PLA-8182, Response to Request for Additional Information to Revise Technical Specification 5.5.12, Primary Containment Leakage Rate Testing Program, for Permanent Extension of Type a and Type C Leak Rate Testing .
| ML25177C510 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 06/26/2025 |
| From: | Casulli E Susquehanna, Talen Energy |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| PLA-8182 | |
| Download: ML25177C510 (1) | |
Text
Edward Casulli Susquehanna Nuclear, LLC Site Vice President 769 Salem Boulevard Berwick, PA 18603 Tel. 570.542.3795 Fax 570.542.1504 Edward.Casulli@TalenEnergy.com June 26, 2025 Attn: Document Control Desk 10 CFR 50.90 U. S. Nuclear Regulatory Commission Washington, DC 20555-0001 SUSQUEHANNA STEAM ELECTRIC STATION RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION TO REVISE TECHNICAL SPECIFICATION 5.5.12, PRIMARY CONTAINMENT LEAKAGE RATE TESTING PROGRAM, FOR PERMANENT EXTENSION OF TYPE A AND TYPE C LEAK RATE TESTING FREQUENCIES AND PERMANENTLY EXTEND THE DRYWELL BYPASS LEAKAGE TEST FREQUENCY PLA-8182 Docket No. 50-387 and 50-388
References:
- 1) Susquehanna letter to NRC, Proposed Amendment to Licenses NPF-14 and NPF-22: Request to Revise Technical Specification 5.5.12, Primary Containment Leakage Rate Testing Program, for Permanent Extension of Type A and Type C Leak Rate Testing Frequencies and Permanently Extend the Drywell Bypass Leakage Test Frequency (PLA-8135), dated November 01, 2024 (ADAMS Accession No. ML24306A122).
- 2) NRC email to Susquehanna, Request for Additional Information (RAI)
Susquehanna Steam Electric Station, Units 1 and 2, Docket Nos. 05000387 and 05000388 (EPID No. L-2024-LLA-0148), dated May 30, 2025 (ADAMS Accession No. ML25153A476).
Pursuant to 10 CFR 50.90, Susquehanna Nuclear, LLC (Susquehanna), submitted, in Reference 1, a request for an amendment to the Technical Specifications (TS) for the Susquehanna Steam Electric Station (SSES), Units 1 and 2, Facility Operating License Numbers NPF-14 and NPF-22. The proposed amendment would modify TS 5.5.12, Primary Containment Leakage Rate Testing Program, by extending testing intervals and frequencies, replacing references, and deleting obsolete information.
TALEN~
ENERGY Document Control Desk PLA-8182 The NRC provided a Request for Additional Information (RAI) in Reference 2. The enclosures provide Susquehannas response to the RAI.
Susquehanna has reviewed the information supporting a finding of No Significant Hazards Consideration and the Environmental Consideration provided to the NRC in Reference 1 and determined the information provided herein does not impact the original conclusions in Reference 1.
There are no new or revised regulatory commitments contained in this submittal.
Should you have any questions regarding this submittal, please contact Ms. Melisa Krick, Manager - Nuclear Regulatory Affairs, at (570) 542-1818.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on June 26, 2025.
E. Casulli
Enclosure:
- 1. Response to Request for Additional Information
- 2. Marked-Up Technical Specification Pages
- 3. Revised (Clean) Technical Specification Pages Copy: NRC Region I Ms. E. Brady, NRC Resident Inspector Ms. A. Klett, NRC Project Manager Mr. M. Shields, PA DEP/BRP
~
to PLA-8182 Response to Request for Additional Information to PLA-8182 Page 1 of 6 Response to Request for Additional Information Pursuant to 10 CFR 50.90, Susquehanna Nuclear, LLC (Susquehanna), submitted, in Reference 1, a request for an amendment to the Technical Specifications (TS) for the Susquehanna Steam Electric Station (SSES), Units 1 and 2, Facility Operating License Numbers NPF-14 and NPF-22.
The proposed amendment would modify TS 5.5.12, Primary Containment Leakage Rate Testing Program, by extending testing intervals and frequencies, replacing references, and deleting obsolete information. The NRC provided a Request for Additional Information (RAI) in Reference 2. This enclosure provides Susquehannas response to the RAI.
RAI-1
Regulatory Basis:
The NRC regulations in 10 CFR Part 50, Section 54, Conditions of licenses, paragraph (o) require primary reactor containments for water-cooled power reactors to be subject to the requirements of 10 CFR Part 50, Appendix J, which specifies containment leakage testing requirements, including the types required to ensure the leak-tight integrity of the primary reactor containment and systems and components which penetrate the containment. In addition, Appendix J to 10 CFR Part 50 discusses leakage rate acceptance criteria, test methodology, frequency of testing, and reporting requirements for each type of test.
