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Category:Inservice/Preservice Inspection and Test Report
MONTHYEARPLA-8089, Submittal of Revision to Inservice Testing Program Plan2023-12-0505 December 2023 Submittal of Revision to Inservice Testing Program Plan PLA-8019, Nd Refueling Outage Owner'S Activity Report, PLA-80192022-07-13013 July 2022 Nd Refueling Outage Owner'S Activity Report, PLA-8019 PLA-7876, 21st Refueling Outage Owner'S Activity Report (PLA-7876)2020-07-21021 July 2020 21st Refueling Outage Owner'S Activity Report (PLA-7876) PLA-7797, Th Refueling Outage Owner'S Activity Report (PLA-7797)2019-07-0909 July 2019 Th Refueling Outage Owner'S Activity Report (PLA-7797) PLA-7724, 20th Refueling Outage Owner'S Activity Report (PLA-7724)2018-07-23023 July 2018 20th Refueling Outage Owner'S Activity Report (PLA-7724) PLA-7507, Transmittal of 19th Refueling Outage Owner'S Activity Report2016-07-27027 July 2016 Transmittal of 19th Refueling Outage Owner'S Activity Report PLA-7368, Submittal of 17th Refueling Outage Owner'S Activity Report2015-08-11011 August 2015 Submittal of 17th Refueling Outage Owner'S Activity Report PLA-7193, Request to Continue Use of a Risk-Informed Inservice Inspection Alternative in a Proposed Relief Request No. 4RR-01 to the Fourth 10-Year Inservice Inspection Program2014-10-29029 October 2014 Request to Continue Use of a Risk-Informed Inservice Inspection Alternative in a Proposed Relief Request No. 4RR-01 to the Fourth 10-Year Inservice Inspection Program PLA-7232, Th Refueling Outage Owner'S Activity Report2014-08-28028 August 2014 Th Refueling Outage Owner'S Activity Report PLA-7194, Susequehanna Steam Electric Station, Unit 2 - Inservice Testing Program Plan2014-06-18018 June 2014 Susequehanna Steam Electric Station, Unit 2 - Inservice Testing Program Plan PLA-7178, Inservice Inspection Program Plan for the Fourth Ten-Year Interval2014-06-0202 June 2014 Inservice Inspection Program Plan for the Fourth Ten-Year Interval PLA-7179, Snubber Program Plan for the Fourth Ten-Year Inservice Inspection Interval, PLA-71792014-06-0202 June 2014 Snubber Program Plan for the Fourth Ten-Year Inservice Inspection Interval, PLA-7179 PLA-7154, Response to Request for Additional Information on Fourth Ten-Year Inservice Inspection Interval Proposed Relief Requests2014-04-28028 April 2014 Response to Request for Additional Information on Fourth Ten-Year Inservice Inspection Interval Proposed Relief Requests PLA-7092, Withdrawal of Relief Requests 1RR07 and 2RR07 for Third Ten-Year Interval Inservice Testing Program Plans for Susquehanna Ses (SSES) Unit 1 and Unit 2, PLA-70922013-10-10010 October 2013 Withdrawal of Relief Requests 1RR07 and 2RR07 for Third Ten-Year Interval Inservice Testing Program Plans for Susquehanna Ses (SSES) Unit 1 and Unit 2, PLA-7092 PLA-7047, Th Rio Steam Dryer Visual Inspection Report2013-07-25025 July 2013 Th Rio Steam Dryer Visual Inspection Report PLA-6871, Th Refueling Outage Owner'S Activity Report2012-08-30030 August 2012 Th Refueling Outage Owner'S Activity Report PLA-6847, Proposed Relief Request No. 3RR-19 to the Third 10-Year Inservice Inspection Program2012-04-24024 April 2012 Proposed Relief Request No. 3RR-19 to the Third 10-Year Inservice Inspection Program PLA-6814, Request in Accordance with 10 CFR 50.55a(f)(4)(iv) for IST Components to Use Subsequent ASME OM Code Edition and Addenda for the Remainder of the Third Ten-Year IST Interval Revision 1, PLA-68142012-02-13013 February 2012 Request in Accordance with 10 CFR 50.55a(f)(4)(iv) for IST Components to Use Subsequent ASME OM Code Edition and Addenda for the Remainder of the Third Ten-Year IST Interval Revision 1, PLA-6814 PLA-6404, Relief Request 2RR07 for Third