Letter Sequence Response to RAI |
---|
|
|
|
|
---|
Category:Inservice/Preservice Inspection and Test Report
MONTHYEARPLA-8089, Submittal of Revision to Inservice Testing Program Plan2023-12-0505 December 2023 Submittal of Revision to Inservice Testing Program Plan PLA-8019, Nd Refueling Outage Owner'S Activity Report, PLA-80192022-07-13013 July 2022 Nd Refueling Outage Owner'S Activity Report, PLA-8019 PLA-7876, 21st Refueling Outage Owner'S Activity Report (PLA-7876)2020-07-21021 July 2020 21st Refueling Outage Owner'S Activity Report (PLA-7876) PLA-7797, Th Refueling Outage Owner'S Activity Report (PLA-7797)2019-07-0909 July 2019 Th Refueling Outage Owner'S Activity Report (PLA-7797) PLA-7724, 20th Refueling Outage Owner'S Activity Report (PLA-7724)2018-07-23023 July 2018 20th Refueling Outage Owner'S Activity Report (PLA-7724) PLA-7507, Transmittal of 19th Refueling Outage Owner'S Activity Report2016-07-27027 July 2016 Transmittal of 19th Refueling Outage Owner'S Activity Report PLA-7368, Submittal of 17th Refueling Outage Owner'S Activity Report2015-08-11011 August 2015 Submittal of 17th Refueling Outage Owner'S Activity Report PLA-7193, Request to Continue Use of a Risk-Informed Inservice Inspection Alternative in a Proposed Relief Request No. 4RR-01 to the Fourth 10-Year Inservice Inspection Program2014-10-29029 October 2014 Request to Continue Use of a Risk-Informed Inservice Inspection Alternative in a Proposed Relief Request No. 4RR-01 to the Fourth 10-Year Inservice Inspection Program PLA-7232, Th Refueling Outage Owner'S Activity Report2014-08-28028 August 2014 Th Refueling Outage Owner'S Activity Report PLA-7194, Susequehanna Steam Electric Station, Unit 2 - Inservice Testing Program Plan2014-06-18018 June 2014 Susequehanna Steam Electric Station, Unit 2 - Inservice Testing Program Plan PLA-7178, Inservice Inspection Program Plan for the Fourth Ten-Year Interval2014-06-0202 June 2014 Inservice Inspection Program Plan for the Fourth Ten-Year Interval PLA-7179, Snubber Program Plan for the Fourth Ten-Year Inservice Inspection Interval, PLA-71792014-06-0202 June 2014 Snubber Program Plan for the Fourth Ten-Year Inservice Inspection Interval, PLA-7179 PLA-7154, Response to Request for Additional Information on Fourth Ten-Year Inservice Inspection Interval Proposed Relief Requests2014-04-28028 April 2014 Response to Request for Additional Information on Fourth Ten-Year Inservice Inspection Interval Proposed Relief Requests PLA-7092, Withdrawal of Relief Requests 1RR07 and 2RR07 for Third Ten-Year Interval Inservice Testing Program Plans for Susquehanna Ses (SSES) Unit 1 and Unit 2, PLA-70922013-10-10010 October 2013 Withdrawal of Relief Requests 1RR07 and 2RR07 for Third Ten-Year Interval Inservice Testing Program Plans for Susquehanna Ses (SSES) Unit 1 and Unit 2, PLA-7092 PLA-7047, Th Rio Steam Dryer Visual Inspection Report2013-07-25025 July 2013 Th Rio Steam Dryer Visual Inspection Report PLA-6871, Th Refueling Outage Owner'S Activity Report2012-08-30030 August 2012 Th Refueling Outage Owner'S Activity Report PLA-6847, Proposed Relief Request No. 3RR-19 to the Third 10-Year Inservice Inspection Program2012-04-24024 April 2012 Proposed Relief Request No. 3RR-19 to the Third 10-Year Inservice Inspection Program PLA-6814, Request in Accordance with 10 CFR 50.55a(f)(4)(iv) for IST Components to Use Subsequent ASME OM Code Edition and Addenda for the Remainder of the Third Ten-Year IST Interval Revision 1, PLA-68142012-02-13013 February 2012 Request in Accordance with 10 CFR 50.55a(f)(4)(iv) for IST Components to Use Subsequent ASME OM Code Edition and Addenda for the Remainder of the Third Ten-Year