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MONTHYEARML15104A5342015-04-14014 April 2015 E-mail from J. Whited to D. Filchner SSES Acceptance of LAR Request to Adopt EAL Scheme Pursuant to NEI 99-01 Rev 6 Project stage: Acceptance Review ML15230A0462015-08-17017 August 2015 Draft RAIs SSES EAL Scheme Change LAR in Accordance with NEI 99-01 Rev 6 Project stage: Draft RAI ML15229A4052015-08-17017 August 2015 E-mail from J. Whited to J. Jennings Draft RAIs Regarding SSES Request to Adopt EAL Scheme Change in Accordance with NEI 99-01 Rev 6 Project stage: Draft RAI ML15230A0802015-08-26026 August 2015 Request for Additional Information Regarding License Amendment Request to Adopt NEI 99-01, Revision 6, EAL Scheme Change Project stage: RAI ML15264A6872015-09-21021 September 2015 SSES Slide Presentation in Support of 9/23 Public Meeting EAL Scheme Change LAR Project stage: Meeting ML15264A6932015-09-21021 September 2015 SSES EAL Scheme Bases Document Redline Strike-out in Support of 9/23 Public Meeting Project stage: Meeting ML15278A4922015-10-0909 October 2015 Summary of Meeting with Susquehanna Nuclear, LLC on the Emergency Action Level Scheme Change Submittal for a License Amendment for Susquehanna Steam Electric Station, Units 1 and 2 Project stage: Meeting ML15296A0602015-10-16016 October 2015 Enclosure 3, Revised (Clean) Copy of the SSES EAL Basis Document Which Includes the Changes Made in Enclosure 2 Project stage: Other ML15296A0592015-10-16016 October 2015 Enclosure 1, Response to NRC Request for Additional Information Regarding License Amendment Request to Adopt Nuclear Energy Institute 99-0 1, Revision 6 and Enclosure 2, Mark-up of the Changes Made to the SSES EAL Basis.. Project stage: Response to RAI PLA-7393, Submittal of Response to NRC Request for Additional Information Regarding License Amendment Request to Adopt NEI 99-01, Revision 6, Emergency Action Level Scheme Change2015-10-16016 October 2015 Submittal of Response to NRC Request for Additional Information Regarding License Amendment Request to Adopt NEI 99-01, Revision 6, Emergency Action Level Scheme Change Project stage: Response to RAI PLA-7425, Supplemental Information to License Amendment Request to Adopt Emergency Action Level Scheme Pursuant to NEI 99-01, Revision 62016-01-0808 January 2016 Supplemental Information to License Amendment Request to Adopt Emergency Action Level Scheme Pursuant to NEI 99-01, Revision 6 Project stage: Supplement 2015-08-17
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Category:Request for Additional Information (RAI)
MONTHYEARML23334A1502023-11-30030 November 2023 NRC Request for Additional Information Re. Susquehanna Relief Request RR-02 ML23277A0412023-10-0505 October 2023 Notification of Commercial Grade Dedication Inspection (05000387/2024011 and 05000388/2024011) and Request for Information ML23013A2082023-01-13013 January 2023 Request for Additional Information ML22146A1022022-05-26026 May 2022 Information Request for the Cyber Security Baseline Inspection, Notification to Perform Inspection 05000387/2022404 and 05000388/2022404 ML22146A0742022-05-25025 May 2022 NRR E-mail Capture - NRC Request for Additional Information - Susquehanna License Amendment Request ML22111A3132022-04-21021 April 2022 NRR E-mail Capture - NRC Request for Additional Information - Susquehanna License Amendment Request ML22041A1562022-02-10010 February 2022 Information Request for a Triennial Baseline Design Bases Assurance Inspection (Team); Inspection Report 05000387/2022013 and 05000388/2022013 ML21316A1242021-11-18018 November 2021 Supplemental Information Needed for Acceptance of Requested Licensing Action Regarding Emergency Core Cooling Technical Specifications ML20056E4392020-02-21021 February 2020 Ti 2515/194 Inspection Documentation Request ML20010D2012020-01-0909 January 2020 Request for Additional Information Related to Request to Allow Application of Framatome Analysis Methodologies Necessary to Support a Planned Transition to Atrium 11 Fuel Under Maximum ML19319B1922019-11-14014 November 2019 NRR E-mail Capture - RAI for Susquehanna, 1 and 2 License Amendment Request - Replace the Emergency Service Water System and Residual Heat Removal Service Water System ML19319A0092019-11-14014 November 2019 NRR E-mail Capture - Draft RAI for SSES Units 1 and 2 LAR to Replace ESW Piping ML19128A0232019-05-0707 May 2019 Request for Additional Information: Susquehanna Steam Electric Station, Units 1 and 2 License Amendment Request for ESW Piping Replacement ML18352B1832018-12-13013 December 2018 