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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-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-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-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-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-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-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
[Table view] Category:Licensee Response to Notice of Violation
MONTHYEARPLA-7838, Reply to Notice of Violation: EA-19-050 (PLA-7838)2020-02-0404 February 2020 Reply to Notice of Violation: EA-19-050 (PLA-7838) PLA-7363, Reply to Notice of Violation; EA-15-0222015-07-21021 July 2015 Reply to Notice of Violation; EA-15-022 PLA-7212, Reply to a Notice of Violation - PLA-72122014-08-29029 August 2014 Reply to a Notice of Violation - PLA-7212 PLA-7043, Response to Apparent Violations in Inspection Report No. IR 05000387-13-008 and 05000388-13-0082013-07-17017 July 2013 Response to Apparent Violations in Inspection Report No. IR 05000387-13-008 and 05000388-13-008 PLA-6588, EA-09-248, Susquehanna, Units 1 and 2, PPL Response to Apparent Violation, Dated December 10, 20092009-12-10010 December 2009 EA-09-248, Susquehanna, Units 1 and 2, PPL Response to Apparent Violation, Dated December 10, 2009 PLA-6180, Response to March 9, 2007 NPDES Violation2007-04-0505 April 2007 Response to March 9, 2007 NPDES Violation PLA-5870, Reply to a Notice of Violation (05000387-04-005-02) PLA-58702005-02-28028 February 2005 Reply to a Notice of Violation (05000387-04-005-02) PLA-5870 2020-02-04
[Table view] |
Text
TALEN~
Jon A. Franke Susquehanna Nuclear, LLC Site Vice President 769 Salem Boulevard Berwick, PA 18603 Tel. 570.542.2904 Fax 570.542.1504 Jon.franke@talenenergy.com ENERGY JUL 2 1£015 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 SUSQUEHANNA STEAM ELECTRIC STATION REPLY TO A NOTICE OF VIOLATION; EA-15-022 Docket Nos. 50-387 PLA-7363 and 50-388
Reference:
I) Letter from NRC (D. H Dorman) to Susquehanna Nuclear, LLC (T S. Rausch), "Final Significance Determination for a White Finding with Assessment Follow-up and Notice of Violation (Inspection Report No . 05000387/20I5504 and 05000388/20I5504)
Susquehanna Steam Electric Station Units I and 2, "dated June 22, 20I5.
In accordance with 10 CFR 2.201, Susquehanna Nuclear, LLC hereby submits the Reply to a Notice of Violation EA-15-022 for the Susquehanna Steam Electric Station (SSES), Units 1 and 2 (Enclosure).
By letter dated June 22, 2015 (Reference 1), the Nuclear Regulatory Commission (NRC) cited Susquehanna Nuclear, LLC for failure to maintain in effect an Emergency Plan that met the standards of 10 CFR 50.47(b)(4) and the requirements in 10 CFR 50, Appendix E, Section IV.C.2. Specifically, SSES's interpretation of the 15-minute assessment and declaration period degraded its ability to make a timely Site Area Emergency declaration for a potential loss of the Reactor Coolant System barrier emergency action level.
Susquehanna Nuclear, LLC accepts the NRC's significance determination for the identified White finding. Susquehanna Nuclear, LLC also understands that the NRC plans to conduct a supplemental inspection in accordance with Inspection Procedure 95001, "Supplemental Inspection for One or Two White Inputs in a Strategic Performance Area." As discussed in the Enclosure to this letter, prompt action has been taken to return to compliance with 10 CFR 50.54(q)(2), 10 CFR 50.47(b)(4) and 10 CFR 50, Appendix E, Section IV.C.2.
Document Control Desk PLA-7363 Should you have any questions regarding this submittal, please contact Mr. Jeffery N. Grisewood, Manager - Nuclear Regulatory Affairs at (570) 542-1330.
There are no regulatory commitments identified in this letter.
J A . Franke Enclosure Copy: Regional Administrator, NRC Region I Mr. J. E. Greives, NRC Sr. Resident Inspector Mr. J. A. Whited, NRC Project Manager Mr. B. R. Fuller, DEP/BRP
Enclosure to PLA-7363 Page 1 of 4 Enclosure Susquehanna Nuclear, LLC Reply to Notice of Violation EA-15-022 Restatement of the Violation "During an NRC inspection conducted from January 12- March 17, 2015, a violation of NRC requirements was identified. In accordance with the NRC Enforcement Policy, the violation is listed below:
10 CFR 50.54(q)(2), requires that a holder of a nuclear power reactor operating license under this part, shall follow and maintain the effectiveness of an emergency plan that meets the requirements in Appendix E of this part and the standards in 10 CFR 50.47(b) and 10 CFR 50, Appendix E.
10 CFR 50.47(b)(4), requires a standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by the nuclear facility licensee, and state and local response plans call for reliance on information provided by facility licensees for determinations of minimum initial offsite response measures.
Appendix E,Section IV.C.2, requires that by June 20, 2012, nuclear power reactor licensees shall establish and maintain the capability to assess, classify, and declare an emergency condition within 15-minutes after the availability of indications to plant operators that an emergency action level has been exceeded and shall promptly declare the emergency condition as soon as possible following identification of the appropriate emergency classification level. Licensees shall not construe these criteria as a grace period to attempt to restore plant conditions to avoid declaring an emergency action due to an EAL that has been exceeded.
