NL-07-0950, NRC Generic Letter 2007-01 Response

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NRC Generic Letter 2007-01 Response
ML071240472
Person / Time
Site: Hatch, Vogtle, Farley  Southern Nuclear icon.png
Issue date: 05/04/2007
From: Stinson L
Southern Nuclear Operating Co
To:
Document Control Desk, NRC/NRR/ADRO
References
GL-07-001, NL-07-0950
Download: ML071240472 (10)


Text

1. M. Stinson (Mike) Southern Nuclear Vice President Operating Company, Inc.

Fleet Operations Support 40 lnverness Center Parkway Post Office Box 1295 Birmingham. Alabama 35201 Tel205.992.5181 Fax 205.992.0341 May 4, 2007 Energy to Serve Your World" DocketNos.: 50-321 50-348 50-424 NL-07-0950 50-366 50-364 50-425 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Joseph M. Farley Nuclear Plant Edwin I. Hatch Nuclear Plant Vogtle Electric Generating Plant NRC Generic Letter 2007-01 Response Ladies and Gentlemen:

Southern Nuclear Operating Company (SNC), the licensed operator for the Edwin I.

Hatch Nuclear Plant, the Joseph M. Farley Nuclear Plant and the Vogtle Electric Generating Plant, received NRC Generic Letter 2007-0 1: Inaccessible or Underground Power Cable Failures that Disable Accident Mitigation Systems or Cause Plant Transients, dated February 7,2007.

In accordance with 10 CFR 50.54(f), SNC hereby submits its response.

Mr. L. M. Stinson states he is a Vice President of Southern Nuclear Operating Company, is authorized to execute this oath on behalf of Southern Nuclear Operating Company and to the best of his knowledge and belief, the facts set forth in this letter are true.

This letter contains no NRC commitments. If you have any questions, please advise.

Respectllly submitted,

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.qb' 7 SOUTHERN NUCLEAR OPERATING COMPANY ..' c, 4:; .-

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L. M. Stinson ,.;:<;. 3 . >.I 2 Vice President Fleet Operations Support

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Sworn to and subscribed before me this 4~day of- 2007.

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Notary Public My commission expires: J;/* 4 20 10

U. S. Nuclear Regulatory Commission NL-07-0950 Page 2

Enclosures:

1. GL 2007-01 Response - Farley Nuclear Plant
2. GL 2007-01 Response - Hatch Nuclear Plant
3. GL 2007-01 Response - Vogtle Electric Generating Plant cc: Southern Nuclear Operating Companv Mr. J. T. Gasser, Executive Vice President Mr. J. R. Johnson, Vice President - Farley Mr. D. R. Madison, Vice President - Hatch Mr. T. E. Tynan, Vice President - Vogtle Mr. D. H. Jones, Vice President - Engineering RType: CFA04.054; CHA02.004; CVC7000; LC# 14575 U. S. Nuclear R e d a t o w Commission Dr. W. D. Travers, Regional Administrator Ms. K. R. Cotton, NRR Project Manager - Farley Mr. R. E. Martin, NRR Project Manager - Hatch Mr. B. K. Singal, NRR Project Manager - Vogtle Mr. E. L. Crowe, Senior Resident Inspector - Farley Mr. J. A. Hickey, Senior Resident Inspector - Hatch Mr. G. J. McCoy, Senior Resident Inspector - Vogtle Alabama Dmartment of Public Health Dr. D. E. Williamson, State Health Officer State of Georgia Mr. N. Holcomb, Commissioner - Department of Natural Resources

Enclosure 1 GL 2007-01 Response - Farley Nuclear Plant

Enclosure 1 GL 2007-0 1 Response - Farley Nuclear Plant GL 2007-01: Inaccessible or Underground Power Cable Failures that Disable Accident Mitigation Systems or Cause Plant Transients GL 2007-01 information reauested:

Within 90 days of the date of this GL, provide the following:

1. Provide a history of inaccessible or underground power cable failures for all cables that are within the scope of 10 CFR 50.65 (the Maintenance Rule) and for all voltage levels. Indicate the type, manufacturer, date of failure, type of service, voltage class, years of service, and the root causes for the failure.
2. Describe inspection, testing and monitoring programs to detect the degradation of inaccessible or underground power cables that support EDGs, offsite power, ESW, service water, component cooling water and other systems that are within the scope of 10 CFR 50.65 (the Maintenance Rule).

