PLA-6841, Request to Expedite Approval of Ppl'S Proposed Amendment Number 281 to Unit 2

Request to Expedite Approval of Ppl'S Proposed Amendment Number 281 to Unit 2

ML12093A367
Person / Time
Site:	Susquehanna
Issue date:	04/02/2012
From:	Helsel J Susquehanna
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
PLA-6841
Download: ML12093A367 (4)

Text

Jeffrey M. Helsel Nuclear Plant Manager PPL Susquehanna, LLC 769 Salem Boulevard Berwick, PA 18603

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Tel. 570.542.3510 Fax 570.542.1504 jmhelsel@pplweb.com

' TM U. S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Stop OP1-17 Washington, DC 20555 SUSQUEHANNA STEAM ELECTRIC STATION REQUEST TO EXPEDITE APPROVAL OF PPL'S PROPSED AMENDMENT NUMBER 281 TO UNIT 2 OPERATING LICENSE NO. NPF-22 PLA-6841 Docket No. 50-388

References:

I. Letter (PLA-68I7) from R. A. Kearney (PPL) to USNRC (Document Control Desk) Titled "Proposed Amendment Number 28I to Unit 2 Operating License No. NPF-22 Temporary Change to Allow Implementation of Multiple Spurious Operations Modifications on SSES Unit I 4I 60 v Buses: Technical Specifications 3.8. 7 and 3. 7. I ", Dated March 8, 20I 2

2. Email from B. Vaidya (USNRC) to PPL, Titled "Susquehanna Unit 2, ME8I 52, Draft Request for Additional Information (RAJ) from Balance of Plant Branch", Dated March I6, 20I2.

3. Letter (PLA -6828) from J M Helsel (PPL) to USNRC (Document Control Desk) Titled "Response to Email (Dated March I6, 20I2) Request for Additional Information Proposed Amendment Number 28I to Unit 2 Operating License No. NPF-22", Dated March 23, 20I2.

4. Email from B. Vaidya (USNRC) to PPL, Titled "Susquehanna Unit 2, ME8I 52, Additional Request for Additional Information (RAJ) from Balance of Plant Branch", Dated March 27, 20I 2.

5. Letter (PLA-6834) from J M Helsel (PPL) to USNRC (Document Control Desk) Titled "Response to Email (Dated March 27, 2012) Request for Additional Information Proposed Amendment Number 28I to Unit 2 Operating License No. NPF-22 ", Dated March 29, 20I2.

6. Email from B. Vaidya (USNRC) to PPL, Titled "Susquehanna Unit 2 LAR-Clarification ofSusquehanna RAJ Response dated Mar 23, FW: RAJ Clarification, Susquehanna Unit 2 LAR ", Dated March 30, 20 I 2.

7. Letter (PLA-6842) from J M Helsel (PPL) to USNRC (Document Control Desk) Titled "Response to Email (Dated March 30, 20I2) Requestfor Additional Information Proposed Amendment Number 28I to Unit 2 Operating License No. NPF-22", Dated April2, 20I2.

The purpose of this letter is to provide supplemental information to the NRC staff regarding PPL's proposed amendment request No. 281. This proposed amendment was submitted on March 8, 2012, and supplemental information in response to NRC's request for additional information (RAI) was provided on March 23, 2012, March 29, 2012 and April 02, 2012. PPL requested this amendment to be processed as an exigent amendment. However, your letter dated March 9, 2012 indicated that the staff found that PPL had not provided sufficient justification for an exigent amendment. It is our understanding that the basis for this decision was the duration of time PPL took in submitting its application for amendment.

Document Control Desk PLA-6841 During the time between initial discovery of the need for the modification and the amendment submittal, PPL finalized the scope of the modifications through plant walkdowns, engineering meetings, etc. and maintained contact with the NRC to ensure that we were providing NRC Staff the information necessary for their review. Until the modification scope was finalized, PPL could not define the temporary LCO extension needed. The original one-time extension was for 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />; however, through reengineering and detailed planning this time was reduced to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Since the Unit outages at Susquehanna SES are scheduled every two years, the scheduled Unit 1 outage in the spring of 2012 provided the first opportunity to implement the required Multiple Spurious Operations (MSO) modifications. Regulatory Guide 1.189 was issued on November 2, 2009. The next scheduled Unit 1 outage was in March 2010.