Contrary to the above, as of June 20, 2012, Susquehanna Nuclear, LLC (Susquehanna) failed to maintain in effect an emergency plan that met the standards in 10 CFR 50.47(b)(4) and the requirements in 10 CFR 50, Appendix E, Section IV.C.2. Specifically, Susquehanna's interpretation of the 15-minute assessment and declaration period degraded their ability to make a timely Site Area Emergency (SAE) declaration for a potential loss of Reactor Coolant System (RCS) barrier emergency action level. Susquehanna interpreted the 15-minute assessment and declaration clock to start when operator actions were, or expected to be, unsuccessful in isolating an RCS leak. Susquehanna's incorrect interpretation of the 15-minute assessment and declaration period degraded its ability to make timely a SAE declaration.
This violation is associated with a White Significance Determination Process finding."
Enclosure to PLA-7363 Page 2 of4 Reply to a Notice of Violation EA-15-022 Pursuant to the requirements of 10 CFR 2.201, Susquehanna Nuclear, LLC, submits the following information in reply to Notice of Violation EA-15-022.
- 1) Reason for the Violation (NOV) or, if contested, the basis for disputing the violation Susquehanna Nuclear, LLC, incorrectly implemented the 15-minute assessment, classification, and declaration period for a potential loss of Reactor Coolant System (RCS) barrier Emergency Action Level (EAL). Specifically, the 15-minute assessment, classification, and declaration clock was interpreted to start when operator actions were, or were expected to be, unsuccessful in isolating a RCS leak rather than upon exceeding the EAL thresholds. This potentially degraded SSES's ability to make a timely Site Area Emergency declaration for one postulated scenario involving an unisolable primary coolant system leak outside of primary containment.
A root cause analysis was performed under Condition Report (CR) 2015-11640 for the identified violation. The following two root causes were identified.
- The Emergency Planning Department manager did not provide adequate oversight during the NRC Rulemaking process regarding the 15-minute emergency declaration period timeliness criteria implemented in 10 CFR 50, Appendix E, Section IV.C.2 on June 20, 2012.
At the time the NRC issued the Preliminary Rulemaking change to the timeliness criteria in 2010, SSES's Emergency Planning Department developed an action plan (under Action Request 1338345) to evaluate the emergency declaration timeliness criteria to ensure compliance with the new Rulemaking.
The AR was subsequently closed stating that SSES met the emergency declaration timeliness requirement as described in the 2010 preliminary rulemaking. This identifies that SSES interpreted the existing EAL bases document for Table F -Fission Product Barrier Degradation as being in compliance with the NRC Rulemaking and that no additional guidance regarding the 15-minute assessment, classification and declaration period was necessary.
- Procedure NDAP-00-0706, "Process for Issues Involving Significant Regulatory Interaction," did not drive an adequate review process to challenge the implementation of the 2012 Emergency Preparedness Rulemaking regarding the 15-minute emergency declaration period timeliness criteria.
Enclosure to PLA-7363 Page 3 of4
- 2) Corrective steps that have been taken and the results achieved The following immediate compensatory actions have been implemented:
- Provided a read and acknowledge memo to the Emergency Response Organization (ERO) that states that the measured trigger time for the Potential Loss 2 - RCS EAL begins with the temperature or radiation readings in the table exceeding the maximum normal levels.
- Revised procedure EP-RM-004, "EAL Classification Bases," Attachment F, "Fission Product Barrier Degradation Bases," Potential Loss 2- RCS section, to state the following:
Potential Loss 2 - RCS is based on primary system leakage outside the drywell determined from procedure E0-000-1 04, "Secondary Containment Control" area temperatures or radiation levels shown in Table F-1, "Max Normal Reactor Building Temperature," and F-2, "Max Normal Reactor Building Radiation Monitor."
NRC regulations require the SSES to establish and maintain the capability to assess, classify, and declare an emergency condition within 15 minutes after the availability of indications to plant operators that an emergency action level has been exceeded (EAL "trigger").
Max Normal conditions shall be assumed to be from RCS leakage until proven otherwise.
- EAL "trigger" for this threshold begins when one or more of the above Max Normal Reactor Building Radiation or Temperature Limits are exceeded.
- If subsequent actions taken to isolate the leak are successful within the 15 minutes classification period, this EAL should not be declared.
- If subsequent investigation, within the 15-minute classification period, reveals that the Max Norm conditions are not due to RCS leakage, this EAL should not be declared.
If it cannot be determined within 15 minutes of the EAL "trigger" that the leak is isolable and not the result of a condition previously described, then the EAL shall be declared.
Enclosure to PLA-7363 Page 4 of4
- 3) Corrective steps that will be taken
- Review selected EALs that require action to ensure they meet the 15-minute timeliness definition as identified in the White Finding and NSIR/DPR-ISG-01.
- Revise procedure NDAP-00-0706, "Process for Issues Involving Significant Regulatory Action," to add a process detailing how to identify the level of risk for proposed NRC Rulemaking. Based on the identified risk, determine necessary team members and required level of senior management oversight.
- 4) Date when full compliance will be achieved PPL is in full compliance with the requirements of 10 CFR 50, Appendix E, Section IV.C.2.