Letter Sequence Response to RAI |
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MONTHYEARPLA-7055, Proposed Relief Requests for the Fourth Ten-Year Inservice Testing Interval2013-10-0808 October 2013 Proposed Relief Requests for the Fourth Ten-Year Inservice Testing Interval Project stage: Request CNL-13-108, Requests for Alternatives 13-ISI-1 and 13-ISI-2 to Extend the Reactor Vessel Weld Inservice Inspection Interval2013-10-15015 October 2013 Requests for Alternatives 13-ISI-1 and 13-ISI-2 to Extend the Reactor Vessel Weld Inservice Inspection Interval Project stage: Other ML13323A4942013-11-19019 November 2013 NRR E-mail Capture - Sequoyah 1 and 2 - Acceptance Review for Requests for Alternatives 13-ISI-1 and 13-ISI-2 to Extend the Reactor Vessel Weld Inservice Inspection Interval Project stage: Acceptance Review ML13326A0022013-11-27027 November 2013 Supplemental Information Needed for Acceptance of Requested Licensing Action Proposed Relief Requests for the Fourth Ten-Year Inservice Testing Interval (TAC Nos. MF2905 Through MF2915) Project stage: Acceptance Review PLA-7120, Revised Proposed Relief Requests for the Fourth Ten-Year Inservice Testing Interval for Susquehanna Units 1 and 2, PLA-71202013-12-12012 December 2013 Revised Proposed Relief Requests for the Fourth Ten-Year Inservice Testing Interval for Susquehanna Units 1 and 2, PLA-7120 Project stage: Request ML13350A5332013-12-18018 December 2013 Acceptance of Requested Licensing Action Proposed Relief Requests for the Fourth 10-Year Inservice Testing Interval (TAC MF2905 Through MF2912 and MF2915) Project stage: Acceptance Review ML14013A1502014-01-31031 January 2014 Request for Additional Information Regarding Relief Requests for the Fourth 10-Year Inservice Testing Interval Project stage: RAI PLA-7142, Response to Request for Additional Information on Fourth Ten-Year Inservice Testing Interval Proposed Relief Requests2014-02-26026 February 2014 Response to Request for Additional Information on Fourth Ten-Year Inservice Testing Interval Proposed Relief Requests Project stage: Response to RAI PLA-7148, Response to Request for Additional Information on Fourth Ten-Year Inservice Testing Interval Proposed Relief Request, PLA-71482014-03-31031 March 2014 Response to Request for Additional Information on Fourth Ten-Year Inservice Testing Interval Proposed Relief Request, PLA-7148 Project stage: Response to RAI CNL-14-073, 151-1 and 13-151-2 Relief Request Interval Applicability Clarification2014-05-0909 May 2014 151-1 and 13-151-2 Relief Request Interval Applicability Clarification Project stage: Request ML14122A1972014-05-22022 May 2014 Relief Requests for the Fourth 10-Year Inservice Testing Interval (TAC Nos. MF2905 Through MF2912 and MF2915) Project stage: Acceptance Review 2013-12-18
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Response to Request for Additional Information on Fourth Ten-Year Inservice Testing Interval Proposed Relief Request, PLA-7148ML14090A507 |
Person / Time |
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Site: |
Susquehanna |
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Issue date: |
03/31/2014 |
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From: |
Franke J Susquehanna |
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To: |
Document Control Desk, Office of Nuclear Reactor Regulation |
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References |
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PLA-7148, TAC MF29015, TAC MF2905, TAC MF2906, TAC MF2907, TAC MF2908, TAC MF2909, TAC MF2910, TAC MF2911, TAC MF2912 |
Download: ML14090A507 (5) |
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Category:Letter type:PLA
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[Table view] |
Text
Jon A. Franke PPL Susquehanna, LLC Site Vice President 769 Salem Boulevard Berwick, PA 18603 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-7148 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 10-Year Inservice Testing Interval (TAC Nos. MF2905 Through MF2912 and MF29I5)," dated January 3I, 2014 (Accession ML14013Al50).
- 4. PPL Letter (PLA-7I42), "Response to Request for Additional Iriformation on Fourth Ten-Year Inservice Testing Interval Proposed Relief Requests," dated February 26, 2014 (Accession ML14059A084).
The purpose of this letter is for PPL Susquehanna, LLC (PPL) to provide clarification to the information previously provided in response to NRC question RAI-4 from Reference 3.
The NRC requested this clarification in a discussion on March 6, 2014, at which time PPL agreed to provide the additional information. This response supports the current NRC review of the proposed alternative requests in References 1 and 2. The requested information is in Attachment 1 to this letter which replaces the original response to RAI-4 (Reference 4) in its entirety.
There are no new regulatory commitments associated with this response.
Document Control Desk PLA-7148 If you have any questions or require additional information, please contact Mr. Duane L. Filchner (570) 542-6501.
J. ~ ranke : 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-7148 Response to Request for Additional Information
Attachment 1 to PLA-7148 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 (IST) 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 NRC requested additional information (RAI) in a letter dated January 31, 2014. (3) PPL responded to the RAI in a letter dated February 26, 2014.<4 ) The NRC clarified the requested information with PPL in a discussion on March 6, 2014, at which time PPL agreed to supplement the information provided in response to the NRC question RAI-4. The balance of this attachment provides the requested information.
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 (Emergency Service Water (ESW) Control Structure Chiller (CSC) Loop A Keepfill) and 086341 (ESW CSC Loop B Keepfill) are tested on a 24 month frequency. Each of these check valves have a separate surveillance test which accomplishes their required inservice testing. The requested alternative requires performance of the closure test at least once per operating cycle, and the scheduled test interval is required to be once every 24 months. This does not allow scheduling this test to be at the beginning of one operating cycle and at the end of the next operating cycle. Therefore, the maximum scheduled interval between tests will remain 24 months.
(1) PPL Letter (PLA-7055), "Proposed Relief Requests for the Fourth Ten-Year In service 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 Inservice 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).
(4) PPL Letter (PLA-7142), "Response to Request for Additional Information on Fourth Ten-Year Inservice Testing Interval Proposed Relief Requests," dated February 26, 2014 (Accession ML14059A084).
Attachment 1 to PLA-7148 Page 2 of 2 Response to Request for Additional Information Check valves 086018 (Emergency Condenser Water Circulating Pump A Discharge Check Valve) and 086118 (Emergency Condenser Water Circulating Pump B Discharge Check Valve) have an open safety function to provide a flow path from the emergency condenser water pump to the chiller condenser. These check valves are exercised tested open on a quarterly frequency.
The valves 086018 and 086118 will close to prevent backflow through an idle pump. The function is not required for safe shutdown or accident mitigation. The requested alternative requires performance of the closure test at least once per operating cycle, and the scheduled test interval is required to be once every 24 months. This does not allow scheduling this test to be at the beginning of one operating cycle and at the end of the next operating cycle. Therefore, the maximum scheduled interval between tests will remain 24 months.