ML14090A507

Response to Request for Additional Information on Fourth Ten-Year Inservice Testing Interval Proposed Relief Request, PLA-7148

ML14090A507
Person / Time
Site:	Susquehanna
Issue date:	03/31/2014
From:	Franke J A Susquehanna
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
PLA-7148, TAC MF29015, TAC MF2905, TAC MF2906, TAC MF2907, TAC MF2908, TAC MF2909, TAC MF2910, TAC MF2911, TAC MF2912
Download: ML14090A507 (5)

Text

Jon A. Franke Site Vice President U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 PPL Susquehanna, LLC 769 Salem Boulevard Berwick , PA 18603 Tel. 570.542.2904 Fax 570.542.1504 jfranke@ pplweb.com SUSQUEHANNA STEAM ELECTRIC STATION RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION ON FOURTH TEN-YEAR INSERVICE TESTING INTERVAL PROPOSED RELIEF REQUESTS PLA-7148 Docket No 50-387 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 Attachment 1: 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, P A 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.