ML14111A052
| ML14111A052 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 05/14/2014 |
| From: | Jeffrey Whited Plant Licensing Branch 1 |
| To: | Rausch T Susquehanna |
| Whited J, NRR/DORL/LPLI-2 | |
| References | |
| TAC MF1955, TAC MF1956 | |
| Download: ML14111A052 (20) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 May 14, 2014 Mr. Timothy S. Rausch, Senior Vice President and Chief Nuclear Officer PPL Susquehanna, LLC 769 Salem Boulevard Berwick, PA 18603-0467
SUBJECT:
SUSQUEHANNA STEAM ELECTRIC STATION, UNITS 1 AND 2 -ISSUANCE OF AMENDMENTS REGARDING CHANGE TO TECHNICAL SPECIFICATION SURVEILLANCE REQUIREMENT 3.5.1.12 (TAC NOS. MF1955 AND MF1956)
Dear Mr. Rausch:
The Commission has issued the enclosed Amendment No. 260 to Renewed Facility Operating License No. NPF-14 and Amendment No. 241 to Renewed Facility Operating License No.
NPF-22 for the Susquehanna Steam Electric Station, Units 1 and 2. These amendments consist of changes to the Renewed Facility Operating Licenses in response to your application dated June 6, 2013, as supplemented by letter dated January 23, 2014.
These amendments change Surveillance Requirement (SR) 3.5.1.12, in Technical Specification (TS) 3.5.1, "ECCS [emergency core cooling system]-Operating." Specifically, the amendments eliminate the TS requirement for the Automatic Depressurization System (ADS) valves to open during manual actuation of the ADS circuitry, change the surveillance frequency from "24 months on a STAGGERED TEST BASIS for each valve solenoid," to "24 months," and remove a note above the SR that stated the SR was "Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after reactor steam pressure and flow are adequate to perform the test."
A copy of our safety evaluation is also enclosed. Notice of Issuance will be included in the Commission's next regular Biweekly Federal Register Notice.
SinQ~~
Jeffrey A. Whited, Project Manager Plant Licensing Branch 1-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-387 and 50-388
Enclosures:
- 1. Amendment No. 260 to License No. NPF-14
- 2. Amendment No. 241 to License No. NPF-22
- 3. Safety Evaluation cc w/encls: Distribution via Listserv
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 PPL SUSQUEHANNA. LLC ALLEGHENY ELECTRIC COOPERATIVE, INC.
DOCKET NO. 50-387 SUSQUEHANNA STEAM ELECTRIC STATION, UNIT 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 260 Renewed 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 June 6, 2013, as supplemented by letter dated January 23, 2014, 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 Renewed 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. 260, 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 Meena K. Khanna, Chief Plant Licensing Branch 1-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Attachment:
Changes to the License and Technical Specifications Date of Issuance:
May 14, 2014
ATTACHMENT TO LICENSE AMENDMENT NO. 260 RENEWED FACILITY OPERATING LICENSE NO. NPF-14 DOCKET NO. 50-387 Replace the following page of the Renewed Facility Operating License with the attached revised page. The revised page is identified by amendment number and contains marginal lines indicating the areas of change.
REMOVE INSERT Page 3 Page 3 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 3.5-6 TS /3.5-6
(3) PPL Susquehanna, LLC, pursuant to the Act and 10 CFR Parts 30,40, and 70, to receive, possess, and use at any time any byproduct, source and special nuclear material as sealed neutron sources for reactor startup, sealed neutron sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required; (4) PPL Susquehanna, LLC, pursuant to the Act and 10 CFR Parts 30, 40, and 70 to receive, possess, and use in amounts as required any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; and (5) PPL Susquehanna, LLC, pursuant to the Act and 10 CFR Parts 30,40, and 70 to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.
C. This license shall be deemed to contain and is subject to the conditions specified in the Commission's regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:
(1) Maximum Power Level PPL Susquehanna, LLC is authorized to operate the facility at reactor core power levels not in excess of 3952 megawatts thermal in accordance with the conditions specified herein. The preoperational tests, startup tests and other items identified in License Conditions 2.C.(36), 2.C.(37), 2.C.(38), and 2.C.(39) to this license shall be completed as specified.
