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| number = ML041190242 | | number = ML041190242 | ||
| issue date = 04/28/2004 | | issue date = 04/28/2004 | ||
| title = (SSES 1 and 2), RAI, Third 10-Year Inservice Inspection Interval Program Plan Alternate Risk-Informed Selection and Examination Criteria for Pressure Retaining Piping Welds | | title = (SSES 1 and 2), RAI, Third 10-Year Inservice Inspection Interval Program Plan Alternate Risk-Informed Selection and Examination Criteria for Pressure Retaining Piping Welds | ||
| author name = Guzman R | | author name = Guzman R | ||
| author affiliation = NRC/NRR/DLPM/LPD1 | | author affiliation = NRC/NRR/DLPM/LPD1 | ||
| Line 24: | Line 24: | ||
==Dear Mr. Shriver:== | ==Dear Mr. Shriver:== | ||
In reviewing your submittal of September 16, 2003, relating to Relief Request No. 3RR-01, the Nuclear Regulatory Commission staff has determined that additional information contained in the enclosure to this letter is needed to complete its review. These questions were discussed with your staff during a teleconference on April 8, 2004. As agreed to by your staff, we request you respond within 30 days of the date of this letter. | In reviewing your submittal of September 16, 2003, relating to Relief Request No. 3RR-01, the Nuclear Regulatory Commission staff has determined that additional information contained in the enclosure to this letter is needed to complete its review. These questions were discussed with your staff during a teleconference on April 8, 2004. As agreed to by your staff, we request you respond within 30 days of the date of this letter. | ||
If you have any questions, please contact me at 301-415-1030. | If you have any questions, please contact me at 301-415-1030. | ||
Sincerely, | Sincerely, | ||
/RA/ | |||
Richard V. Guzman, Project Manager, Section 1 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-387 and 50-388 | Richard V. Guzman, Project Manager, Section 1 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-387 and 50-388 | ||
| Line 40: | Line 39: | ||
==Dear Mr. Shriver:== | ==Dear Mr. Shriver:== | ||
In reviewing your submittal of September 16, 2003, relating to Relief Request No. 3RR-01, the Nuclear Regulatory Commission staff has determined that additional information contained in the enclosure to this letter is needed to complete its review. These questions were discussed with your staff during a teleconference on April 8, 2004. As agreed to by your staff, we request you respond within 30 days of the date of this letter. | In reviewing your submittal of September 16, 2003, relating to Relief Request No. 3RR-01, the Nuclear Regulatory Commission staff has determined that additional information contained in the enclosure to this letter is needed to complete its review. These questions were discussed with your staff during a teleconference on April 8, 2004. As agreed to by your staff, we request you respond within 30 days of the date of this letter. | ||
If you have any questions, please contact me at 301-415-1030. | If you have any questions, please contact me at 301-415-1030. | ||
Sincerely, | Sincerely, | ||
/RA/ | |||
Richard V. Guzman, Project Manager, Section 1 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-387 and 50-388 | Richard V. Guzman, Project Manager, Section 1 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-387 and 50-388 | ||
==Enclosure:== | ==Enclosure:== | ||
RAI cc w/encl: See next page DISTRIBUTION: | RAI cc w/encl: See next page DISTRIBUTION: | ||
Public | Public OGC CBixler, Rgn-1 MRubin RGuzman PDI-1 R/F RLaufer MOBrien SDinsmore ACRS MMelnicoff RDavis DLPM DPR Accession Number: ML041190242 OFFICE PDI-1/PM PDI-2/LA SPSB/SC PDI-1/SC NAME RGuzman MOBrien MRubin RLaufer DATE 4/20/04 4/20/04 4/22/04 4/26/04 OFFICIAL RECORD COPY | ||