IST Interval Revision 1, PLA-6814 PLA-6404, Relief Request 2RR07 for Third Ten-Year Interval Inservice Testing Program Plan2008-08-0505 August 2008 Relief Request 2RR07 for Third Ten-Year Interval Inservice Testing Program Plan PLA-6099, Notification of Changes to Snubber Inspection and Testing Requirements for Third 10-Year Interval In-Service Inspection Program Plan2007-03-19019 March 2007 Notification of Changes to Snubber Inspection and Testing Requirements for Third 10-Year Interval In-Service Inspection Program Plan ML0634501312006-11-30030 November 2006 Fourth Ten-Year Inservice Inspection Interval Request for Alternate (Relief Request 2004-ON-001) PLA-5960, Relief Requests 1RR06 and 2RR06 for Third Ten-Year Interval Inservice Testing Program Plans2005-09-29029 September 2005 Relief Requests 1RR06 and 2RR06 for Third Ten-Year Interval Inservice Testing Program Plans PLA-5905, Reconciliation of the Second 10-Year Interval Inservice Inspection Program Plan, PLA-59052005-05-31031 May 2005 Reconciliation of the Second 10-Year Interval Inservice Inspection Program Plan, PLA-5905 ML0427303382004-09-20020 September 2004 Third Ten Year Inservice Inspection Interval Request for Relief No. 04-ON-006 PLA-5805, Relief Requests 1RR05 and 2RR05 for Third Ten-year Interval Inservice Testing Program Plans for Susquehanna Ses Units 1&22004-09-10010 September 2004 Relief Requests 1RR05 and 2RR05 for Third Ten-year Interval Inservice Testing Program Plans for Susquehanna Ses Units 1&2 ML0421801822004-07-26026 July 2004 Proposed Relief Request No. 3RR-12 to the Third 10-year Inservice Inspection Program PLA-5775, Thirteenth Refueling and Inspection Outage ISI Summary Report2004-07-16016 July 2004 Thirteenth Refueling and Inspection Outage ISI Summary Report PLA-5783, Proposed Relief Request No. 3RR-13 to the Third 10-year Inservice Inspection Program for Plant Units 1 and 2 PLA-57832004-07-14014 July 2004 Proposed Relief Request No. 3RR-13 to the Third 10-year Inservice Inspection Program for Plant Units 1 and 2 PLA-5783 PLA-5753, Response to NRC Request for Additional Information Relating to Relief Request 3RR-032004-05-27027 May 2004 Response to NRC Request for Additional Information Relating to Relief Request 3RR-03 PLA-5743, Supplemental Information for Proposed Relief Requests No. 29 and 30 to the Second 10-Year Inservice Inspection Program for Susquehanna Ses Unit 12004-04-0707 April 2004 Supplemental Information for Proposed Relief Requests No. 29 and 30 to the Second 10-Year Inservice Inspection Program for Susquehanna Ses Unit 1 PLA-5662, Proposed Third Ten-Year Inservice Inspection, Interval Inservice Inspection Program Plan2003-09-16016 September 2003 Proposed Third Ten-Year Inservice Inspection, Interval Inservice Inspection Program Plan PLA-5649, Eleventh Refueling & Inspection Outage ISI Summary Report, PLA-56492003-07-18018 July 2003 Eleventh Refueling & Inspection Outage ISI Summary Report, PLA-5649 PLA-5503, Twelfth Refueling & Inspection Outage ISI Summary Report, Appendix D.2, Modification Group NIS-2 Forms2002-07-19019 July 2002 Twelfth Refueling & Inspection Outage ISI Summary Report, Appendix D.2, Modification Group NIS-2 Forms 2023-12-05
[Table view] Category:Letter type:PLA