Issue:
In its License Amendment Request (LAR), the licensee requested to modify Technical Specification 5.5.12, Primary Containment Leakage Rate Testing Program, to allow, in part, the following changes:
adopting an extension of the containment isolation valve leakage rate testing (Type C) frequency from the 60 months currently permitted by 10 CFR 50, Appendix J, Primary Reactor Containment Leakage Testing for Water-Cooled Power Reactors, Option B, to 75 months for Type C leakage rate testing of selected components, in accordance with NEI 94-01, Revision 3-A (ML12221A202).
adopting a more conservative allowable test interval extension of nine months, for Type A, Type B and Type C leakage rate tests in accordance with NEI 94-01, Revision 3-A.
Section 3.4.7, Type B and Type C Tested Components on Extended Intervals, of attachment 1 to the LAR states for both Unit 1 and Unit 2, Of the 52 Type B tested components, 48 are eligible for an extended interval, and 84.62% of the eligible components are on an extended interval. However, 84.62% of 48 eligible components gives components that are on an extended interval as 40.62, which seems incorrect because it is not an integer.
to PLA-8182 Page 2 of 6 Request:
Provide confirmation that the Type B and Type C components in each unit that are on extended intervals have been properly identified and provide the numbers of Type B and Type C components in each unit that are on extended intervals.
Susquehanna Response The information provided in Section 3.4.7 in Reference 1 was reviewed and an error in the calculation of eligible components was identified. This condition has been entered into the SSES Corrective Action Program. The components on extended interval have been properly identified and are summarized below. The population of Local Leak Rate Test components for each unit was reviewed to identify the Type B and Type C components eligible for extended interval. The eligible population performance history was then reviewed to identify those on extended interval. Note that the values below differ from the values identified in Section 3.4.7 in Reference 1 due to recent performance data and reevaluation of eligible components based on actual testing requirements (e.g., if a component is required to be tested every refueling outage for reasons other than regulatory requirements, the component was excluded from the eligible population). The revised values do not impact any conclusions provided in Reference 1.
For Unit 1, there are 51 Type B tested components, 43 of which are eligible for extended interval, and 43 of the eligible components are on extended interval.
For Unit 1, there are 199 Type C tested components, 142 of which are eligible for extended interval, and 134 components are on extended interval.
For Unit 2, there are 51 Type B tested components, 43 of which are eligible for extended interval, and 43 of the eligible components are on extended interval.
For Unit 2, there are 201 Type C tested components, 148 of which are eligible for extended interval, and 141 of the eligible components are on extended interval.
RAI-2
Regulatory Basis:
10 CFR 50.55a(b)(2)(ix)(A) and 10 CFR 50.55a(b)(2)(viii)(E) state that for Class MC and CC applications, the following apply to inaccessible areas.
(1)
The applicant or licensee must evaluate the acceptability of inaccessible areas when conditions exist in accessible areas that could indicate the presence of or could result in degradation to such inaccessible areas.
to PLA-8182 Page 3 of 6 (2)
For each inaccessible area identified for evaluation, the applicant or licensee must provide the following in the Inservice Inspection (ISI) Summary Report as required by IWA-6000:
(i) A description of the type and estimated extent of degradation, and the conditions that led to the degradation; (ii) An evaluation of each area, and the result of the evaluation; and (iii) A description of necessary corrective actions.
Issue:
NRC Regulatory Guide (RG) 1.163, Performance-Based Containment Leak-Test Program (ML23073A154), endorses NEI 94-01, Revision 3-A for implementing Option B in Appendix J to 10 CFR Part 50, subject to the regulatory positions in section C of the RG. Condition 3 in section C of RG 1.163 states, in part, The LAR should address the areas of the containment structure potentially subject to degradation... In addition, the LAR should also address such inaccessible degradation-susceptible areas in plant-specific inspections, using viable, commercially available NDE methods (such as boroscopes, guided wave techniques, etc.)
Sections 3.6.2 and 3.6.3 of attachment 1 to the LAR state that inaccessible degradation-susceptible areas, per provisions of 10 CFR 50.55a(b)(2)(ix)(A) for IWE and 10 CFR 50.55a(b)(2)(viii)(E) for IWL, are within the scope of the in-service inspection program. It is unclear whether inaccessible degradation-susceptible areas were evaluated and, if so, how the conditions were evaluated.