Ten-Year Interval Inservice Testing Program Plan2008-08-0505 August 2008 Relief Request 2RR07 for Third Ten-Year Interval Inservice Testing Program Plan PLA-6099, Notification of Changes to Snubber Inspection and Testing Requirements for Third 10-Year Interval In-Service Inspection Program Plan2007-03-19019 March 2007 Notification of Changes to Snubber Inspection and Testing Requirements for Third 10-Year Interval In-Service Inspection Program Plan ML0634501312006-11-30030 November 2006 Fourth Ten-Year Inservice Inspection Interval Request for Alternate (Relief Request 2004-ON-001) PLA-5960, Relief Requests 1RR06 and 2RR06 for Third Ten-Year Interval Inservice Testing Program Plans2005-09-29029 September 2005 Relief Requests 1RR06 and 2RR06 for Third Ten-Year Interval Inservice Testing Program Plans PLA-5905, Reconciliation of the Second 10-Year Interval Inservice Inspection Program Plan, PLA-59052005-05-31031 May 2005 Reconciliation of the Second 10-Year Interval Inservice Inspection Program Plan, PLA-5905 ML0427303382004-09-20020 September 2004 Third Ten Year Inservice Inspection Interval Request for Relief No. 04-ON-006 PLA-5805, Relief Requests 1RR05 and 2RR05 for Third Ten-year Interval Inservice Testing Program Plans for Susquehanna Ses Units 1&22004-09-10010 September 2004 Relief Requests 1RR05 and 2RR05 for Third Ten-year Interval Inservice Testing Program Plans for Susquehanna Ses Units 1&2 ML0421801822004-07-26026 July 2004 Proposed Relief Request No. 3RR-12 to the Third 10-year Inservice Inspection Program PLA-5775, Thirteenth Refueling and Inspection Outage ISI Summary Report2004-07-16016 July 2004 Thirteenth Refueling and Inspection Outage ISI Summary Report PLA-5783, Proposed Relief Request No. 3RR-13 to the Third 10-year Inservice Inspection Program for Plant Units 1 and 2 PLA-57832004-07-14014 July 2004 Proposed Relief Request No. 3RR-13 to the Third 10-year Inservice Inspection Program for Plant Units 1 and 2 PLA-5783 PLA-5753, Response to NRC Request for Additional Information Relating to Relief Request 3RR-032004-05-27027 May 2004 Response to NRC Request for Additional Information Relating to Relief Request 3RR-03 PLA-5743, Supplemental Information for Proposed Relief Requests No. 29 and 30 to the Second 10-Year Inservice Inspection Program for Susquehanna Ses Unit 12004-04-0707 April 2004 Supplemental Information for Proposed Relief Requests No. 29 and 30 to the Second 10-Year Inservice Inspection Program for Susquehanna Ses Unit 1 PLA-5662, Proposed Third Ten-Year Inservice Inspection, Interval Inservice Inspection Program Plan2003-09-16016 September 2003 Proposed Third Ten-Year Inservice Inspection, Interval Inservice Inspection Program Plan PLA-5649, Eleventh Refueling & Inspection Outage ISI Summary Report, PLA-56492003-07-18018 July 2003 Eleventh Refueling & Inspection Outage ISI Summary Report, PLA-5649 PLA-5503, Twelfth Refueling & Inspection Outage ISI Summary Report, Appendix D.2, Modification Group NIS-2 Forms2002-07-19019 July 2002 Twelfth Refueling & Inspection Outage ISI Summary Report, Appendix D.2, Modification Group NIS-2 Forms 2023-12-05
[Table view] Category:Letter type:PLA
MONTHYEARPLA-8096, Response to Request for Additional Information Regarding Proposed Relief Request for the Fifth 10-Year Inservice Test Program Interval2024-01-0404 January 2024 Response to Request for Additional Information Regarding Proposed Relief Request for the Fifth 10-Year Inservice Test Program Interval PLA-8077, Emergency Plan Revision 67 (PLA-8077)2023-12-27027 December 2023 Emergency Plan Revision 67 (PLA-8077) PLA-8089, Submittal of Revision to Inservice Testing Program Plan2023-12-0505 December 2023 Submittal of Revision to Inservice Testing Program Plan PLA-8084, Application