(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 260 and the Environmental Protection Plan contained in Appendix Bare hereby incorporated in the license. PPL Susquehanna, LLC shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.
For Surveillance Requirements (SRs) that are new in Amendment 178 to Facility Operating License No. NPF-14, the first performance is due at the end of the first surveillance interval that begins at implementation of Amendment 178. For SRs that existed prior to Amendment 178, including SRs with modified acceptance criteria and SRs whose frequency of performance is being extended, the first performance is due at the end of the first surveillance interval that begins on the date the Surveillance was last performed prior to implementation of Amendment 178.
Renewed Operating License No. NPF-14 Amendment No. 260
PPL Rev. 1 ECCS - Operating 3.5.1 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY SR 3.5.1.9 ----------------------------NOTE-----------------------------
Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after reactor steam pressure and flow are adequate to perform the test.
Verify, with reactor pressure ::; 165 psig, the HPCI 24 months pump can develop a flow rate ~ 5000 gpm against a system head corresponding to reactor pressure.
SR 3.5.1.1 0 --------------------------------NOTE--------------------------
Vessel injection/spray may be excluded.
Verify each ECCS injection/spray subsystem 24 months actuates on an actual or simulated automatic initiation signal.
S R 3. 5. 1. 11 -------------------------------NOTE---------------------------
Valve actuation may be excluded.
Verify the ADS actuates on an actual or simulated 24 months automatic initiation signal.
SR 3.5.1.12 Verify each ADS valve actuator strokes when 24 months manually actuated.
(continued)
SUSQUEHANNA- UNIT 1 TS I 3.5-6 Amendment 4-78, 260
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 PPL SUSQUEHANNA, LLC ALLEGHENY ELECTRIC COOPERATIVE, INC.
DOCKET NO. 50-388 SUSQUEHANNA STEAM ELECTRIC STATION, UNIT 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 241 Renewed 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 the PPL Susquehanna, LLC, dated June 6, 2013, as supplemented by letter dated January 23, 2014, 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 Renewed 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. 241, 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 Meena K. Khanna, Chief Plant Licensing Branch 1-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Attachment:
Changes to the License and Technical Specifications Date of Issuance: May 14, 2014
ATTACHMENT TO LICENSE AMENDMENT NO. 241 RENEWED FACILITY OPERATING LICENSE NO. NPF-22 DOCKET NO. 50-388 Replace the following page of the Renewed Facility Operating License with the attached revised page. The revised page is identified by amendment number and contains marginal lines indicating the areas of change.
REMOVE INSERT Page 3 Page 3 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 3.5-6 TS I 3.5-6
(3) PPL Susquehanna, LLC, pursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive, possess, and use at any time any byproduct, source and special nuclear material as sealed neutron sources for reactor startup, sealed neutron sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required; (4) PPL Susquehanna, LLC, pursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive, possess, and use in amounts as required any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; and (5) PPL Susquehanna, LLC, pursuant to the Act and 10 CFR Parts 30, 40, and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.
C. This license shall be deemed to contain and is subject to the conditions specified in the Commission's regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:
(1) Maximum Power Level PPL Susquehanna, LLC is authorized to operate the facility at reactor core power levels not in excess of 3952 megawatts thermal in accordance with the conditions specified herein. The preoperational test, startup tests and other items identified in License Conditions 2.C.(20), 2.C.(21), 2.C.(22), and 2.C.(23) to this license shall be completed as specified.
(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 241, and the Environmental Protection Plan contained in Appendix 8, are hereby incorporated in the license. PPL Susquehanna, LLC shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.
For Surveillance Requirements (SRs) that are new in Amendment 151 to Facility Operating License No. NPF-22, the first performance is due at the end of the first surveillance interval that begins at implementation of Amendment 151. For SRs that existed prior to Amendment 151, including SRs with modified acceptance criteria and SRs whose frequency of performance is being extended, the first performance is due at the end of the first surveillance interval that begins on the date the Surveillance was last performed prior to implementation of Amendment 151.
