ML081780698
| ML081780698 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 07/03/2008 |
| From: | Gettys E NRC/NRR/ADRO/DLR/RLRA |
| To: | Mckinney B Susquehanna |
| Gettys Evelyn, NRR/DLR/RLRA 415-4029 | |
| References | |
| Download: ML081780698 (9) | |
Text
July 3, 2008 Mr. Britt T. McKinney Sr. Vice President and Chief Nuclear Officer PPL Susquehanna, LLC 769 Salem Blvd., NUCSB3 Berwick, PA 18603-0467
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE SUSQUEHANNA STEAM ELECTRIC STATION, UNITS 1 AND 2, LICENSE RENEWAL APPLICATION
Dear Mr. McKinney:
By letter dated September 13, 2006, PPL Susquehanna, LLC submitted an application pursuant to Title 10 of the Code of Federal Regulations Part 54 (10 CFR Part 54), to renew the operating licenses for Susquehanna Steam Electric Station, Units 1 and 2, for review by the U.S. Nuclear Regulatory Commission (NRC or the staff). The staff is reviewing the information contained in the license renewal application and has identified, in the enclosure, areas where additional information is needed to complete the review. Further requests for additional information may be issued in the future.
Items in the enclosure were discussed with Duane Filchner, and a mutually agreeable date for the response is within 30 days from the date of this letter. If you have any questions, please contact me at 301-415-4029 or e-mail evelyn.gettys@nrc.gov.
Sincerely,
/RA/
Evelyn Gettys, Project Manager Projects Branch 1 Division of License Renewal Office of Nuclear Reactor Regulation Docket Nos. 50-387 and 50-388
Enclosure:
As stated cc w/encl: See next page
July 3, 2008 Mr. Britt T. McKinney Sr. Vice President and Chief Nuclear Officer PPL Susquehanna, LLC 769 Salem Blvd., NUCSB3 Berwick, PA 18603-0467
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE SUSQUEHANNA STEAM ELECTRIC STATION, UNITS 1 AND 2, LICENSE RENEWAL APPLICATION
Dear Mr. McKinney:
By letter dated September 13, 2006, PPL Susquehanna, LLC submitted an application pursuant to Title 10 of the Code of Federal Regulations Part 54 (10 CFR Part 54), to renew the operating licenses for Susquehanna Steam Electric Station, Units 1 and 2, for review by the U.S. Nuclear Regulatory Commission (NRC or the staff). The staff is reviewing the information contained in the license renewal application and has identified, in the enclosure, areas where additional information is needed to complete the review. Further requests for additional information may be issued in the future.
Items in the enclosure were discussed with Duane Filchner, and a mutually agreeable date for the response is within 30 days from the date of this letter. If you have any questions, please contact me at 301-415-4029 or e-mail evelyn.gettys@nrc.gov.
Sincerely,
/RA/
Evelyn Gettys, Project Manager Projects Branch 1 Division of License Renewal Office of Nuclear Reactor Regulation Docket Nos. 50-387 and 50-388
Enclosure:
As stated cc w/encl: See next page DISTRIBUTION: See following pages ADAMS Accession Number: ML081780698 OFFICE LA:DLR PM:RPB1:DLR BC: RPB1:DLR BC: RPB1:DLR NAME IKing EGettys RAuluck BPham acting for LLund DATE 6/30/08 6/30/08 7/01/08 7/03/08 OFFICIAL RECORD COPY
SUSQUEHANNA STEAM ELECTRIC STATION, UNITS 1 AND 2 LICENSE RENEWAL APPLICATION REQUEST FOR ADDITIONAL INFORMATION Aging Management Programs (AMPs) Generic Electrical Questions
- 1. Under the operating experience program element in the license renewal application (LRA),
the applicant states that the aging management program (AMP) B.2.41, B.2.42, B.2.43, B.2.44, and B.2.45 are new programs for which there is no Susquehanna Steam electric Station (SSES) specific operating experience. However, staff noticed some operating experiences while performing the audit on site.
- a. Provide a summary of the plant specific operating that is experience relating to each AMP.