to Revise Technical Specifications to Adopt TSTF-568, Revise Applicability of BWR TS 3.6.2.5 and TS 3.6.3.22023-11-29029 November 2023 Application to Revise Technical Specifications to Adopt TSTF-568, Revise Applicability of BWR TS 3.6.2.5 and TS 3.6.3.2 PLA-8091, Response to Request for Additional Information Regarding Proposed Relief Request for the Fifth 10-Year Inseervice Inspection Interval (PLA-8091)2023-11-0808 November 2023 Response to Request for Additional Information Regarding Proposed Relief Request for the Fifth 10-Year Inseervice Inspection Interval (PLA-8091) PLA-8082, Proposed Amendment to Licenses NPF-14 and NPF-22: Application to Revise Technical Specifications to Adopt TSTF-563, Revise Instrument Testing Definitions to Incorporate the Surveillance Frequency Control Program2023-11-0202 November 2023 Proposed Amendment to Licenses NPF-14 and NPF-22: Application to Revise Technical Specifications to Adopt TSTF-563, Revise Instrument Testing Definitions to Incorporate the Surveillance Frequency Control Program PLA-8080, Proposed Relief for Valve 251130 (PLA-8080)2023-08-14014 August 2023 Proposed Relief for Valve 251130 (PLA-8080) PLA-8074, Proposed Relief Request for the Fifth 10-Year Inservice Test Program Interval2023-08-0303 August 2023 Proposed Relief Request for the Fifth 10-Year Inservice Test Program Interval PLA-8076, Unit 2 - 21st Refueling Outage Owner'S Activity Report (PLA-8076)2023-07-20020 July 2023 Unit 2 - 21st Refueling Outage Owner'S Activity Report (PLA-8076) PLA-8078, Submittal of Unit 2 Cycle 22 Core Operating Limits Report, Revision 1, PLA-80782023-07-0505 July 2023 Submittal of Unit 2 Cycle 22 Core Operating Limits Report, Revision 1, PLA-8078 PLA-8054, Proposed Amendment to Licenses NPF-14 and NPF-22: Remove Control Rod Operability Separation Criteria and Replace Reference to Banked Position Withdrawal Sequence with the Analyzed Rod Position Sequence2023-06-0808 June 2023 Proposed Amendment to Licenses NPF-14 and NPF-22: Remove Control Rod Operability Separation Criteria and Replace Reference to Banked Position Withdrawal Sequence with the Analyzed Rod Position Sequence PLA-8073, Proposed Relief Request for the Fifth 10-Year Inservice Inspection Interval2023-06-0101 June 2023 Proposed Relief Request for the Fifth 10-Year Inservice Inspection Interval PLA-8067, Notification of Completion of Emergence from Bankruptcy (PLA-8067)2023-05-17017 May 2023 Notification of Completion of Emergence from Bankruptcy (PLA-8067) PLA-8064, Response to NRC Regulatory Issue Summary 2023-01 (PLA-8064)2023-05-17017 May 2023 Response to NRC Regulatory Issue Summary 2023-01 (PLA-8064) PLA-8066, Notification of Planned Closing Date and Information Identified in March 30, 2023 Order, PLA-80662023-05-0808 May 2023 Notification of Planned Closing Date and Information Identified in March 30, 2023 Order, PLA-8066 PLA-8053, Radiation Exposure Information and Reporting System2023-04-27027 April 2023 Radiation Exposure Information and Reporting System PLA-8058, Annual Radiological Environmental Operating Report (PLA-8058)2023-04-26026 April 2023 Annual Radiological Environmental Operating Report (PLA-8058) PLA-8041, Radioactive Effluent Release Report and Offsite Dose Calculation Manual (PLA-8041)2023-04-25025 April 2023 Radioactive Effluent Release Report and Offsite Dose Calculation Manual (PLA-8041) PLA-8047, 2022 Annual Environmental Operating Report (Nonradiological), PLA-80472023-04-19019 April 2023 2022 Annual Environmental Operating Report (Nonradiological), PLA-8047 PLA-8062, Supplement to Relief Request 4RR-10 Relief from Code Seal Weld Requirement for Valve 252F007B, PLA-80622023-04-11011 April 2023 Supplement to Relief Request 4RR-10 Relief from Code Seal Weld