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| | issue date = 01/29/2014 | | | issue date = 01/29/2014 |
| | title = Update to Response to NRC 10 CFR 50.54(F) Request for Information Regarding Near-Term Task Force Recommendation 2.3, Flooding-Review of Available Physical Margin (APM) Assessments PLA-7123 | | | title = Update to Response to NRC 10 CFR 50.54(F) Request for Information Regarding Near-Term Task Force Recommendation 2.3, Flooding-Review of Available Physical Margin (APM) Assessments PLA-7123 |
| | author name = Rausch T S | | | author name = Rausch T |
| | author affiliation = PPL Susquehanna, LLC | | | author affiliation = PPL Susquehanna, LLC |
| | addressee name = | | | addressee name = |
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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 - 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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] |
Text
Timothy S. Rausch Senior Vice President
& Chief Nuclear Officer PPL Susquehanna, LLC 769 Salem Boulevard Berwick, PA 18603 Tel. 570.542.3345 Fax 570.542.1504 tsrausch@
pplweb.com JAN 2 9 2014 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 SUSQUEHANNA STEAM ELECTRIC STATION UPDATE TO RESPONSE TO NRC 10 CFR 50.54(F) REQUEST FOR INFORMATION REGARDING NEAR-TERM TASK FORCE RECOMMENDATION 2.3, FLOODING -REVIEW OF AVAILABLE PHYSICAL MARGIN (APM) ASSESSMENTS PLA-7123
References:
Docket Nos. 50-387 and 50-388 ( 1) NRC Letter, "Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(]) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-Ichi Accident," dated March 12, 2012, Accession No. ML12073A348.
(2) NRC Letter to Nuclear Energy Institute, Endorsement of Nuclear Energy Institute (NEI) 12-07, "Guidelines for Peiforming Verification Walkdowns of Plant Flood Protection Features," dated May 31, 2012, Accession No. ML12144A142.
(3) PPL Letter (PLA-6938), "Response to Request for Information Pursuant to 10 CFR 50.54(]) Regarding Results of the SSES Flooding Walkdown," dated November 21, 2012. ( 4) NRC Letter , "Request for Additional Information Associated with Near-Term Task Force Recommendation 2.3, Flooding Walkdowns," dated December 23, 2013, Accession No. ML13325A891.
On March 12, 2012, the NRC staff issued Reference 1 requesting information pursuant to Title 10 of the Code of Federal Regulations 50.54(f).
Enclosure 4 of that letter contains specific Requested Information associated with Near-Term Task Force Recommendation 2.3 for Flooding.
Per Reference 2, the NRC endorsed Nuclear Energy Institute (NEI) 12-07, "Guidelines for Performing Verification Walkdowns of Plant Flood Protection Features," dated May 31, 2012. By Reference 3, PPL Susquehanna, LLC (PPL) submitted the final Flooding Walkdown Report in response to the request for information.
One of the requirements of NEI 12-07 is to identify the available physical margin (APM) associated with each flood protection feature, determine if the margin provided i s small, TM Document Control Desk PLA-7123 and evaluate any small margins that have potentially signif i cant consequences through the corrective act i on process. The results of this effort were to be maintained on site for f uture NRC audits. Following the NRC staff's initial review of the walkdown reports , regulatory s i te audits were conducted at a sampling of plants. Based on the walkdown report reviews and site audits, the staff identified additional information necessary to allow them to complete its assessments.
Accordingly, by Reference 4 the NRC staff has issued a request for addition information (RAI). The RAI questions and the PPL's responses are provided below. RAI Number 1: Confirmation that the process for evaluating APM was reviewed.
Response:
PPL has completed a review of the process used at Susquehanna Steam Electric Station (SSES) to evaluate APMs. RAI Number 2: Confirmation that the APM process is now or was always consistent with the guidance in NEI 12-07 and discussed in this RAI. Response:
The original walkdown effort followed the guidance provided in NEI 12-07. Additional actions will be taken to make the process consistent with the information provided in this RAI. RAI Number 3: If changes are necessary, a general description of any process changes to establish this consistency.
