Letter Sequence RAI |
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EPID:L-2019-LLA-0004, Response to Request for Additional Information - License Amendment Request to Revise Existing Facility Operating License Conditions Regarding NFPA 805 Modifications (Approved, Closed) |
Results
Other: ML19140A456, ML20028E884, PLA-7658, Seventh Six-Month Status Report in Response to June 6, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Operation Under Severe Accident, PLA-7710, Report of Full Compliance with March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (NRC Order EA-12-049), PLA-7711, Report of Full Compliance with June 06, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (NRC Order EA-13-109)
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MONTHYEARPLA-7658, Seventh Six-Month Status Report in Response to June 6, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Operation Under Severe Accident2017-12-12012 December 2017 Seventh Six-Month Status Report in Response to June 6, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Operation Under Severe Accident Project stage: Other PLA-7711, Report of Full Compliance with June 06, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (NRC Order EA-13-109)2018-06-26026 June 2018 Report of Full Compliance with June 06, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (NRC Order EA-13-109) Project stage: Other PLA-7710, Report of Full Compliance with March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (NRC Order EA-12-049)2018-06-26026 June 2018 Report of Full Compliance with March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (NRC Order EA-12-049) Project stage: Other PLA-7751, Proposed Amendment to Licenses NPF-14 and NPF-22: Temporary Change to the Technical Specifications to Allow Replacement of Emergency Service Water System Piping2019-01-0909 January 2019 Proposed Amendment to Licenses NPF-14 and NPF-22: Temporary Change to the Technical Specifications to Allow Replacement of Emergency Service Water System Piping Project stage: Request ML19039A0892019-02-0808 February 2019 Acceptance of Requested Licensing Action License Amendment Request to Revise Emergency Service Water Piping Technical Specifications During Replacement Project stage: Acceptance Review PNP 2019-007, License Amendment Request to Change the Full Compliance Implementation Date for the Fire Protection Program Transition License Condition for Required Modifications2019-03-0808 March 2019 License Amendment Request to Change the Full Compliance Implementation Date for the Fire Protection Program Transition License Condition for Required Modifications Project stage: Request ULNRC-06478, Specifications to Adopt TSTF-545 Revision 3, TS Inservice Testing Program Removal & Clarify SR Usage Rule Application to Section 5.5 Testing, (LDCN 18-0021)2019-03-22022 March 2019 Specifications to Adopt TSTF-545 Revision 3, TS Inservice Testing Program Removal & Clarify SR Usage Rule Application to Section 5.5 Testing, (LDCN 18-0021) Project stage: Request ML19099A3672019-04-0909 April 2019 Revise the Technical Specifications for Permanent Extension of Types a and C Leak Rate Test Frequencies and Permanently Extend the Drywell Bypass Leakage Test Frequency Project stage: Request ML19109A1002019-04-11011 April 2019 Application to Revise Technical Specifications to Adopt TSTF-522, Revise Ventilation System Surveillance Requirements to Operate for 10 Hours Per Month Project stage: Request ML19080A1862019-05-0303 May 2019 1) Letter to Hobbs, Crystal River Unit 3 Issuance of Amendment Approving ISFSI-Only Emergency Plan Revision 1 Project stage: Request ML19128A0232019-05-0707 May 2019 Request for Additional Information: Susquehanna Steam Electric Station, Units 1 and 2 License Amendment Request for ESW Piping Replacement Project stage: RAI ML19140A4562019-05-28028 May 2019 Biweekly Federal Register Notice - Applications and Amendments to Facility Operating Licenses and Combined Licenses Involving No Significant Hazards Considerations - Publication Date: 06/04/2019 Project stage: Other ML19149A3002019-05-28028 May 2019 Response to Request for Additional Information - License Amendment Request to Revise Existing Facility Operating License Conditions Regarding NFPA 805 Modifications Project stage: Request PLA-7793, Response to Request for Additional Information Regarding Proposed License Amendment Requesting a