Request:
- 1. Provide descriptions for how inaccessible areas were evaluated and accepted when conditions exist in accessible areas that could indicate the presence of or could result in degradation to such inaccessible areas.
- 2. Provide a summary of results of the evaluations for degradation-susceptible inaccessible areas related to Class MC and CC components applicable to the IWE and IWL ISI programs.
Susquehanna Response Table 3.4.3-5 in Reference 1 identifies inspection zones considered to be inaccessible, which consists of upper elevations of the drywell exterior concrete and interior liner (zones 25, 26, 27, and 28, and zones 69, 70, 71, and 72 respectively). Per the Susquehanna ISI Program Plan, for each inaccessible area identified for evaluation, the station must provide the applicable to PLA-8182 Page 4 of 6 information specified in 10 CFR 50.55a(b)(2)(viii)(E) and 10 CFR 50.55a(b)(2)(ix)(A) in the ISI Summary Report.
Tables 3.4.5-1 through 3.4.5-6 in Reference 1 provide a summary of recent IWE inspection results. No IWE inspection results identified conditions to exist in accessible areas of the drywell upper elevations that could indicate the presence of or result in degradation to such inaccessible areas (zones 69, 70, 71, and 72). Table 3.4.5-4 documents an unacceptable condition for an inspection of the suppression pool floor; however, this area is not representative of the inaccessible areas of the upper drywell elevations. All suppression pool inspections zones are accessible.
Tables 3.4.5-7 and 3.4.5-8 in Reference 1 provide a summary of recent IWL inspection results.
As shown in the tables, no conditions were identified to exist in accessible areas that could indicate the presence of or result in degradation to such inaccessible areas (zones 25, 26, 27, and 28).
In addition, Susquehanna reviewed historical inspection summaries identifying no conditions requiring evaluation. Based on the above, evaluations of inaccessible areas per the regulatory requirements have not been necessary.
RAI-3
Currently, Susquehanna TS 5.5.12, in part states:
A program shall be established to implement the leakage rate testing of the containment as required by 10 CFR 50.54(o) and 10 CFR 50, Appendix J, Option B, as modified by approved exemptions. This program shall be in accordance with the guidelines contained in Regulatory Guide (RG) 1.163, Performance-Based Containment Leak-Test Program, dated September 1995.
The licensee proposed change to TS 5.5.12 would state, in part (with changes using strike-out for deleted text and bold-type for added text for clarification purposes):
A program shall be established, implemented, and maintained to comply with the leakage rate testing of the containment as required by 10 CFR 50.54(o) and 10 CFR 50, Appendix J, Option B, as modified by approved exemptions. This program shall be in accordance with the guidelines contained in RG 1.163, Revision 1, Performance-Based Containment Leak-Test Program, dated September 1995 June 2023, and NEI 94-01, Revision 3-A, Industry Guideline for Implementing Performance-Based Option of 10 CFR 50, Appendix J, dated July 2012 As noted above, RG 1.163, Revision 1, was issued in June of 2023. This revision of the RG endorsed the guidance in NEI 94-01, Revision 3-A, issued July 2012, for implementing Option B of Appendix J to 10 CFR Part 50, subject to the regulatory positions listed in Section C of the to PLA-8182 Page 5 of 6 RG. In the proposed change, the licensee includes the NEI document in the TS markup in addition to citing RG 1.163, Revision 1. The LAR does not appear to provide an explanation as to why the NEI guidance was explicitly included in the TS markup, given that the RG 1.163 endorses the NEI guidance. As such, the rationale for why the licensee cited the NEI document in TS 5.5.12 is not clear to the NRC staff. Providing information that clarifies why the NEI guidance is cited would help to ensure compliance with program requirements that are necessary to ensure operation of the facility in a safe manner. Therefore, the NRC staff requests that the licensee provide information that explains the rationale for citing both the RG and NEI guidance in TS 5.5.12.
Susquehanna Response As stated in the RAI, a reference to NEI 94-01, Revision 3-A, in the TS mark-up in addition to citing RG 1.163, Revision 1, is not necessary given that the RG endorses the NEI guidance.
Susquehanna therefore revises the proposed SSES Units 1 and 2 TS 5.5.12, Primary Containment Leakage Rate Testing Program, changes by removing the reference to NEI 94-01, Revision 3-A. The revised marked-up TS pages are provided in Enclosure 2. The revised (clean)
TS pages are provided in Enclosure 3.