MONTHYEARPLA-8096, Response to Request for Additional Information Regarding Proposed Relief Request for the Fifth 10-Year Inservice Test Program Interval2024-01-0404 January 2024 Response to Request for Additional Information Regarding Proposed Relief Request for the Fifth 10-Year Inservice Test Program Interval PLA-8077, Emergency Plan Revision 67 (PLA-8077)2023-12-27027 December 2023 Emergency Plan Revision 67 (PLA-8077) PLA-8089, Submittal of Revision to Inservice Testing Program Plan2023-12-0505 December 2023 Submittal of Revision to Inservice Testing Program Plan PLA-8084, Application to Revise Technical Specifications to Adopt TSTF-568, Revise Applicability of BWR TS 3.6.2.5 and TS 3.6.3.22023-11-29029 November 2023 Application to Revise Technical Specifications to Adopt TSTF-568, Revise Applicability of BWR TS 3.6.2.5 and TS 3.6.3.2 PLA-8091, Response to Request for Additional Information Regarding Proposed Relief Request for the Fifth 10-Year Inseervice Inspection Interval (PLA-8091)2023-11-0808 November 2023 Response to Request for Additional Information Regarding Proposed Relief Request for the Fifth 10-Year Inseervice Inspection Interval (PLA-8091) PLA-8082, Proposed Amendment to Licenses NPF-14 and NPF-22: Application to Revise Technical Specifications to Adopt TSTF-563, Revise Instrument Testing Definitions to Incorporate the Surveillance Frequency Control Program2023-11-0202 November 2023 Proposed Amendment to Licenses NPF-14 and NPF-22: Application to Revise Technical Specifications to Adopt TSTF-563, Revise Instrument Testing Definitions to Incorporate the Surveillance Frequency Control Program PLA-8080, Proposed Relief for Valve 251130 (PLA-8080)2023-08-14014 August 2023 Proposed Relief for Valve 251130 (PLA-8080) PLA-8074, Proposed Relief Request for the Fifth 10-Year Inservice Test Program Interval2023-08-0303 August 2023 Proposed Relief Request for the Fifth 10-Year Inservice Test Program Interval PLA-8076, Unit 2 - 21st Refueling Outage Owner'S Activity Report (PLA-8076)2023-07-20020 July 2023 Unit 2 - 21st Refueling Outage Owner'S Activity Report (PLA-8076) PLA-8078, Submittal of Unit 2 Cycle 22 Core Operating Limits Report, Revision 1, PLA-80782023-07-0505 July 2023 Submittal of Unit 2 Cycle 22 Core Operating Limits Report, Revision 1, PLA-8078 PLA-8054, Proposed Amendment to Licenses NPF-14 and NPF-22: Remove Control Rod Operability Separation Criteria and Replace Reference to Banked Position Withdrawal Sequence with the Analyzed Rod Position Sequence2023-06-0808 June 2023 Proposed Amendment to Licenses NPF-14 and NPF-22: Remove Control Rod Operability Separation Criteria and Replace Reference to Banked Position Withdrawal Sequence with the Analyzed Rod Position Sequence PLA-8073, Proposed Relief Request for the Fifth 10-Year Inservice Inspection Interval2023-06-0101 June 2023 Proposed Relief Request for the Fifth 10-Year Inservice Inspection Interval PLA-8067, Notification of Completion of Emergence from Bankruptcy (PLA-8067)2023-05-17017 May 2023 Notification of Completion of Emergence from Bankruptcy (PLA-8067) PLA-8064, Response to NRC Regulatory Issue Summary 2023-01 (PLA-8064)2023-05-17017 May 2023 Response to NRC Regulatory Issue Summary 2023-01 (PLA-8064) PLA-8066, Notification of Planned Closing Date and Information Identified in March 30, 2023 Order, PLA-80662023-05-0808 May 2023 Notification of Planned Closing Date and Information Identified in March 30, 2023 Order, PLA-8066 PLA-8053, Radiation Exposure Information and Reporting System2023-04-27027 April 2023 Radiation Exposure Information and Reporting System PLA-8058, Annual Radiological Environmental Operating Report (PLA-8058)2023-04-26026 April 2023 Annual Radiological Environmental Operating Report (PLA-8058) PLA-8041, Radioactive Effluent Release Report and Offsite Dose Calculation Manual (PLA-8041)2023-04-25025 April 2023 Radioactive Effluent Release Report and Offsite Dose Calculation Manual (PLA-8041) PLA-8047, 2022 Annual Environmental Operating Report (Nonradiological), PLA-80472023-04-19019 April 2023 2022 Annual Environmental