REQUEST FOR ADDITIONAL INFORMATION RELATING TO RELIEF REQUEST NO. 3RR-01 FOR THIRD 10-YEAR INSERVICE INSPECTION PROGRAM PLAN ALTERNATE RISK-INFORMED SELECTION AND EXAMINATION CRITERIA FOR PRESSURE RETAINING PIPING WELDS FOR SUSQUEHANNA STEAM ELECTRIC STATION, UNITS 1 AND 2 PPL SUSQUEHANNA, LLC DOCKET NOS. 50-387 AND 50.388 | Enclosure REQUEST FOR ADDITIONAL INFORMATION RELATING TO RELIEF REQUEST NO. 3RR-01 FOR THIRD 10-YEAR INSERVICE INSPECTION PROGRAM PLAN ALTERNATE RISK-INFORMED SELECTION AND EXAMINATION CRITERIA FOR PRESSURE RETAINING PIPING WELDS FOR SUSQUEHANNA STEAM ELECTRIC STATION, UNITS 1 AND 2 PPL SUSQUEHANNA, LLC DOCKET NOS. 50-387 AND 50.388 1. | ||
Regulatory Guide (RG) 1.178, An Approach for Plant-Specific Risk-Informed Decisionmaking for Inservice Inspection of Piping, Revision 1, dated September 2003, replaced the original For Trial Use RG 1.178, dated September 1998. RG 1.178, Revision 1, includes guidance on what should be included in Risk-Informed Inservice Inspection (RI-ISI) submittals. Particularly, in RG 1.178, Section 4.1, the following information is requested: | |||
A description of the staff and industry reviews performed on the [probabilistic risk assessment] PRA. Limitations, weakness, or improvements identified by the reviewers that could change the results of the PRA should be discussed. The resolution of the review comments, or an explanation of the insensitivity of the analysis, used to support the submittal, should be provided. | A description of the staff and industry reviews performed on the [probabilistic risk assessment] PRA. Limitations, weakness, or improvements identified by the reviewers that could change the results of the PRA should be discussed. The resolution of the review comments, or an explanation of the insensitivity of the analysis, used to support the submittal, should be provided. | ||
a) | a) | ||
Please briefly describe all weaknesses and limitations identified by the Nuclear Regulatory Commission (NRC) staff during the review of the individual plant examination (IPE) and how these issues have been resolved or an explanation of the insensitivity of the analysis used to support the submittal to the comment. | |||
Your submittal also described an expert review on May 29, 1997. Please provide any weakness or limitation identified by the expert and how these issues have been resolved or an explanation of the insensitivity of the analysis used to support the submittal to the comment. | Your submittal also described an expert review on May 29, 1997. Please provide any weakness or limitation identified by the expert and how these issues have been resolved or an explanation of the insensitivity of the analysis used to support the submittal to the comment. | ||
b) | b) | ||
Has your PRA been peer-reviewed by one of the industry-based groups using a format similar to Nuclear Energy Institute (NEI) 00-02, Probabilistic Risk Assessment (PRA) Peer Review Process Guidance (Revision A3)? If so, please provide the facts and observations that the peer review team identified as important and necessary to address (Significance Level A and B in NEI 00-02) and describe how these issues have been resolved or provide an explanation of the insensitivity of the analysis used to support the submittal to the comment. | |||
c) | |||
c) | If your PRA has not been peer-reviewed by one of the industry groups, please explain how the reviews that have been performed provide confidence that the quality of the PRA is sufficient to support your RI-ISI analysis. | ||
2. | |||
