Susquehanna Steam Electric Station - Proposed Amendment No. … · 2012. 11. 18. · NFP-14 AND...

George T. Jones Vice President

Nuclear Engineering & Support

PPL Susquehanna, LLC Two North Ninth Street

Allentown, PA 18101-1179 Tel. 610.774.7602 Fax 610.774.7797

[email protected]

.~TM

JUL 3 0 2001

U.S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Station OP 1- 17 Washington, DC 20555

SUSQUEHANNA STEAM ELECTRIC STATION PROPOSED AMENDMENT NO. 241 TO LICENSE NFP-14 AND PROPOSED AMENDMENT NO. 206 TO LICENSE NFP-22: REQUEST FOR A ONE TIME DEFERRAL OF THE TYPE A CONTAINMENT INTEGRATED LEAK RATE TEST (ILRT) PLA-5342

Docket No. 50-387 and 50-388

The purpose of this letter is to propose revisions to the Susquehanna Steam Electric Station Units 1 and 2 Technical Specifications to allow a one-time deferral of the Type A Containment Integrated Leakage Rate Test (ILRT) from the Spring 2002 Refuel and Inspection Outage (RIO) to no later than the Spring 2007 RIO for Unit 1 and from the Spring 2003 RIO to no later than the Spring 2008 RIO for Unit 2. The justification for this request is based on past successful Type A, B, and C tests, and American Society of Mechanical Engineers (ASME) Section XI inspections at Susquehanna Steam Electric Station Unit 1 and Unit 2. Further justification is based on research documented in NUREG- 1493 that very few potential containment leakage paths fail to be identified by Type B and C tests.

One of the risk measures used in the generic study to estimate the risk impact due to extending the ILRT interval is population dose (person-rem/year). PPL Susquehanna LLC is currently developing site specific risk-informed information to document that this request compares favorably with the generic analysis. This information is similar to that submitted by Indian Point 3 in their submittal of January 18, 2001. This information will be submitted no later than September 30, 2001.

1*WL1'7

-2 - Document Control Desk PLA-5342

Attachment I to this letter is the "Safety Assessment" supporting this change. Attachment 2 to this letter contains the "No Significant Hazards Considerations Evaluation" performed in accordance with the criteria of 10CFR 50.92 and the categorical exclusion for an Environmental Assessment as specified in 1OCFR 51.22. Attachment 3 to this letter contains the current pages of the Susquehanna SES Units 1

and 2 Technical Specifications marked to show the proposed changes. Attachment 4 to

this letter is the "camera ready" version of the revised Technical Specification pages.

The Susquehanna SES Plant Operations Review Committee and the Susquehanna Review Committee have reviewed the proposed changes.

This proposed change is similar to one granted to Indian Point 3 to allow a one-time deferral of the ILRT for five (5) years. (Ref: NRC letter to Entergy Nuclear Operations, Inc. for Indian Point Nuclear Generating Unit No. 3 - Issuance of Amendment Re: Frequency of Performance - Based Leakage Rate Testing (TAC No. MB0178), April 17, 2001.)

The ILRT for Unit 1 is currently scheduled during April 2002 in the 12 th RIO. The ILRT

for Unit 2 is currently scheduled during April 2003 in the 11th RIO. Therefore, we request NRC to complete the review of this change request by November 1, 2001 to

allow for the finalization of the outage schedule and vendor support in advance of the Unit 1 Spring 2002 RIO start date.

If you have any questions, please contact Mr. C. T. Coddington at (610) 774-4019.

Sincerely,

G. T. Y•es

Attachment

copy: NRC Region I Mr. S. Hansell, NRC Sr. Resident Inspector Mr. R. Schaaf, NRC Project Manager Mr. D. J. Allard, PA Dept. of Environmental Protection

BEFORE THE

BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION

In the Matter of

PPL Susquehanna, LLC: Docket No. 50-387

PROPOSED AMENDMENT NO. 241 TO LICENSE NPF-14: ONE TIME DEFERRAL OF THE CONTAINMENT

INTEGRATED LEAK RATE TEST (ILRT) UNIT NO. 1

Licensee, PPL Susquehanna, LLC, hereby files Proposed Amendment No. 241 in support of a revision to its Facility Operating License No. NPF-14 dated July 17, 1982.