Temporary Change to the Technical Specifications to Allow Replacement of Emergency Service Water System Piping2019-06-0303 June 2019 Response to Request for Additional Information Regarding Proposed License Amendment Requesting a Temporary Change to the Technical Specifications to Allow Replacement of Emergency Service Water System Piping Project stage: Response to RAI ML19198A0802019-08-20020 August 2019 Issuance of Amendments No. 269 Regarding Changes to NFPA 805 Modifications and Change to Full Compliance Implementation Date for the Fire Protection Program (Epids L-2018-LLA-0296 and L-2019-LLA-0049) Project stage: Approval 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 Project stage: RAI ML19319A0092019-11-14014 November 2019 NRR E-mail Capture - Draft RAI for SSES Units 1 and 2 LAR to Replace ESW Piping Project stage: Draft RAI PLA-7830, Response to Second Request for Additional Information Regarding Proposed License Amendment Requesting a Temporary Change to the Technical Specifications to Allow Replacement of Emergency Service Water System Piping2019-12-0909 December 2019 Response to Second Request for Additional Information Regarding Proposed License Amendment Requesting a Temporary Change to the Technical Specifications to Allow Replacement of Emergency Service Water System Piping Project stage: Request ML19248A8442020-01-17017 January 2020 Issuance of Amendment Nos. 275 and 257 Temporary Changes to Allow Replacement of Emergency Service Water System Piping Project stage: Approval ML20028E8842020-02-10010 February 2020 Correction to Amendment Nos. 275 and 257 Temporary Changes to Allow Replacement of the Emergency Service Water System Piping Project stage: Other 2019-04-11
[Table View] |
Text
From:
Goetz, Sujata Sent:
Thursday, November 14, 2019 3:40 PM To:
Jurek, Shane
Subject:
RAI for SSES UNITS 1 AND 2 RE: LAR TO REPLACE ESW PIPING (EPID: L-2019-LLA-0004 Attachments:
DORL RAI.docx
Dear Mr. Jurek,
By letter dated January 09, 2019 (Agencywide Documents Access and Management System (ADAMS) Accession Number ML19009A431), Susquehanna Nuclear, LLC (the licensee) submitted a license amendment request (LAR) for the Susquehanna Steam Electric Station (SSES), Unit 1 and 2. The proposed amendment would permit one division of the emergency service water system (ESW) and residual heat removal service water (RHRSW) systems to be inoperable for up to 14 days to allow for ESW piping replacements.
The Nuclear Regulatory Commissions (NRC) staff has reviewed your LAR and has determined that additional information is needed to complete its review. The specific request for additional information (RAI) question is in the attachment to this email.
Your response to NRC is due by Dec 16, 2019.
Sujata Goetz Project Manager, Susquehanna Steam Electric Station Nuclear Regulatory Commission 11555 Rockville Pike Office of the Nuclear Reactor Regulation NRC/NRR/DORL/LPL3 Office O8F2 Mailroom O8-B1A Rockville, MD 20852-2738 Washington, DC 20555-0001 (o) 301.415.8004 (f) 301.415.3313
Hearing Identifier:
NRR_DRMA Email Number:
312 Mail Envelope Properties (CH2PR09MB4005AE58E50EDACEB748103480710)
Subject:
RAI for SSES UNITS 1 AND 2 RE: LAR TO REPLACE ESW PIPING (EPID:
L-2019-LLA-0004 Sent Date:
11/14/2019 3:40:29 PM Received Date:
11/14/2019 3:40:00 PM From:
Goetz, Sujata Created By:
Sujata.Goetz@nrc.gov Recipients:
"Jurek, Shane" <Shane.Jurek@talenenergy.com>
Tracking Status: None Post Office:
CH2PR09MB4005.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 1142 11/14/2019 3:40:00 PM DORL RAI.docx 34127 Options Priority:
Normal Return Notification:
No Reply Requested:
No Sensitivity:
Normal Expiration Date:
REQUEST FOR ADDITIONAL INFORMATION LICENSE AMENDMENT REQUEST REGARDING TEMPORARY CHANGE TO TECHNICAL SPECIFICATIONS 3.7.1 AND 3.7.2 SUSQUEHANNA NUCLEAR, LLC SUSQUEHANNA STEAM ELECTRIC STATION, UNITS 1 AND 2 DOCKET NOS.: 50-387, AND 50-388 (EPID: L-2019-LLA-0004 By letter dated January 09, 2019 (Agencywide Documents Access and Management System (ADAMS) Accession Number ML19009A431), Susquehanna Nuclear, LLC (the licensee) submitted a license amendment request (LAR) for the Susquehanna Steam Electric Station (SSES), Unit 1 and 2. The proposed amendment would permit one division of the emergency service water system (ESW) and residual heat removal service water (RHRSW) systems to be inoperable for up to 14 days to allow for ESW piping replacements.