Your submittal discusses the use of the Markov piping analysis method to estimate the change in risk due to adding and removing inspection locations from the inspection program. The submittal refers to Section 3.7.2 of Electric Power Research Institute (EPRI), Topical Report (TR) 112657. The safety evaluation (SE) approving the EPRI methodology (Adams accession no. ML013470102) approved the use of the Markov model as a basis for the direct estimation of pipe failure frequencies instead of the bounding pipe failure frequencies. The SE did not approve the use of the Markov model to estimate the inspection efficiency factor (IEF) that is used in Equation 3-9 in TR-112657 because there is insufficient information in EPRI TR-112657 to fully define the method. The methodology description for estimating the IEF is located in EPRI TR-110161, Piping System Reliability and Failure Rate Estimation Models for Use in Risk-Informed Inservice Inspection Applications, and EPRI TR-111880, Piping System Failure Rates and Rupture Frequencies for Use in Risk-Informed In-Service Inspection Applications, (both proprietary). The use of the Markov method to estimate the IEF in Equation 3-9 in EPRI TR-112657 has been approved in some relief requests after sufficient information was provided to fully define the method and the staff found the specific method acceptable (i.e, the SE for Dresden (Adams accession no. | |||
ML012050103)). | ML012050103)). | ||
Please clarify how the Markov method was used to estimate the change in risk due to adding and removing inspection locations from the inspection program. If it is possible to identify a previously approved risk-informed inservice inspection relief request that used the same methodology that was used in your submittal, a more limited discussion of the method and the identification of the relevant relief request should be sufficient. | Please clarify how the Markov method was used to estimate the change in risk due to adding and removing inspection locations from the inspection program. If it is possible to identify a previously approved risk-informed inservice inspection relief request that used the same methodology that was used in your submittal, a more limited discussion of the method and the identification of the relevant relief request should be sufficient. | ||
: 3. In Tables 7 and 8 of your submittal dated September 16, 2003, there are columns provided for ASME Code, Section XI, core damage frequency (CDF), RI-ISI CDF, and delta CDF (that can be obtained as the difference of the first two columns). Although there are no columns for Section XI large early release frequency (LERF) and RI-ISI LERF, there is a column for delta LERF. Please confirm that delta LERF reported in the tables was calculated as it was for CDF and that the two LERF values were intentionally not provided in the tables. | : 3. | ||
In Tables 7 and 8 of your submittal dated September 16, 2003, there are columns provided for ASME Code, Section XI, core damage frequency (CDF), RI-ISI CDF, and delta CDF (that can be obtained as the difference of the first two columns). Although there are no columns for Section XI large early release frequency (LERF) and RI-ISI LERF, there is a column for delta LERF. Please confirm that delta LERF reported in the tables was calculated as it was for CDF and that the two LERF values were intentionally not provided in the tables. | |||
Susquehanna Steam Electric Station, Unit Nos. 1 and 2 cc: | Susquehanna Steam Electric Station, Unit Nos. 1 and 2 cc: | ||
Richard L. Anderson | Richard L. Anderson Vice President - Nuclear Operations PPL Susquehanna, LLC 769 Salem Blvd., NUCSB3 Berwick, PA 18603-0467 Aloysius J. Wrape, III General Manager - Nuclear Assurance PPL Susquehanna, LLC Two North Ninth Street, GENPL4 Allentown, PA 18101-1179 Terry L. Harpster General Manager - Plant Support PPL Susquehanna, LLC 769 Salem Blvd., NUCSA4 Berwick, PA 18603-0467 Robert A. Saccone General Manager - Nuclear Engineering PPL Susquehanna, LLC 769 Salem Blvd., NUCSB3 Berwick, PA 18603-0467 Rocco R. Sgarro Manager - Nuclear Regulatory Affairs PPL Susquehanna, LLC Two North Ninth Street, GENPL4 Allentown, PA 18101-1179 Walter E. Morrissey Supervising Engineer Nuclear Regulatory Affairs PPL Susquehanna, LLC 769 Salem Blvd., NUCSA4 Berwick, PA 18603-0467 Michael H. Crowthers