This amendment involves a revision to the Susquehanna SES Unit 1 Technical Specifications.

PPL Susquehanna, LLC By:

44 P.000"Engineering/Support

Sworn to and subs *ib d before me this .0" day of ,2001.

otary Puub~liccYv

Notarlal Seal Nam J. Lannen, Nobty Public

Alentown Lehigh My Commission Fxptres June U, 2004

BEFORE THE

BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION

In the Matter of

PPL Susquehanna, LLC Docket No. 50-388

PROPOSED AMENDMENT NO. 206 TO LICENSE NPF-22: ONE TIME DEFERRAL OF THE CONTAINMENT

INTEGRATED LEAK RATE TEST (ILRT) UNIT NO. 2

Licensee, PPL Susquehanna, LLC, hereby files Proposed Amendment No. 206 in support of a

revision to its Facility Operating License No. NPF-22 dated March 23, 1984.

This amendment involves a revision to the Susquehanna SES Unit 2 Technical Specifications.

PPL Susquehanna, LLC By:

G. T.J s Swor toandsub *bd bfor meVP-N ear Engineering/Support

Sworn to, and subspp'ib~ed before me this 30 t-day of 2001.

otary Public

Notarial Seal Nancy J. Lannon, Notaa Publik

My Commission Expires JuneU, 2004

Attachment 1 to PLA-5342

Safety Assessment

ATTACHMENT 1 TO PLA-5342 Page 1 of 5

SAFETY ASSESSMENT

Section I: Summary of Proposed Change

The purpose of this submittal is to request a one-time deferral of the Type A Containment Integrated Leakage Rate Test (ILRT) from Spring 2002 to no later than Spring 2007 for Unit 1 and from Spring 2003 to no later than Spring 2008 for Unit 2. The justification for this request is based on past successful Type A, B, and C tests, and American Society of Mechanical Engineers (ASME) Section XI inspections at Susquehanna Steam Electric Station Unit 1 (SSES1) and Unit 2 (SSES2). Further justification is based on research documented in NUREG- 1493 that very few potential containment leakage paths fail to be identified by Type B and C tests. In fact, only 5 out of 180 ILRTs had failures that could not be detected by Type B and C tests. NUREG-1493 documents no failures of the containment liner. NUREG-1493 concluded that increasing the Type A (ILRT) testing interval to once per twenty years is possible with minimal impact on public risk. This request is similar to a Technical Specification Amendment granted to Indian Point 3 on April 17, 2001.

PPL proposes to revise the SSES1 Technical Specifications (TS) 5.5.12, Containment Leakage Rate Testing Program," by adding a sentence to the end of the first paragraph:

"Performance of the May 2002 Integrated Leakage Rate (Type A) test has been deferred to no later than May 2007."

PPL proposes to revise the SSES2 Technical Specifications (TS) 5.5.12, Containment Leakage Rate Testing Program," by adding a sentence to the end of the first paragraph:


The ILRT at SSES1 is currently scheduled during April 2002 in the 12 th Refuel and Inspection Outage (RIO). The ILRT at SSES2 is currently scheduled during April 2003 in the 1 1 th Refuel and Inspection Outage (RIO). With approval of this request, PPL Susquehanna LLC will move the ILRT to one of two subsequent refueling outages where it can be performed off critical path due to major turbine work. The savings by moving the ILRT off critical path would amount to $2.4 million per unit. The critical path will be reduced by about 72 hours.


The requested approval date of November 1, 2001 allows PPL to finalize the SSES 1 outage schedule and vendor support in advance of the Spring 2002 RIO start date.