Requirement for Valve 252F007B, PLA-8062 PLA-8061, Relief Request 4RR-10 Relief from Code Seal Weld Requirement for Valve 25F007B, PLA-80612023-04-10010 April 2023 Relief Request 4RR-10 Relief from Code Seal Weld Requirement for Valve 25F007B, PLA-8061 PLA-8060, Submittal of Unit 2 Cycle 22 Core Operating Limits Report (PLA-8060)2023-03-30030 March 2023 Submittal of Unit 2 Cycle 22 Core Operating Limits Report (PLA-8060) PLA-8057, Application for Order Approving Indirect Transfer of Control of Licenses and Approving Conforming License Amendments- Supplemental Information, PLA-80572023-03-15015 March 2023 Application for Order Approving Indirect Transfer of Control of Licenses and Approving Conforming License Amendments- Supplemental Information, PLA-8057 PLA-8052, (Sses), Proof of Financial Protection and Guarantee of Payment of Deferred Premiums2023-02-13013 February 2023 (Sses), Proof of Financial Protection and Guarantee of Payment of Deferred Premiums PLA-8048, Response to Request for Additional Information Regarding License Amendment Requesting Temporary Addition of Analyzed Rod Position Sequence2023-01-14014 January 2023 Response to Request for Additional Information Regarding License Amendment Requesting Temporary Addition of Analyzed Rod Position Sequence PLA-8042, Proposed Emergency Amendment to License NPF-22: Temporary Addition of Analyzed Rod Position Sequence2023-01-10010 January 2023 Proposed Emergency Amendment to License NPF-22: Temporary Addition of Analyzed Rod Position Sequence PLA-8039, Application for Order Approving Indirect Transfer of Control of License Amendments - Supplemental Information2022-12-22022 December 2022 Application for Order Approving Indirect Transfer of Control of License Amendments - Supplemental Information PLA-8038, Notification of Petition for Bankruptcy (PLA-8038)2022-12-14014 December 2022 Notification of Petition for Bankruptcy (PLA-8038) PLA-8036, Registration for the Use of Spent Fuel Storage Casks 203, 202, and 204, PLA-80362022-11-30030 November 2022 Registration for the Use of Spent Fuel Storage Casks 203, 202, and 204, PLA-8036 PLA-8035, Registration for the Use of Spent Fuel Storage Casks 205, 200, and 201, PLA-80352022-11-0808 November 2022 Registration for the Use of Spent Fuel Storage Casks 205, 200, and 201, PLA-8035 PLA-8031, Emergency Plan Revision 66 (PLA-8031)2022-11-0707 November 2022 Emergency Plan Revision 66 (PLA-8031) PLA-8032, Application for Order Approving Indirect Transfer of Control of Licenses and Approving Conforming License Amendments - Supplemental Information (PLA-8032)2022-10-28028 October 2022 Application for Order Approving Indirect Transfer of Control of Licenses and Approving Conforming License Amendments - Supplemental Information (PLA-8032) PLA-8026, Biennial 10 Crf 50.59 and 72.48 Summary Report and Changes to Regulatory Commitment (PLA-8026)2022-10-19019 October 2022 Biennial 10 Crf 50.59 and 72.48 Summary Report and Changes to Regulatory Commitment (PLA-8026) PLA-8015, Application for Order Approving Indirect Transfer of Control of Licenses2022-09-29029 September 2022 Application for Order Approving Indirect Transfer of Control of Licenses PLA-8030, Evacuation Time Estimate Report PLA-80302022-09-15015 September 2022 Evacuation Time Estimate Report PLA-8030 PLA-8025, Supplement to License Amendment to Revise Reactor Steam Dome Pressure - Low Instrumentation Function Allowable Value2022-08-10010 August 2022 Supplement to License Amendment to Revise Reactor Steam Dome Pressure - Low Instrumentation Function Allowable Value PLA-8019, Nd Refueling Outage Owner'S Activity Report, PLA-80192022-07-13013 July 2022 Nd Refueling Outage Owner'S Activity Report, PLA-8019 PLA-8013, Response to Request for