Response:
As stated above, the original walkdown effort followed the guidance provided in NEI 12-07. A specific APM had been assigned to the seals associated with flood protection features.
However, a value for small APM was not specifically determined.
This action will be addressed in accordance with the guidance provided in this RAI and entered into the corrective action process, as appropriate, for further evaluation.
RAI Number 4: As a result of the audits and subsequent interactions with industry during public meetings, NRC staff recognized that evaluation of APM for seals (e.g., flood doors, penetrations, flood gates, etc.) was challenging for some licensees.
Generally, licensees were expected to use either Approach A or Approach B (described below) to determine the APM for seals: Document Control Desk PLA-7123 a) If seal pressure ratings were known, the seal ratings were used to determine APM (similar to example 2 in Section 3.13 of NEI 12-07). A numerical value for APM was documented.
No further action was performed if the APM value was greater than the pre-established small-margin threshold value. If the APM value was small, an assessment of "significant consequences" was performed and the guidance in NEI 12-07 Section 5.8 was followed. b) If the seal pressure rating was not known, the APM for seals in a flood barrier is assumed to be greater than the pre-established small-margin threshold value if the following conditions were met: ( 1) the APM for the barrier in which the seal is located is greater than the small-margin threshold value and there is evidence that the seals were designed/procured, installed, and controlled as flooding seals in accordance with the flooding licensing basis. Note that in order to determine that the seal has been controlled as a flooding seal, it was only necessary to determine that the seal configuration has been governed by the plant's design control process since installation.
In this case, the APM for the seal could have been documented as "not small." As part of the RAI response, state if either Approach A or Approach B was used as part of the initial walkdowns or as part of actions taken in response to this RAI. No additional actions are necessary if either Approach A or B was used. If neither Approach A or B was used to determine the APM values for seals (either as part of the walkdowns or as part of actions taken in response to this RAI), then perform the following two actions:
- Enter the condition into the CAP (note: it is acceptable to utilize a single CAP entry to capture this issue for multiple seals). CAP disposition of "undetermined" APM values for seals should consider the guidance provided in NEI 12-07, Section 5.8. The CAP disposition should confirm all seals can perform their intended safety function against floods up to the current licensing basis flood height. Disposition may occur as part of the Integrated Assessment.
If an Integrated Assessment is not performed, determine whether there are significant consequences associated with exceeding the capacity of the seals and take interim action(s), if necessary, via the CAP processes.
These actions do not need to be complete prior to the RAI response. Document Control Desk PLA-7123
- Report the APM as "undetermined" and provide the CAP reference in the RAJ response.
Response:
Approach A was used to determine APM at SSES. A numerical value for APM was documented for each penetration seal in the station flood walkdown records. Penetrations with inadequate APM were entered in the corrective action process and an assessment of "significant consequences" performed.
As part of the actions taken to address this RAI, a value for small APM will be determined and the impact assessed (AR-2014-01305).
Implementation of interim actions will be pursued, if necessary.
This letter contains one new Regulatory Commitment and no revision to existing Regulatory Commitments.
Regulatory Commitment Completion Date CAP Tracking Number PPL will det e rmine a va l ue for small 03/14/2014 AR-2014-01305 APM and assess the impact. If you have any questions regarding the content of this letter, please contact Mr. John L. Tripoli, Manager, Nuclear Regulatory Affairs, at (5 7 0) 542-3100. I declare under penalty of perjury that the foregoing is true and correct. Executed on: D \ ( 7... '7 I 2..0 I L( T. S. Rausch Copy: J. E. Greives, NRC Sr. Resident Inspector J. A. Whited, NRC Project Manager L. J. Winker, PA DEP/BRP Region I Administrator, NRC