PLA-7142, Response to Request for Additional Information on Fourth Ten-Year Inservice Testing Interval Proposed Relief Requests

Response to Request for Additional Information on Fourth Ten-Year Inservice Testing Interval Proposed Relief Requests

ML14059A084
Person / Time
Site:	Susquehanna
Issue date:	02/26/2014
From:	Franke J Susquehanna
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
PLA-7142
Download: ML14059A084 (5)

Text

Jon A. Franke PPL Susquehanna, LLC Site Vice President 769 Salem Boulevard Berwick, PA 18603 F£8 2 6 2014 Tel. 570.542.2904 Fax 570.542.1504 jfranke@ pplweb.com U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 SUSQUEHANNA STEAM ELECTRIC STATION RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION ON FOURTH TEN-YEAR INSERVICE TESTING INTERVAL PROPOSED RELIEF REQUESTS Docket No 50-387 PLA-7142 and No. 50-388

References:

I. PPL Letter (PLA-7055), "Proposed Relief Requests for the Fourth Ten-Year Inservice Testing Interval for Susquehanna Units I and 2," dated October 8, 2013 (Accession ML13282A554).

2. PPL Letter (PLA -7I20), "Revised Proposed Relief Requests for the Fourth Ten- Year Inservice Testing Interval for Susquehanna Units I and 2, " dated December 12, 2013 (Accession ML13347B233 ).

3. NRC Letter, "Request for Additional Information Regarding Relief Requests for the Fourth IO-Year Inservice Testing Interval (TAC Nos. MF2905 Through MF2912 and MF29I5)," dated January 3I, 2014 (Accession MLI4013AI50).

The purpose of this letter is for PPL Susquehanna, LLC (PPL) to provide a response to the request for additional information contained in Reference 3. The NRC discussed a draft of the requested information with PPL on January 29, 2014, at which time PPL agreed to provide this response by February 28, 2014. The information supports a review of the proposed alternative requests described in References 1 and 2. The requested information is in Attachment 1 to this letter.

There are no regulatory commitments associated with this response.

If you have any questions or require additional information, please contact Mr. Duane L. Filchner (570) 542-6501.

. A. Franke

/

Document Control Desk PLA-7142 : Response to Request for Additional Information Copy: NRC Region I Mr. J. Greives, NRC Sr.- Resident Inspector Mr. J. Whited, NRC Project Manager Mr. L. Winker, PA DEP/BRP

Attachment 1 to PLA-7142 Response to Request for Additional Information

Attachment 1 to PLA-7142 Page 1 of 2 Response to Request for Additional Information This additional information relates to PPL letters dated October 8,<1) and December 12, 2013(2) that submitted a group of relief requests for the Susquehanna Steam Electric Station, (SSES)

Units 1 and 2. These relief requests are associated with the Fourth 10-Year Inservice Testing (1ST) Interval. The additional information provided in this attachment relates specifically to the relief request 1RR-05, regarding alternative requirements for check valve testing frequency. The relief request 1RR-05 is an alternative to requirements of the American Society of Mechanical Engineers Operation and Maintenance Code (ASME OM Code), Section ISTC-3522(c), for four check valves (086018, 086118,086241, and 086341). The balance of this attachment provides the response to the NRC's request for additional information (RAI), dated January 31, 2014.(3)

RAI-l:

It appears that this relief request is for SSES-1 only. However, Section 5, "Proposed Alternate Testing," of your supplement states, in part, that "[p]ursuant to 10 CFR 50.55a(a)(3)(i), SSES 1 and 2 proposes an alternative testing frequency for performing inservice testing of the valves identified above."

Please verify that this relief requests is only for SSES Unit 1.

PPL's Response:

Check valves 086018, 086118, 086241, and 086341 are considered SSES Unit 1 components.

1ST relief request 1RR-05 applies toSSES Unit 1 only.

RAI-2

If these valves have been tested at refueling outage intervals in the past, is it documented in the 1ST program refueling outage justifications?

PPL's Response:

No, during the current 10 year SSES 1ST interval (June 1, 2004 to May 31, 2014) check valves 086018, 086118, 08641, and 086341 are being tested in accordance with 1ST relief request 1RR06. This relief request permits testing on a 24 month frequency during system outages.

(1) PPL Letter (PLA-7055), "Proposed Relief Requests for the Fourth Ten-Year Inservice Testing Interval for Susquehanna Units 1 and 2," dated October 8, 2013 (Accession ML13282A554).

(2) PPL Letter (PLA-7120), "Revised Proposed Relief Requests for the Fourth Ten-Year In service Testing Interval for Susquehanna Units 1 and 2," dated December 12, 2013 (Accession ML13347B233).

(3) NRC Letter, "Request for Additional Information Regarding Relief Requests for the Fourth 10-Year Inservice Testing Interval (TAC Nos. MF2905 Through MF2912 and MF2915)," dated January 31, 2014 (Accession ML14013A150).

Attachment 1 to PLA-7142 Page 2 of 2 Response to Request for Additional Information

RAI-3

Do check valves 086241 and 086341 have a leakage criteria? If not, can the valve close verification be accomplished using non-intrusive techniques, such as, an accelerometer verifying that the disk hits the seat?

PPL's Response:

Check valves 086241 and 086341 do not have a design leakage limit criteria; however, leakage acceptance criteria has been assigned to these valves for testing and performance trending purposes. An accelerometer cannot be utilized for the closure testing of these check valves because SSES does not utilize nonintrusive check valve testing technologies. Check valves 086241 and 086341 are tested in the closed direction using a leakage test.

RAI-4

The proposed alternative, of this relief request, is to verify the close function once during the operating fuel cycle instead of during refueling outages. This method has the potential of testing a valve at the end of a cycle and then again at the beginning of the next cycle. This could lead to a situation where the close verify test will not be performed for almost 4 years. Please verify that the maximum interval between tests will be less than 24 months.

PPL's Response:

Check valves 086241 and 086341 are tested on a 24 month frequency. Each of these check valves have a separate surveillance test which accomplishes their required IST testing. Each surveillance test is performed on a 24 month frequency and, therefore, the maximum interval between the tests is 24 months.