SNC Response:

The scope of this response is based on NRC letter dated April 13,2007 (Agencywide Documents and Access Management System, Accession No. ML070940311) in response to a Nuclear Energy Institute letter dated March 26, 2007 regarding interpretation of GL 2007-01.

Information Request Item 1:

During the investigation of cable failures at Farley Nuclear Plant (FNP), Engineering Support personnel:

Reviewed the functional failure database Searched Condition Reports Performed a SNC records database broadness review for "cable failures" Searched the legacy work order database for work orders related to Maintenance Rule components Reviewed Licensee Event Reports for cable failure issues The result of this investigation yielded one "in-scope" cable failure, identified in the following table:

Page 2 of 2 GL 2007-0 1 Response - Farley Nuclear Plant FNP Cable Failure within the Scope of Generic Letter 2007-01 I Type I Single conductor, 750 MCM, shielded, EPR insulation I

I I Manufacturer Okonite Date of

~

July 1998 Failure Type of Phase C power cable to 1B Circulating Water Pump Motor, Service normally energized, cable ID: 1VXDB04-R Cable Rating: 5000V Senice: 4 160V years Approximately 22 years Service Cable shorted to ground. Apparent cause was damage during installation that allowed the cable insulation to break down

~ o o Cause t with time (cable appeared to have been cut/scuffed/scraped at installation).

Reference:

Work Order 98004738 (microfilm 17504-1039)

Information Reuuest Item 2:

FNP does not have a cable testinglmonitoring program to detect the degradation of inaccessible or underground power cables. Cable failures are entered into the corrective action program, which provides a mechanism for trending events and causes. The SNC is monitoring industry activities regarding cable testing. Currently there is no definitive golno-go test that will identify impending cable failures (reference: NEI 06-05, Medium Voltage Underground Cable White Paper).

Enclosure 2 GL 2007-01 Response - Hatch Nuclear Plant

Enclosure 2 GL 2007-01 Response - Hatch Nuclear Plant GL 2007-01: Inaccessible or Underground Power Cable Failures that Disable Accident Mitigation Systems or Cause Plant Transients GL 2007-01 information requested:

Within 90 days of the date of this GL, provide the following:

1. Provide a history of inaccessible or underground power cable failures for all cables that are within the scope of 10 CFR 50.65 (the Maintenance Rule) and for all voltage levels. Indicate the type, manufacturer, date of failure, type of service, voltage class, years of service, and the root causes for the failure.
2. Describe inspection, testing and monitoring programs to detect the degradation of inaccessible or underground power cables that support EDGs, offsite power, ESW, service water, component cooling water and other systems that are within the scope of 10 CFR 50.65 (the Maintenance Rule).

SNC Response:

The scope of this response is based on NRC letter dated April 13,2007 (Agencywide Documents and Access Management System, Accession No. ML070940311) in response to a Nuclear Energy Institute letter dated March 26, 2007 regarding interpretation of GL 2007-0 1.

Information Reauest Item 1:

During the investigation of cable failures at Hatch Nuclear Plant (HNP), Engineering Support personnel:

Reviewed the functional failure database Searched Condition Reports Performed a SNC records database broadness review for "cable failures" Searched the legacy work order database for work orders related to Maintenance Rule components Reviewed Licensee Event Reports for cable failure issues The investigation results did not indicate any "in-scope" cable failures.

Information Request Item 2:

HNP does not have a cable testinglmonitoring program to detect the degradation of inaccessible or underground power cables. Cable failures are entered into the corrective action program, which provides a mechanism for trending or events and causes. SNC is monitoring industry activities regarding cable testing. Currently there is no definitive gotno-go test that will identify impending cable failures (reference:

NEI 06-05, Medium Voltage Underground Cable White Paper).

Enclosure 3 GL 2007-0 1 Response - Vogtle Electric Generating Plant

Enclosure 3 GL 2007-01 Response - Vogtle Electric Generating Plant GL 2007-01 : Inaccessible or Underground Power Cable Failures that Disable Accident Mitigation Systems or Cause Plant Transients GL 2007-01 information requested:

Within 90 days of the date of this GL, provide the following:

1. Provide a history of inaccessible or underground power cable failures for all cables that are within the scope of 10 CFR 50.65 (the Maintenance Rule) and for all voltage levels. Indicate the type, manufacturer, date of failure, type of service, voltage class, years of service, and the root causes for the failure.
2. Describe inspection, testing and monitoring programs to detect the degradation of inaccessible or underground power cables that support EDGs, offsite power, ESW, service water, component cooling water and other systems that are within the scope of 10 CFR 50.65 (the Maintenance Rule).