Supervising Engineer Nuclear Regulatory Affairs PPL Susquehanna, LLC Two North Ninth Street, GENPL4 Allentown, PA 18101-1179 Dale F. Roth Manager - Quality Assurance PPL Susquehanna, LLC 769 Salem Blvd., NUCSB2 Berwick, PA 18603-0467 Herbert D. Woodeshick Special Office of the President PPL Susquehanna, LLC 634 Salem Blvd., SSO Berwick, PA 18603-0467 Bryan A. Snapp, Esq Assoc. General Counsel PPL Services Corporation Two North Ninth Street, GENTW3 Allentown, PA 18101-1179 Supervisor - Document Control Services PPL Susquehanna, LLC Two North Ninth Street, GENPL4 Allentown, PA 18101-1179 Richard W. Osborne Allegheny Electric Cooperative, Inc. | ||
212 Locust Street P.O. Box 1266 Harrisburg, PA 17108-1266 Director - Bureau of Radiation Protection Pennsylvania Department of Environmental Protection P.O. Box 8469 Harrisburg, PA 17105-8469 Senior Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 35, NUCSA4 Berwick, PA 18603-0035 Regional Administrator, Region 1 U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 | |||
Susquehanna Steam Electric Station, Unit Nos. 1 and 2 cc: | Susquehanna Steam Electric Station, Unit Nos. 1 and 2 cc: | ||
Board of Supervisors Salem Township P.O. Box 405 Berwick, PA 18603-0035 Dr. Judith Johnsrud National Energy Committee Sierra Club 443 Orlando Avenue State College, PA 16803}} | Board of Supervisors Salem Township P.O. Box 405 Berwick, PA 18603-0035 Dr. Judith Johnsrud National Energy Committee Sierra Club 443 Orlando Avenue State College, PA 16803}} | ||
Latest revision as of 03:20, 16 January 2025
| ML041190242 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 04/28/2004 |
| From: | Richard Guzman NRC/NRR/DLPM/LPD1 |
| To: | Shriver B Susquehanna |
| Guzman R, NRR/DLPM 415-1030 | |
| References | |
| TAC MC1181, TAC MC1182 | |
| Download: ML041190242 (6) | |
Text
April 28, 2004 Mr. Bryce L. Shriver Senior Vice President and Chief Nuclear Officer PPL Susquehanna, LLC 769 Salem Boulevard, NUCSB3 Berwick, PA 18603-0467
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION (RAI) - SUSQUEHANNA STEAM ELECTRIC STATION, UNITS 1 AND 2 (SSES 1 AND 2) - THIRD 10-YEAR INSERVICE INSPECTION INTERVAL PROGRAM PLAN RE: ALTERNATE RISK-INFORMED SELECTION AND EXAMINATION CRITERIA FOR PRESSURE RETAINING PIPING WELDS (TAC NOS. MC1181 AND MC1182)
Dear Mr. Shriver:
In reviewing your submittal of September 16, 2003, relating to Relief Request No. 3RR-01, the Nuclear Regulatory Commission staff has determined that additional information contained in the enclosure to this letter is needed to complete its review. These questions were discussed with your staff during a teleconference on April 8, 2004. As agreed to by your staff, we request you respond within 30 days of the date of this letter.
If you have any questions, please contact me at 301-415-1030.
Sincerely,
/RA/
Richard V. Guzman, Project Manager, Section 1 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-387 and 50-388
Enclosure:
RAI cc w/encl: See next page
April 28, 2004 Mr. Bryce L. Shriver Senior Vice President and Chief Nuclear Officer PPL Susquehanna, LLC 769 Salem Boulevard, NUCSB3 Berwick, PA 18603-0467
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION (RAI) - SUSQUEHANNA STEAM ELECTRIC STATION, UNITS 1 AND 2 (SSES 1 AND 2) - THIRD 10-YEAR INSERVICE INSPECTION INTERVAL PROGRAM PLAN RE: ALTERNATE RISK-INFORMED SELECTION AND EXAMINATION CRITERIA FOR PRESSURE RETAINING PIPING WELDS (TAC NOS. MC1181 AND MC1182)
Dear Mr. Shriver:
In reviewing your submittal of September 16, 2003, relating to Relief Request No. 3RR-01, the Nuclear Regulatory Commission staff has determined that additional information contained in the enclosure to this letter is needed to complete its review. These questions were discussed with your staff during a teleconference on April 8, 2004. As agreed to by your staff, we request you respond within 30 days of the date of this letter.
