ML081960683
| ML081960683 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 07/23/2008 |
| From: | Gettys E NRC/NRR/ADRO/DLR |
| To: | Mckinney B Susquehanna |
| Gettys Evelyn, NRR/DLR/RPB1 415-4029 | |
| References | |
| Download: ML081960683 (8) | |
Text
July 23, 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 Regulation 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 by BPham for/
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
ML081960683 OFFICE LA:DLR PM:RPB1:DLR BC(A):RPB1:DLR NAME SFigueroa BPham for EGettys BPham DATE 07/18/08 07/23/08 07/23/08
SUSQUEHANNA STEAM ELECTRIC STATION, UNITS 1 AND 2 LICENSE RENEWAL APPLICATION REQUEST FOR ADDITIONAL INFORMATION (RAI)
RAI 3.x.2.1-1 For aging management review (AMR) Table-2 line items that reference NUREG-1801 Volume 2 Items V.B-1 and VII.F3-3, the generic aging lessons learned (GALL) Report recommends that the GALL Report aging management program (AMP) XI.M38 Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components be used to inspect the internal surfaces of steel ducting and components for loss of material. However Susquehanna Steam Electric Station (SSES) has credited the System Walkdown Program for aging management of the internal surfaces of steel ducting and components for loss of material in the Standby Gas Treatment and Primary Containment Atmosphere Circulation System. The Systems Walkdown Program is the AMP that is analogous to the GALL Report AMP XI.M36 External Surfaces Monitoring which is limited to only visual examinations of alloy steel components on their external surfaces. Provide your basis for crediting the System Walkdown Program, for aging management of loss of material on the internal surfaces of these steel components in the standby gas treatment and primary containment atmosphere circulation system, particularly when there will be no inspections of the internal component surfaces.
RAI B.2.13-5 (Piping Corrosion Program)
In the license renewal application (LRA) Section B.2.13, the applicant stated an exception in the monitoring and trending program element that inspection frequencies are based on operating conditions and past history; flow rates, water quality, lay-up and heat exchanger design. The GALL AMP XI.M20 recommends testing and inspections are performed annually and during refueling outages.
Please confirm if these frequencies are in accordance with the information provided in Generic Letter (GL) 89-13 concerning a routine inspection and maintenance program and Section D frequency of testing and maintenance, in GL 89-13, Supplement 1. If not, please justify why the GALL recommended frequencies are not followed.
RAI 3.2.2.2.4.2-1 LRA Section 3.2.2.2.4.2 states that the Heat Exchanger Inspection activity is a one-time inspection that will detect and characterize reduction in heat transfer of stainless steel heat exchanger tubes exposed to treated water. Standard Review Plan-License Renewal (SRP-LR)
Section 3.2.2.2.4.2 recommends water chemistry and one-time inspection.
Please justify why water chemistry is not credited as recommended by the GALL Report and how the one-time heat exchanger inspection activity by itself will manage the aging effect of reduction in heat transfer.
ENCLOSURE
RAI 3.2.2.1-1 In Tables 3.2.2.-2 and 3.2.2-4, the LRA states that reduction of heat transfer of reactor core isolation cooling (RCIC) and high pressure coolant injection (HPCI) heat exchanger copper alloy tubes in an internal environment of treated water is managed by the Heat Exchanger Inspection Program and referenced GALL Report item V.A-11. For this item, the GALL Report recommends the GALL AMP XI.M21 Closed-Cycle Cooling Water System. This GALL Program includes preventive measures such as maintaining the treated water chemistry and detection of aging effects through inspection.
Please justify why water chemistry is not credited as recommended by the GALL Report and how the one-time heat exchanger inspection activity by itself will manage the aging effect of reduction in heat transfer.
RAI 3.3.2.1-2 In Table 3.3.2-4, the LRA states that reduction of heat transfer of control structure chilled water chiller evaporator copper and copper alloy tubes in an internal environment of treated water is managed by the Heat Exchanger Inspection Program, and referenced the GALL Report item VII.C2-2. For this item, the GALL Report recommends GALL AMP XI.M21 Closed-Cycle Cooling Water System. This GALL Program includes preventive measures such as maintaining the treated water chemistry and detection of aging effects through inspection.
Please justify why water chemistry is not credited as recommended by the GALL Report and how the one-time heat exchanger inspection activity by itself will manage the aging effect of reduction in heat transfer.
