PLA-8115, Relief Request IRR06 One Time Extension to the Fourth 10-Year Inservice Testing Program Interval (PLA-8115)
| ML24144A273 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 05/23/2024 |
| From: | Casulli E Susquehanna, Talen Energy |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| PLA-8115 | |
| Download: ML24144A273 (1) | |
Text
Edward Casulli Susquehanna Nuclear, LLC SiteVice President 769 Salem Boulevard Berwick, PA 18603 TALEN~
Tel. 570.542.3795 Fax 570.542.1504 Edward.Casulli@TalenEnergy.com ENERGY
May 23, 2024
Attn: Document Control Desk 10 CFR 50.55a U. S. Nuclear Regulatory Commission Washington, DC 20555-0001
SUSQUEHANNA STEAM ELECTRIC STATION RELIEF REQUEST 1RR06 ONE TIME EXTENSION TO THE FOURTH 10-YEAR INSERVICE TESTING PROGRAM INTERVAL PLA-8115 Docket No. 50-387
In accordance with 10 CFR 50.55a(z)(2), Susquehanna Nucl ear, LLC (Susquehanna), requests NRC approval of proposed relief request from the requirements of American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code) ISTA-3120, Inservice Test Interval, sub-section (d). This relief request is a one-time extension to the end of the fourth 10-year interv al for the Inservice Testing (IST) Program for the Susquehanna Steam Electric Station (SSES) Unit 1, which is beyond the code allowed one-year cumulative extension permitted by ISTA-3120(d).
The fourth 10-year IST Program interval is based on th e ASME OM Code, 2004 Edition through the 2006 Addenda. The fourth 10-year IST Program interval for Unit 1 began on June 01, 2014, and is currently scheduled to end May 31, 2024. To align the Unit 1 and Unit 2 intervals, Susquehanna previous ly applied the code allowed one-year extension to extend the Unit 1 first 10-year IST Program interval end date from June 03, 1993, to May 31, 1994. The SSES IST Program interval has maintained this extension to the present date. Therefore, relief is required to extend the end of the Unit 1 fourth 10-year IST Program from May 31, 2024, to May 31, 2025. If approved, the fifth 10-year IST Program interval for SSES Unit 1 will begin on June 01, 2025, and end by May 31, 2034.
Susquehanna requests authorization of the proposed alternative by May 29, 2024.
There are no new or revised regulatory commitments contained in this submittal.
- 2 - Document Control Desk PLA-8115
Should you have any questions regarding this submittal, please contact Ms. Melisa Krick, Manager-Nuclear Regulatory Affairs, at (570) 542-1818.
E. Casulli
Enclosure:
Relief Request 1RR06
Copy: NRC Region I Ms. J. England, NRC Senior Resident Inspector Ms. A. Klett, NRC Project Manager Mr. M. Shields, PA DEP/BRP Enclosure to PLA-8115
Relief Request 1RR06
Enclosure to PLA-8115 Page 1 of 7
- 1. ASME Code Component(s) Affected
Unit(s) Affected: Susquehanna Steam Electric Station (SSES), Unit 1 Code Class: ASME Code Class 1, 2, 3, and augmented components
References:
ISTA-3120(d)
Component Numbers: All SSES Unit 1 components that are included in the scope of the Inservice Testing (IST) Program
- 2. Applicable Code Edition and Addenda
The IST Program for the fourth 10-year interval is based on the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code), 2004 Edition through the 2006 Addenda. The fourth 10-year IST Program interval began on June 01, 2014, and is currently scheduled to end on May 31, 2024.
- 3. Applicable Code Requirement
The ASME OM Code, Section IST, Sub-section ISTA-3120 states in part,
(a) The frequency for inservice testing shall be in accordance with the requirements of Section IST.
(c) The inservice test intervals shall comply with the following, except as modified by ISTA-3120(d) and ISTA-3120(e):
(1) Initial Test Interval: 10 years following initial start of unit commercial service (2) Successive Test Intervals: 10 years following the previous test interval (d) Each of the inservice test intervals may be extended or decreased by as much as 1 year. Adjustments shall not cause successive intervals to be altered by more than 1 year from the original pattern of intervals.
Susquehanna Nuclear, LLC (Susquehanna) is requesting relief from the ISTA-3120(d) requirement that adjustments shall not cause successive intervals to be altered by more than one (1) year from the original pattern of intervals. 10 CFR 50.55a(f)(4)(ii) identifies successive 120-month intervals must comply with latest edition of the ASME OM Code incorporated by reference in 10 CFR 50.55a(a)(1)(iv). NUREG-1482, Revision 3 (Reference 8.1), states, An extension beyond 1 year requires NRC authorization of an alternative to or exemption from the OM Code provisions of 10 CFR 50.55a, as applicable.
