PLA-6842, Response to E-mail (Dated March 30, 2012), Request for Additional Information on Proposed Amendment Number 281

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Response to E-mail (Dated March 30, 2012), Request for Additional Information on Proposed Amendment Number 281
ML12093A222
Person / Time
Site: North Anna Dominion icon.png
Issue date: 04/02/2012
From: Helsel J
Susquehanna
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
PLA-6842
Download: ML12093A222 (9)
v • d • e


Text

\ I I Jeffrey M. Helsel PPLSusquehann~LLC \ ' I I I Nuclear Plant Manager 769 Salem Boulevard '~ \***/ ,~ "

Berwick, PA 18603 * * *"

ppl .;~~~:

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 20 55 5 SUSQUEHANNA STEAM ELECTRIC STATION RESPONSE TO EMAIL (DATED MARCH 30, 2012)

REQUEST FOR ADDITIONAL INFORMATION ON PROPOSED AMENDMENT NUMBER 281 TO UNIT 2 OPERATING LICENSE NO. NPF-22 PLA-6842 Docket No. 50-388

References:

1. Letter (PLA-6817) from R. A. Kearney (PPL) to USNRC (Document Control Desk) Titled "Proposed Amendment Number 281 to Unit 2 Operating License No. NPF-22 Temporary Change to Allow Implementation of Multiple Spurious Operations Modifications on SSES Unit 1 4160 v Buses: Technical Specifications 3.8. 7 and 3. 7.1 ",Dated March 8, 2012.
2. Email from B. Vaidya (USNRC) to PPL Titled "Susquehanna Unit 2, ME8152, Draft Request for Additional Information (RAJ) from Balance of Plant Branch",

Dated March 16, 2012.

3. Letter (PLA-6828) from J M Helsel (PPL) to USNRC (Document Control Desk) Titled "Response to Email (Dated March 16, 2012) Request for AdditionalJnformation Proposed Amendment Number 281 to Unit 2 Operating License No. NPF-22 ",

Dated March 23, 2012.

4. Email from B. Vaidya (USNRC) to PPL Titled "Susquehanna Unit 2, ME8152; Additional Request for AdditionalJnformation (RAJ) from Balance of Plant Branch",

Dated March 27, 2012.

5. Letter (P LA -6834) from J M Helsel (P PL) to USNRC (Document Control Desk) Titled "Response to Email (Dated March 27, 2012) Request for Additional Information Proposed Amendment Number 281 to Unit 2 Operating License No. NPF-22 ",

Dated March 29, 2012.

6. Email from B. Vaidya (USNRC) to PPL, Titled "Susquehanna Unit 2 LAR-Clari.fication of Susquehanna RAJ Response dated Mar 2 3, FW* RAJ Clarification, Susquehanna Unit 2 LAR", Dated March 30, 2012.

The purpose of this letter is to respond to a Request for Additional Information (RAI)

(Reference 6) from the NRC on March 30,2012. The responses to the NRC questions are contained in Attachment 1.

Document Control Desk PLA-6842 There are no regulatory commitments associated with the proposed changes.

PPL Susquehanna, LLC is providing the Commonwealth of Pennsylvania with a copy of this response to the RAI.

If you have any questions or require additional information, please contact Mr. Cornelius T. Coddington at (610) 774-4019.

J. M. Helsel Attachments: Response to Request for Additional Information, dated March 30, 2012 Revised Mark-up for Technical Specification LCO 3.7.1 Footnote to Clarify Applicability Copy: NRC Region I Mr. J. W. Andersen, NRRIEEEB/BC Mr. R. B. Elliot, NRR/STSB/BV Mr. P. W. Finney, NRC Sr. Resident Inspector Mr. D. M. Frumkin, NRR/AFPB Mr. D. G. Harrison, NRR/APLA/BC Mr. R. R. Janati, DEP/BRP Mr. A. R. Klein, NRR/AFPB/BC Mr. G. S. Matharu, NRR/EEEB Mr. B. K. Vaidya, NRC Project Manager Mr. K. V. Scales, NRR/EEEB Mr. G. M. Waig, NRR/STSB {Tech Specification Branch)

Mr. G. A. Wilson, NRR/DORL/LPL1-1/BC

Attachment 1 to PLA-6842 PPL Susquehanna, LLC Response to Request for Additional Information, dated March 30, 2012

Attachment 1 to PLA-6842 Page 1 of3 NRC Question #1:

Table 1 of the licensee's letter dated March 23 needs clarification. Specifically, a) the line items on pages 7 of 19 and 10 of 19 refer to "at least 2 of."