SNC Response:

The scope of this response is based on NRC letter dated April 13,2007 (Agencywide Documents and Access Management System, Accession No. ML070940311) in response to a Nuclear Energy Institute letter dated March 26, 2007 regarding interpretation of GL 2007-01.

Information Request Item 1:

To investigate cable failures at Vogtle Electric Generating Plant (VEGP),

Engineering Support personnel:

Reviewed the functional failure database Searched Condition Reports Performed a SNC records database broadness review for "cable failures" Searched the legacy work order database for work orders related to Maintenance Rule components Reviewed Licensee Event Reports for cable failure issues The result of this investigation yielded one "in-scope" cable failure, identified in the following table:

Page 2 of 2 GL 2007-01 Response - Vogtle Electric Generating Plant VNP Cable within the Scope of Generic Letter 2007-01 Single conductor, 350 MCM, unshielded, EPR insulation Manufacturer Okonite Date of October 2002 Failure*

Phase C power cable to 2A NSCW Tower fan # Motor, Type of Service normally energized, cable ID 2AB1508HB Cable Rating: 2000V Voltage Class Service: 480V Years of Approximately 14 years Service

  • Cable did not fail but had unsatisfactory meggar reading.

Cable and motor exhibited declining insulation resistance, the motor issue was attributed to the cable. An Root Cause approximately 125 foot section of cable was replaced. The cable was discovered to be submerged in water.

References:

Condition Report 2002002765 Work Order 20 103189 Information Reauest Item 2:

VEGP does not have a cable testinglmonitoring program to detect the degradation of inaccessible or underground power cables. Cable failures are entered into the corrective action program, which provides a mechanism for trending or events and causes. The SNC is monitoring industry activities regarding cable testing. Currently there is no definitive golno-go test that will identify impending cable failures (reference: NEI 06-05, Medium Voltage Underground Cable White Paper).

Text

1. M. Stinson (Mike) Southern Nuclear Vice President Operating Company, Inc.

Fleet Operations Support 40 lnverness Center Parkway Post Office Box 1295 Birmingham. Alabama 35201 Tel205.992.5181 Fax 205.992.0341 May 4, 2007 Energy to Serve Your World" DocketNos.: 50-321 50-348 50-424 NL-07-0950 50-366 50-364 50-425 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Joseph M. Farley Nuclear Plant Edwin I. Hatch Nuclear Plant Vogtle Electric Generating Plant NRC Generic Letter 2007-01 Response Ladies and Gentlemen:

Southern Nuclear Operating Company (SNC), the licensed operator for the Edwin I.

Hatch Nuclear Plant, the Joseph M. Farley Nuclear Plant and the Vogtle Electric Generating Plant, received NRC Generic Letter 2007-0 1: Inaccessible or Underground Power Cable Failures that Disable Accident Mitigation Systems or Cause Plant Transients, dated February 7,2007.

In accordance with 10 CFR 50.54(f), SNC hereby submits its response.

Mr. L. M. Stinson states he is a Vice President of Southern Nuclear Operating Company, is authorized to execute this oath on behalf of Southern Nuclear Operating Company and to the best of his knowledge and belief, the facts set forth in this letter are true.

This letter contains no NRC commitments. If you have any questions, please advise.

Respectllly submitted,

,,,,  ::.:lll,*fi.#

l~

  • .".>3 . -*.I b-2'.,,.*

.qb' 7 SOUTHERN NUCLEAR OPERATING COMPANY ..' c, 4:; .-

5-.,y;5;5,

2;e 7 3
;tL!g

= . x i ,,-7 & j ;;;:..; -

L. M. Stinson ,.;:<;. 3 . >.I 2 Vice President Fleet Operations Support

-.- :.'~

s,, ,...,

,-.A

):.(

.-.,+- +

,.e.

A>

Sworn to and subscribed before me this 4~day of- 2007.

'd,,

<ltd:

J,,  %

!.?

>*,,,,:+.