If you have any questions, please contact me at 301-415-1030.
Sincerely,
/RA/
Richard V. Guzman, Project Manager, Section 1 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-387 and 50-388
Enclosure:
RAI cc w/encl: See next page DISTRIBUTION:
Public OGC CBixler, Rgn-1 MRubin RGuzman PDI-1 R/F RLaufer MOBrien SDinsmore ACRS MMelnicoff RDavis DLPM DPR Accession Number: ML041190242 OFFICE PDI-1/PM PDI-2/LA SPSB/SC PDI-1/SC NAME RGuzman MOBrien MRubin RLaufer DATE 4/20/04 4/20/04 4/22/04 4/26/04 OFFICIAL RECORD COPY
Enclosure REQUEST FOR ADDITIONAL INFORMATION RELATING TO RELIEF REQUEST NO. 3RR-01 FOR THIRD 10-YEAR INSERVICE INSPECTION PROGRAM PLAN ALTERNATE RISK-INFORMED SELECTION AND EXAMINATION CRITERIA FOR PRESSURE RETAINING PIPING WELDS FOR SUSQUEHANNA STEAM ELECTRIC STATION, UNITS 1 AND 2 PPL SUSQUEHANNA, LLC DOCKET NOS. 50-387 AND 50.388 1.
Regulatory Guide (RG) 1.178, An Approach for Plant-Specific Risk-Informed Decisionmaking for Inservice Inspection of Piping, Revision 1, dated September 2003, replaced the original For Trial Use RG 1.178, dated September 1998. RG 1.178, Revision 1, includes guidance on what should be included in Risk-Informed Inservice Inspection (RI-ISI) submittals. Particularly, in RG 1.178, Section 4.1, the following information is requested:
A description of the staff and industry reviews performed on the [probabilistic risk assessment] PRA. Limitations, weakness, or improvements identified by the reviewers that could change the results of the PRA should be discussed. The resolution of the review comments, or an explanation of the insensitivity of the analysis, used to support the submittal, should be provided.
a)
Please briefly describe all weaknesses and limitations identified by the Nuclear Regulatory Commission (NRC) staff during the review of the individual plant examination (IPE) and how these issues have been resolved or an explanation of the insensitivity of the analysis used to support the submittal to the comment.
Your submittal also described an expert review on May 29, 1997. Please provide any weakness or limitation identified by the expert and how these issues have been resolved or an explanation of the insensitivity of the analysis used to support the submittal to the comment.
b)
Has your PRA been peer-reviewed by one of the industry-based groups using a format similar to Nuclear Energy Institute (NEI) 00-02, Probabilistic Risk Assessment (PRA) Peer Review Process Guidance (Revision A3)? If so, please provide the facts and observations that the peer review team identified as important and necessary to address (Significance Level A and B in NEI 00-02) and describe how these issues have been resolved or provide an explanation of the insensitivity of the analysis used to support the submittal to the comment.
c)
If your PRA has not been peer-reviewed by one of the industry groups, please explain how the reviews that have been performed provide confidence that the quality of the PRA is sufficient to support your RI-ISI analysis.
2.
Your submittal discusses the use of the Markov piping analysis method to estimate the change in risk due to adding and removing inspection locations from the inspection program. The submittal refers to Section 3.7.2 of Electric Power Research Institute (EPRI), Topical Report (TR) 112657. The safety evaluation (SE) approving the EPRI methodology (Adams accession no. ML013470102) approved the use of the Markov model as a basis for the direct estimation of pipe failure frequencies instead of the bounding pipe failure frequencies. The SE did not approve the use of the Markov model to estimate the inspection efficiency factor (IEF) that is used in Equation 3-9 in TR-112657 because there is insufficient information in EPRI TR-112657 to fully define the method. The methodology description for estimating the IEF is located in EPRI TR-110161, Piping System Reliability and Failure Rate Estimation Models for Use in Risk-Informed Inservice Inspection Applications, and EPRI TR-111880, Piping System Failure Rates and Rupture Frequencies for Use in Risk-Informed In-Service Inspection Applications, (both proprietary). The use of the Markov method to estimate the IEF in Equation 3-9 in EPRI TR-112657 has been approved in some relief requests after sufficient information was provided to fully define the method and the staff found the specific method acceptable (i.e, the SE for Dresden (Adams accession no.