- b. Explain how the AMP will be effective in managing the aging degradation from the plant specific operating experience describes above.
- 2. The Standard Review Plan for Review of License Renewal (SRP-LR), Table 3.6-2 FSAR Supplement for Aging Management of Electrical and Instrumentation and Control System identifies when the inspection will be implemented and how often the inspection will be performed. Susquehanna Final Safety Analysis Report (FSAR) supplement for AMP B.2.41, B.2.42, B.2.43, B.2.44, and B.2.45 do not provide the frequency of inspection. Provide the inspection frequency for each AMP in the FSAR.
- 3. In the LRA, the applicant states that the AMPs are consistent with the generic aging lessons learned (GALL) Report and referred to a corrective action element in LRA, Section B.1.3, that is common to all SSES AMPs. The corrective actions described in Section B.1.3 do not contain certain requirements as described in the GALL AMP XI.E1, E2, E3, E4, and E6.
Explain in detail how the generic corrective actions in Section B.1.3 are consistent with those in the GALL AMPs.
Request for Additional Information (RAI)
RAI-B.2.41-1 The GALL Report AMP XI.E1 considers the technical information and guidance provided in NUREG/CR-5643, IEEE Std. P1205, SAND 96-0344, and EPRI TR-109619. In the LRA B.2.41, the applicant states that this program is consistent with GALL. However, the applicant did not provide technical information and guidance as reference in the GALL Report AMP XI.E1.
Provide specific technical/industrial guidance for which will be used to develop this AMP.
RAI-B.2.41-2 The GALL Report AMP XI.E1 states that [a]n adverse localized environment is a condition in a limited plant area that is significantly more severe than the specified service environment for the cable. Explain in detail how an adverse localized environment, with the most limiting service environment such as, radiation, temperature, and moisture is determined.
ENCLOSURE
RAI-B.2.42-1 The GALL Report AMP XI.E2 recommends the technical information and guidance provided in NUREG/CR-5643, IEEE Std. P1205, SAND 96-0344 and EPRI TR-109619. In the LRA AMP B.2.42, the applicant states that its program will be consistent with the GALL Report and yet it did not provide any information on industrial technical guidance. Provide specific technical guidance which will be used to develop this new AMP.
RAI-B.2.42-2 The GALL Report AMP XI.E2 states that a proven cable system test for detecting deterioration of the insulation system (such as insulation resistance tests, time domain reflectometry tests, or other testing judged to be effective in determining cable insulation condition as justified in the application) will be performed. In AMP B.2.42, under the same element, the applicant stated that the testing methodology will be specified prior to the first test. Provide the type of tests that will be used to detect degradation of insulation in high voltage, and low level signal instrumentation circuits.
RAI-B.2.43-1 In the LRA AMP B.2.43, under the scope of program element, it states that this program applies to six cables associated with the offsite power supply for SSES and that these are the only inaccessible medium-voltage cables at SSES that are within the scope of license renewal and are exposed to significant moisture and significant voltage. The staff noted that the residual heat removal and emergency service water pump cables could be subjected to significant moisture. Explain why these cables are not in-scope of B.2.43.
RAI-B.2.43-2 The staff reviewed operating experience and noted that inaccessible medium-voltage cables in certain manholes at SSES have experienced significant moisture (cable in standing water for more than few days). In addition, during a walk down, the staff found several feet of water in Manholes Number 2 and 16.
- a. Identify manholes that have experienced significant water. Identify specific circuits in those manholes that have significant water. Are these cable qualified for submergence? If they are, provide manufacturer qualification for these cables.
- b. Provide a basis as to how performing cable test every 10 years is adequate to detect aging effects given the plants field operating experience.
- c. How is inspection frequency adjusted based on field operating experience?
- d. What corrective actions have been taken or planned to address significant moisture conditions in these manholes?
RAI-B.2.43-3 The GALL Report AMP XI.E3 recommends the technical information and guidance in NUREG/CR-5643, IEEE Std. P1205, SAND 96-0344 and EPRI TR-109619. In the LRA AMP B.2.43, the applicant states that its program is consistent with the GALL Report and yet it did not provide any information on industrial technical guidance. Provide technical guidance for AMP B.2.43 or provide a justification of why this guidance is not necessary.