Enclosurequest for Additional Information (Letter to K. Cimorelli Request for Additional Information Regarding Susquehanna Nuclear, Llc'S Decommissioning Funding Plan Update for Susquehanna Steam Electric Station Independent Spent Fuel Stor ML17180A2002017-07-0707 July 2017 Request for Additional Information Regarding License Amendment Request to Revise Diesel Generator Surveillance Requirements with New Steady State Voltage and Frequency Limits ML17059D2142017-03-0606 March 2017 Susquehanna Steam Electric Station - Supplemental Information Needed for Acceptance of Requested Licensing Action Re: License Amendment Request to Revise Diesel Generator Surveillance Requirements with New Steady State Voltage Frequency Limits ML16251A0652016-09-0909 September 2016 Susquehanna Steam Electric Station, Unit 2 - RAI Regarding Temporary Change of Unit 2, Technical Specifications 3.7.1 & 3.8.7 to Allow Replacement of Unit 1, 480 Volt Engineered Safeguard System Load Center Transformers(CAC No. MF7298) ML16245A2052016-09-0101 September 2016 Draft Request for Additional Information Replacement of Load Center Transformers ML16243A0952016-08-30030 August 2016 Draft Request for Additional Information Application for Approval of Indirect Transfer of Control of Licenses ML16060A2302016-03-24024 March 2016 Acceptance of Requested Licensing Action License Amendment Request for Temporary Change of Unit 2 Technical Specifications 3.71 and 3.87 to Allow Replacement of Unit 1 480V Ess Load Center Transformers ML15316A5632015-11-13013 November 2015 Request for Additional Information Regarding Proposed Relief Requests for the Third 10-Year Inservice Inspection Interval(Cac Nos. MF6302 Through MF6307) ML15292A1782015-10-15015 October 2015 TSTF-425 LAR Draft 3rd RAIs ML15230A0802015-08-26026 August 2015 Request for Additional Information Regarding License Amendment Request to Adopt NEI 99-01, Revision 6, EAL Scheme Change ML15209A9742015-08-24024 August 2015 Request for Additional Information License Amendment Request to Adopt Technical Specifications Task Force Traveler (TSTF)-425 ML15229A2002015-08-17017 August 2015 E-mail from J. Whited to J. Jennings SSES Draft TSTF-425 RAIs ML15229A2092015-08-17017 August 2015 SSES Draft Request for Additional Information Licensee Request to Adopt TSTF-425 ML15230A0462015-08-17017 August 2015 Draft RAIs SSES EAL Scheme Change LAR in Accordance with NEI 99-01 Rev 6 ML15183A3502015-07-0202 July 2015 SSES Relief Requests 3RR-19, 3RR-20, and 3RR-21 Draft Identified Information Insufficiencies (TAC Nos. MF6302 Through MF6307) ML15103A3962015-05-22022 May 2015 Request for Additional Information License Amendment Request to Adopt Technical Specifications Task Force Traveler (TSTF)-425 (TAC Nos. MF5151 and MF5152) ML15128A5162015-05-0808 May 2015 SSES Draft Request for Additional Information LAR for Implementation of TSTF-425 ML15128A5092015-05-0808 May 2015 E-mail from J. Whited to D. Filchner SSES Draft Request for Additional Information LAR for Implementation of TSTF-425 ML15008A4702015-01-30030 January 2015 Request for Additional Information Request to Revise Technical Specification 3.4.10, RCS Pressure and Temperature (P/T) Limits. ML15016A2742015-01-16016 January 2015 Draft RAIs License Amendment Request for Change to TS 3.4.10 P/T Limits (TAC Nos. MF4597 and MF45980) ML15016A2722015-01-16016 January 2015 E-mail from J. Whited to D. Filchner Draft RAIs License Amendment Request for Change to TS 3.4.10 P/T Limits (TAC Nos. MF4597 and MF45980) ML14343A9842015-01-0808 January 2015 Request for Additional Information Relief Request 4RR-01 ML14345A2412014-12-16016 December 2014 Request for Additional Information Request for Order Approving Indirect Transfer of Control and Conforming License Amendments ML14346A1022014-12-12012 December 2014 Draft License Transfer Revised 2nd RAIs ML14346A4022014-12-12012 December 2014 Draft RAIs Relief Request 4RR-01 ML14346A4012014-12-12012 December 2014 E-mail from J. Whited to D. Filchner Susquehanna Steam Electric Station Draft RAIs Relief Request 4RR-01 ML14346A1002014-12-12012 December 2014 E-mail from J. Whited to R. Sgarro Susquehanna Steam Electric Station Draft License Transfer Revised 2nd RAIs ML14342A8082014-12-0808 December 2014 E-mail from J. Whited to R. Sgarro (PPL) SSES Units 1 and 2 Draft RAIs Application for Approval of Indirect Transfer of Control of Licenses ML14342A8132014-12-0808 December 2014 SSES Units 1 and 2 Draft RAIs Application for Approval of Indirect Transfer of Control of Licenses ML14233A2772014-08-27027 August 2014 Request for Additional