ML081960536
| ML081960536 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 08/12/2008 |
| From: | Bhalchandra Vaidya NRC/NRR/ADRO/DORL/LPLI-1 |
| To: | Mckinney B Susquehanna |
| vaidya B, NRR/Dorl/lpl1-1, 415-3308 | |
| References | |
| TAC MD7886, TAC MD7887 | |
| Download: ML081960536 (8) | |
Text
August 12, 2008 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 - GENERIC LETTER 2008-01, MANAGING GAS ACCUMULATION IN EMERGENCY CORE COOLING, DECAY HEAT REMOVAL, AND CONTAINMENT SPRAY SYSTEMS, PROPOSED ALTERNATIVE COURSE OF ACTION (TAC NOS. MD7886 AND MD7887)
Dear Mr. McKinney:
On January 11, 2008, the Nuclear Regulatory Commission (NRC) issued Generic Letter (GL) 2008-01, Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems (Agencywide Documents Access and Management System (ADAMS) Accession No. ML072910759). The GL requested licensees to submit information to demonstrate that the emergency core cooling, decay heat removal, and containment spray systems (hereinafter referred to as the subject systems) are in compliance with the current licensing and design bases and applicable regulatory requirements, and that suitable design, operational, and testing control measures are in place for maintaining this compliance.
In accordance with Section 50.54(f) of Title 10 of the Code of Federal Regulations (10 CFR),
GL 2008-01 required that each licensee submit the requested information within 9 months (hereinafter referred to as the 9-month submittal) of the date of the GL. The GL also stated that if a licensee cannot meet the requested 9-month response date, the licensee is required to provide a response within 3 months (hereinafter referred to as the 3-month submittal) of the date of the GL, describing the alternative course of action it proposes to take, including the basis for the acceptability of the proposed alternative course of action.
By letter dated May 27, 2008, PPL Susquehanna (PPL), the licensee, submitted a 3-month response to GL 2008-01 for Susquehanna Steam Electric Station, Units 1 and 2 (SSES-1 and SSES-2). The NRC staffs assessment of the licensees response is contained in the enclosure.
The NRC staff reviewed the licensees proposed alternative course of action and the associated basis for acceptance and concluded that for SSES-1 and SSES-2, with the exception of the clarifications and associated requests discussed in Enclosure 1, they are acceptable. This letter allows the licensee to implement its proposed alternative course of action provided that implementation is consistent with the clarifications and associated requests discussed in the enclosure.
B.
If you have any questions regarding this letter, please feel free to contact me at (301) 415-3308.
Sincerely
/RA/
Bhalchandra K. Vaidya, Project Manager Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-387 and 50-388
Enclosure:
As Stated cc w/encl: See next page
B.
If you have any questions regarding this letter, please feel free to contact me at (301) 415-3308.
Sincerely,
/RA/
Bhalchandra K. Vaidya, Project Manager Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-387 and 50-388
Enclosure:
As Stated cc w/encl: See next page Distribution:
PUBLIC PDI-1 RF RidsNrrDorlLPL1-1 RidsNrrPMBVaidya (hard copy)
RidsNrrSLittle (hard copy)
RidsNrrDorlDPR RidsOgcRp RidsAcrsAcnw&mMailCenter RidsRgn1MailCenter Rids NrrDprPgcb(MMurphy) RidsNrrDssD(JWermeil)
DBeaulieu, DPR /PGCB WLyons, DSS/SRXB SSun, DSS/SRXB ADAMS Accession Number: ML081960536 NRR-106 OFFICE LPLI-1/PM LPLI-1/LA PGCB:BC DCI/DD LPLI-1/BC NAME BVaidya SLittle MMurphy JWermeil MKowal DATE 7/28/08 7/28/08 8/11/08 8/08/08 8/12/08 OFFICIAL RECORD COPY
Susquehanna Steam Electric Station, Unit Nos. 1 and 2 cc:
Cornelius J. Gannon Vice President - Nuclear Operations PPL Susquehanna, LLC 769 Salem Blvd., NUCSB3 Berwick, PA 18603-0467 Robert M. Paley General Manager - Plant Support PPL Susquehanna, LLC 769 Salem Blvd., NUCSB2 Berwick, PA 18603-0467 Michael H. Crowthers Manager - Nuclear Regulatory Affairs PPL Susquehanna, LLC Two North Ninth Street, GENPL4 Allentown, PA 18101-1179 Dayne R. Brophy-Nuclear Regulatory Affairs PPL Susquehanna, LLC 769 Salem Blvd., NUCSA4 Berwick, PA 18603-0467 Ronald E. Smith General Manager - Site Preparedness and Services PPL Susquehanna, LLC 769 Salem Blvd., NUCSA4 Berwick, PA 18603-0467 Michael H. Rose Manager - Quality Assurance PPL Susquehanna, LLC 769 Salem Blvd., NUCSB2 Berwick, PA 18603-0467 Joseph J. Scopelliti Community Relations Manager, Susquehanna PPL Susquehanna, LLC 634 Salem Blvd., SSO Berwick, PA 18603-0467 Bryan A. Snapp, Esq Assoc. General Counsel PPL Services Corporation Two North Ninth Street, GENTW20 Allentown, PA 18101-1179 Document Control Services PPL Susquehanna, LLC Two North Ninth Street, GENPL4 Allentown, PA 18101-1179 Richard W. Osborne Allegheny Electric Cooperative, Inc.
