ML112020401

ME5050 & ME5051, RAIs to the Licensee TS Changes to SRV Test Tolerances

ML112020401
Person / Time
Site:	Susquehanna
Issue date:	07/21/2011
From:	Bhalchandra Vaidya Plant Licensing Branch 1
To:	Coddington C, Rochester M Susquehanna
vaidya B, NRR/Dorl/lpl1-1, 415-3308
References
TAC ME5050, TAC ME5051
Download: ML112020401 (2)

Text

From: Vaidya, Bhalchandra Sent: Thursday, July 21, 2011 1:46 PM To: 'Cornelius Coddington'; 'Rochester, Margaret' Cc: Salgado, Nancy; Finney, Patrick; Greives, Jonathan; Krohn, Paul; McMurtray, Anthony; Huang, John; Lingam, Siva; Boyle, Patrick

Subject:

Request for Additional Information, ME5050 & ME5051, LAR for TS Change Re: SRV Testing tolerance change Based on its review of the License Amendment Request (LAR), the NRC staff has determined that additional information is required to complete its review. The Request for Additional Information (RAI) is provided below.

Request for Additional Information (RAI)

PPL Susquehanna, LLC Susquehanna Steam Electric Station Units 1 and 2

Reference:

Licensees Submittal dated November 10, 2010 Docket Nos. 50-387 and 50-388 (TAC Nos. ME5050 and ME5051)

RAI-1

American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code), Mandatory Appendix I, I-1310(e), requires that, The Owner, based upon system and valve design basics or technical specification, shall establish and document acceptance criteria for tests required by this Appendix. Please provide the valve design document and basics such as consideration of simmering, seat leakages, and reliability for establishing low set-point pressure tolerances including the manufacture recommended low set-point pressure limits for the main steam safety/relief valves PSV141F013A, B, C, D, E, F, G, H, J, K, L, M, N, P, R, and S.

RAI-2

ASME OM Code Mandatory Appendix I, I-1330(c)(3) requires that the owner evaluate the cause and effect of valves that failed to comply with the set-pressure acceptance criteria established in I-1330(c)(1). I-1330(c)(3) applies to both high and low set-point pressures. Please provide a test history over the past ten years showing any low set-point pressures that exceeded acceptance criteria, and a summary of the evaluations of the causes and generic concerns of the valves identified in RAI-1 that failed to meet the low set point pressure limits.

RAI-3

On page 8 of the submittal referenced above, PPL states that no additional valves will be tested if the as-found set point is below the nameplate set point. This appears to conflict with I-1330(c)(1), which requires that additional valves be tested if the specified set-point pressure tolerance limits including the lower set-point pressures are not met. During a conference call on June 8, 2011, PPL cited relief request RR-02 for basis not complying with I-1330(c). RR-02 was submitted to the NRC for review in a letter from PPL dated May 24, 2004. A revised letter was submitted to the NRC on June 1, 2010.

Specifically, RR-02 requested relief from ASME OM Code, Appendix I, paragraph I-1330(a), Test Frequencies, Class 1 Pressure Relief Valves. The NRC staff reviewed these two letters and authorized the proposed alternative including that no additional valves will be tested if the as-found set-point

pressure is below the nameplate set-point. Note that the relief request was authorized for low set-point pressure tolerance of -3% in letters dated March 10, 2005 and January 4, 2011. However, the current proposed technical specification amendment will revise the low set-point pressure tolerances from -3%

to -5 %, which represents an additional 67% set point pressure drifting or accelerated valve degradation. As a valve experiences abnormal degradation, it is prudent to verify the condition of additional valves in the same group. Therefore, PPL is requested to provide justification for not testing additional valves if the low set-point pressure exceeds -5%.

The response to the above RAI is needed by August 26, 2011, in order to support the requested completion date for the LAR.

Please contact me ASAP, if PPL needs clarification of the questions in the above RAI.

Thanks, Bhalchandra K. Vaidya Licensing Project Manager NRC/NRR/DORL/LPL1-1 (301)-415-3308 (O) bhalchandra.vaidya@nrc.gov