Operating Report (Nonradiological), PLA-8047 PLA-8062, Supplement to Relief Request 4RR-10 Relief from Code Seal Weld Requirement for Valve 252F007B, PLA-80622023-04-11011 April 2023 Supplement to Relief Request 4RR-10 Relief from Code Seal Weld Requirement for Valve 252F007B, PLA-8062 PLA-8061, Relief Request 4RR-10 Relief from Code Seal Weld Requirement for Valve 25F007B, PLA-80612023-04-10010 April 2023 Relief Request 4RR-10 Relief from Code Seal Weld Requirement for Valve 25F007B, PLA-8061 PLA-8060, Submittal of Unit 2 Cycle 22 Core Operating Limits Report (PLA-8060)2023-03-30030 March 2023 Submittal of Unit 2 Cycle 22 Core Operating Limits Report (PLA-8060) PLA-8057, Application for Order Approving Indirect Transfer of Control of Licenses and Approving Conforming License Amendments- Supplemental Information, PLA-80572023-03-15015 March 2023 Application for Order Approving Indirect Transfer of Control of Licenses and Approving Conforming License Amendments- Supplemental Information, PLA-8057 PLA-8052, (Sses), Proof of Financial Protection and Guarantee of Payment of Deferred Premiums2023-02-13013 February 2023 (Sses), Proof of Financial Protection and Guarantee of Payment of Deferred Premiums PLA-8048, Response to Request for Additional Information Regarding License Amendment Requesting Temporary Addition of Analyzed Rod Position Sequence2023-01-14014 January 2023 Response to Request for Additional Information Regarding License Amendment Requesting Temporary Addition of Analyzed Rod Position Sequence PLA-8042, Proposed Emergency Amendment to License NPF-22: Temporary Addition of Analyzed Rod Position Sequence2023-01-10010 January 2023 Proposed Emergency Amendment to License NPF-22: Temporary Addition of Analyzed Rod Position Sequence PLA-8039, Application for Order Approving Indirect Transfer of Control of License Amendments - Supplemental Information2022-12-22022 December 2022 Application for Order Approving Indirect Transfer of Control of License Amendments - Supplemental Information PLA-8038, Notification of Petition for Bankruptcy (PLA-8038)2022-12-14014 December 2022 Notification of Petition for Bankruptcy (PLA-8038) PLA-8036, Registration for the Use of Spent Fuel Storage Casks 203, 202, and 204, PLA-80362022-11-30030 November 2022 Registration for the Use of Spent Fuel Storage Casks 203, 202, and 204, PLA-8036 PLA-8035, Registration for the Use of Spent Fuel Storage Casks 205, 200, and 201, PLA-80352022-11-0808 November 2022 Registration for the Use of Spent Fuel Storage Casks 205, 200, and 201, PLA-8035 PLA-8031, Emergency Plan Revision 66 (PLA-8031)2022-11-0707 November 2022 Emergency Plan Revision 66 (PLA-8031) PLA-8032, Application for Order Approving Indirect Transfer of Control of Licenses and Approving Conforming License Amendments - Supplemental Information (PLA-8032)2022-10-28028 October 2022 Application for Order Approving Indirect Transfer of Control of Licenses and Approving Conforming License Amendments - Supplemental Information (PLA-8032) PLA-8026, Biennial 10 Crf 50.59 and 72.48 Summary Report and Changes to Regulatory Commitment (PLA-8026)2022-10-19019 October 2022 Biennial 10 Crf 50.59 and 72.48 Summary Report and Changes to Regulatory Commitment (PLA-8026) PLA-8015, Application for Order Approving Indirect Transfer of Control of Licenses2022-09-29029 September 2022 Application for Order Approving Indirect Transfer of Control of Licenses PLA-8030, Evacuation Time Estimate Report PLA-80302022-09-15015 September 2022 Evacuation Time Estimate Report PLA-8030 PLA-8025, Supplement to License Amendment to Revise Reactor Steam Dome Pressure - Low Instrumentation Function Allowable