Information License Amendment Request to Change the Low Pressure Safety Limit ML14233A3392014-08-21021 August 2014 Draft RAIs for Susquehanna Steam Electric Station Units 1 and 2 License Amendment Request for Changes to the Low Pressure Safety Limits ML13298A7582014-03-0707 March 2014 Request for Additional Information Regarding Request for Changes to Technical Specification Surveillance Requirements to Increase Diesel Generator Minimum Steady State Voltage (TAC ME9607 and ME960) ML13298A7812014-03-0707 March 2014 Request for Additional Information Regarding Request for Changes to Technical Specification Surveillance Requirement 3.8.1.19 to Increase Diesel Generator Minimum Steady State Frequency (TACs ME9609. ML14013A1502014-01-31031 January 2014 Request for Additional Information Regarding Relief Requests for the Fourth 10-Year Inservice Testing Interval ML14024A4752014-01-24024 January 2014 Draft 4th IST RRs 1RR05 RAIs ML13338A4422013-12-19019 December 2013 Request for Additional Information Regarding Relief Requests for the Fourth Ten-Year Inservice Inspection Interval ML13312A9142013-12-18018 December 2013 Request for Additional Information Regarding Request for Changes to Technical Specification Surveillance Requirements 3.5.1.12 2023-11-30
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DRAFT REQUESTS FOR ADDITIONAL INFORMATION LICENSE AMENDMENT REQUEST EMERGENCY ACTION LEVEL SCHEME CHANGE SUSQUEHANNA STEAM ELECTRIC STATION, UNITS 1 AND 2 DOCKET NOS. 50-387 AND 50-388 By letter dated March 19, 2015,1 Susquehanna Nuclear, LLC (Susquehanna, the licensee),2 requested approval for an emergency action level (EAL) scheme change for the Susquehanna Steam Electric Station, Units 1 and 2 (SSES). SSES proposes to revise their current EAL scheme to one based upon Revision 6 to Nuclear Energy Institute (NEI) document NEI 99-01, Development of Emergency Action Levels for Non-Passive Reactors.3 The requests for additional information (RAIs) listed below are needed to support the NRC staffs completion of the technical review of the proposed EAL scheme change.
RAI-1 Section 4.3, Instrumentation Used for EALs, to NEI 99-01, Revision 6, states, in part:
Scheme developers should ensure that specific values used as EAL setpoints are within the calibrated range of the referenced instrumentation... Please confirm that all setpoints and indications used in the proposed EAL scheme are within the calibrated range(s) of the stated instrumentation and that the resolution of the instrumentation is appropriate for the setpoint/indication.
RAI-2 Section 2.1, Background, and Section 4.0, References, of the licensees license amendment request (LAR) refer to ADAMS Accession Number ML110240324 as the document endorsed by the NRC, when in fact it is ML12326A805, which is part of the endorsement package contained within ML13091A209. Please revise accordingly to specify either one of these ADAMS numbers to reference the correct NRC-endorsed EAL scheme development guidance.
RAI-3 Section 2.5, Technical Bases Information, of the LAR states, in part, that:
A Plant-specific basis section provides Susquehanna-relevant information concerning the EAL. This is followed by a Generic basis section that 1
Agencywide Documents Access and Management System (ADAMS) Accession Number ML15091A657.
2 This License Amendment Request was submitted by PPL Susquehanna, LLC, however, on April 10, 2015, the NRC staff issued an Order approving the transfer of the license of SSES to Talen Energy.
Subsequently, on June 1, 2015, the NRC staff issued an amendment approving a name change of the licensee for SSES to Susquehanna Nuclear, LLC.
3 ADAMS Accession Number ML12326A805.
DRAFT
provides a description of the rationale for the EAL as provided in NEI 99-01 Rev. 6.
Due to the potential that EAL decision-makers may be confused between these two basis sections if the information appears to be inconsistent, please clarify the rational for separate Generic and Plant-specific basis sections when it is acceptable to just have one basis section that is specific to the plant, or revise accordingly.
RAI-4 Section 5.0, Definitions, does not include definitions for the following:
Alert, Notification of Unusual Event (UE),
Site Area Emergency (SAE),
General Emergency (GE),
Emergency Action Level (EAL),
Emergency Classification Level (ECL),
Fission Product Barrier Threshold, Initiating Condition (IC).
Please incorporate definitions for the above terms for staff review to ensure consistency with NRC-endorsed guidance, or provide a basis for not defining these terms.