Susquehanna previously applied the code allowed one-year extension to extend the Unit 1 first 10-year IST Program interval end date from June 03, 1993, to May 31, 1994, to align Enclosure to PLA-8115 Page 2 of 7
the Unit 1 and 2 interval dates (Reference 8.2), and has maintained this extension to the present date. Therefore, NRC authorization is required to extend the current Unit 1 IST Program interval. The SSES IST Program interval dates are identified in Table 1.
Table 1: SSES 10-Year IST Program Interval Dates Unit 1 Unit 2 Interval Approx. Approx.
Start End Duration Start End Duration (Months) (Months) 06/03/1993 120 02/15/1995 (original) (original) 111.5 First 06/04/1983 02/15/1985 05/31/1994 132 05/31/1994 (extended) (decreased)
Second 06/01/1994 05/31/2004 120 06/01/1994 05/31/2004 120 Third 06/01/2004 05/31/2014 120 06/01/2004 05/31/2014 120 05/31/2024 120 05/31/2024 120 (original) (original)
Fourth 06/01/2014 06/01/2014 05/31/2025 132 05/31/2025 132 (proposed) (extended)
Cumulative Deviation from Original 3.5 Pattern 24 Fifth 05/31/2034 (proposed) 06/01/2025 05/31/2034 (decreased) 108 06/01/2025 (decreased) 108 Cumulative Deviation from Original 8.5 Pattern 12
- 4. Reason for Request
In accordance with 10 CFR 50.55a(z)(2), Susquehanna is requesting relief from the ISTA-3120(d) requirement that adjustments shall not cause successive intervals to be altered by more than one (1) year from the original pattern of intervals. The basis of this request is that compliance with the specified requirement would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. In addition, for the duration of the interval, the IST Program will continue to verify the operational readiness of components in accordance with ASME OM Code, 2004 Edition through 2006 Addenda, and diagnostic testing will continue to be performed in accordance with current program requirements to verify capability of active safety-related motor operated valves and air operated valves, providing an acceptable level of quality and safety.
Enclosure to PLA-8115 Page 3 of 7
Susquehanna is proposing a one-time extension to the end of the fourth 10-year IST Program interval by approximately one (1) year beyond the code allowed one-year cumulative extension, from May 31, 2024, to May 31, 2025. This extension was complete d to align the Unit 1 and Unit 2 IST Program intervals after the first interval of operation. Susquehanna previously applied the code allowed one-year extension to extend the Unit 1 first 10-year IST Program interval end date from June 03, 1993, to May 31, 1994. The SSES IST Program interval has maintained this extension to the present date. The proposed extension will allow the station additional time to align the IST Program with the ASME OM Code, 2020 Edition, no Addenda, which will be implemented in the fifth 10-year IST Program interval.
Although Susquehanna understood the scope of changes needed to transition to the updated ASME OM Code, additional time is needed for development and implementation due to the complexity and magnitude of required changes. Susquehanna failed to recognize the resources, including expertise and manhours, needed to adequately execute the fifth 10-year IST Program interval and the new requirements of the 2020 Edition of the ASME OM Code. For example, the inclusion of Appendix III and Appendix IV in the 2020 Edition of the ASME OM Code, and the added requirements of Supplemental Position Indication (SPI) and Pump Periodic Verification Testing, have affected hundreds of components in the IST scope, resulting in the need for extensive procedure development and revisions to implement the fifth 10-year IST Program interval. Procedure development and revision to support the fifth 10-year IST Program interval requires additional specialty resources with Susquehanna-specific licensed operator knowledge.
To meet the implementation date of June 01, 2024, on-shift operations staff, who hold the appropriate qualifications and level of knowledge, will be needed to support procedure development and revisions. The use of on-shift operations staff to support the evolution could result in challenges to operations staffing.
Although Susquehanna has made progress towards implementation, if Susquehanna were required to transition to the fifth 10-year IST Program interval by June 01, 2024, Susquehanna would be required to short-cycle procedure updates associated with the program change, resulting in impacts being identified as they come due in the schedule. This approach increases the probability of introducing an error or even potentially missing impacted scope, which ultimately reduces the value of adopting the updated code. If Susquehanna were not effective in this reactive approach, the station could be forced into unit(s) shutdown in order to prevent non-compliance with applicable TS completion times affected by the IST program.
Based on the above, development and implementation of these changes by June 01, 2024, would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety due to the impact to already limited operations staff, increased potential for introducing an error by rushing procedures changes, and potential reactivity management risk due to possibility of plant shutdown to develop procedures to comply with the updated code.