Renewed Operating License No. NPF-22 Amendment No. 241
PPL Rev. 1 ECCS - Operating 3.5.1 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY SR 3. 5.1. 9 ----------------------------NOTE------------------------------
Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after reactor steam pressure and flow are adequate to perform the test.
Verify, with reactor pressure:::; 165 psig, the HPCI 24 months pump can develop a flow rate ~ 5000 gpm against a system head corresponding to reactor pressure.
SR 3.5.1.1 0 --------------------------------NOTE--------------------------
Vessel injection/spray may be excluded.
Verify each ECCS injection/spray subsystem 24 months actuates on an actual or simulated automatic initiation signal.
SR 3.5.1.11 -------------------------------NOTE---------------------------
Valve actuation may be excluded.
Verify the ADS actuates on an actual or simulated 24 months automatic initiation signal.
SR 3.5.1.12 Verify each ADS valve actuator strokes when 24 months manually actuated.
(continued)
SUSQUEHANNA- UNIT 2 TS /3.5-6 Amendment 4M, 241
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 260 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-14 AND AMENDMENT NO. 241 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-22 PPLSUSQUEHANNA,LLC ALLEGHENY ELECTRIC COOPERATIVE, INC.
SUSQUEHANNA STEAM ELECTRIC STATION, UNITS 1 AND 2 DOCKET NOS. 50-387 AND 50-388
1.0 INTRODUCTION
By letter dated June 6, 2013, 1 as supplemented by letter dated January 23, 2014, 2 PPL Susquehanna, LLC (the licensee) requested Nuclear Regulatory Commission (NRC) approval of changes to the Technical Specifications (TSs) for Susquehanna Steam Electric Station, Units 1 and 2 (SSES). These amendments proposed changes to Surveillance Requirement (SR) 3.5.1.12, in TS 3.5.1, "ECCS [emergency core cooling system]-Operating." Specifically, the amendments proposed to: (1) eliminate the TS requirement for the Automatic Depressurization System (ADS) valves to open during manual actuation of the ADS circuitry; (2) change the surveillance frequency in SR 3.5.1.12 from "24 months on a STAGGERED TEST BASIS for each valve solenoid," to "24 months;" and (3) remove a note above the SR that stated the SR was "Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after reactor steam pressure and flow are adequate to perform the test."
The supplemental letter dated January 23, 2014, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the NRC staff's original proposed no significant hazards consideration determination as published in the Federal Register on December 10, 2013 (78 FR 74183).
1 Agencywide Documents Access and Management System (ADAMS) Accession No. ML13158A096.
2 ADAMS Accession No. ML14023A881.
Enclosure
2.0 REGULATORY EVALUATION
2.1 Regulatory Reguirements and Guidance The NRC staff evaluated the requested changes based on the following regulations and guidance:
- Title 10 of the Code of Federal Regulations, Part 50, Section 50.36(c)(2)(ii)(C) (1 0 CFR 50.36(c)(2)(ii)(C)), "Criterion 3," which requires, in part, that a TS limiting condition for operation (LCO) be established for a component that is part of the primary success path and which functions or actuates to mitigate a design-basis accident or transient that either assumes the failure of, or presents a challenge to, the integrity of a fission product barrier.
- 10 CFR 50.36(c)(3), "Surveillance requirements," which requires that SRs be established to ensure that the necessary quality of components is maintained, that facility operation will be within safety limits, and that the LCOs will be met.
- 10 CFR 50.55a(f), "lnservice testing requirements," requires, in part, that lnservice Testing (1ST) of certain American Society of Mechanical Engineers (ASME) Code Class 1, 2, and 3 components must meet the requirements of the ASME Operation and Maintenance of Nuclear Power Plants (OM Code) and applicable addenda, except where alternatives have been authorized pursuant to paragraphs (a)(3)(i) or (a)(3)(ii).