The time between the issuance of Regulatory Guide 1.189 and the Unit 1 Spring 2010 outage did not provide sufficient time to develop the corrective actions and design any modifications for implementation in the Spring 2010 outage, which was concluded in May 2010. PPL' s corrective actions were entered into the corrective action program in May 20 10 with the design and implementation of the modifications scheduled for the Spring of2012 outage which was concluded in April2010.

Implementing the modifications while both Unit 1 and Unit 2 were on line presents unique issues and additional requests for extension of completion times.

First, completion of the modifications requires the performance of Surveillance Requirement (SR) 3 .8.1.8 which requires the verification of automatic and manual transfer of unit power supply from the normal offsite circuit to the alternate offsite circuit. This SR is amended by a NOTE that states, "The automatic transfer of the unit power supply shall not be performed in MODE 1 or 2." Justification for not performing the transfer in MODES 1 or 2 is provided in the Technical Specification Bases for this SR. The Bases read in part:

"This SR is modified by a Note. The reason for the Note is that, during operation with the reactor critical, performance of the automatic transfer of the unit power supply could cause perturbations to the electrical distribution systems that could challenge continued steady state operation and, as a result, plant safety systems. The manual transfer of unit power supply should not result in any perturbation to the electrical distribution system; therefore, no mode restriction is specified. This Surveillance tests the applicable logic associated with Unit 1. The comparable test specified in Unit 2 Technical Specifications tests the applicable logic associated with Unit 2.

Consequently, a test must be performed within the specified Frequency for each unit. As the Surveillance represents separate tests, the Note specifying the restriction for not performing the test while the unit is in MODE 1 or 2

Document Control Desk PLA-6841 does not have applicability to Unit 2. The NOTE only applies to Unit 1, thus the Unit 1 Surveillance shall not be performed with Unit 1 in MODE 1 or 2."

Unit 2 SR 3 .8.1.8 contains the same note.

Second, the presently requested Unit 2 Technical Specification completion time extensions would also apply.

Third, Unit 1 Technical Specification 3.7.1 would require extensions for the completion time to 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> for a RHRSW loop out of service. In addition, Technical Specification 3.8.7 would require an extension for the completion time for a bus to be out of service from 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> to 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br />.

Based upon the above restrictions, possible safety system challenges and additional completion time requests, it is not prudent to perform these modifications while Unit 1 and Unit 2 are online.

PPL has expeditiously responded to the NRC Staffs questions and it is our understanding that we have satisfactorily resolved all the staffs questions. In addition, PPL understands that the Commonwealth of Pennsylvania did not object to the proposed amendment.

When there is a finding of no significant hazards, 10 C.P.R. § 50.91(a)(5) allows for an amendment to be issued without notice to the public on an emergency basis when failure to act would result in derating or a shutdown of a unit and 10 C .F .R. 50.91 (a)( 6) allows for a limited comment period where an exigent circumstance exists. An exigent situation is something "short of an emergency" i.e., short of an immediate shutdown or derate. (48 Federal Register 14876) In this case, use of an exigent amendment is appropriate, as there is not an immediate risk of shutdown thus allowing a limited public comment period. PPL recognizes that these provisions should be used when there is a net increase in safety or reliability and in this case, performing the MSO modification without unnecessarily shutting down Unit 2 will result in increased safety to Unit 1 without jeopardizing safety at Unit 2 or reliability for our customers.

Based on the above, PPL respectfully requests that NRC process this amendment as an exigent amendment or in the alternative, if necessary as an emergency amendment.

There are no regulatory commitments associated with the proposed changes.

PPL Susquehanna, LLC is providing the Commonwealth of Pennsylvania with a copy of this letter.

Document Control Desk PLA-6841 If you have any questions or require additional information, please contact Mr. Cornelius T. Coddington at (610) 774-4019.

Sincerely, J. M. Helsel Copy: NRC Region I Mr. P. W. Finney, NRC Sr. Resident Inspector Mr. R. R. Janati, DEP/BRP Mr. B. K. Vaidya, NRC Project Manager Mr. G. A. Wilson, NRR/DORL/LPL1-1/BC