ML012050103)).
Please clarify how the Markov method was used to estimate the change in risk due to adding and removing inspection locations from the inspection program. If it is possible to identify a previously approved risk-informed inservice inspection relief request that used the same methodology that was used in your submittal, a more limited discussion of the method and the identification of the relevant relief request should be sufficient.
- 3.
In Tables 7 and 8 of your submittal dated September 16, 2003, there are columns provided for ASME Code,Section XI, core damage frequency (CDF), RI-ISI CDF, and delta CDF (that can be obtained as the difference of the first two columns). Although there are no columns for Section XI large early release frequency (LERF) and RI-ISI LERF, there is a column for delta LERF. Please confirm that delta LERF reported in the tables was calculated as it was for CDF and that the two LERF values were intentionally not provided in the tables.
Susquehanna Steam Electric Station, Unit Nos. 1 and 2 cc:
Richard L. Anderson Vice President - Nuclear Operations PPL Susquehanna, LLC 769 Salem Blvd., NUCSB3 Berwick, PA 18603-0467 Aloysius J. Wrape, III General Manager - Nuclear Assurance PPL Susquehanna, LLC Two North Ninth Street, GENPL4 Allentown, PA 18101-1179 Terry L. Harpster General Manager - Plant Support PPL Susquehanna, LLC 769 Salem Blvd., NUCSA4 Berwick, PA 18603-0467 Robert A. Saccone General Manager - Nuclear Engineering PPL Susquehanna, LLC 769 Salem Blvd., NUCSB3 Berwick, PA 18603-0467 Rocco R. Sgarro Manager - Nuclear Regulatory Affairs PPL Susquehanna, LLC Two North Ninth Street, GENPL4 Allentown, PA 18101-1179 Walter E. Morrissey Supervising Engineer Nuclear Regulatory Affairs PPL Susquehanna, LLC 769 Salem Blvd., NUCSA4 Berwick, PA 18603-0467 Michael H. Crowthers Supervising Engineer Nuclear Regulatory Affairs PPL Susquehanna, LLC Two North Ninth Street, GENPL4 Allentown, PA 18101-1179 Dale F. Roth Manager - Quality Assurance PPL Susquehanna, LLC 769 Salem Blvd., NUCSB2 Berwick, PA 18603-0467 Herbert D. Woodeshick Special Office of the President PPL Susquehanna, LLC 634 Salem Blvd., SSO Berwick, PA 18603-0467 Bryan A. Snapp, Esq Assoc. General Counsel PPL Services Corporation Two North Ninth Street, GENTW3 Allentown, PA 18101-1179 Supervisor - Document Control Services PPL Susquehanna, LLC Two North Ninth Street, GENPL4 Allentown, PA 18101-1179 Richard W. Osborne Allegheny Electric Cooperative, Inc.
212 Locust Street P.O. Box 1266 Harrisburg, PA 17108-1266 Director - Bureau of Radiation Protection Pennsylvania Department of Environmental Protection P.O. Box 8469 Harrisburg, PA 17105-8469 Senior Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 35, NUCSA4 Berwick, PA 18603-0035 Regional Administrator, Region 1 U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406
Susquehanna Steam Electric Station, Unit Nos. 1 and 2 cc:
Board of Supervisors Salem Township P.O. Box 405 Berwick, PA 18603-0035 Dr. Judith Johnsrud National Energy Committee Sierra Club 443 Orlando Avenue State College, PA 16803