- Regulatory Guide (RG) 1.118, 3 "Periodic Testing of Electrical Power and Protection Systems," provides a regulatory position replacement description for a logic system functional test. The logic system functional test does not have to include the actuated device, to verify operability. Simultaneous testing of the system from the sensor to the actuated equipment may not be practical, and thus a system design shall provide an overlap testing capability as part of the periodic surveillance testing procedure. Furthermore the testing of an instrument channel and logic circuits separate from the actuator devises is acceptable.
3.0 TECHNICAL EVALUATION
3.1 Licensee's Basis for the Proposed Changes to TS Surveillance Requirements In the license amendment request submitted by letter dated June 6, 2013, the licensee stated, in part, that:
The SSES Unit 1 and Unit 2 ADS valves are Crosby Dual Function Safety/Relief Valves, Model HB-65-BP. These valves are designed to perform either as a safety valve or as a relief valve. The safety mode of operation (ADS) is independent and separate from the relief mode.
3 ADAMS Accession No. ML003739468.
Each Susquehanna unit utilizes six of the reactor safety/relief valves (S/RVs) as ADS valves to reduce reactor pressure during small breaks in the event of High Pressure Coolant Injection (HPCI) failure. After the reactor vessel pressure is reduced to the capability of the low-pressure systems, Residual Heat Removal (RHR) low pressure coolant injection (LPCI) mode and Core Spray (CS), these low-pressure systems provide inventory makeup so that acceptable post-accident temperatures are maintained. The ADS functions to depressurize the Reactor Coolant System (RCS) to allow the combination of the LPCI and CS operation to inject into the RCS. The ADS valves can be opened automatically or manually.
SR 3.5.1.12 currently verifies that the ADS valves can be manually opened. The Susquehanna set point testing program includes manual actuation of the ADS valves during a bench-test in accordance with the valve control program. After the ADS valves have been tested, reworked and reinstalled in the plant, SR 3.5.1.12 is performed on those ADS valves to manually actuate them (i.e., opens and closes the valves) utilizing the valve actuator.
The ADS (safety mode of operation) is initiated when the increasing static inlet steam pressure overcomes the restraining spring and frictional forces acting against the inlet steam pressure to move the disc in the opening direction.
The relief mode of operation is initiated when an electrical signal is received at any or all of the solenoid valves located on the pneumatic relief-mode actuator assembly. The manual actuation of the ADS valves is initiated from the control room. The solenoid and air control valve open to allow an air source to pressurize the lower side of the piston in the pneumatic cylinder to push it upwards. This action is transmitted through a lever arm and dog pivot mechanism, which in turn pulls the valve lifting nut upwards, thereby opening the valve to allow steam to discharge through the valve. Upon de-energization of the solenoid, the air valve repositions to allow the pressurized air in the cylinder to vent to atmosphere and thus closing the valve.
Experience at other nuclear sites has indicated that repeated manual actuation of the ADS valves can lead to undesirable seat leakage during operation. ADS valve leakage is directed to the primary containment suppression pool, which in turn causes increased suppression pool water temperatures and the need for increased cooling.
Currently, after the S/RVs are removed from the plant, they are sent to an offsite test facility where as-found testing, valve rework, and a certified bench test are performed to demonstrate operation, prior to shipment back to SSES. After the valves are reinstalled in the plant, the ADS valves are tested to meet SR 3.5.1.12 surveillance requirements by manually actuating them from the control room in accordance with plant procedures. The design of the SSES valves was reviewed by both the vendor and PPL. The design appears to be adequate and is not
considered to be a cause for valve seat leakage, as a result of manual operation of the ADS valves.
This proposed change to SR 3.5.1.12 will allow the valve stems to be uncoupled from their actuators to allow testing of the manual actuation electrical circuitry, manual actuation of the solenoid and air control valve, and the operation of the pneumatic cylinder without causing the ADS valve to change position (open).
The ADS valves will continue to be manually actuated during bench-testing at an offsite test facility as a part of certification testing in which the set point for each S/RV is verified prior to installation in the plant. The current practice of replacing a portion of the S/RVs each operating cycle (24 months) will be maintained. A main disk exercise test performed on all S/RVs at least once every 6 years and when the entire valve assembly is shipped to the certified test facility, will ensure that the main disks can freely open.