Complete/correct/clarify the statement.

b) For the same line items, the statement says to declare the associated pumps inoperable. Clarify the association. Is the association of each pump with a particular fan or is the association of each pump with the ESSW Pumphouse Ventilation subsystem?

PPL Response:

Technical Requirements Manual Section 3.7.6, ESSW Pumphouse Ventilation, requires two ESSW Pumphouse Ventilation Subsystems to be OPERABLE. An OPERABLE ESSW Pumphouse Subsystems consists of four (4) trains. A train consists of a fan and associated dampers. Each ventilation subsystem provides cooling for separate divisions of equipment. Each division consists of two ESW Pumps, one Unit 1 RHRSW Pump and one Unit 2 RHRSW Pump.

The fans for the Division 1 ESSW Pumphouse Ventilation subsystem are powered from 4.16 kV Bus 1A20 1. When 4.16 kV Bus 1A20 1 is out of service for Appendix R MSO work, all four Division 1 ESSW Pumphouse subsystem fans lose their power. With this loss of power to the Division 1 ESSW Pumphouse subsystem, an entry into TRO 3.7.6 Condition C would be required. Condition C requires that at least two fans in the inoperable subsystem be restored to OPERABLE status in 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. Failure to satisfy the requirements of Condition C requires entry into Condition E. Condition E requires that the associated RHRSW/ESW Pumps be declared inoperable immediately. With the loss of the power from 1A201, ESW Pump A, ESW Pump C, Unit 1 RHRSW Pump A and Unit 2 RHRSW Pump A would need to be declared inoperable immediately after the 36 hour4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> period elapsed.

Similarly, the fans for the Division 2 ESSW Pumphouse Ventilation subsystem are powered from 4.16 kV Bus 1A202. When 4.16 kV Bus 1A202 is out of service for Appendix R MSO work, all four Division 2 ESSW Pumphouse subsystem fans lose their power. With this loss of power to the Division 2 ESSW Pumphouse subsystem, an entry into TRO 3. 7.6 Condition C would be required. Condition C requires that at least two fans in the inoperable subsystem be restored to OPERABLE status in 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. Failure to satisfy the requirements of Condition C requires entry into Condition E. Condition E requires that the associated RHRSW/ESW Pumps be declared inoperable immediately.

With the loss of the power from 1A202, ESW Pump B, ESW Pump D, Unit 1 RHRSW

Attachment 1 to PLA-6842 Page 2 of3 Pump B and Unit 2 RHRSW Pump B would need to be declared inoperable immediately after the 36 hour4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> period elapsed.

Based on engineering calculations, however, the ability to safely operate any of these pumps without forced ventilation would be available as long as an air flow path through the ESSW Pumphouse is established. Plant procedures provide direction to the Operator for establishing the required flow path. With the required flow path established, operation of Unit 2 RHRSW Pumps would be possible since the power to these pumps is from the Unit 2- 4.16 kV Buses. Therefore, even in the conditions described above with the 1A20 1 or the 1A202 Bus out of service, the affected Unit 2 RHRSW Pump is functional.

NRC Question #2:

The line items on page 7 of 19 and 10 of 19 of Table 1 of the March 23 letter show that when component 2V506A and 2V506B lose power, an RHRSW pump would be declared inoperable in 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. This does not agree with the statement on pages 10 and18 of30 in the March 8 submittal which states "Since the RHRSW pumps on Unit 2 are not impacted by the Unit 1-4.16 kV ESS Bus outages, with this return flow path established, the affected RHRSW Loop on Unit 2 will be functional." Please clarify the effect on the inoperable/functional RHRSW train for Unit 2 and the operable RHRSW train for Unit 2 when Buses 1A201 and 1A202 are de-energized causing RHRSW pumps to become inoperable.

PPL Response:

The intent ofthe statement in the March 8, 2012 submittal on pages 10 and 18 of30 related to impacts to the Unit 2 RHRSW Pumps is that power to the Unit 2 Pumps is not impacted by shutting down the buses on Unit 1, since the Unit 2 RHRSW Pumps are powered from the Unit 2- 4.16 kV Buses. Since, as described above, procedural guidance is available to establish an air flow path when the forced ventilation system is impacted and since calculations are available concluding that, with the air flow path established, room temperatures will remain below the operability temperatures for the pumps, the loss ofHVAC does not impact the ability of the RHRSW Pumps to function.