RAI 3.5.2.3.10-1 In Table 3.5.2-10, the LRA states that galvanized steel fire doors in a protected from weather environment has no aging effects and credits the Fire Protection Program with a reference to GALL item VII.G-3 and Note I. The GALL Report Item VII.G-3 identifies an aging effect of loss of material due to wear. Please justify why loss of material due to wear is not an aging effect for galvanized steel fire doors in a protected from weather environment. Also, please justify why Note I is used, when a GALL Report line item is specified, since Note I by definition implies it is not consistent with the GALL Report.
RAI 3.2.2.3.1-1 In Table 3.2.2-1, residual heat removal system, the LRA credits Supplemental Piping/Tank Inspection Program to manage the aging effect of loss of material of carbon steel piping in an indoor air external environment and has referenced Note H and Note 0203. The definition of Note H implies that these line items are not consistent with GALL Report. The Note 0203 states that this piping is in the air/water interface in the suppression pool. However, the LRA has also referenced the GALL Report item V.D2-2 and Table 3.2.1, line item 3.2.1-31.
Please justify why a GALL Report and Table 1 item is identified, if the line item is not consistent with the GALL Report.
RAI 3.4.2.1-1 In Table 3.4.2-6, Main Steam System, the LRA credits Supplemental Piping/Tank Inspection Program to manage the aging effect of loss of material of carbon steel piping in an indoor air external environment and has referenced Note E, and Note 0401. The Note 0401 states that this piping is in the air/water interface in the suppression pool. The LRA has also referenced Table 3.4.1, item 3.4.1-28.
The discussion column of Table 3.4.1, line item 3.4.1-28 only credits the System Walkdown Program, and does not address the Supplementary Piping/Tank Inspection Program. Please clarify this discrepancy.
Furthermore, for the same air/water interface environment, in some cases the LRA tables reference Note H and in some cases, it references Note E. See RAI 3.2.2.3.1-1 for Note H example.
RAI 3.3.2.3.13-1 In Table 3.3.2-13, the LRA states that elastomers (synthetic rubber) in lubricating oil, fuel oil and raw water internal environments have no aging effect. Similarly, Teflon in a raw water environment has no aging effect.
Please provide the basis for this statement.
RAI B2.17-1-R In RAI B.2.17-1, the staff had requested justification why Standby Gas Treatment System (SGTS) was not included in the scope of the Fire Water System Program. During a review of the program basis document, the staff noticed that the systems listed in the scope of program element did not include SGTS.
In its letter dated June 30, 2008, PP&L did not address this issue. A new component, piping, was added to Table 3.3.2-7, however, the response did not indicate if the program will be enhanced to either include SGTS in the scope or provide justification why it was not included.
Please provide clarification.
Letter to B. McKinney from E. Gettys, dated July 23, 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:
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Susquehanna Steam Electric Station, Units 1 and 2 cc:
Cornelius J. Gannon Vice President - Nuclear Operations PPL Susquehanna, LLC 769 Salem Blvd., NUCSB3 Berwick, PA 18603-0467 Robert M. Paley General Manager - Plant Support PPL Susquehanna, LLC 769 Salem Blvd., NUCSB2 Berwick, PA 18603-0467 Rocco R. Sgarro Manager - Nuclear Regulatory Affairs PPL Susquehanna, LLC Two North Ninth Street, GENPL4 Allentown, PA 18101-1179 Supervisor - Nuclear Regulatory Affairs PPL Susquehanna, LLC 769 Salem Blvd., NUCSA4 Berwick, PA 18603-0467 Michael H. Crowthers Supervisor - Nuclear Regulatory Affairs PPL Susquehanna, LLC Two North Ninth Street, GENPL4 Allentown, PA 18101-1179 Ronald E. Smith General Manager - Site Preparedness and Services PPL Susquehanna, LLC 769 Salem Blvd., NUCSA4 Berwick, PA 18603-0467 Michael H. Rose Manager - Quality Assurance PPL Susquehanna, LLC 769 Salem Blvd., NUCSB2 Berwick, PA 18603-0467 Joseph J. Scopelliti Community Relations Manager, Susquehanna PPL Susquehanna, LLC 634 Salem Blvd., SSO Berwick, PA 18603-0467 Bryan A. Snapp, Esq.
Associate General Counsel PPL Services Corporation Two North Ninth Street, GENTW3 Allentown, PA 18101-1179 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 Rachel Carson State Office Building 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, 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