Additional Information Regarding License Amendment Requesting Adoption of TSTF-505, Revision 2 PLA-80132022-06-27027 June 2022 Response to Request for Additional Information Regarding License Amendment Requesting Adoption of TSTF-505, Revision 2 PLA-8013 PLA-8012, 10 CFR 50.46 Annual Report2022-06-10010 June 2022 10 CFR 50.46 Annual Report PLA-8005, Response to Request for Additional Information Regarding License Amendment to Revise Reactor Steam Dome Pressure - Low Instrumentation Function Allowable Value (PLA-8005)2022-05-23023 May 2022 Response to Request for Additional Information Regarding License Amendment to Revise Reactor Steam Dome Pressure - Low Instrumentation Function Allowable Value (PLA-8005) PLA-8001, Radiation Exposure Information and Reporting System - PLA-80012022-04-28028 April 2022 Radiation Exposure Information and Reporting System - PLA-8001 PLA-7987, Radioactive Effluent Release Report and Offsite Dose Calculation Manual - (PLA-7987)2022-04-26026 April 2022 Radioactive Effluent Release Report and Offsite Dose Calculation Manual - (PLA-7987) PLA-7986, 2021 Annual Environmental Operating Report (Nonradiological) Docket No. 50-387, PLA-79862022-04-26026 April 2022 2021 Annual Environmental Operating Report (Nonradiological) Docket No. 50-387, PLA-7986 PLA-7985, Annual Radiological Environmental Operating Report2022-04-22022 April 2022 Annual Radiological Environmental Operating Report PLA-7883, Proposed Amendment to Licenses NPF-14 and NPF-22: Relocate Technical Specification Unit Staff Qualification Requirements to Quality Assurance Program (PLA-7883)2022-03-31031 March 2022 Proposed Amendment to Licenses NPF-14 and NPF-22: Relocate Technical Specification Unit Staff Qualification Requirements to Quality Assurance Program (PLA-7883) PLA-7995, Property Insurance Program (PLA-7995)2022-03-30030 March 2022 Property Insurance Program (PLA-7995) PLA-7998, Submittal of Unit 1 Cycle 23 Core Operating Limits Report and Reload Safety Analysis Report2022-03-29029 March 2022 Submittal of Unit 1 Cycle 23 Core Operating Limits Report and Reload Safety Analysis Report PLA-7991, Proof of Financial Protection and Guarantee of Payment of Deferred Premium2022-03-24024 March 2022 Proof of Financial Protection and Guarantee of Payment of Deferred Premium PLA-7984, Supplement to License Amendment Requesting Adoption of TSTF-505, Revision 22022-03-0808 March 2022 Supplement to License Amendment Requesting Adoption of TSTF-505, Revision 2 PLA-7962, Application to Revise Technical Specifications to Adopt TSTF-564, Safety Limit MCPR PLA-79622022-01-0505 January 2022 Application to Revise Technical Specifications to Adopt TSTF-564, Safety Limit MCPR PLA-7962 2024-01-04
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Britt T. McKlnney PPL Susquehanna, LLC Vice President-Nuclear Site Operations 769 Salem Boulevard Berwick, PA 18603 Tel. 570.542.3149 Fax 570.542.1504 btmckinney@pplweb.com PP TV SEP 10 2004 U.S. Nuclear Regulatory Commission Attn.: Document Control Desk Mail Station P1-137 Washington, DC 20555 SUSQUEHANNA STEAM ELECTRIC STATION RELIEF REQUESTS 1RR05 AND 2RR05 FOR THIRD TEN-YEAR INTERVAL INSERVICE TESTING PROGRAM PLANS FOR SUSQUEHANNA SES UNITS 1&2 Docket Nos. 50-387 I PLA-5805 and 50-388 Attached please find, pursuant to 10 CFR 50.55a, "Codes and Standards," paragraph (a)(3), relief requested from the requirements of ASME OM Code ISTC-3522(c) for HPCI and RCIC systems' check valves. The basis of the relief request is that the proposed alternative would provide an equivalent level of quality and safety. This proposed alternative is requested for the duration of the Third Ten-Year Interval Susquehanna Steam Electric Station Unit 1 IST Program (June 1, 2004 through May 31, 2014).
