal Contributor: J. Pulsipher Date: August 4, 2005