Therefore, Susquehanna is requesting this extension to ensure quality program documents are Enclosure to PLA-8115 Page 4 of 7
developed which will mitigate the likelihood of errors during the fifth 10-year IST Program interval. The fifth 10-year IST Program interval is requested to begin June 01, 2025.
The request is not applicable to SSES Unit 2 as the code allowable extension is still applicable (i.e., the original interval began February 15, 1985). Specifically, extension of the Unit 2 fourth 10-year IST Program interval from May 31, 2024, to May 31, 2025, results in a cumulative deviation from the original interval pattern of approximately 3.5 months which is less than the 12 months permitted by Subsection ISTA-3120(d) of the ASME OM Code. The applicable code of record for SSES Unit 2 fourth 10-Year IST Program interval is the ASME OM Code, 2004 Edition through 2006 Addenda. The Unit 2 fifth 10-year IST Program interval will start no later than June 01, 2025, and is currently scheduled to end May 31, 2034.
- 5. Proposed Alternative and Basis for Use
The proposed alternative is a one-time extension to the end of the Unit 1 fourth 10-year IST Program interval by approximately one (1) year beyond the ASME OM Code ISTA-3120(d) allowed one-year cumulative extension. During the extension, the IST Program will continue to verify the operational readiness of components in accordan ce with ASME OM Code, 2004 Edition through 2006 Addenda, and diagnostic testing will continue to be performed in accordance with current program requirements to verify capability of active safety-related motor operated valves and air operated valves, providing an acceptable level of quality and safety.
Susquehanna will utilize the extension to review and revise IST Program procedures to ensure compliance with the requirements of ASME OM Code, 2020 Edition, which will be implemented during the fifth 10-year IST Program interval on June 01, 2025. The proposed alternative is requested pursuant to 10 CFR 50.55a(z)(2) on the basis that compliance with the specified requirement would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. In addition, the proposed alternative continues to provide an acceptable level of quality and safety.
The proposed duration of the extension is one (1) year. As noted previously, Susquehanna used the one-year extension permitted by the code in 1992 (Reference 8.2) to align the Unit 1 and 2 IST Program intervals. In the over thirty intervening years, Susquehanna did not reclaim this allowance. While permitted by the code, failure to recoup a portion of the one-year allowance was a legacy programmatic error, resulting in the need for this request. The gap between these extensions, however, means that Susquehanna does not currently benefit from the time gained by the 1992 extension, nor does the proposed extension impact the quality and safety provided by compliance with the existing code. Providing a one-time one-year extension will allow Susquehanna to prepare for and implement the ASME OM Code, 2020 Edition, no Addenda, consistent with References 8.3 and 8.4, with quality such that the performance of the program and station are maintained.
Enclosure to PLA-8115 Page 5 of 7
NUREG-1482, Revision 3 (Reference 8.1), states, "when extending its 120-month IST interval by as much as 1 year, as allowed by ISTA-3120, licensees may continue to apply the same OM Code edition and addenda from its current 120-month interval during this extended 1-year period. During the one-year extension, Susquehanna will comply with ASME OM Code, 2004 Edition through 2006 Addenda and the reliefs approved by Reference 8.5 for the fourth 10-year IST Program as summarized in Table 2.
Table 2: Unit 1 Fourth 10-year IST Program Interval Relief Requests Identifier Description 1RR01 Authorized alternative tests in lieu of the requirements found in the 2004 Edition through 2006 Addenda of the ASME OM Code Section ISTC-3522(c) and ISTC-3700 for SSES, Units 1 and 2, instrument process line excess flow check valves (EFCVs). Functional testing and verification of the EFCVs is performed per Technical Specification Surveillance Requirement (SR) 3.6.1.3.9. SR 3.6.1.3.9 allows a representative sample of EFCVs to be tested every 24 months, such that each EFCV will be tested at least once every 10 years.
1RR02 Authorized an alternative test in lieu of the requirements found in the 2004 Edition through 2006 Addenda of the ASME OM Code Section ISTC-3630(a) for sixteen (16) pressure isolation valves.
1RR03 Authorized an alternative to the 5-Year Test Interval requirements of ASME OM Code, Appendix I, Section l-1320(a), for the Main Steam Safety/Relief Valves. Provides allowance for the test interval to be increased from five (5) years to 72 months in accordance with ASME OM Code Case, OMN-17.
1RR04 Authorized use of the ASME OM Code Case OMN-20, from the 2012 Edition of the ASME OM Code, as an alternative for grace period associated with lnservice Testing Requirements.
1RR05 Authorized alternative testing frequency for performing inservice testing of valves 086018, 086118, 086241, and 086341. The valves are closure tested by leak testing on a frequency of at least once per operating cycle in lieu of once each refueling outage as currently allowed by ASME OM Code, 2004 Edition through 2006 Addenda ISTC-3522(c).
