Letter Sequence Request |
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MONTHYEARPLA-6817, Temporary Change to Allow Implementation of Multiple Spurious Operations Modifications on SSES Unit 1 4160 V Buses Unit 2 Technical Specifications 3.8.7 and 3.7.1 PLA-68172012-03-0808 March 2012 Temporary Change to Allow Implementation of Multiple Spurious Operations Modifications on SSES Unit 1 4160 V Buses Unit 2 Technical Specifications 3.8.7 and 3.7.1 PLA-6817 Project stage: Request ML12068A4222012-03-0909 March 2012 Notice of Consideration of Issuance of Amendment to Facility Operating License, Proposed No Significant Hazards Consideration Determination, and Opportunity for a Hearing Project stage: Other ML12068A4192012-03-0909 March 2012 Individual Notice of Consideration of Issuance of Amendment to Facility Operating License, Proposed No Significant Hazards Consideration Determination, and Opportunity for Hearing Project stage: Other NRC-2012-0063, Notice of Consideration of Issuance of Amendment to Facility Operating License, Proposed No Significant Hazards Consideration Determination, and Opportunity for a Hearing2012-03-0909 March 2012 Notice of Consideration of Issuance of Amendment to Facility Operating License, Proposed No Significant Hazards Consideration Determination, and Opportunity for a Hearing Project stage: Approval PLA-6828, Eleam Electric Station, Response to E-mail (Dated March 16, 2012) Request for Additional Information on Proposed Amendment Number 281 to Unit 2 Operating License No. NPF-222012-03-23023 March 2012 Eleam Electric Station, Response to E-mail (Dated March 16, 2012) Request for Additional Information on Proposed Amendment Number 281 to Unit 2 Operating License No. NPF-22 Project stage: Request ML1208703622012-03-27027 March 2012 ME8152, Additional RAI from Sbpb to Licensee LAR for Temporary Change to SSES TS 3.7.1 and TS 3.8.7, to Allow Implementation of Multiple Spurious Operations Modifications on SSES Unit 1 4160 V Buses Project stage: RAI ML12090A1552012-03-29029 March 2012 Response to E-mail (Dated March 27, 2012) Request for Additional Information on Proposed Amendment Number 281 to Unit 2 Operating License No. NPF-22 Project stage: Request PLA-6841, Request to Expedite Approval of Ppl'S Proposed Amendment Number 281 to Unit 22012-04-0202 April 2012 Request to Expedite Approval of Ppl'S Proposed Amendment Number 281 to Unit 2 Project stage: Request ML12096A1582012-04-19019 April 2012 Issuance of Amendment Temporary Change to Unit 2 Technical Specifications 3.8.7 and 3.7.1 to Allow Implementation of Multiple Spurious Operations Modifications on SSES Unit 1, 4160 V Buses Project stage: Approval ML1211701292012-04-27027 April 2012 Correction to Issuance of Amendment Project stage: Approval 2012-03-08
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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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Jeffrey M. Helsel Nuclear Plant Manager PPL Susquehanna, LLC 769 Salem Boulevard Berwick, PA 18603
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Tel. 570.542.3510 Fax 570.542.1504 jmhelsel@pplweb.com
' TM U. S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Stop OP1-17 Washington, DC 20555 SUSQUEHANNA STEAM ELECTRIC STATION REQUEST TO EXPEDITE APPROVAL OF PPL'S PROPSED AMENDMENT NUMBER 281 TO UNIT 2 OPERATING LICENSE NO. NPF-22 PLA-6841 Docket No. 50-388
References:
I. Letter (PLA-68I7) from R. A. Kearney (PPL) to USNRC (Document Control Desk) Titled "Proposed Amendment Number 28I to Unit 2 Operating License No. NPF-22 Temporary Change to Allow Implementation of Multiple Spurious Operations Modifications on SSES Unit I 4I 60 v Buses: Technical Specifications 3.8. 7 and 3. 7. I ", Dated March 8, 20I 2
- 2. Email from B. Vaidya (USNRC) to PPL, Titled "Susquehanna Unit 2, ME8I 52, Draft Request for Additional Information (RAJ) from Balance of Plant Branch", Dated March I6, 20I2.
- 3. Letter (PLA -6828) from J M Helsel (PPL) to USNRC (Document Control Desk) Titled "Response to Email (Dated March I6, 20I2) Request for Additional Information Proposed Amendment Number 28I to Unit 2 Operating License No. NPF-22", Dated March 23, 20I2.
- 4. Email from B. Vaidya (USNRC) to PPL, Titled "Susquehanna Unit 2, ME8I 52, Additional Request for Additional Information (RAJ) from Balance of Plant Branch", Dated March 27, 20I 2.
- 5. Letter (PLA-6834) from J M Helsel (PPL) to USNRC (Document Control Desk) Titled "Response to Email (Dated March 27, 2012) Request for Additional Information Proposed Amendment Number 28I to Unit 2 Operating License No. NPF-22 ", Dated March 29, 20I2.
- 6. Email from B. Vaidya (USNRC) to PPL, Titled "Susquehanna Unit 2 LAR-Clarification ofSusquehanna RAJ Response dated Mar 23, FW: RAJ Clarification, Susquehanna Unit 2 LAR ", Dated March 30, 20 I 2.
- 7. Letter (PLA-6842) from J M Helsel (PPL) to USNRC (Document Control Desk) Titled "Response to Email (Dated March 30, 20I2) Requestfor Additional Information Proposed Amendment Number 28I to Unit 2 Operating License No. NPF-22", Dated April2, 20I2.