Value2022-08-10010 August 2022 Supplement to License Amendment to Revise Reactor Steam Dome Pressure - Low Instrumentation Function Allowable Value PLA-8019, Nd Refueling Outage Owner'S Activity Report, PLA-80192022-07-13013 July 2022 Nd Refueling Outage Owner'S Activity Report, PLA-8019 PLA-8013, Response to Request for Additional Information Regarding License Amendment Requesting Adoption of TSTF-505, Revision 2 PLA-80132022-06-27027 June 2022 Response to Request for Additional Information Regarding License Amendment Requesting Adoption of TSTF-505, Revision 2 PLA-8013 PLA-8012, 10 CFR 50.46 Annual Report2022-06-10010 June 2022 10 CFR 50.46 Annual Report PLA-8005, Response to Request for Additional Information Regarding License Amendment to Revise Reactor Steam Dome Pressure - Low Instrumentation Function Allowable Value (PLA-8005)2022-05-23023 May 2022 Response to Request for Additional Information Regarding License Amendment to Revise Reactor Steam Dome Pressure - Low Instrumentation Function Allowable Value (PLA-8005) PLA-8001, Radiation Exposure Information and Reporting System - PLA-80012022-04-28028 April 2022 Radiation Exposure Information and Reporting System - PLA-8001 PLA-7987, Radioactive Effluent Release Report and Offsite Dose Calculation Manual - (PLA-7987)2022-04-26026 April 2022 Radioactive Effluent Release Report and Offsite Dose Calculation Manual - (PLA-7987) PLA-7986, 2021 Annual Environmental Operating Report (Nonradiological) Docket No. 50-387, PLA-79862022-04-26026 April 2022 2021 Annual Environmental Operating Report (Nonradiological) Docket No. 50-387, PLA-7986 PLA-7985, Annual Radiological Environmental Operating Report2022-04-22022 April 2022 Annual Radiological Environmental Operating Report PLA-7883, Proposed Amendment to Licenses NPF-14 and NPF-22: Relocate Technical Specification Unit Staff Qualification Requirements to Quality Assurance Program (PLA-7883)2022-03-31031 March 2022 Proposed Amendment to Licenses NPF-14 and NPF-22: Relocate Technical Specification Unit Staff Qualification Requirements to Quality Assurance Program (PLA-7883) PLA-7995, Property Insurance Program (PLA-7995)2022-03-30030 March 2022 Property Insurance Program (PLA-7995) PLA-7998, Submittal of Unit 1 Cycle 23 Core Operating Limits Report and Reload Safety Analysis Report2022-03-29029 March 2022 Submittal of Unit 1 Cycle 23 Core Operating Limits Report and Reload Safety Analysis Report PLA-7991, Proof of Financial Protection and Guarantee of Payment of Deferred Premium2022-03-24024 March 2022 Proof of Financial Protection and Guarantee of Payment of Deferred Premium PLA-7984, Supplement to License Amendment Requesting Adoption of TSTF-505, Revision 22022-03-0808 March 2022 Supplement to License Amendment Requesting Adoption of TSTF-505, Revision 2 PLA-7962, Application to Revise Technical Specifications to Adopt TSTF-564, Safety Limit MCPR PLA-79622022-01-0505 January 2022 Application to Revise Technical Specifications to Adopt TSTF-564, Safety Limit MCPR PLA-7962 2024-01-04
[Table view] |
Text
Jon A. Franke PPL Susquehanna, LLC Site Vice President 769 Salem Boulevard Berwick, PA 18603 Tel. 570.542.2904 Fax 570.542.1504 jfranke@ pplweb.com APR 2 8 2014 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 SUSQUEHANNA STEAM ELECTRIC STATION RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION ON FOURTH TEN-YEAR INSERVICE INSPECTION INTERVAL PROPOSED RELIEF REQUESTS Docket No 50-387 PLA-7154 and No. 50-388
References:
- 1. PPL Letter (PIA-7052), "Proposed Relief Requests for the Fourth Ten- Year Inservice Inspection Interval for Susquehanna Units 1 and 2," dated August 30, 2013 (Accession ML13247A167).