Notary Public My commission expires: J;/* 4 20 10

U. S. Nuclear Regulatory Commission NL-07-0950 Page 2

Enclosures:

1. GL 2007-01 Response - Farley Nuclear Plant
2. GL 2007-01 Response - Hatch Nuclear Plant
3. GL 2007-01 Response - Vogtle Electric Generating Plant cc: Southern Nuclear Operating Companv Mr. J. T. Gasser, Executive Vice President Mr. J. R. Johnson, Vice President - Farley Mr. D. R. Madison, Vice President - Hatch Mr. T. E. Tynan, Vice President - Vogtle Mr. D. H. Jones, Vice President - Engineering RType: CFA04.054; CHA02.004; CVC7000; LC# 14575 U. S. Nuclear R e d a t o w Commission Dr. W. D. Travers, Regional Administrator Ms. K. R. Cotton, NRR Project Manager - Farley Mr. R. E. Martin, NRR Project Manager - Hatch Mr. B. K. Singal, NRR Project Manager - Vogtle Mr. E. L. Crowe, Senior Resident Inspector - Farley Mr. J. A. Hickey, Senior Resident Inspector - Hatch Mr. G. J. McCoy, Senior Resident Inspector - Vogtle Alabama Dmartment of Public Health Dr. D. E. Williamson, State Health Officer State of Georgia Mr. N. Holcomb, Commissioner - Department of Natural Resources

Enclosure 1 GL 2007-01 Response - Farley Nuclear Plant

Enclosure 1 GL 2007-0 1 Response - Farley Nuclear Plant GL 2007-01: Inaccessible or Underground Power Cable Failures that Disable Accident Mitigation Systems or Cause Plant Transients GL 2007-01 information reauested:

Within 90 days of the date of this GL, provide the following:

1. Provide a history of inaccessible or underground power cable failures for all cables that are within the scope of 10 CFR 50.65 (the Maintenance Rule) and for all voltage levels. Indicate the type, manufacturer, date of failure, type of service, voltage class, years of service, and the root causes for the failure.
2. Describe inspection, testing and monitoring programs to detect the degradation of inaccessible or underground power cables that support EDGs, offsite power, ESW, service water, component cooling water and other systems that are within the scope of 10 CFR 50.65 (the Maintenance Rule).

SNC Response:

The scope of this response is based on NRC letter dated April 13,2007 (Agencywide Documents and Access Management System, Accession No. ML070940311) in response to a Nuclear Energy Institute letter dated March 26, 2007 regarding interpretation of GL 2007-01.

Information Request Item 1:

During the investigation of cable failures at Farley Nuclear Plant (FNP), Engineering Support personnel:

Reviewed the functional failure database Searched Condition Reports Performed a SNC records database broadness review for "cable failures" Searched the legacy work order database for work orders related to Maintenance Rule components Reviewed Licensee Event Reports for cable failure issues The result of this investigation yielded one "in-scope" cable failure, identified in the following table:

Page 2 of 2 GL 2007-0 1 Response - Farley Nuclear Plant FNP Cable Failure within the Scope of Generic Letter 2007-01 I Type I Single conductor, 750 MCM, shielded, EPR insulation I

I I Manufacturer Okonite Date of

~

July 1998 Failure Type of Phase C power cable to 1B Circulating Water Pump Motor, Service normally energized, cable ID: 1VXDB04-R Cable Rating: 5000V Senice: 4 160V years Approximately 22 years Service Cable shorted to ground. Apparent cause was damage during installation that allowed the cable insulation to break down

~ o o Cause t with time (cable appeared to have been cut/scuffed/scraped at installation).

Reference:

Work Order 98004738 (microfilm 17504-1039)

Information Reuuest Item 2:

FNP does not have a cable testinglmonitoring program to detect the degradation of inaccessible or underground power cables. Cable failures are entered into the corrective action program, which provides a mechanism for trending events and causes. The SNC is monitoring industry activities regarding cable testing. Currently there is no definitive golno-go test that will identify impending cable failures (reference: NEI 06-05, Medium Voltage Underground Cable White Paper).