RAI-1
In the January 9, 2019, LAR Enclosure 1, Section 3.3 Compensatory Measures, lists ten compensatory measure Susquehanna will implement to mitigate risk during replacement of the ESW piping. Susquehanna lists an additional four actions they will take to mitigate consequences on accident on Unit 2 when replacing transformer 1X210 during initial ESW pipe replacement evolution in 2020.
The licensee proposes to add a note in Technical Specification (TS) Limited Condition for Operation (LCO) 3.7.1, Two RHRSW subsystems and the UHS [Ultimate Heat Sink] shall be OPERABLE and LCO 3.7.2, Two ESW subsystems shall be OPERABLE for Unit 1 that states:
This Completion Time is only applicable during the Unit 2 A and B ESW piping replacement while the compensatory measures identified in Section 3.3 of Enclosure 1 to letter PLA-7751 are in place. Upon completion of pipe replacement activities, this temporary extension is no longer applicable and will expire on June 25, 2027.
And in TS LCO 3.7.1 and LCO 3.7.2, for Unit 2, the proposed NOTE states:
This Completion Time is only applicable during the Unit 1 A and B ESW piping replacement while the compensatory measures identified in Section 3.3 of Enclosure 1 to letter PLA-7751 are in place. Upon completion of pipe replacement activities, this temporary extension is no longer applicable and will expire on June 25, 2026.
- a. Please confirm that all fourteen compensatory measures will be taken during each time ESW pipes are replaced. If all fourteen compensatory measure are not going to be
implemented each time, please describe which compensatory measure will be implemented and under what conditions.
- b. Also please provide how all these compensatory measures can be taken every time, if the compensatory measures expire at different dates.
RAI-2
The January 09, 2019, LAR Enclosure 1, page 29 response states:
The non-impacted division is capable of serving 100 percent of the heat loads for both the online and outage units during an accident. As such, there is no impact on consequence mitigation for any transient or accident.
The licensing basis includes consideration of a single failure. While the staff recognizes that the LCO is not met while in the proposed condition and action completion time, the ability to withstand single component failures is part of the safety assessment.
To provide risk insights associated with the proposed maintenance, qualitatively address the reliability of both the ESW and RHRSW subsystems by addressing the effects of credible single failures or explain how a single ESW and RHRSW pump would provide adequate flow to mitigate the loss of offsite power event in the operating unit while maintaining the other unit in cold shutdown or in the refueling modes while in one of the extended completion times (with ESW piping breached).
RAI-3
In the January 9, 2019, LAR Enclosure 1, page 23, compensatory measure 8 states:
A sump pump will be staged at the work area to prevent flooding into the reactor building in the event of torrential rain during the pipe replacement activities.
Please describe the configuration of the external flood boundary during the maintenance activity (e.g., the building penetration seal remains intact and the boundary becomes the ESW system piping inside the reactor building) and how the proposed risk management activity enhances the protection against reactor building flooding (e.g., the sump pump provides defense-in-depth by ensuring water does not flow into the ESW system piping through the breach in the system or that rain water runoff entering the building will be limited such that other required components or systems would not be adversely affected).