- 2. NRC Letter, "Request for Additional Information Regarding Relief Requests for the Fourth 10-Year Inservice Inspection Interval (TAC Nos. MF2705, MF2706, MF2709, and MF2710)," dated December 19, 2013 (Accession ML13338A442).
- 3. PPL Letter (PIA-7126), "Response to Request for Additional Information on Fourth Ten-Year Inservice Inspection Interval Proposed Relief Requests," dated January 31, 2014 (Accession ML14031A081).
The purpose of this letter is for PPL Susquehanna, LLC (PPL) to provide clarification to the information previously provided in response to NRC question RAI 4RR-06 1 from Reference 2. The NRC requested this clarification in a discussion on March 28, 2014, at which time PPL agreed to provide the additional information.
Additionally, PPL determined on April 3, 2014, that the requested alternative 4RR-07 for the reactor pressure vessel head flange seal leak detection line visual examination incorrectly described the line as Code Class 2. This line is in fact a Code Class 1 component.
The changes necessary to 4RR-06 1 in response to the RAI that have been discussed with the NRC are described in Attachment 1. The change in Code Class described in 4RR-07 is provided in Attachment 2 as 4RR-07, Revision 1, which replaces the original revision in its entirety. The station's Corrective Action Program addresses the condition in 4RR-07 for evaluation, and this response supports the current NRC review of the proposed alternative requests in Reference 1.
Document Control Desk PLA-7154 The attachments to this provide a response to the NRC RAI 4RR-06 1, which replaces the original response provided in Reference 3. Additionally, the revised 4RR-07, Revision 1, is provided in Attachment 2.
There are no new regulatory commitments associated with this response.
If you have any questions or require additional information, please contact Mr. Duane L. Filchner (570) 542-6501.
J. * .Franke : Response to Request for Additional Information : Relief Request 4RR-07, Revision 1 Copy: NRC Region I Mr. J. Greives, NRC Sr. Resident Inspector Mr. J. Whited, NRC Project Manager Mr. L. Winker, PA DEP/BRP
Attachment 1 to PLA-7154 Response to Request for Additional Information
Attachment 1 to PLA-7154 Page 1 of2 Response to Request for Additional Information By letter dated August 30, 2013, (I) PPL Susquehanna, LLC (PPL the licensee), submitted a set of Alternative Requests from the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code),Section XI for the Fourth Ten-Year Inservice Inspection (lSI)
Interval at Susquehanna Steam Electric Station (SSES) Units 1 and 2. The NRC requested additional information (RAI) in a letter dated December 19, 2013. (Z) PPL provided the additional information requested in a letter dated January 31, 2014. (3) The additional information provided in this attachment is for the purpose of clarifying the response previously provided in Reference 3 to the NRC question 4RR-06 1. This will replace the response in its entirety, related to the requirements for inspection of snubbers, supports and attachments.