With 4.16 kV power available and with measures in place to address the effects of the loss of HVAC, it can be concluded that the affected pump will be functional and available for cooling through the functional RHRSW Loop.

Therefore, when 4.16 kV Buses 1A 201 or 1A202 are taken out of service for performing Appendix R MSO work, there will be an operable loop ofRHRSW, i.e., Loop B when 1A20 1 is out of service and Loop A when 1A202 is out of service, and a functional loop of RHRSW, i.e., Loop A when 1A20 1 is taken out of service and Loop B when 1A202 is

Attachment 1 to PLA-6842 Page 3 of3 taken out of service. The functional loops are considered to be functional because power to the Unit 2 RHRSW Pump will be available from a Unit 2 4.16 kV Bus and measures and calculations are in place demonstrating that with an adequate air flow path, the RHRSW Pumps will be capable of performing their function even without forced ventilation.

The commitment for having an operable and functional RHRSW flow path applies to the 1A20 1 and 1A202 Bus outages only, since there is no impact to the Unit 2 RHRSW Pumps when Buses 1A203 and 1A204 are taken out of service.

The footnote in LCO 3. 7.1 has been clarified to state that it only applicable when the 1A201 or 1A202 4.16 kV ESS buses is removed from service to perform the MSO modifications. This applicability was contained in PLA-6817 and the Bases for LCO 3.7.1.

Attachment 2 to PLA-6842 PPL Susquehanna, LLC Revised Mark-up for Technical Specification LCO 3. 7.1 Footnote to Clarify Applicability

PPL Rev.+

RHRSW System and UHS 3.7.1

3. 7 PLANT SYSTEMS 3.7.1 Residual Heat Removal SeNice Water (RHRSW) System and the Ultimate Heat Sink (UHS)

LCO 3. 7.1 Two RHRSW subsystems and the UHS shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3.

ACTIONS

N0 T E----------------------------------------------------------

Enter applicable Conditions and Required Actions of LCO 3.4.8, "Residual Heat Removal (RHR) Shutdown Cooling System-Hot Shutdown," for RHR shutdown cooling made inoperable by RHRSW System.

CONDITION REQUIRED ACTION COMPLETION TIME A. ---------------NOTE--------------- A1 Declare the associated RH RSW Immediately Separate Condition entry is subsystems inoperable.

allowed for each valve.

One valve in Table 3.7.1-1 A.2 Establish an open flow path to the 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> inoperable. UHS.

OR One valve in Table 3. 7.1-2 A.3 Restore the inoperable valve(s) to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> from the inoperable. OPERABLE status. discovery of an inoperable RHRSW subsystem in the opposite loop from the One valve in Table 3.7.1-3 inoperable valve( s) inoperable.

72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Any combination of valves in Table 3.7.1-1, Table 3.7.1-2, or Table 3.7.1-3 in the same return loop inoperable. 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> during the installation of the multiple fire-induced spurious operations modifications in Unit 1(1)

(continued) 1

( ) Upon completion of the MSO modifications on the Unit 1 1A201 and 1A202 4.16 kV buses, this temporary extension is no longer applicable and will expire on May 31, 2012 .

SUSQUEHANNA- UNIT 2 TS I 3.7-1 Amendment 4-§..+, +00, ~

PPL Rev.+

RHRSW System and UHS 3.7.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. One Unit 2 RHRSW subsystem B.1 Restore the Unit 2 RHRSW 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> from inoperable. subsystem to OPERABLE status. discovery of the associated Unit 1 RHRSW subsystem inoperable OR 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> during the installation of the multiple fire-induced spurious operations modifications in Unit 1 (1)

AND 7 days C. Both Unit 2 RHRSW C.1 Restore one Unit 2 RHRSW 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> from discovery subsystems inoperable. subsystem to OPERABLE status. of one Unit 1 RHRSW subsystem not capable of supporting associated Unit 2 RHRSW subsystem AND 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> D. Required Action and associated D.1 Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Completion Time not met.

AND OR D.2 Be in MODE 4. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> UHS inoperable.

1

< > Upon completion of the MSO modifications on Unit 1 1A201 and 1A202 4.16 kV buses, this temporary extension is no longer applicable and will expire on May 31 , 2012.

SUSQUEHANNA- UNIT 2 TS /3.7-2 Amendment 4-94, +W,

+00

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