Section II: Description and Basis (both Licensing and Design) of the Current Requirements

Integrated Leakage Rate Tests (ILRTs) have been required of operating nuclear power plants to ensure the public health and safety in the case of an accident that releases radioactivity to the primary containment. Conservative design and construction combined with stringent configuration control have led to very few primary containment concerns identified during Type A testing. The NRC has extended the allowable ILRT test period from three times in ten years to once in ten years using a performance based evaluation of past successful tests. NUREG-1493 that supported the change also states that test periods of up to twenty years do not significantly increase public risk.

FSAR Section 3.8.1 describes the primary containment. The SSES primary containment structure for both units is a General Electric Mark II design. Each containment is a free standing, heavily reinforced structure constructed of axially, radially, and diagonally reinforced concrete. The exterior walls have a thickness of 6 feet. The containment base foundation slab is a 7 ft. 9 in. thick reinforced concrete mat. It is completely enclosed in the Reactor building. The exterior surface of the containment structure is concrete. The interior of the drywell, the drywell floor, and the suppression chamber are lined with a 1/" steel liner that serves as a leaktight membrane to prevent leakage out of the structure. The liner sections are completely welded together and anchored into the concrete. The liner plate on the walls is protected by an inorganic zinc coating.

FSAR Section 6.2.6 describes primary reactor containment leakage rate testing. The Type A test provides a pressure test for the liner, drywell head, all exposed penetrations and hatches. The Type A test is the only pressure test for the liner, drywell head, closure caps on spare penetrations, lines that are not Type C tested, and hatches. Most penetrations are Type C tested. The seals on the drywell head and all hatches are Type B tested. The penetrations that are not Type C tested are instrument lines, and thus are passive in nature.

The SSES primary containment is inspected in accordance with the requirements of ASME Section XI Subsection IWE and IWL. These inspections include the interior liner and the exterior concrete surfaces. As of April 2001, all inspections of both Unit 1 and Unit 2 primary containment for the first inspection period are complete and no degradation was identified.


Section III: Evaluation of Proposed Change and Basis

The satisfactory results from previous ILRTs at SSES, as well as continued satisfactory

results of local leakage rate tests, containment inspections, and operating data support

deferral of the ILRT. The SSES primary containment will continue to be inspected under

the requirements of ASME Section XI Subsection IWE and IWL and SSES Technical

Specifications. The existing Type B and C containment penetration testing program will

continue to be performed as required.

PPL has performed one preoperational Type A test and three operational Type A tests on

SSES1. The as-left acceptance criteria is 0.75% of the maximum allowable primary

containment leak rate (La)/day. The as-found acceptance criteria is 1.0% La/day. The

results are as follows:

Unit 1

As-Found As-Left Test Test Result Type A Result (Total (Total Time Leakage not Time Upper Upper As-Left Type attributed to Confidence Confidence B & C Min Type B & C

Test Date Limit) Limit) Path Leakage Penetrations

May 23, 1982 0.516 %/day Pre-op June 1, 1985 0.425 %/day 0.755 %/day Not calculated Not calculated May 29, 1989 0.665 %/day 0.745 %/day 0.035 %/day 0.630 %/day May 4, 1992 0.606 %/day 0.715 %/day 0.091 %/day 0.515 %/day

PPL has performed one preoperational Type A test and three operational Type A tests on

SSES2. The as-left acceptance criteria is 0.75% La/day. The as-found acceptance criteria

is 1.0% La/day. The results are as follows:

Unit 2

As-Found As-Left Test Test Result Type A Result (Total (Total Time As-Left Type Leakage not Time Upper Upper B & C Min attributed to Confidence Confidence Path Type B & C

Test Date Limit) Limit) Leakage Penetrations

November 2, 1983 0.432 %/day Pre-op June 9, 1986 0.629 %/day 2.6 %/day ** Not calculated Not calculated November 3, 1989 0.471 %/day 0.515 %/day 0.044 %/day 0.427 %/day

October 31, 1992 0.337 %/day 0.481 %/day 0.078 %/day 0.259 %/day


** The As-found test in 1986 failed due to failure of solenoid valves for two penetrations in the Containment Atmosphere Control System. These failures can be identified by Type C testing.