Additionally, and as described in the balance of this Attachment, PPL is correcting information previously submitted in Reference 1, in an alternative request 4RR-07 for the reactor pressure vessel head flange seal leak detection line visual examination. This is discussed further below, and Revision 1 of 4RR-07 is provided in Attachment 2.
RAI 4RR-06 1:
Based on information in the relief request, two different ASME Codes will be used. Verify that for snubbers (pin-to-pin), ASME OM Code 2004 Edition with 2005 and 2006 Addenda and for the snubber supports and attachments, ASME Section XI 2007 Edition with 2008 addenda will be used.
PPL's Response:
Examinations of snubbers and their associated supports will be administered and scheduled per the PPL Snubber Program under the requirements of the ASME OM Code 2004 Edition through the 2006 Addenda. Examination of the snubber attachments is required per ASME Section XI Code 2007 Edition with the 2008 Addenda and the PPL lSI Program. Visual examinations of the associated attachments will be performed at the same time as the required visual examination of the snubber. This is being done as a dose and time saving effort. For both examinations, a VT-3 qualified inspector will be performing the examination. Examination of 100 percent of the snubber attachments exceeds Code requirements as defined in the ASME Section XI Code.
(1) PPL Letter (PLA-7052), "Proposed Relief Requests for the Fourth Ten-Year In service Inspection Interval for Susquehanna Units 1 and 2," dated August 30,2013 (Accession ML13247A167).
(2) NRC Letter, "Request for Additional Information Regarding Relief Requests for the Fourth 10-Year Inservice Inspection Interval (TAC Nos. MF2705, MF2706, MF2709, and MF2710)," dated December 19, 2013 (Accession ML13338A442).
(3) PPL Letter (PLA-7126), "Response to Request for Additional Information on Fourth Ten-Year Inservice Inspection Interval Proposed Relief Requests," dated January 31, 2014 (Accession ML14031A081).
Attachment 1 to PLA-7154 Page 2 of2 4RR-07, Revision 1:
The station's Corrective Action Program addresses a condition in the alternative request 4RR-07, Revision 0, where the reactor pressure vessel head flange seal leak detection line is described incorrectly as a Code Class 2 component, when it is in fact a Code Class 1 component. The request has also been revised further to replace 10 CFR 50.55a(a)(3)(i) provisions for an alternative with an equivalent level of quality and safety, with a request for an alternative pursuant to 10 CFR 50.55a(a)(3)(ii), on the basis that compliance with the Code specified pressure requirement to test the leak-off lines at system operating pressure would result in hardship or unusual difficulty without a compensating increase in the level of quality or safety. provides Revision 1 of 4RR-07 to replace Revision 0, in its entirety. This corrects the information and uses the appropriate Reference to Table IWB-2500-1 and Examination Category B-P. The corrected information also results in the leakage test being required each refueling outage. Accordingly, the alternative required examination will be performed with the frequency specified in Table IWB-2500-1 for a System Leakage Test (once each refueling outage).
Attachment 2 to PLA-7154 Relief Request 4RR-07, Revision 1
RELIEF REQUEST NUMBER: 4RR-07 REVISION 1 (Page 1 of 3)
COMPONENT IDENTIFICATION Code Class: 1
Reference:
Table IWB-2500-1 Examination Category: B-P Item Number: B15.10
==
Description:==
Request for Alternative from System Leakage Testing Reactor Pressure Vessel Head Flange Seal Leak Detection System Component Number: Flange Seal Leak Detection Line Pressure Retaining Components APPLICABLE CODE EDITION AND ADDENDA The Susquehanna Steam Electric Station's will start the 4th 10-Year Inservice Inspection (IS I)
Program Interval on June 1, 2014 and is required to follow the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code,Section XI, "Rules for Inservice Inspection of Nuclear Power Plant Components," (ASME Section XI), 2007 Edition through the 2008 Addenda.