RAI-4
The LAR Section 4.3, No Significant Hazards Considerations Analysis, proposed change description appears to suggest that 10 CFR 50, Appendix J, Option B is being replaced with a reference to NEI 94 01, Revision 3-A. This description appears to be an editorial error. The description for the proposed change provided in LAR Section 1, Summary Description, appears to be consistent with the proposed TS markups, which retain reference to Appendix J.
Therefore, the NRC staff requests that the licensee explain the apparent inconsistency in the proposed change description contained in the LAR and make any changes, as appropriate.
Susquehanna Response The paragraph in Section 4.3 in Reference 1 was not intended to suggest that 10 CFR 50, Appendix J, Option B is being replaced with reference to NEI 94-01, Revision 3-A. For clarity, the second paragraph of Section 4.3 in Reference 1 is revised as follows:
Specifically, the proposed change revises SSES Units 1 and 2 TS 5.5.12, "Primary Containment Leakage Rate Testing Program," paragraph a., by replacing the reference to RG 1.163, Revision 0, with a reference to RG 1.163, Revision 1, and 10 CFR 50, Appendix J, "Option B - Performance-Based Requirements," with a reference to NEI 94-01, Revision 3-A.
to PLA-8182 Page 6 of 6 This editorial revision to the No Significant Hazards Considerations Analysis does not impact the original conclusions documented in Reference 1.
References
- 1. Susquehanna letter to NRC, Proposed Amendment to Licenses NPF-14 and NPF-22:
Request to Revise Technical Specification 5.5.12, Primary Containment Leakage Rate Testing Program, for Permanent Extension of Type A and Type C Leak Rate Testing Frequencies and Permanently Extend the Drywell Bypass Leakage Test Frequency (PLA-8135), dated November 01, 2024 (ADAMS Accession No. ML24306A122).
- 2. NRC email to Susquehanna, Request for Additional Information (RAI) Susquehanna Steam Electric Station, Units 1 and 2, Docket Nos. 05000387 and 05000388 (EPID No. L-2024-LLA-0148), dated May 30, 2025 (ADAMS Accession No. ML25153A476).
to PLA-8182 Marked-Up Technical Specification Pages
Programs and Manuals 5.5 (continued)
SUSQUEHANNA - UNIT 1 5.0-18 Amendment 178, 202, 209, 241, 246, xxx 5.5 Programs and Manuals 5.5.11 Safety Function Determination Program (SFDP) (continued)
The SFDP identifies where a loss of safety function exists. If a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered. When a loss of safety function is caused by the inoperability of a single Technical Specification support system, the appropriate Conditions and Required Actions to enter are those of the support system.
5.5.12 Primary Containment Leakage Rate Testing Program A program shall be established, implemented, and maintained to comply with the leakage rate testing of the containment as required by 10 CFR 50.54(o) and 10 CFR 50, Appendix J, Option B, as modified by approved exemptions. This program shall be in accordance with the guidelines contained in Regulatory Guide 1.163, Revision 1, Performance-Based Containment Leak-Test Program, dated September 1995June 2023, as modified by the following exceptions:
- a. The visual examination of containment concrete surfaces intended to fulfill the requirements of 10 CFR 50, Appendix J, Option B testing, will be performed in accordance with the requirements of and frequency specified by the ASME Section XI Code, Subsection IWL, except where relief has been authorized by the NRC.
- b. The visual examination of the steel liner plate inside containment intended to fulfill the requirements of 10 CFR 50, Appendix J, Option B, will be performed in accordance with the requirements of and frequency specified by the ASME Section XI Code, Subsection IWE, except where relief has been authorized by the NRC.
- c. NEI 94-01-1995, Section 9.2.3: The first Type A test performed after the May 4, 1992 Type A test shall be performed no later than May 3, 2007.
The peak calculated containment internal pressure for the design basis loss of coolant accident, Pa, is 48.6 psig.
The maximum allowable primary containment leakage rate, La, at Pa, shall be 1% of the primary containment air weight per day.
Programs and Manuals 5.5 (continued)
SUSQUEHANNA - UNIT 2 5.0-18 Amendment 151, 176, 183, 219, 224, xxx 5.5 Programs and Manuals 5.5.11 Safety Function Determination Program (SFDP) (continued)
The SFDP identifies where a loss of safety function exists. If a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered. When a loss of safety function is caused by the inoperability of a single Technical Specification support system, the appropriate Conditions and Required Actions to enter are those of the support system.