Table 3 identifies an additional relief request authorization received during the fourth 10-year IST Program interval. This relief was reviewed and determined to only be applicable to SSES Unit 2; therefore, the relief request is not affected by the request herein.
Enclosure to PLA-8115 Page 6 of 7
Table 3: Additional Fourth 10-year IST Program Interval Relief Requests Identifier Description
RR-02 Authorized alternative to ASME OM Code pressure isolation valve leak test frequency requirements for the Susquehanna, Unit 2, residual heat removal cross-connect check valve 251130. Reference 8.6
The ASME OM Code, Subsection ISTD, is applicable to the Susquehanna Snubber Program.
However, the Susquehanna Snubber Program is maintained as an independent program and interval, and therefore, is not impacted by the requested one-year extension to the end of the fourth 10-year interval of the IST Program.
Approval of the proposed alternative is requested by May 29, 2024.
- 6. Duration of Proposed Alternative
Use of this proposed alternative is applicable to the fourth 10-year IST Program interval. Upon approval, the proposed alternative of extending the fourth 10-year IST Program interval end date will be implemented for SSES Unit 1 starting June 01, 2024, and continuing through to the start of the fifth 10-year IST Program interval on June 01, 2025. The previously approved relief requests for the fourth 10-year IST program interval would be applicable to this extension (Reference 8.5). After the one-time extension is elapsed, the IST Program interval for both Units 1 and 2 will return to the previously synchronized schedule (i.e., scheduled end date of May 31, 2034).
- 7. Precedent
7.1 Letter from NRC to Exelon Generation Company, LLC, James A. Fitzpatrick Nuclear Power Plant - Issuance of Relief Request No. RR Alternative to Certain Requirements of the ASME Code for Extension of the Fourth 10-Year Inservice Testing Interval (CAC No. MF9819), dated August 4, 2017 (ADAMS Accession No. ML17201M289).
7.2 Letter from NRC to Entergy Nuclear Operation, Inc, Indian Point Nuclear Generation Unit No. 3 - Issuance of Relief Request IP3-IST-RR-001 - Alternative to Certain Requirements of the ASME Code for Extension of the Fourth 10-Year Inservice Test Interval (EPID L-2019-LLR-0094), dated April 13, 2020 (ADAMS Accession No. ML20099A182).
7.3 Letter from NRC to Vistra Operations Company, LLC, Comanche Peak Nuclear Power Plant, Unit Nos. 1 and 2 - Proposed Alternative SNB-3 for the Snubber Inservice
Enclosure to PLA-8115 Page 7 of 7
Program Third Interval Extension, dated March 24, 2022 (ADAMS Accession No. ML22077A841).
NRC approval of the above relief requests are relevant to Susquehanna as the requests are associated with relief from the same ASME OM Code requirements and authorize extension beyond the one-year code allowance.
- 8. References
8.1 NUREG-1482, Revision 3, "Guidelines for Inservice Testing at Nuclear Power Plants:
Inservice Testing of Pumps and Valves and Inservice Examination and Testing of Dynamic Restraints (Snubbers) at Nuclear Power Plants," dated July 2020 (ADAMS Accession No. ML20202A473).
8.2 PPL letter to NRC, Susquehanna Steam Electric Station Revision to the Ten-Year Inservice Inspection Interval (PLA-3746), dated April 09, 1992 (ADAMS Accession No. ML17157B132).
8.3 Letter from NRC to Susquehanna Nuclear, LLC, Susquehanna Steam Electric Station, Units 1 and 2 - Authorization and Safety Evaluation for Alternative Request RR01 for Fifth 10-Year Inservice Testing Program (EPID L-2023-LLR-0043), dated March 27, 2024 (ADAMS Accession No. ML24080A502).
8.4 Letter from NRC to Susquehanna Nuclear, LLC, Susquehanna Steam Electric Station, Units 1 and 2 - Authorization and Safety Evaluation for Alternative Request RR02 for Fifth 10-Year Interval Inservice Testing Program (EPID L-2023-LLR-0044), dated March 28, 2024 (ADAMS Accession No. ML24080A395).
8.5 Letter from NRC to PPL Susquehanna, LLC, Susquehanna Steam Electric Station, Units 1 and 2 - Relief Requests for the Fourth 10-Year Inservice Testing Interval (TAC Nos.
MF2905 through MF2912 and MF2915), dated May 22, 2014 (ADAMS Accession No. ML14122A197).
8.6 Letter from NRC to Susquehanna Nuclear, LLC, Susquehanna Steam Electric Station, Unit 2 - Authorization and Safety Evaluation for Alternative Request for Valve 251130 (EPID L-2023-LLR-0045), dated September 19, 2023 (ADAMS Accession No. ML23257A122).