Enclosure 2 GL 2007-01 Response - Hatch Nuclear Plant

Enclosure 2 GL 2007-01 Response - Hatch Nuclear Plant GL 2007-01: Inaccessible or Underground Power Cable Failures that Disable Accident Mitigation Systems or Cause Plant Transients GL 2007-01 information requested:

Within 90 days of the date of this GL, provide the following:

1. Provide a history of inaccessible or underground power cable failures for all cables that are within the scope of 10 CFR 50.65 (the Maintenance Rule) and for all voltage levels. Indicate the type, manufacturer, date of failure, type of service, voltage class, years of service, and the root causes for the failure.
2. Describe inspection, testing and monitoring programs to detect the degradation of inaccessible or underground power cables that support EDGs, offsite power, ESW, service water, component cooling water and other systems that are within the scope of 10 CFR 50.65 (the Maintenance Rule).

SNC Response:

The scope of this response is based on NRC letter dated April 13,2007 (Agencywide Documents and Access Management System, Accession No. ML070940311) in response to a Nuclear Energy Institute letter dated March 26, 2007 regarding interpretation of GL 2007-0 1.

Information Reauest Item 1:

During the investigation of cable failures at Hatch Nuclear Plant (HNP), Engineering Support personnel:

Reviewed the functional failure database Searched Condition Reports Performed a SNC records database broadness review for "cable failures" Searched the legacy work order database for work orders related to Maintenance Rule components Reviewed Licensee Event Reports for cable failure issues The investigation results did not indicate any "in-scope" cable failures.

Information Request Item 2:

HNP does not have a cable testinglmonitoring program to detect the degradation of inaccessible or underground power cables. Cable failures are entered into the corrective action program, which provides a mechanism for trending or events and causes. SNC is monitoring industry activities regarding cable testing. Currently there is no definitive gotno-go test that will identify impending cable failures (reference:

NEI 06-05, Medium Voltage Underground Cable White Paper).

Enclosure 3 GL 2007-0 1 Response - Vogtle Electric Generating Plant

Enclosure 3 GL 2007-01 Response - Vogtle Electric Generating Plant GL 2007-01 : Inaccessible or Underground Power Cable Failures that Disable Accident Mitigation Systems or Cause Plant Transients GL 2007-01 information requested:

Within 90 days of the date of this GL, provide the following:

1. Provide a history of inaccessible or underground power cable failures for all cables that are within the scope of 10 CFR 50.65 (the Maintenance Rule) and for all voltage levels. Indicate the type, manufacturer, date of failure, type of service, voltage class, years of service, and the root causes for the failure.
2. Describe inspection, testing and monitoring programs to detect the degradation of inaccessible or underground power cables that support EDGs, offsite power, ESW, service water, component cooling water and other systems that are within the scope of 10 CFR 50.65 (the Maintenance Rule).

SNC Response:

The scope of this response is based on NRC letter dated April 13,2007 (Agencywide Documents and Access Management System, Accession No. ML070940311) in response to a Nuclear Energy Institute letter dated March 26, 2007 regarding interpretation of GL 2007-01.

Information Request Item 1:

To investigate cable failures at Vogtle Electric Generating Plant (VEGP),

Engineering Support personnel:

Reviewed the functional failure database Searched Condition Reports Performed a SNC records database broadness review for "cable failures" Searched the legacy work order database for work orders related to Maintenance Rule components Reviewed Licensee Event Reports for cable failure issues The result of this investigation yielded one "in-scope" cable failure, identified in the following table:

Page 2 of 2 GL 2007-01 Response - Vogtle Electric Generating Plant VNP Cable within the Scope of Generic Letter 2007-01 Single conductor, 350 MCM, unshielded, EPR insulation Manufacturer Okonite Date of October 2002 Failure*

Phase C power cable to 2A NSCW Tower fan # Motor, Type of Service normally energized, cable ID 2AB1508HB Cable Rating: 2000V Voltage Class Service: 480V Years of Approximately 14 years Service

  • Cable did not fail but had unsatisfactory meggar reading.

Cable and motor exhibited declining insulation resistance, the motor issue was attributed to the cable. An Root Cause approximately 125 foot section of cable was replaced. The cable was discovered to be submerged in water.

References:

Condition Report 2002002765 Work Order 20 103189 Information Reauest Item 2:

VEGP does not have a cable testinglmonitoring program to detect the degradation of inaccessible or underground power cables. Cable failures are entered into the corrective action program, which provides a mechanism for trending or events and causes. The SNC is monitoring industry activities regarding cable testing. Currently there is no definitive golno-go test that will identify impending cable failures (reference: NEI 06-05, Medium Voltage Underground Cable White Paper).