PLA-8126, Response to Request for Confirmation of Information Regarding Relief Request 1RR06
| ML24150A162 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 05/29/2024 |
| From: | Casulli E Susquehanna, Talen Energy |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| PLA-8126 | |
| Download: ML24150A162 (1) | |
Text
Edward Casulli Susquehanna Nuclear, LLC
SiteVicePresident 769 Salem Boulevard Berwick, PA 18603 Tel. 570.542.3795 Fax 570.542.1504 Edward.Casulli@TalenEnergy.com May 29, 2024 Attn: Document Control Desk 10 CFR 50.55a U. S. Nuclear Regulatory Commission Washington, DC 20555-0001 SUSQUEHANNA STEAM ELECTRIC STATION RESPONSE TO REQUEST FOR CONFIRMATION OF INFORMATION REGARDING RELIEF REQUEST 1RR06 PLA-8126 Docket No. 50-387
References:
- 1) Susquehanna letter to NRC, Relief Request 1RR06 One Time Extension to the Fourth 10-Year Inservice Testing Program Interval (PLA-8115), dated May 23, 2024 (ADAMS Accession No. ML24144A273).
- 2) NRC email to Susquehanna, Request for Confirmation of Information (RCI)
Relief Request 1RR06 (Proposed Alternative) Susquehanna Nuclear, LLC, Susquehanna Steam Electric Station (Susquehanna), Unit 1, Docket No.
50-387 (EPID L-2024-LLR-0033), dated May 29, 2024.
In accordance with 10 CFR 50.55a(z), Susquehanna Nuclear, LLC (Susquehanna), in Reference 1, requested NRC approval of relief request 1RR06 associated with the fourth 10-year Inservice Testing (IST) Program interval for the Susquehanna Steam Electric Station, Unit 1.
Relief request 1RR06 proposed relief 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 interval for the 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 NRC provided a Request for Confirmation of Information (RCI) in Reference 2. The enclosure provides Susquehannas response to the RCI.
Susquehanna requests authorization of the proposed alternative by May 30, 2024.
There are no new or revised regulatory commitments contained in this submittal.
TALEN~
ENERGY Document Control Desk PLA-8126 Should you have any questions regarding this submittal, please contact Ms. Melisa Krick, Manager - Nuclear Regulatory Affairs, at (570) 542-1818.
E. Casulli
Enclosure:
Response to Request for Confirmation of Information 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-8126 Response to Request for Confirmation of Information
Enclosure to PLA-8126 Page 1 of 3 Response to Request for Confirmation of Information On May 23, 2024, Susquehanna Nuclear, LLC (Susquehanna), submitted a relief request, 1RR06, associated with the fourth 10-year Inservice Testing Program (IST) interval for the Susquehanna Steam Electric Station, Unit 1. Relief request 1RR06 proposed relief 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 interval for the 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). Subsequently, the NRC provided a Request for Confirmation of Information (RCI) in Reference 2. The response to this RCI is provided below.
RCI-1 The last paragraph of section5, Proposed Alternative and Basis for Use, of Relief Request1RR06 (Agencywide Documents Access and Management System (ADAMS)
Accession No.ML24144A273) states:
The ASME OM Code [American Society of Mechanical Engineers Codefor Operation and Maintenance of Nuclear Power Plants], 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
[inservice testing] Program.
Susquehanna Nuclear, LLC (the licensee) previously submitted a request 5RR-02 related to snubber attachments dated June 1, 2023 (ML23152A244), which states:
The Fifth 10-Year ISI [inservice inspection] Interval and Fifth 10-Year Snubber Program Interval at SSES [Susquehanna Steam Electric Station] will begin on June 1, 2024, and are currently scheduled to end May 31, 2034. Accordingly, Susquehanna [the licensee]
requests authorization of this request by March 31, 2024, to support the Fifth 10-Year ISI Interval. The Fifth 10-Year ISI Interval of the ISI Program at SSES will comply with the 2019 Edition of the ASME BPV [boiler and pressure vessel] Code. The relief request is for relief of the ISI requirements of 2019 Edition of ASME Section XI on examination boundaries and sample size of snubbers.
NUREG-1482, Revision 3, Guidelines for Inservice Testing at Nuclear Power Plants (ML20202A473), Appendix A, Guidelines for Inservice Examination and Testing Program for
Enclosure to PLA-8126 Page 2 of 3 Dynamic Restraints (Snubbers) at Nuclear Power Plants, sectionA.2.6, Snubber Program Plan and its Update Documents, states:
As required by 10 CFR 50.55a(g), the Snubber Program Plan and its update should be developed and aligned with the plants 10-year ISI program interval. Currently, the industry is transitioning and updating their snubber programs from the ASME BPV Code,Section XI, to the OM Code. Therefore, the Snubber Program Plan may be aligned with 10-year IST program interval. Licensees should provide details about this in the snubber program and the applicable plants 10-year IST program interval or 10-year ISI program interval document with the start and end dates.
The NRC staff requests the licensee to confirm the following:
- a. The Susquehanna, Units 1 and 2 Fifth 10-Year Snubber Program is aligned with the Susquehanna, Unit 1 and 2 Fifth 10-Year ISI interval and, therefore, the Snubber Program would not be affected by authorizing the alternative in Relief Request 1RR06.
- b. The Susquehanna, Units 1 and 2 Fifth 10-Year Snubber Program is based on ASME OM Code, Edition 2020.
Susquehanna Response
- a. Yes, Susquehanna confirms the Unit 1 and Unit 2 Fifth 10-Year Snubber Program is aligned with the Susquehanna Unit 1 and Unit 2 Fifth 10-Year ISI interval and, therefore, the Snubber Program would not be affected by authorizing the alternative in Relief Request 1RR06.
- b. Yes, Susquehanna confirms the Unit 1 and Unit 2 Fifth 10-Year Snubber Program is based on ASME OM Code, Edition 2020.
RCI-2 Relief Request 1RR06, Table 3-Additional Fourth 10-year IST Program Interval Relief Requests only lists the Susquehanna, Unit 2 Request RR02; however, the Unit 2 Fourth 10-Year IST Interval Program submitted on October 7, 2014 (ML14294A624, Enclosure 2, Attachment E), lists requests 2RR01, 2RR02, 2RR03, and 2RR04.
The NRC staff requests the licensee to confirm whether it considered the impacts of extending the Unit 2 Fourth 10-Year IST Program interval on requests 2RR01, 2RR02, 2RR03, and 2RR04.
Enclosure to PLA-8126 Page 3 of 3 Susquehanna Response Susquehanna is invoking the ASME OM Code ISTA-3120(d) allowed extension for Unit 2, which includes the relief requests identified. Susquehanna has reviewed relief requests 2RR01, 2RR02, 2RR03, and 2RR04, and concluded that extension of the Unit 2 Fourth 10-Year IST Program Interval in accordance with the code does not affect or alter the NRC's prior authorization of the reliefs. Therefore, Susquehanna will continue to use these reliefs during the extended interval.
References
- 1. Susquehanna letter to NRC, Relief Request 1RR06 One Time Extension to the Fourth 10-Year Inservice Testing Program Interval (PLA-8115), dated May 23, 2024 (ADAMS Accession No. ML24144A273).
- 2. NRC email to Susquehanna, Request for Confirmation of Information (RCI) Relief Request 1RR06 (Proposed Alternative) Susquehanna Nuclear, LLC, Susquehanna Steam Electric Station (Susquehanna), Unit 1, Docket No. 50-387 (EPID L-2024-LLR-0033), dated May 29, 2024.