The purpose of this letter is to provide supplemental information to the NRC staff regarding PPL's proposed amendment request No. 281. This proposed amendment was submitted on March 8, 2012, and supplemental information in response to NRC's request for additional information (RAI) was provided on March 23, 2012, March 29, 2012 and April 02, 2012. PPL requested this amendment to be processed as an exigent amendment. However, your letter dated March 9, 2012 indicated that the staff found that PPL had not provided sufficient justification for an exigent amendment. It is our understanding that the basis for this decision was the duration of time PPL took in submitting its application for amendment.
Document Control Desk PLA-6841 During the time between initial discovery of the need for the modification and the amendment submittal, PPL finalized the scope of the modifications through plant walkdowns, engineering meetings, etc. and maintained contact with the NRC to ensure that we were providing NRC Staff the information necessary for their review. Until the modification scope was finalized, PPL could not define the temporary LCO extension needed. The original one-time extension was for 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />; however, through reengineering and detailed planning this time was reduced to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
Since the Unit outages at Susquehanna SES are scheduled every two years, the scheduled Unit 1 outage in the spring of 2012 provided the first opportunity to implement the required Multiple Spurious Operations (MSO) modifications. Regulatory Guide 1.189 was issued on November 2, 2009. The next scheduled Unit 1 outage was in March 2010.
The time between the issuance of Regulatory Guide 1.189 and the Unit 1 Spring 2010 outage did not provide sufficient time to develop the corrective actions and design any modifications for implementation in the Spring 2010 outage, which was concluded in May 2010. PPL' s corrective actions were entered into the corrective action program in May 20 10 with the design and implementation of the modifications scheduled for the Spring of2012 outage which was concluded in April2010.
Implementing the modifications while both Unit 1 and Unit 2 were on line presents unique issues and additional requests for extension of completion times.
First, completion of the modifications requires the performance of Surveillance Requirement (SR) 3 .8.1.8 which requires the verification of automatic and manual transfer of unit power supply from the normal offsite circuit to the alternate offsite circuit. This SR is amended by a NOTE that states, "The automatic transfer of the unit power supply shall not be performed in MODE 1 or 2." Justification for not performing the transfer in MODES 1 or 2 is provided in the Technical Specification Bases for this SR. The Bases read in part:
"This SR is modified by a Note. The reason for the Note is that, during operation with the reactor critical, performance of the automatic transfer of the unit power supply could cause perturbations to the electrical distribution systems that could challenge continued steady state operation and, as a result, plant safety systems. The manual transfer of unit power supply should not result in any perturbation to the electrical distribution system; therefore, no mode restriction is specified. This Surveillance tests the applicable logic associated with Unit 1. The comparable test specified in Unit 2 Technical Specifications tests the applicable logic associated with Unit 2.
Consequently, a test must be performed within the specified Frequency for each unit. As the Surveillance represents separate tests, the Note specifying the restriction for not performing the test while the unit is in MODE 1 or 2
Document Control Desk PLA-6841 does not have applicability to Unit 2. The NOTE only applies to Unit 1, thus the Unit 1 Surveillance shall not be performed with Unit 1 in MODE 1 or 2."
Unit 2 SR 3 .8.1.8 contains the same note.
Second, the presently requested Unit 2 Technical Specification completion time extensions would also apply.
Third, Unit 1 Technical Specification 3.7.1 would require extensions for the completion time to 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> for a RHRSW loop out of service. In addition, Technical Specification 3.8.7 would require an extension for the completion time for a bus to be out of service from 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> to 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br />.
Based upon the above restrictions, possible safety system challenges and additional completion time requests, it is not prudent to perform these modifications while Unit 1 and Unit 2 are online.
PPL has expeditiously responded to the NRC Staffs questions and it is our understanding that we have satisfactorily resolved all the staffs questions. In addition, PPL understands that the Commonwealth of Pennsylvania did not object to the proposed amendment.
When there is a finding of no significant hazards, 10 C.P.R. § 50.91(a)(5) allows for an amendment to be issued without notice to the public on an emergency basis when failure to act would result in derating or a shutdown of a unit and 10 C .F .R. 50.91 (a)( 6) allows for a limited comment period where an exigent circumstance exists. An exigent situation is something "short of an emergency" i.e., short of an immediate shutdown or derate. (48 Federal Register 14876) In this case, use of an exigent amendment is appropriate, as there is not an immediate risk of shutdown thus allowing a limited public comment period. PPL recognizes that these provisions should be used when there is a net increase in safety or reliability and in this case, performing the MSO modification without unnecessarily shutting down Unit 2 will result in increased safety to Unit 1 without jeopardizing safety at Unit 2 or reliability for our customers.
Based on the above, PPL respectfully requests that NRC process this amendment as an exigent amendment or in the alternative, if necessary as an emergency amendment.
There are no regulatory commitments associated with the proposed changes.
PPL Susquehanna, LLC is providing the Commonwealth of Pennsylvania with a copy of this letter.
Document Control Desk PLA-6841 If you have any questions or require additional information, please contact Mr. Cornelius T. Coddington at (610) 774-4019.
Sincerely, J. M. Helsel Copy: NRC Region I Mr. P. W. Finney, NRC Sr. Resident Inspector Mr. R. R. Janati, DEP/BRP Mr. B. K. Vaidya, NRC Project Manager Mr. G. A. Wilson, NRR/DORL/LPL1-1/BC