We request that Relief Requests IRRO5 and 2RR05 to the Third Ten-Year Interval IST Program Plans for Susquehanna SES Units I and 2 be approved by January 1, 2005.
Should you have any questions, please contact C. T. Coddington at (610) 774-4019.
Sincerely, B. T. McKinney 01-
Document Control Desk PLA-5805 Attachments:
Attachment 1 - Relief Request IRR05 to the Susquehanna Steam Electric Station Unit 1 Third Ten-Year Interval Inservice Testing Program Plan Attachment 2 - Relief Request 2RR05 to the Susquehanna Steam Electric Station Unit 2 Proposed Third Ten-Year Interval Inservice Testing Program Plan Copy: Regional Administrator - Region I Mr. A. J. Blarney, NRC Sr. Resident Inspector Mr. R. V. Guzman, NRC Project Manager Mr. R. Janati, DEP/BRP p..
I Attachment No. 1 to PLA-5805 Relief Request 1RRO5 to Susquehanna SES Unit 1 Third Ten-Year Interval Inservice Testing Program Plan
Attachment I to PLA-5805 Page I of 3 RELIEF REQUEST 1RRO5 Relief in' accordance with 10 CFR 50.55a (a)(3)(i)
Alternative Provides Acceptable Level of Quality and Safety I1. ASME Code Component(s) Affected Valve System Cat Safety Number SseCa. Class 149F028 Reactor Core A/C 2 Isolation Cooling 149F040 Reactor Core A/C 2 Isolation Cooling _
155F049 High Pressure A/C 2 Coolant injection Function Check valve 149F028 is the Reactor Core Isolation Cooling (RCIC) Vacuum Pump discharge check valve to the suppression pool. It has a close safety function for containment isolation. Check Valve 149F040 is the Reactor Core Isolation Cooling (RCIC) Turbine Exhaust check valve to the suppression pool. It has an open safety function to provide a flow path from the RCIC turbine exhaust to the suppression pool and a close safety function for containment isolation. Check valve 155F049 is the High Pressure Coolant Injection (HPCI) Turbine Exhaust check valve to the suppression pool. It has an open safety function to provide a flow path from the HPCI turbine exhaust to the suppression pool and a close safety function for containment isolation.
- 2. Applicable Code Requirement ASME OM Code 1998 Edition through OMb-2000 Addenda ISTC-3522(c), "Category C Check Valves" "If exercising is not practical during operation at power and cold shutdowns, it shall be performed during refueling outages."
Attachment 1 to PLA-5805 Page 2 of 3
- 3. Basis for Relief ^:-.os; Pursuant to 10 CFR 50.55a, "Codes and Standards," paragraph (a)(3), relief is requested from the requirements of ASME OM Code ISTC-3522(c). The basis of the relief request is that the proposed alternative would provide an acceptable level of quality and safety.
The components listed above are check valves with no external means for exercising and no external position indication. The only practical means to verify closure is by Appendix J local leakage rate testing. This involves setup of test equipment and system configuration changes that are impractical on a quarterly or cold shutdown basis. The Appendix J testing can be performed at intervals other than refueling outages such as during system outage windows.
Prior to performing a system outage on-line, its effect on risk is evaluated in accordance with requirements of 10 CFR 50.65(a)(4), "Requirements for Monitoring the Effectiveness of Maintenance at Nuclear power Plants." This requirement states in part that: "Before performing maintenance activities (including but not limited to surveillance, post-maintenance testing, and corrective and preventive maintenance), the licensee shall assess and manage the increase in risk that may result from the proposed maintenance activities."
SSES complies with the requirements of 10 CFR 50.65(a)(4) via application of a program governing maintenance scheduling. The program dictates the requirements for risk evaluations as well as the necessary levels of action required for risk management in each case. The program also controls operation of the on-line risk monitoring system, which is based on probabilistic risk assessment (PRA). With the use of risk evaluation for various aspects of plant operations, SSES has initiated efforts to perform additional maintenance, surveillance, and testing activities during normal operation. Planned activities are evaluated utilizing risk insights to determine the impact on safe operation of the plant and the ability to maintain associated safety margins. Individual system components, a system train, or a complete system may be planned to be out of service to allow maintenance, or other activities, during normal operation.