The only potential for a failure would be a human performance issue related to incorrect reassembly of the valve and actuator. This is a relatively simple procedure that requires removal of two cotter pins and reassembly in accordance with a plant procedure. Independent verification of the valve reassembly is required by the procedure to ensure that the valve is properly reassembled.
The proposed change to SR 3.5.1.12 also requires testing of all manual valve solenoids on a 24 month frequency, rather than a staggered test frequency basis.
This change is beneficial since the operation of the all the actuators will be demonstrated every 24 months.
Therefore, all the components of the ADS will continue to be tested at the current frequency in accordance with the setpoint testing program requirements and this proposed change to SR 3.5.1.12.
In the request for additional information (RAI) response submitted by letter dated January 23, 2014, the licensee stated, in part, that:
The existing note in SR 3.5.1.12 allows waiting until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after reactor steam pressure and flow are adequate to perform the AD[S] valve open test. The note will no longer be necessary when AD[S] valve opening for this surveillance requirement is replaced with an actuator stroke that does not require reactor steam pressure and flow to perform. to the licensee's application dated June 6, 2013, and Attachment 3 to the licensee's RAI response dated January 23, 2014, provided revised TS Bases pages to be implemented with the associated TS changes. These pages were provided for information only and will be revised by the licensee in accordance with the TS Bases Control Program.
3.2 NRC Staff Evaluation of the Proposed Changes toTS SR 3.2.1 SR 3.5.1.12 SURVEILLANCE change The SURVEILLANCE section of SR 3.5.1.12 currently states:
Verify each ADS valve opens when manually actuated.
The licensee proposed to change the SURVEILLANCE section of SR 3.5.1.12 to state:
Verify each ADS valve actuator strokes when manually actuated.
This proposed change to SR 3.5.1.12 would allow the valve stems to be uncoupled from their actuators to allow testing of the manual actuation electrical circuitry, manual actuation of the solenoid and air control valve, and the operation of the pneumatic cylinder, without causing the ADS valve to open. The ADS S/RVs would continue to be manually actuated during bench-testing at an offsite test facility as a part of certification testing in which the set point for each S/RV is verified prior to installation in the plant. The current practice of replacing a portion of the S/RVs each operating cycle would be maintained. A main disk exercise test, performed on all S/RVs at least once every 6 years when the entire valve assembly is shipped to the certified test facility, would ensure that the main disks can freely open. The only potential for a failure would be a human performance issue related to an incorrect reassembly of the valve and actuator.
The licensee stated that it is a relatively simple procedure that requires removal of two cotter pins and reassembly in accordance with a plant procedure. Independent verification of the valve reassembly is required by the procedure to ensure that the valve is properly reassembled.
The NRC staff has received requests forTS changes related to the testing requirements for boiling-water reactor dual-function main steam S/RVs similar to those used for SSES's ADS valves. This set pressure shift can contribute to undesirable seat leakage of the valves during subsequent plant operation. Licensees have received NRC approval to perform testing at a test facility coupled with in-situ tests and other verifications of component performance. The NRC staff has reviewed the licensee's proposed TS changes and agrees that the current TS requirement to perform manual actuation of the ADS valves on reactor steam could cause undesirable valve leakage.
In its response to the NRC staff's RAI, the licensee demonstrated that further cycling of the valves with the actuator not only misaligns the valve's load-bearing parts, but also can upset/shift the S/RVs setpoint from the criteria set forth in the TS. In its RAI response dated January 23, 2014, the licensee listed six licensee event reports that showed a continued pattern and a general lowering of the valve's set pressure.
The current TS SR language requires testing in a manner that verifies that the ADS valve components actuate as designed and discharge lines are not blocked. This test provides assurance that the necessary quality of components is maintained, and that facility operation will be within safety limits. The NRC staff had concerns regarding whether or not ADS valves that have been bench-tested will actuate as designed and that discharge lines are not blocked once the valves are installed. In its RAI response, the licensee stated that its quality assurance
and foreign material exclusion programs provide assurance that the valves and discharge piping remain free of obstructions. The NRC staff finds that the licensee acceptably addressed this concern. The staff determined that the overlapping SRs 3.3.5.1.5, SR 3.5.1.11, and 3.5.1.12 along with bench testing at a certified facility will continue to provide complete testing of the safety function.