CODE REQIDRE:MENT Table IWB-2500-1 requires a VT-2 visual examination to be performed during a system leakage test each refueling outage. Subparagraph IWB-5221(a) requires that the system leakage test be performed at a pressure not less than the pressure corresponding to 100 percent rated reactor power.
BASIS FOR RELIEF Pursuant to 10CFR 50.55a(a)(3)(ii), relief is requested on the basis that compliance with the Code specified pressure requirement to test the leak-off lines at system operating pressure would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
The Reactor Pressure Vessel Head Flange Leak Detection Line is separated from the reactor pressure boundary by one passive membrane, a silver plated 0-ring located on the vessel flange. A second 0-ring is located on the opposite side of the tap in the vessel flange (See Figure 4RR-07.1).
This line is required during plant operation in order to indicate failure of the inner flange seal 0-ring. Failure of the inner 0-ring is the only condition under which this line is pressurized.
The configuration of this system precludes manual testing while the vessel head is removed because the odd configuration of the vessel tap (See Figure 4RR-07.1), combined with the small size of the tap and the high test pressure requirement (1035 psig minimum), prevents the tap in the flange from being temporarily plugged. The opening in the flange is only 3116 of an inch in diameter and is smooth walled making a high pressure temporary seal very difficult. Failure of this seal could possibly cause ejection of the device used for plugging into the vessel.
A pneumatic test performed with the head installed is precluded due to the configuration of the top head. The top head of the vessel contains two grooves that hold the 0-rings. The 0-rings are held in place by a series of retainer clips. The retainer clips are contained in a recessed cavity in the top
RELIEF REQUEST NUMBER: 4RR-07 REVISION 1 (Page 2 of 3)
BASIS FOR RELIEF (Continued) head (See Figure 4RR-07.1). If a pressure test was performed from the leak-off line side with the head on, the inner 0-ring would be pressurized in a direction opposite to what it would see in normal operation. This test pressure would result in a net inward force on the 0-ring that would tend to push it into the recessed cavity that houses the retainer clips. The 0-ring material is a thin silver plating and could very likely be damaged by this deformation into the recessed areas on the top head.
In addition to the problems associated with the 0-ring design that preclude this testing it is also questionable whether a pneumatic test is appropriate for this line. Although the line will initially contain steam if the inner 0-ring leaks, the system actually detects leakage rate by measuring the level of condensate in a collection chamber. This would make the system medium water at the level switch. Finally, the use of a pneumatic test performed at a minimum of 1035 psig would represent an unnecessary risk in safety for the inspectors and test engineers in the unlikely event of a test failure, due to the large amount of stored energy contained in air pressurized to 1035 psig.
System leakage testing of this line is precluded because the line will only be pressurized in the event of a failure of the inner 0-ring. It is extremely impractical to purposely fail the inner 0-ring in order to perform a test.
Based on the above, SSES requests relief from the ASME Section XI requirements for system leakage testing of the Reactor Pressure Vessel Head Flange Seal Leak Detection System.
PROPOSED ALTERNATE EXAMINATIONS A VT-2 visual examination will be performed on the accessible portions of the line after the refueling cavity has been filled to its normal refueling water level for at least 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. For sections of the line that are inaccessible for direct VT-2 visual examination, examination will include the surrounding area underneath the piping for evidence of leakage, as permitted by IW A-5241(b). The static head developed due to the water above the vessel flange during flood-up will allow for the detection of any gross indications in the line. This examination will be performed with the frequency specified by Table IWB-2500-1 for a System Leakage Test (once each refueling outage).
DURATION OF PROPOSED ALTERNATIVE This relief will remain in effect for the duration of the Fourth 10 year interval of the lSI Program for SSES Units 1 and 2 (June 1, 2024).
PRECEDENTS None
RELIEF REQUEST NUMBER: 4RR-07 REVISION 1 (Page 3 of 3)
FIGURE 4RR-07.1 FLANGE SEAL LEAK DETECTION LINE DETAIL METALLIC "0" RINGS TO DRYWELL--+
DRILLED PASSAGE REACTOR VESSEL---+