ML24102A125
| ML24102A125 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 04/10/2024 |
| From: | Audrey Klett Plant Licensing Branch 1 |
| To: | Brown K Susquehanna |
| Klett A | |
| References | |
| EPID L-2024-LLR-0028 | |
| Download: ML24102A125 (3) | |
Text
From:
Audrey Klett To:
Brown, Katie-Elizabeth Rosser
Subject:
Request for Additional Information for Susquehanna Unit 1 Alternative Request 4RR-11 Date:
Wednesday, April 10, 2024 4:38:00 PM Attachments:
Request for Additional Information for Susquehanna Unit 1 Alternative Request 4RR-11.docx Hi Katie,
By application dated April 9, 2024 (Agencywide Documents Access and Management System Accession No. ML24100A832), Susquehanna Nuclear, LLC (the licensee) submitted Relief Request 4RR-11 in accordance with Paragraph 50.55a(z)(2) of Title 10 of the Code of Federal Regulations (10 CFR) for a proposed alternative to certain requirements of the American Society of Mechanical Engineers Code incorporated by reference in 10 CFR 50.55a, Codes and standards, for Susquehanna Steam Electric Station (Susquehanna), Unit 1.
The U.S. Nuclear Regulatory Commission (NRC) staff has reviewed the application and determined that the information requested in the attached document is needed to complete its review. As discussed with licensee staff on April 10, 2024, the NRC staff is requested a response to the request on or by April 11, 2024, to support the licensees requested date for an NRC decision.
Respectfully,
Audrey Klett, Senior Project Manager U.S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation Division of Operating Reactor Licensing Plant Licensing Branch 1 301-415-0489
Request for Additional Information Relief [Alternative] Request 4RR-11 Proposed Alternative for Main Steam Line Pressure Test Fourth and Fifth 10-Year Interval Inservice Inspection Programs Susquehanna Steam Electric Station, Unit 1 Docket No. 50-387 EPID L-2024-LLR-0028
Background
By application dated April 9, 2024 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML24100A832), Susquehanna Nuclear, LLC (the licensee) submitted Relief Request 4RR-11 in accordance with Paragraph 50.55a(z)(2) of Title 10 of the Code of Federal Regulations (10 CFR) for a proposed alternative to certain requirements of the American Society of Mechanical Engineers (ASME) Code incorporated by reference in 10 CFR 50.55a, Codes and standards, for Susquehanna Steam Electric Station (Susquehanna), Unit 1. The proposed alternative would allow the licensee to defer the part of the IWB-5222(b) pressure boundary inspection for the volume between the inboard (IB) and outboard (OB) main steam isolation valves (MSIVs) on the D main steam line.
The U.S. Nuclear Regulatory Commission (NRC) staff has reviewed the application and determined that the information below is needed to complete its review. As discussed with licensee staff on April 10, 2024, the NRC staff is requested a response to the request on or by April 11, 2024, to support the licensees requested date for an NRC decision.
Requests for Additional Information
- 1. Section 3, Applicable Code Requirement, of the alternative states, ASME Code,Section XI, IWB-5222(b) requires the system leakage test pressure retaining boundary to extend to all Class 1 components. However, the alternative is taking exception to the specific ASME Code requirement that system leakage test be performed at or near the end of the interval per IWB-5222(b). Therefore, the staff requests the licensee to discuss the specific requirement to which the alternative is taking exception, in this section of the submittal.
- 2. Section 5 of the alternative, states:
... the proposed alternative is to perform a partial IWB-5222(b) pressure boundary test during the 2024 RIO [refuel and inspection outage], including all piping applicable to the IWB-5222(b) pressure boundary and the Main Steam system MSL D to the IB MSIV, subsequently test the remainder of the boundary (all piping applicable to the IWB-5222(a) pressure boundary and the Main Steam system MSL D to the OB MSIV) during the next Unit 1 RIO (projected for spring 2026).
Confirm whether the above means the following:
The IWB-5222(b) pressure boundary inspection performed during the 2024 RIO will include all required piping systems, including the Main Steam System, except for Main Steam system MSL D IB MISV to OB MISV. The Main Steam system MSL D IB MISV to OB MISV will be deferred this RIO and be performed during
the next RIO (projected for spring 2026) during the IWB-5222(a) pressure boundary inspection. Hence, all the inspections required under IWB-5222 will be completed at least once during the 2024 and/or 2026 RIO.
- 3. The alternative states that when these tests are considered in the aggregate, the entire Class 1 pressure boundary is shown to be pressure tested to requirements of IWB-5222(b) within the fourth 10-year ISI interval. The NRC staff notes that the alternative is only asking an exception to the requirement that the testing was not performed at or near the end of the interval (2014-2024). Testing was performed during this interval in 2016, 2018 and 2020, but the timing of these inspections was not at the end of the interval (2024). To meet the intent of the ASME Code of ensuring the inspection interval does not exceed 10 years, the alternative is proposing to perform the deferred inspection in 2026, thereby making the time between inspections less than 10 years. Based on the understanding above, confirm whether the licensee would conclude that the information provided in the proposed alternative, including the previous inspections performed, would justify that the proposed alternative provides for an acceptable level of quality and safety as set forth in 10 CFR 50.55a(z)(1).