RAI-B.2.43-4 The GALL Report AMP XI.E3, under detection of aging effects attribute, states that the specific type of test is to be a proven test for detecting deterioration of the insulation system due to wetting, such as power factor, partial discharge, or polarization index, as described in EPRI TR-103834-P1-2, or other testing that is state-of-the-art at the time of the test is performed. LRA Section B.2.43, under the same attribute, states that the program will utilize a proven test for detecting deterioration of the cable insulation due to wetting (and energization) and will reflect the actual test methodology prior to the initial performance of the cable testing. Describe the proposed testing methodology for detecting deterioration of the cable insulation under this AMP.
RAI-B.3.2-1 In the LRA section A.1.3.4, the applicant provided an updated FSAR supplement of summary description of environmental qualification of electrical equipment. This summary description is not consistent with that in Table 4.4.2 of SRP-LR as it does not contain reanalysis attributes.
Reanalysis must address attributes of analytical methods, data collection and reduction methods, underlying assumptions, acceptance criteria, corrective actions if acceptance criteria are not met, and the period of time prior to the end of qualified life when the reanalysis will be completed. Please revise the FSAR supplement description to include these reanalysis attributes.
Aging Management Reviews (AMRs)
RAI-3.6-1 The GALL Report Item VI.A-8, identifies corrosion and fatigue as one of aging effect/mechanism for fuse holders (metallic clamp) that requires an AMP (GALL XI.E5). The LRA, Section 3.6.2.3.1, states that the fuse holders are located in metallic electrical boxes (terminal boxes) which have covers that protect the interior of the box from the environment. The LRA further states that by design, these fuses are not removed more than once per year, therefore, fatigue due to frequent manipulation does not apply.
- a. Explain why corrosion of fuse holders inside the metallic electrical boxes due to condensation is not an aging effect requiring management for fuse holders (metallic clamps).
- b. Given the life of the plant is 40 years plus 20 years of extended operations, the fuse holders could be subject to about 60 times of manipulation (removing and inserting of fuse elements to fuse holders). Provide technical justification of how the manipulation of 60 times will not create fatigue aging effect.
RAI-3.6-2 Please explain how the tests were conducted at Ontario Hydroelectric and explain in detail how SSES transmission conductors are bounded by the tests conducted at Ontario Hydroelectric and will have adequate margin for 60 years.
RAI-3.6-3 The LRA Section 3.6.2.2.3 states that bolted connections associated with transmission conductors employ the use of good bolting practices consistent with the recommendation of EPRI 1003471, Electrical Connector Application Guidelines. In addition, it stated that bolting
hardware is selected to be comparable with the lugs used on transmission conductors and Belleville washers are used to compensate for temperature change and to maintain proper tightness.
- a. Describe good bolting practice as recommended in EPRI 1003471 and how the bolted connections associated with transmission conductor at SSES follows this recommendation.
- b. The EPRI document TR-104213, Bolted Joint Maintenance & Application Guide, identifies a special problem with Belleville washers. It states that hydrogen embrittlement is a recurring problem with Belleville washers and other springs. When springs are electroplated, the plating process forces hydrogen into the metal grain boundaries.
If the hydrogen is not removed, the spring may spontaneously fail at any time while in service. Describe the types of finish the Belleville washers currently have at SSES and current activities used to confirm the effectiveness of switchyard bolted connections.
- c. Increased resistance on connection due to oxidation may occur in transmission conductors and connections and in switchyard buses and connections. Explain why increased connection resistance of switchyard connections is not identified as an aging effect requiring management at SSES.
RAI-3.6-4 Tie wraps may be taken credit for in seismic analysis and in plant design specifications primary for separation to preclude ampacity degrading. Operating experience has identified issues with tie wraps, such as, tie wraps were brittle, degraded, or missing and tie wraps failures affected safety functions of other system/components. The LRA does not discuss tie wraps as a commodity type requiring aging management reviews (AMRs). Explain why tie wraps are not required an AMR. Respond to the following:
- a. Are tie wraps taken credit for seismic analysis in the current licensing basis?