The Type A test results for the last 2 tests on each unit indicate that the parts of the containment that are tested only during the Type A test are not aging. This was determined by subtracting the known Type B & Type C minimum path leakage rates measured just prior to the Type A test. For both units, the remaining Type A leakage from the 1992 test is lower than the 1989 test.

The most recent visual inspections performed in 2000 on SSES1 and in 1999 on SSES2 included a General Visual of all accessible areas of the internal liner, external concrete surface, and penetrations. These Level 1 visual inspections identified no significant deterioration that required Level 2 Non Destructive Examination or Level 3 sampling and testing investigation.

The Type A test is the only pressure test to which the liner, drywell head, closure caps on spare penetrations, and hatches are subjected. These components are visually inspected under various programs. These components are massive and are not subjected to the weather. These components are passive in nature and they are not operated between outages. In addition, the hatch seals are Type B tested after each containment hatch is installed. Thus, these components are not the weak link to maintain containment integrity. The Type C and Type B testing on active penetrations and seals provide the assurance that containment integrity is achieved.

The Mark II primary containment during power operations provides feedback to the control room that containment integrity is maintained as follows. During startup procedures, the containment is inerted. As RPV heatup continues, containment pressure increases due to the temperature rise in a closed volume. This necessitates opening vent valves to reduce drywell pressure. During power operation, the drywell is normally maintained at a slight positive pressure. If containment does not hold this positive pressure, containment integrity is investigated.

During operation, the oxygen concentration is monitored. If oxygen concentration increases quicker than the normal rate, investigations are conducted to determine the source of in-leakage. Most times the source of oxygen is an air leak into the containment instrument gas compressors. However, a recent example shows that oxygen monitoring can detect containment leaks, as well. In March 2001, investigations determined that check valves in the vacuum relief line for the HPCI steam exhaust line to the Suppression Chamber leaked air into containment when Suppression Chamber pressure was slightly negative. Degradation may not be identified immediately, but the detection time will occur in days as compared to the ILRT interval measured in years. Appropriate actions will be taken when degradation is discovered.


NUREG-1493 Section 5.2.4 states that for BWR's, calculated risks were found to be very insensitive to the assumed containment leakage rates, even as high as 50 times the maximum allowable primary containment leak rate (La) per day. The scrubbing of fission products by suppression pool water contributes to the observed lack of risk sensitivity to containment leakage rate. In order to have a 50 La leakage rate, the primary containment would have to degrade at 3.3 La per year. This is over 5 times the allowed leakage of 0.6 La for Type B and Type C tested penetrations by Technical Specifications. Type B and Type C tested penetrations represent 95% of the leakage paths per NUREG1493.

NUREG-1493 Section 4.1 & 7.2 states that only 5 ILRT failures out of 180 reports were found which an LLRT could not detect. All 5 failures had actual leakage rates only slightly above acceptance criteria. Thus, the combination of 3% failure rate, leakage rate marginally above prescribed limits, and insensitivity of accident risk to leakage rate indicate that increasing the Type A test interval will have a minimal impact on public risk.

One of the risk measures used in the generic study to estimate the risk impact due to extending the ILRT interval is population dose (person-rem/year). PPL Susquehanna LLC is currently developing site specific risk-informed information to document that this request compares favorably with the generic analysis. This information is similar to that submitted by Indian Point 3 in their submittal of January 18, 2001. This information will be submitted no later than September 30, 2001.

Section IV: Conclusion

The tests, inspections, and investigations conducted to date indicate that containment integrity at SSES is maintained and monitored continuously. The containment design, operating, and maintenance programs at SSES are bounded by the analysis performed in NUREG-1493 and EPRI TR-104285. It is therefore concluded that the risk to the public will not be adversely affected by the requested extension of the Type A test interval for SSESI and SSES2.