SSES is currently in its third 10-year 1ST Interval. The 1998 Edition of the ASME OM Code through the 2000 Addenda is currently applicable. The fourth 10-year 1ST Interval for SSES will commence on June 1, 2014, and continue through May 31, 2024, and SSES will comply with the 2004 Edition of the ASME OM Code through the 2006 Addenda during this time. Both of the aforementioned versions of the Code require only that a sample of S/RVs be setpoint tested in any test period. Furthermore, the ASME OM Code provides fo*r the stroking of S/RV actuators only when setpoint tests or maintenance or repair activities are performed. Therefore, the NRC staff determined that the proposed change to the TS SR meets the requirements of the applicable ASME OM Code.
As noted in the regulatory evaluation in RG 1. 118, the logic system functional test does not have to include the actuated device, to verify operability. Simultaneous testing of the system from the sensor to the actuated equipment may not be practical, and thus a system design shall provide an overlap testing capability. The proposed change to allow detachment of the valve from the actuator under a controlled periodic surveillance testing procedure acceptably falls within the regulations and thus improves system accuracy.
The NRC staff determined that the proposed change will continue to provide assurance that the necessary quality of components will be maintained, that facility operation will be within safety limits, and that the LCO will be met. Therefore, the staff determined that the proposed change to the SURVEILLANCE section of SR 3.5. 1.12 is acceptable.
3.2.2 SR 3.5. 1.12 FREQUENCY change The FREQUENCY section of SR 3.5.1. 12 currently states:
24 months on a STAGGERED TEST BASIS for each valve solenoid The licensee proposed to change the FREQUENCY section of SR 3.5. 1.12 to state:
24 months The proposed change to SR 3.5. 1.12 would also require testing of all valve solenoids on a 24 month frequency rather than a 24 month on a staggered test basis frequency. This change would effectively require operation of all the solenoids every 24 months, which is more frequent testing than is currently required. Therefore, the staff determined that the proposed change to the FREQUENCY section of SR 3.5. 1.12 is acceptable.
3.2.3 SR 3.5.1.12 NOTE change The NOTE located in SR 3.5.1.12 currently states:
Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after reactor steam pressure and flow are adequate to perform the test.
The licensee proposed to delete the NOTE in SR 3.5.1.12.
The NOTE above the current SR 3.5.1.12 is necessary to provide an allowance for plant conditions to be established to test the S/RVs using reactor steam. Given that the proposed change would remove the requirement to test the S/RVs using reactor steam, the NOTE is no longer necessary. Therefore, the staff determined that deletion of the NOTE from SR 3.5.1.12 is acceptable.
3.2.4 Technical Evaluation Conclusion Based on the evaluations in Sections 3.2.1, 3.2.2, and 3.2.3 above, the NRC staff finds that the licensee has demonstrated the adequacy of the proposed changes to SR 3. 5.1.12 for SSES.
The proposed changes provide for testing of the ADS S/RVs to demonstrate adequate relief mode function without the need for actually stroking the ADS S/RVs, thereby reducing the potential for valve seat misalignment and leakage. Furthermore, the NRC staff finds that the proposed changes meet the regulatory requirements of 10 CFR 50.36, because they provide assurance that the necessary quality of components will be maintained, that facility operation will be within safety limits, and that the LCO will be met. Therefore, the NRC staff finds the proposed changes to SR 3.5.1.12 acceptable.
4.0 STATE CONSULTATION
In accordance with the Commission's 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 requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. 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 (78 FR 74183). 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) there is reasonable assurance that such activities will be conducted in compliance with the Commission's 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.
Principal Contributors: J. Billerbeck, NRR K. Sturzebecher, NRR M. Hamm, NRR Date: May 14, 2014
ML14111A052 *via e-mail OFFICE DORL/LPLI-2/PM DORL/LPLI-2/LA DORL!DE/EICB/BC DORLIDE/EPNB/BC NAME JWhited ABaxter