ML24155A087
| ML24155A087 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 05/30/2024 |
| From: | Robert Davis Plant Licensing Branch 1 |
| To: | Office of Nuclear Reactor Regulation |
| Klett A | |
| References | |
| EPID L-2024-LLR-0033 | |
| Download: ML24155A087 (1) | |
Text
VERBAL AUTHORIZATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELIEF REQUEST 1RR06 (PROPOSED ALTERNATIVE)
REGARDING EXTENDED FOURTH 10-YEAR INTERVAL INSERVICE TESTING PROGRAM SUSQUEHANNA NUCLEAR, LLC SUSQUEHANNA STEAM ELECTRIC STATION, UNIT 1 DOCKET NO. 50-387 EPID L-2024-LLR-0033 Technical Evaluation read by Stewart Bailey, Chief of the Mechanical Engineering and Inservice Testing Branch, Division of Engineering and External Hazards, NRC Office of Nuclear Reactor Regulation In your letter dated May 23, 2024, as supplemented by letter dated May 29, 2024, you submitted 1RR06 asking for an alternative to specific inservice testing requirements for the Susquehanna [Steam Electric Station], Unit 1. The request was made pursuant to 10 CFR
[Title 10 of the Code of Federal Regulations], Part 50, Section 50.55a(z)(2).
The request is to extend the fourth 10-year inservice testing program interval by an additional 12 months, which would be through May 31, 2025. This extension is an alternative to the ASME OM Code [American Society of Mechanical Engineers code for Operation and Maintenance of Nuclear Power Plants], Subsection ISTA, paragraph ISTA-3120, subparagraph (d) requirements that allow 10-year inservice testing program intervals to be extended or decreased by as much as 1 year, with the provision that the adjustments shall not cause successive intervals to be altered by more than 1 year from the original pattern of intervals. Extending the Unit 1 fourth 10-year interval to May 31, 2025, would extend the interval beyond the 1 year allowed by ISTA-3120(d) because Susquehanna, Unit 1 already used a lot of that time when they extended the first 10-year interval end date from June 3, 1993, to May 31, 1994. The plan going forward is for both Susquehanna units to start their fifth 10-year interval on June 1, 2025. The schedule adjustment for Unit 2 is less than the one year permitted by ISTA-3120(d), so no alternative is needed for Unit 2. The Susquehanna, Units 1 and 2, snubber program is aligned with the inservice inspection interval, not the inservice testing interval and, therefore, is not in the scope of the relief request.
In your submittal, you stated that compliance with the specified requirement in paragraph ISTA-3120(d) for Susquehanna, Unit 1 would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety, which is the criterion in 10 CFR 50.55a(z)(2). The reason for the hardship is the large difference in [ASME] OM Code requirements between the 2004 Edition through 2006 Addenda, which is being used for the fourth 10-year interval, and the 2020 Edition that will be used for the fifth 10-year interval. The changes affect hundreds of components within the inservice testing scope, resulting in the need for extensive plant procedure development and revisions to implement the fifth 10-year interval inservice testing program. You indicated that highly qualified reactor operations staff are needed to support the evolution of the inservice testing program, so meeting the required schedule might challenge plant staffing and operations. You also stated that short-cycling procedure updates increases the probability of introducing program or scope errors, which could result in a forced unit shutdown to prevent noncompliance with applicable technical specification completion times affected by the inservice testing program.
In your submittal, you stated that the inservice testing requirements of the ASME OM Code in the 2004 Edition through the 2006 Addenda, as incorporated by reference in 10 CFR 50.55a,
2 will continue to be implemented during the 1-year extension of the Unit 1 fourth 10-year interval, that diagnostic testing will continue to be performed in accordance with current program requirements to verify the capability of active safety-related motor-operated valves and air-operated valves, and that you will continue to comply with those alternatives that are already authorized for the fourth interval during the 1-year extension. Therefore, you conclude that these inservice testing activities will provide an acceptable level of quality and safety for components within the scope of the program.
The NRC [staff] has reviewed 1RR06. In this limited circumstance, the staff finds that compliance with the specified requirement in paragraph ISTA-3120(d) would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety because of the potential impact on reactor operations staff needed to develop procedures to comply with the updated ASME OM Code, the associated increased potential for introducing procedural errors, and potential reactivity management risk due to the possibility of a plant shutdown. In consideration of the hardship required for compliance with paragraph ISTA-3120(d) at the current time, the staff finds that the licensee will provide reasonable assurance of the operational readiness of the components within the scope of the inservice testing program by compliance with (1) the inservice testing requirements of the ASME OM Code in the 2004 Edition through the 2006 Addenda, as incorporated by reference in 10 CFR 50.55a; (2) the authorized alternatives to those ASME OM Code requirements and (3) the diagnostic testing of active safety-related motor-operated valves and air-operated valves in accordance with the current programs.
Therefore, the NRC staff finds that the proposed alternative in Relief Request 1RR06 for a 1-year extension of the fourth 10-year interval along with all previously authorized alternative requests listed in the submittal may be authorized in accordance with the requirements of 10 CFR 50.55a(z)(2).
Authorization read by Hipólito González, Chief of the Plant Licensing Branch I, Office of Nuclear Reactor Regulation
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conclusions of the Mechanical Engineering and Inservice Testing Branch.
The NRC staff determines that the proposed alternative provides reasonable assurance that the components and systems are operationally ready. The NRC staff determined that compliance with the ASME OM Code requirement would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. Accordingly, the NRC staff concludes that the licensee has adequately addressed all regulatory requirements set forth in
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Therefore, as of today, May 30, 2024, the NRC staff authorizes the use of Alternative 5HTXHVW55DW6XVTXHKDQQD8QLWWRH[WHQGWKHHQGGDWHIRUWKHIRXUWK-year interval inservice testing program to May 31, 2025.
All other requirements in ASME OM Code for which an alternative was not specifically requested and authorized remain applicable.
This verbal authorization does not preclude the NRC staff from asking additional clarification questions regarding the proposed alternative while subsequently preparing the written safety evaluation.