No Significant Hazards Considerations Evaluation

and

Environmental Assessment

Attachment 2 to PLA-5342 Page 1 of 3

NO SIGNIFICANT HAZARDS CONSIDERATION EVALUATION

PPL Susquehanna, LLC has evaluated the proposed amendment and determined that it involves no significant hazards consideration. According to 1OCFR50.92 (c) a proposed amendment to an operating license involves no significant hazards consideration if operation of the facility with the proposed amendment would not:

"* Involve a significant increase in the probability of occurrence or consequences of an accident previously evaluated;

"* Create the possibility of a new or different kind of accident from any previously

analyzed; or

"* Involve a significant reduction in a margin of safety.

PPL Susquehanna, LLC proposes to:

Revise SSES 1 Technical Specifications (TS) 5.5.12, Containment Leakage Rate Testing Program," by adding a sentence to the end of the first paragraph:


Revise SSES2 Technical Specifications (TS) 5.5.12, Containment Leakage Rate Testing Program," by adding a sentence to the end of the first paragraph:


The determination that the criteria set forth in 1 OCFR50.92 are met for this amendment as indicated below:

1. Does the proposed change involve a significant increase in the probability of occurrence or consequences of an accident previously evaluated?

The frequency of Type A testing does not change the probability of an event that results in core damage or vessel failure. Primary containment is the engineered feature that contains the energy and fission products from evaluated events. The SSES IPE documents events that lead to containment failure. The frequency of events


that lead to containment failure does not change because it is not a function of the Type A test interval. Containment failure is a function of loss of safety systems that shutdown the reactor, provide adequate core cooling, provide decay heat removal, and drywell sprays.

The consequences of the evaluated accidents are the amount of radioactivity that is released to secondary containment and subsequently to the public. Normally, extending a test interval increases the probability that a Structure System or Component will be failed. However, NUREG-1493, Performance-Based Containment Leak-Test Program, states that calculated risks in BWR's is very insensitive to the assumed leakage rates. The remaining testing and inspection programs provide the same coverage as the Type A test. These other programs will maintain containment leakage low. Any leakage path problems will be identified and repairs will be made. Additionally the containment is continuously monitored during power operation. Anomalies are investigated and resolved. Thus there is a high confidence that containment integrity will be maintained independent of the Type A test frequency.

Therefore, this proposed amendment does not involve a significant increase in the probability of occurrence or consequences of an accident previously evaluated.

2. Does the proposed change create the possibility of a new or different kind of accident from any previously analyzed?

Primary containment is designed to contain energy and fission products during and after an event. The SSES IPE identifies events that lead to containment failure. Revision to the Type A test interval does not change this list of events. There are no physical changes being made to the plant and there are no changes to the operation of the plant that could introduce a new failure mode creating an accident or affecting mitigation of an accident.

Therefore, this proposed amendment does not involve a possibility of a new or different kind of accident from any previously analyzed.

3. Does the proposed change involve a significant reduction in a margin of safety?

The proposed revision to Technical Specifications adds a one time extension to the current interval for Type A testing. The current level of 10 years, based on past performance, would be extended on a one time basis to 15 years from the last Type A test. The NUREG- 1493 generic study of the effects of extending containment leakage testing found that a 20-year interval in Type A leakage testing resulted in an imperceptible increase in risk to the public. NUREG-1493 found that, generically, the

design containment leakage rate contributes about 0.1% to the individual risk and that


increasing the Type A test interval would have minimal affect on this risk since 95% of the potential leakage paths are detected by Type B and Type C testing. Technical Specifications require that maximum allowable primary containment leakage rate is less than 1% primary containment air weight per day. During unit startup following Type B and Type C testing, leakage rate acceptance criteria must be less than 0.6% primary containment air weight per day. (TS 5.5.12) Therefore, Type B and Type C testing combined with visual inspection programs will maintain containment leakage low.

Therefore, these changes do not involve a significant reduction in margin of safety.

Based upon the above, the proposed amendment does not involve a significant hazards consideration.