212 Locust Street P.O. Box 1266 Harrisburg, PA 17108-1266 Director, Bureau of Radiation Protection Pennsylvania Department of Environmental Protection Rachel Carson State Office Building P.O. Box 8469 Harrisburg, PA 17105-8469 Senior Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 35, NUCSA4 Berwick, PA 18603-0035 Regional Administrator, Region 1 U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 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
NRC STAFF ASSESSMENT OF 3-MONTH RESPONSE TO GENERIC LETTER 2008-01 SUSQUEHANNA STEAM ELECTRIC STATION, UNITS 1 AND 2 DOCKET NOS. 50-387 AND 50-388 1.0
Background
On January 11, 2008, the Nuclear Regulatory Commission (NRC) issued Generic Letter (GL) 2008-01, Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems (Agencywide Documents Access and Management System (ADAMS) Accession No. ML072910759). The GL requested licensees to submit information to demonstrate that the emergency core cooling, decay heat removal, and containment spray systems (hereinafter referred to as the subject systems) are in compliance with the current licensing and design bases and applicable regulatory requirements, and that suitable design, operational, and testing control measures are in place for maintaining this compliance.
Specifically, the GL requested licensees to provide: (1) a description of the results of evaluations that were performed in response to the GL; (2) a description of all corrective actions that the licensee determined were necessary; and (3) a statement regarding which corrective actions were completed, the schedule for completing the remaining corrective actions, and the basis for that schedule.
In accordance with Section 50.54(f) of Title 10 of the Code of Federal Regulations (10 CFR),
GL 2008-01 required that each licensee submit the requested information within 9 months (hereinafter referred to as the 9-month submittal) of the date of the GL. The GL also stated that if a licensee cannot meet the requested 9-month response date, the licensee is required to provide a response within 3 months (hereinafter referred to as the 3-month submittal) of the date of the GL, describing the alternative course of action it proposes to take, including the basis for the acceptability of the proposed alternative course of action.
2.0 Licensees Proposed Alternative Course of Action By letter dated May 27, 2008, PPL Susquehanna (PPL), the licensee, submitted a 3-month response to GL 2008-01 for Susquehanna Steam Electric Station, Units 1 and 2 (SSES-1 and SSES-2). PPL indicated that SSES would complete within the requested 9 months all GL-requested actions, except those involving walkdowns and the associated evaluation. The licensee cannot complete the walkdowns within the requested 9 months because portions of the subject systems, including high-pressure coolant injection (HPCI), core spray (CS) and residual heat removal (RHR) systems, are inaccessible during power operation due to the need to enter into the containment or radiation environments. PPL plans to conduct the SSES system walkdowns inside primary containment and/or high radiation areas during the next refueling outages that are planned in the spring of 2009 and the spring of 2010 for Unit 2 and Unit 1, respectively. System walkdowns in accessible areas outside primary containment will be completed to support the 9-month response. The licensee identified that the following systems contain piping sections that will not be accessed until the next refueling outages on SSES-1 and SSES-2:
Enclosure
HPCI discharge piping - inside the main steam pipe tunnel up to and including the connection to feedwater, and inaccessible areas outside containment, as determined during walkdowns.
CS discharge piping - from the containment penetration to the reactor pressure vessel, and inaccessible areas outside containment, as determined during walkdowns.
RHR (Shutdown Cooling mode) - RHR pump discharge piping inside containment, and inaccessible areas outside containment, as determined during walkdowns.
