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Category:Letter
MONTHYEARIR 05000387/20230042024-02-0707 February 2024 Integrated Inspection Report 05000387/2023004 and 05000388/2023004 PLA-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) IR 05000387/20230102023-12-11011 December 2023 Fire Protection Team Inspection Report 05000387/2023010 and 05000388/2023010 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 ML23345A0682023-11-28028 November 2023 Technical Specification Bases, Manual 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) IR 05000387/20230032023-11-0303 November 2023 Integrated Inspection Report 05000387/2023003 and 05000388/2023003 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 ML23291A1132023-10-12012 October 2023 Submittal of Revision 71 to Updated Final Safety Analysis Report and Revision 25 to Fire Protection Review Report ML23279A0612023-10-0505 October 2023 Paragon Energy Solutions LLC, Part 21 Final Report Re Potential Defect with Eaton Jd and Hjd Series Molded Case Circuit Breakers (Mccbs) ML23277A0412023-10-0505 October 2023 Notification of Commercial Grade Dedication Inspection (05000387/2024011 and 05000388/2024011) and Request for Information IR 05000387/20233012023-09-20020 September 2023 Initial Operator Licensing Examination Report 05000387/2023301 and 05000388/2023301 ML23254A0242023-09-0606 September 2023 Paragon Energy Solutions LLC, Potential Defect with Eaton Jd and Hjd Series Molded Case Circuit Breakers (Mccbs) IR 05000387/20230052023-08-31031 August 2023 Updated Inspection Plan for Susquehanna Steam Electric Station, Units 1 and 2 (Report 05000387/2023005 and 05000388/2023005) ML23228A1952023-08-21021 August 2023 Summary of August 10, 2023, Public Observation Meeting Re. Proposed Alternative 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 IR 05000387/20230022023-08-0101 August 2023 Integrated Inspection Report 05000387/2023002 and 05000388/2023002 ML23195A1852023-07-27027 July 2023 Correction to Technical Specifications Page 3.3-73 in Amendment No. 265 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) ML23201A0152023-07-20020 July 2023 Operator Licensing Examination Approval ML23200A1012023-07-19019 July 2023 Notification of Conduct of a Fire Protection Team Inspection ML23193A0062023-07-12012 July 2023 Requalification Program Inspection 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 ML23163A1012023-06-12012 June 2023 10 CFR 50.46 Annual Report (Pla 8065) 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 IR 05000387/20234012023-06-0707 June 2023 Security Baseline Inspection Report 05000387/2023401 and 05000388/2023401 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) ML23132A3212023-05-17017 May 2023 Associated Independent Spent Fuel Storage Installation - Issuance of Amendment Nos. 285 and 269 Related to Order Approving Transfer of Licenses 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) IR 05000387/20230012023-05-12012 May 2023 Integrated Inspection Report 05000387/2023001 and 05000388/2023001 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 ML23090A2302023-03-31031 March 2023 NRC Decommissioning Funding Status Report PLA-8049 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) ML23095A0572023-03-29029 March 2023 NRC Decommissioning Funding Status Report December 31, 2022 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 ML23065A1962023-03-0202 March 2023 EN 56387 Paragon - Part 21 Report Re Defect Identified in Automatic Transfer Switch Pn: NLI-ATS480A400X1 IR 05000387/20220062023-03-0101 March 2023 Annual Assessment Letter for Susquehanna Steam Electric Station, Units 1 and 2 (Reports 05000387/2022006 and 05000388/2022006) 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 IR 05000387/20220042023-02-0808 February 2023 Integrated Inspection Report 05000387/2022004 and 05000388/2022004 ML23010A0882023-01-15015 January 2023 Summary of Regulatory Audit in Support of License Amendment Request to Revise Control Rod Technical Specifications 2024-02-07
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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 is small, TM Document Control Desk PLA-7123 and evaluate any small margins that have potentially significant consequences through the corrective action process.
The results of this effort were to be maintained on site for future NRC audits. Following the NRC staff's initial review of the walkdown reports, regulatory site 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 determine a value 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 (570) 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