ENVIRONMENTAL ASSESSMENT

An environmental assessment is not required for the proposed change because the requested change conforms to the criteria for actions eligible for categorical exclusion as specified in 10 CFR 51.22(c)(9). The requested change will have no impact on the environment. As discussed in the "No Significant Hazards Consideration Evaluation", the proposed change does not involve a significant hazard consideration. The proposed change does not involve a change in the types or increase in the amounts of effluents that may be released off-site. In addition, the proposed change does not involve an increase in the individual or cumulative occupational radiation exposure.


Technical Specification Markups

(Units 1&2)

Programs and Manuals 5.5

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.

5.5.12 Primary Containment Leakaqe Rate Testinq 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, "Performance-Based Containment Leak-Test Program", dated September 1995.

The peak calculated containment internal pressure for the design basis loss of coolant accident, Pa, is 45.0 psig.

The maximum allowable primary containment leakage rate, La, at Pa, shall be 1% of the primary containment air weight per day.

Leakage Rate Acceptance Criteria are:

a. Primary Containment leakage rate acceptance criterion is -5 1.0 La. During each unit startup following testing in accordance with this program, the leakage rate acceptance criteria are < 0.60 La for Type B and Type C tests and - 0.75 La for Type A tests;

b. Air lock testing acceptance criteria are:

1) Overall air lock leakage rate is - 0.05 La when tested at 2 Pa.

2) For each door, leakage rate is 5 5 scfh when pressurized to - 10 psig.

The provisions of SR 3.0.2 do not apply to the test frequencies specified in the Primary Containment Leakage Rate Testing Program.

The provisions of SR 3.0.3 are applicable to the Primary Containment Leakage Rate Testing Program.

SUSQUEHANNA - UNIT 1

Performance of the May 2002 Integrated Leakage Rate (Type A) test has been deferred to no later than May 2007.

5.0-18 Amendment 178





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, "Performance-Based Containment Leak-Test Program", dated September 1995.




a. Primary Containment leakage rate acceptance criterion is

S1.0 La. During each unit startup following testing in

accordance with this program, the leakage rate acceptance criteria are s 0.60 La for Type B and Type C tests and S0.75 La for Type A tests;


1) Overall air lock leakage rate is 5 0.05 La when tested at : Pa,

2) For each door, leakage rate is s 5 scfh when pressurized to ý 10 psig.



SUSQUEHANNA - UNIT 2


5.0-18 Amendment 151


"Camera Ready" Technical Specifications

(Units 1&2)






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, "Performance-Based Containment Leak-Test Program", dated September 1995.





a. Primary Containment leakage rate acceptance criterion is _ 1.0 La. During each unit startup following testing in accordance with this program, the leakage rate acceptance criteria are < 0.60 La for Type B and Type C tests and • 0.75 La for Type A tests;


1) Overall air lock leakage rate is • 0.05 La when tested at > Pa,

2) For each door, leakage rate is • 5 scfh when pressurized to >_ 10 psig.



SUSQHEHANNA- UNIT 1 TS / 5.0-18 Amendment






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, "Performance-Based Containment Leak-Test Program", dated September 1995.



The maximum allowable primary containment leakage rate, La, at Pa, shall be

1 % of the primary containment air weight per day.


a. Primary Containment leakage rate acceptance criterion is < 1.0 La. During each unit startup following testing in accordance with this program, the leakage rate acceptance criteria are < 0.60 La for Type B and Type C tests and _< 0.75 La for Type A tests;


1) Overall air lock leakage rate is < 0.05 La when tested at > Pa,

2) For each door, leakage rate is < 5 scfh when pressurized to > 10 psig.



SUSQUEHANNA - UNIT 2 AmendmentTS / 5.0-18

Susquehanna Steam Electric Station - Proposed Amendment No. … · 2012. 11. 18. · NFP-14 AND...

Documents

Transcript of Susquehanna Steam Electric Station - Proposed Amendment No. … · 2012. 11. 18. · NFP-14 AND...