RHR (Low-Pressure Coolant Injection mode) - RHR pump discharge piping from containment penetration to the reactor pressure vessel, and inaccessible areas outside containment, as determined during walkdowns.
As an alternative course of action, the licensees letter dated May 27, 2008, listed the following commitments:
For Unit 1 -
(1)
Complete the walkdowns of Unit 1 inaccessible sections of GL 2008-01 subject systems prior to startup from the next refueling outage that is planned for the spring of 2010.
(2)
Complete evaluations of GL 2008-01 subject systems using results of walkdowns of Unit 1 inaccessible piping sections and submit a supplemental response to the NRC documenting completion of the Unit 1 walkdowns and any impact upon the GL 2008-01 9-month response as a result of the completed evaluations within 90 days following startup from the spring 2010 refueling outage.
For Unit 2 -
(1) Complete the walkdowns of Unit 2 inaccessible sections of GL 2008-01 subject systems prior to startup from the next refueling outage that is planned for the spring of 2009.
(2) Complete evaluations of GL 2008-01 subject systems using results of walkdowns of Unit 2 inaccessible piping sections and submit a supplemental response to the NRC documenting completion of the Unit 2 walkdowns and any impact upon the GL 2008-01 9-month response as a result of the completed evaluations within 90 days following startup from the spring 2009 refueling outage.
The licensee stated that it has confidence the GL subject systems can fulfill their required design functions, based on the following reasons:
(1)
The GL subject systems discharge piping is filled by a keep fill system to prevent the possibility of water hammer. In addition, a redundant passive keep fill system is connected to the subject systems for use in the event of failure of the normal keep fill system.
(2)
Significant gas accumulation has not been found at the high point vents in the subject systems during technical specification (TS) surveillance testing.
(3)
Periodic flow tests of the subject systems have not indicated any adverse impacts on ability of the subject systems to perform their design basis functions.
Based on the above-described designs, operating experience and tests associated with managing gas accumulation, the licensee concluded that completing the walkdowns of the inaccessible portions of the subject systems beyond the requested 9-month period, but no later than startup from the next refueling outage (that is planned in the spring of 2009 for SSES-2 and spring of 2010 for SSES-1) is an acceptable alternative course of action.
3.0 NRC Staff Assessment The NRC staff finds that, with the exception of the clarifications and associated requests discussed below, the licensees proposed alternative course of action is acceptable based on the above-described operating experience, tests and designs associated with managing gas accumulation at the SSES. The NRC staff noted that the licensees 3-month submittal dated May 27, 2008, did not clearly describe the content for the 9-month submittals. The NRC staff requests that the licensee submit the information requested in the GL as follows:
(1) 9-Month Initial Submittal - For the portions of the subject systems that are accessible prior to the spring 2009 and spring 2010 refueling outages for SSES-2 and SSES-1, respectively, provide all GL requested information to the NRC by October 11, 2008.
(2) 9-Month Supplemental (Post-Outage) Submittals - Except for the long-term items described below, provide all remaining GL requested information for the subject systems to the NRC within 90 days following completion of each of the spring 2009 and spring 2010 refueling outages for SSES-2 and SSES-1, respectively.
For each of these two submittals (the 9-month initial and supplemental submittals), and consistent with the information requested in the GL, the licensees should provide: (1) a description of the results of evaluations that were performed in response to the GL; (2) a description of all corrective actions that the licensee determined were necessary; and (3) a statement regarding which corrective actions were completed, the schedule for completing the remaining corrective actions, and the basis for that schedule.
The NRC staff noted that the licensees submittal dated May 27, 2008, did not mention other potential long-term actions that are identified in the GL. For instance, the industry is assessing whether it is necessary to perform pump testing to determine the allowable limits on ingested gas volume in pump suctions, as well as the need to develop an analysis capability to adequately predict void movement (entrapped gas) from piping on the suction side of pumps into the pumps. It is unlikely this industry effort will be completed for the 9-month initial or supplemental submittals. Further, TS changes may be necessary to reflect the improved understanding achieved during response to the GL, but these cannot be fully developed for the 9-month initial or supplemental submittals. A Technical Specifications Task Force traveler may provide a generic example that can be adopted by licensees. The NRC staff requests that the licensee address in its 9-month submittal how it plans to track such long-term actions (e.g.,
Corrective Action Program and/or commitment tracking). The NRC plans to perform follow up inspections of licensee responses to GL 2008-01 at all plants using a Temporary Instruction inspection procedure.