- b. Address the effects of tie wraps for 10 CFR 54.4 (a)(2) over 10 CFR 54.4(a)(1), non safety components whose failure could affect safety-functions.
- c. Provide a quantitative analysis of the effects of cables spacing not being maintained as original design specifications (due to tie wraps failure). The analysis should provide the worst case scenario with ampacity reduction and the maximum amperes required for motors to start and run during a design basis accident.
RAI-3.6-5 The LRA Section 3.6.2.2.2 states that the high-voltage insulators within the scope of license renewal for SSES are connected to rigid components, such that significant movement is not considered as a stressor, and wear is not identified as an aging mechanism. Describe what components are connected to the insulators and explain why wear is not identified as an aging mechanism. Also provide plant specific operating experience with high-voltage insulators at SSES.
Letter to B. McKinney from E. Gettys, dated July 3, 2008 DISTRIBUTION:
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE SUSQUEHANNA STEAM ELECTRIC STATION, UNITS 1 AND 2, LICENSE RENEWAL APPLICATION HARD COPY:
DLR RF E-MAIL:
PUBLIC RidsNrrDlr RidsNrrDlrRlra RidsNrrDlrRlrb RidsNrrDlrRlrc RidsNrrDlrReba RidsNrrDlrRebb RidsNrrDciCvib RidsNrrDciCpnb RidsNrrDraAfpb RidsNrrDeEmcb RidsNrrDeEeeb RidsNrrDssSrxb RidsNrrDssSbpb RidsNrrDssScvb RidsOgcMailCenter
EGettys FJaxheimer
Susquehanna Steam Electric Station, Units 1 and 2 cc:
Cornelius J. Gannon Joseph J. Scopelliti Vice President - Nuclear Operations Community Relations Manager, PPL Susquehanna, LLC Susquehanna 769 Salem Blvd., NUCSB3 PPL Susquehanna, LLC Berwick, PA 18603-0467 634 Salem Blvd., SSO Berwick, PA 18603-0467 Robert M. Paley General Manager - Plant Support Bryan A. Snapp, Esq.
PPL Susquehanna, LLC Associate General Counsel 769 Salem Blvd., NUCSB2 PPL Services Corporation Berwick, PA 18603-0467 Two North Ninth Street, GENTW3 Allentown, PA 18101-1179 Rocco R. Sgarro Manager - Nuclear Regulatory Affairs Document Control Services PPL Susquehanna, LLC PPL Susquehanna, LLC Two North Ninth Street, GENPL4 Two North Ninth Street, GENPL4 Allentown, PA 18101-1179 Allentown, PA 18101-1179 Supervisor - Nuclear Regulatory Affairs Richard W. Osborne PPL Susquehanna, LLC Allegheny Electric Cooperative, Inc.
769 Salem Blvd., NUCSA4 212 Locust Street Berwick, PA 18603-0467 P.O. Box 1266 Harrisburg, PA 17108-1266 Michael H. Crowthers Supervisor - Nuclear Regulatory Affairs Director, Bureau of Radiation Protection PPL Susquehanna, LLC Pennsylvania Department of Two North Ninth Street, GENPL4 Environmental Protection Allentown, PA 18101-1179 Rachel Carson State Office Building P.O. Box 8469 Ronald E. Smith Harrisburg, PA 17105-8469 General Manager - Site Preparedness and Services Senior Resident Inspector PPL Susquehanna, LLC U.S. Nuclear Regulatory Commission 769 Salem Blvd., NUCSA4 P.O. Box 35, NUCSA4 Berwick, PA 18603-0467 Berwick, PA 18603-0035 Michael H. Rose Regional Administrator, Region 1 Manager - Quality Assurance U.S. Nuclear Regulatory Commission PPL Susquehanna, LLC 475 Allendale Road 769 Salem Blvd., NUCSB2 King of Prussia, PA 19406 Berwick, PA 18603-0467
Susquehanna Steam Electric Station, Units 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