RAI-5 The licensee references NOTE 3 for EALs RG1.2, RS1.2, and RA1.2 in the LAR.
However, NOTE 3 is not applicable to these particular EALs as revised. Please explain why NOTE 3 is included, or revise accordingly.
RAI-6 Concerning EAL CU1.2, all information that is applicable to the declaration timing should be included in the EAL and reflected on the EAL Wallboard. Since the proposed EAL scheme differs in how it is formatted, the addition of a note is appropriate; however, it must be in the appropriate format as described above. Please move the note from the Susquehanna Basis to the EAL itself and incorporate onto the EAL Wallboard.
RAI-7 For EALs CU2.1, SA1.1, and SU1.1, please add a list of the AC power sources to the EAL to ensure consistent and timely recognition of the event, or provide justification for not including this list. It is not necessary to have this list for EALs CA2.1, SG1.1, SG1.2, and SS1.1 as these EALs are concerned with a loss of all AC power sources.
RAI-8 For EALs CU3.1, SG1.2, and SS2.1, the basis language states, in part, that:
Indicated voltage for the vital 125 VDC main distribution buses is local only. Local voltage indication is available from each bus based on dispatching a field operator in accordance with Control Room alarm response procedure AR-1(2)06-001 (A12, B12, C12, D12). Field observation of indicated voltage constitutes the point in time when
availability of indications to plant operators that an emergency action level has been, or may be, exceeded.
The inclusion of the above basis language to these EALs requires further justification.
Please explain the use of an open-ended timing statement, such that the time of declaration cannot be reasonably understood by the staff. It is expected that events requiring declaration are declared within a reasonable time period of availability. This particular indication is available as reflected by the panel-trouble annunciator, even though the actual panel indication may not be known until an operator is dispatched to the panel to confirm. While the staff understands this, it is difficult to determine the adequacy of these EALs, as part of the overall EAL scheme, when the staff cannot make a reasonable assurance finding as to when they will be declared.
RAI-9 For EAL CA4.1, please incorporate, or provide a justification for not incorporating, the guidance SSES added, as follows, as a note to the EAL and reflect on the EAL Wallboard to support timely and accurate event classification: In the absence of reliable RCS temperature indication caused by the loss of decay heat removal capability, classification should be based on the RPV increase criteria when the RCS is intact in Mode 4 or based on time to boil data when in Mode 5 or the RCS is not intact in Mode 4.
RAI-10 The basis for EAL HG1.1, states, in part, that:
Loss of [Secondary Alarm Station] SAS and/or [Central Alarm Station]
CAS does not impact equipment needed for safety functions Please explain why the above statement was added to the EAL basis, or revise accordingly. This statement may not be entirely accurate if access to areas needed to operate equipment needed for safety functions can be controlled by SAS and/or CAS, such that an adversary can preclude timely access.
RAI-11 The proposed basis for EAL HU3.2 states, in part:
Refer to NPE 91 001, SSES IPE, to identify susceptible internal flooding areas.
If the intent of this statement is to limit the areas of consideration, then provide a list of areas in the EAL for the staff to review, or otherwise explain the purpose for this statement.
RAI-12 For EALs HU4.1 and HU4.2, the areas listed in Table H-1 seem to be limited. Please explain if the listed areas are all the areas that contain equipment needed for safe operation, safe shutdown and safe cool-down, or revise accordingly.
RAI-13 For EALs HU4.2 and HU4.4, please confirm that the Independent Spent Fuel Storage Installation (ISFSI) would be an area applicable to these EALs, or revise accordingly.
RAI-14 Category E - Independent Spent Fuel Storage Installation (ISFSI) guidance, states, in part, that:
Formal offsite planning is not required because the postulated worst-case accident involving an ISFSI has insignificant consequences to the public health and safety The above statement is not applicable to this proposed EAL scheme. Please remove, or provide further justification for inclusion.
Category E further states:
A hostile security event that leads to potential loss in the level of safety of the ISFSI is a classifiable event under Security Category EAL HS1.1 Please explain why this statement was added, since EAL HS1.1 specifically excludes the ISFSI. However, please incorporate guidance related to the fact that EALs HU1 and HA1 are also considered for events that occur at the ISFSI.
RAI-15 For the Fission Product Barrier (FPB) Matrix:
- a. Fuel Clad Barrier (FC) Loss A.1 and Primary Containment Barrier (PC) Potential Loss A.1 should be SAG Entry required, rather than SAGs entered, as this more closely aligns with the Boiling Water Reactor Owners Group (BWROG) revision to their guidance. Please revise, or provide further justification for consideration.
- b. The cited NEI 99-01 Basis sections for several of the FPB criteria are not from NRC-endorsed NEI 99-01, Revision 6. Please either revise to what has actually been endorsed, or (depending on how SSES responds to RAI-03) unify the basis sections into one.