5.5.12 Primary Containment Leakage Rate Testing Program A program shall be established, implemented, and maintained to comply with the leakage rate testing of the containment as required by 10 CFR 50.54(o) and 10 CFR 50, Appendix J, Option B, as modified by approved exemptions. This program shall be in accordance with the guidelines contained in Regulatory Guide 1.163, Revision 1, "Performance-Based Containment Leak-Test Program," dated September 1995June 2023, as modified by the following exceptions:
- a. The visual examination of containment concrete surfaces intended to fulfill the requirements of 10CFR 50, Appendix J, Option B testing, will be performed in accordance with the requirements of and frequency specified by the ASME Section XI Code, Subsection IWL, except where relief has been authorized by the NRC.
- b. The visual examination of the steel liner plate inside containment intended to fulfill the requirements of 10 CFR 50, Appendix J, Option B, will be performed in accordance with the requirements of and frequency specified by the ASME Section XI Code, Subsection IWE, except where relief has been authorized by the NRC.
- c. NEI 94-01-1995, Section 9.2.3: The first Type A test performed after the October 31, 1992 Type A test shall be performed no later than October 30, 2007.
The peak calculated containment internal pressure for the design basis loss of coolant accident, Pa, is 48.6 psig.
The maximum allowable primary containment leakage rate, La, at Pa, shall be 1% of the primary containment air weight per day.
to PLA-8182 Revised (Clean) Technical Specification Pages
Programs and Manuals 5.5 (continued)
SUSQUEHANNA - UNIT 1 5.0-18 Amendment 178, 202, 209, 241, 246, xxx 5.5 Programs and Manuals 5.5.11 Safety Function Determination Program (SFDP) (continued)
The SFDP identifies where a loss of safety function exists. If a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered. When a loss of safety function is caused by the inoperability of a single Technical Specification support system, the appropriate Conditions and Required Actions to enter are those of the support system.
5.5.12 Primary Containment Leakage Rate Testing Program A program shall be established, implemented, and maintained to comply with the leakage rate testing of the containment as required by 10 CFR 50.54(o) and 10 CFR 50, Appendix J, Option B, as modified by approved exemptions. This program shall be in accordance with the guidelines contained in Regulatory Guide 1.163, Revision 1, Performance-Based Containment Leak-Test Program, dated June 2023, as modified by the following exceptions:
- a. The visual examination of containment concrete surfaces intended to fulfill the requirements of 10 CFR 50, Appendix J, Option B testing, will be performed in accordance with the requirements of and frequency specified by the ASME Section XI Code, Subsection IWL, except where relief has been authorized by the NRC.
- b. The visual examination of the steel liner plate inside containment intended to fulfill the requirements of 10 CFR 50, Appendix J, Option B, will be performed in accordance with the requirements of and frequency specified by the ASME Section XI Code, Subsection IWE, except where relief has been authorized by the NRC.
The peak calculated containment internal pressure for the design basis loss of coolant accident, Pa, is 48.6 psig.
The maximum allowable primary containment leakage rate, La, at Pa, shall be 1% of the primary containment air weight per day.
Programs and Manuals 5.5 (continued)
SUSQUEHANNA - UNIT 2 5.0-18 Amendment 151, 176, 183, 219, 224, xxx 5.5 Programs and Manuals 5.5.11 Safety Function Determination Program (SFDP) (continued)
The SFDP identifies where a loss of safety function exists. If a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered. When a loss of safety function is caused by the inoperability of a single Technical Specification support system, the appropriate Conditions and Required Actions to enter are those of the support system.
5.5.12 Primary Containment Leakage Rate Testing Program A program shall be established, implemented, and maintained to comply with the leakage rate testing of the containment as required by 10 CFR 50.54(o) and 10 CFR 50, Appendix J, Option B, as modified by approved exemptions. This program shall be in accordance with the guidelines contained in Regulatory Guide 1.163, Revision 1, "Performance-Based Containment Leak-Test Program," dated June 2023, as modified by the following exceptions:
- a. The visual examination of containment concrete surfaces intended to fulfill the requirements of 10CFR 50, Appendix J, Option B testing, will be performed in accordance with the requirements of and frequency specified by the ASME Section XI Code, Subsection IWL, except where relief has been authorized by the NRC.
- b. The visual examination of the steel liner plate inside containment intended to fulfill the requirements of 10 CFR 50, Appendix J, Option B, will be performed in accordance with the requirements of and frequency specified by the ASME Section XI Code, Subsection IWE, except where relief has been authorized by the NRC.
The peak calculated containment internal pressure for the design basis loss of coolant accident, Pa, is 48.6 psig.
The maximum allowable primary containment leakage rate, La, at Pa, shall be 1% of the primary containment air weight per day.