Appendix J testing may involve a system breach, if required to repair a failed valve. However, during the disassembly process to perform maintenance, the subject valve is isolated and the associated section of piping drained. Thus, the system breach does not increase the risk due to internal flooding or internal system loss-of-coolant accident. The risk associated with these activities would be bounded by the risk experienced due to the system outage. Therefore, closure testing of these valves by Appendix J during schedule system outages while on-line would have no additional impact on core damage frequency.
Attachment 1 to PLA-5805 Page 3 of 3 As more system outages are performed on-line, it is evident that selected refueling outage inservice testing activities, (e.g., closure testing by leak testing) could be performed during theise system outage windows witih6it sacrificing the level of quality or safety. Inservice testing performed on a refueling outage frequency is currently acceptable in accordance with ASME OM Code, 1998 Edition through 2000 Addenda. By specifying testing activities on a frequency commensurate with each refueling outage, ASME OM Code, 1998 Edition through 2000 Addenda, establishes an acceptable time period between testing. Historically, the refueling outage has provided a convenient and defined time period in which testing activities could be safely and efficiently performed. However, an acceptable testing frequency can be maintained separately without being tied directly to a refueling outage. Inservice testing performed on a frequency that maintains the acceptable time period between testing activities during the operating cycle is consistent with the intent of ASME OM Code, 1998 Edition through 2000 Addenda.
Over time, approximately the same number of tests will be performed using the proposed operating cycle frequency as would be performed using the current refueling outage frequency. Thus, inservice testing activities performed during the proposed operating cycle test frequency provide an equivalent level of quality and safety.
- 4. Proposed Alternate Testing Pursuant to 10 CFR 50.55a(a)(3)(i), SSES proposes an alternative testing frequency for performing inservice testing of the valves identified above. The valves will be closure tested by Appendix J on a frequency of at least once per operating cycle in lieu of once each refueling outage as currently allowed by ASME OM Code, 1998 Edition through 2000 Addenda, ISTC-3522(c),
"Category C Check Valves." The open safety function of check valve 149F040 will be demonstrated quarterly in conjunction with the RCIC flow verification (inservice pump test). The open safety function of check valve 155F049 will be demonstrated quarterly in conjunction with the HPCI flow verification (inservice pump test). As required by ISTC-5221 (a)(3), the open function of check valve 149F028 will be demonstrated quarterly in conjunction with the RCIC flow verification (inservice pump test).
- 5. Duration of Relief Request This proposed alternative is requested for the duration of the Third Ten-Year Interval Susquehanna Steam Electric Station Unit 1 IST Program (June 1, 2004 through May 31, 2014).
Attachment No. 2 to PLA-5805 Relief Request 2RR05 to Susquehanna SES Unit 2 Third Ten-Year Interval Inservice Testing Program Plan
Attachment 2 to PLA-5805 Page I of 3 RELIEF REQUEST 2RR05 Relief in accordance with 10 CFR 50.55a (a)(3)(i)
Alternative Provides Acceptable Level of Quality and Safety ASME Code Component(s) Affected Valve System Cat. Safety Number SseCa. Class 249F028 Reactor Core A/C 2 Isolation Cooling 249F040 Reactor Core A/C 2 Isolation Cooling 255F049 High Pressure A/C 2
_ Coolant injection I Function Check valve 249F028 is the Reactor Core Isolation Cooling (RCIC) Vacuum Pump discharge check valve to the suppression pool. It has a close safety function for containment isolation. Check Valve 249F040 is the Reactor Core Isolation Cooling (RCIC) Turbine Exhaust check valve to the suppression pool. It has an open safety function to provide a flow path from the RCIC turbine exhaust to the suppression pool and a close safety function for containment isolation. Check valve 255F049 is the High Pressure Coolant Injection (HPCI) Turbine Exhaust check valve to the suppression pool. It has an open safety function to provide a flow path from the HPCI turbine exhaust to the suppression pool and a close safety function for containment isolation.
2. Applicable Code Requirement
ASME OM Code 1998 Edition through OMb-2000 Addenda ISTC-3522(c), "Category C Check Valves" "If exercising is not practical during operation at power and cold shutdowns, it shall be performed during refueling outages."
Attachment 2 to PLA-5805 Page 2 of 3
- 3. Basis for Relief Pursuant to 10 CFR50.55a, "Codes and Standards," paiagraph (a)(3), relief is requested from the requirements of ASME OM Code ISTC-3522(c). The basis of the relief request is that the proposed alternative would provide an acceptable level of quality and safety.
The components listed above are check valves with no external means for exercising and no external position indication. The only practical means to verify closure is by Appendix J local leakage rate testing. This involves setup of test equipment and system configuration changes that are impractical on a quarterly or cold shutdown basis. The Appendix J testing can be performed at intervals other than refueling outages such as during system outage windows.
Prior to performing a system outage on-line, its effect on risk is evaluated in accordance with requirements of 10 CFR 50.65(a)(4), "Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants." This requirement states in part that: "Before performing maintenance activities (including but not limited to surveillance, post-maintenance testing, and corrective and preventive maintenance), the licensee shall assess and manage the increase in risk that may result from the proposed maintenance activities."
SSES complies with the requirements of 10 CFR 50.65(a)(4) via application of a program governing maintenance scheduling. The program dictates the requirements for risk evaluations as well as the necessary levels of action required for risk management in each case. The program also controls operation of the on-line risk monitoring system, which is based on probabilistic risk assessment (PRA). With the use of risk evaluation for various aspects of plant operations, SSES has initiated efforts to perform additional maintenance, surveillance, and testing activities during normal operation. Planned activities are evaluated utilizing risk insights to determine the impact on safe operation of the plant and the ability to maintain associated safety margins. Individual system components, a system train, or a complete system may be planned to be out of service to allow maintenance, or other activities, during normal operation.
Appendix J testing may involve a system breach, if required to repair a failed valve. However, during the disassembly process to perform maintenance, the subject valve is isolated and the associated section of piping drained. Thus, the system breach does not increase the risk due to internal flooding or internal system loss-of-coolant accident. The risk associated with these activities would be bounded by the risk experienced due to the system outage. Therefore, closure testing of these valves by Appendix J during schedule system outages while on-line would have no additional impact on core damage frequency.
Attachment 2 to PLA-5805 Page 3 of 3 As more system outages are performed on-line, it is evident that selected refueling outage inservice testing activities, (e.g., closure testing by leak testing) could be performed during these'system outage windows without sacrificing the level of quality or safety. Inservice testing performed on a'refueling outage frequency is currently acceptable in accordance with ASME OM Code, 1998 Edition through 2000 Addenda. By specifying testing activities on a frequency commensurate with each refueling outage, ASME OM Code, 1998 Edition through 2000 Addenda, establishes an acceptable time period between testing. Historically, the refueling outage has provided a convenient and defined time period in which testing activities could be safely and efficiently performed. However, an acceptable testing frequency can be maintained separately without being tied directly to a refueling outage. Inservice testing performed on a frequency that maintains the acceptable time period between testing activities during the operating cycle is consistent with the intent of ASME OM Code, 1998 Edition through 2000 Addenda.
Over time, approximately the same number of tests will be performed using the proposed operating cycle frequency as would be performed using the current refueling outage frequency. Thus, inservice testing activities performed during the proposed operating cycle test frequency provide an equivalent level of quality and safety.
- 4. Proposed Alternate Testing Pursuant to 10 CFR 50.5 5a(a)(3)(i), SSES proposes an alternative testing frequency for performing inservice testing of the valves identified above. The valves will be closure tested by Appendix J on a frequency of at least once per operating cycle in lieu of once each refueling outage as currently allowed by ASME OM Code, 1998 Edition through 2000 Addenda, ISTC-3522(c),
"Category C Check Valves." The open safety function of check valve 249F040 will be demonstrated quarterly in conjunction with the RCIC flow verification (inservice pump test). The open safety function of check valve 255F049 will be demonstrated quarterly in conjunction with the HPCI flow verification (inservice pump test). As required by ISTC-5221(a)(3), the open function of check valve 249F028 will be demonstrated quarterly in conjunction with the RCIC flow verification (inservice pump test).
- 5. Duration of Relief Request This proposed alternative is requested for the duration of the Third Ten-Year Interval Susquehanna Steam Electric Station Unit 2 IST program (June 1, 2004 through May 31, 2014).