ONS-2014-061, Licensing Basis for the Protected Service Water (Psw) System - Response to Requests for Additional Information Regarding Psw Cabling Aging Management Program and Fant Line Supply to Psw Degraded Voltage Protection; License Amendment Req

Licensing Basis for the Protected Service Water (Psw) System - Response to Requests for Additional Information Regarding Psw Cabling Aging Management Program and Fant Line Supply to Psw Degraded Voltage Protection; License Amendment Request

ML14210A356
Person / Time
Site:	Oconee
Issue date:	07/24/2014
From:	Batson S Duke Energy Carolinas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
ONS-2014-061
Download: ML14210A356 (8)

Text

SCOTT L. BATSON Vice President DEN ERGY Oconee Nuclear Station Duke Energy ONOIVP/ 7800 Rochester Hwy Seneca, SC 29672 864-873-3274 864-8734208 fax ONS-2014-061 Scott.Batson@duke-energy.corn July 24, 2014 10 CFR 50.90 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852-2746 Duke Energy Carolinas, LLC Oconee Nuclear Station (ONS), Units 1, 2, and 3 Docket Numbers 50-269, 50-270, and 50-287, Renewed Operating Licenses DPR-38, DPR-47, and DPR-55

Subject:

Licensing Basis for the Protected Service Water (PSW) System - Response to Requests for Additional Information Regarding PSW Cabling Aging Management Program and FANT Line Supply to PSW Degraded Voltage Protection; License Amendment Request (LAR) 2008 Supplement 11

Reference:

1. Letter from T. Preston Gillespie, Jr., Vice President, Oconee Nuclear Station, Duke Energy Carolinas, LLC, to the U. S. Nuclear Regulatory Commission, "Licensing Basis for the Protected Service Water System - Responses to Request for Additional Information"; License Amendment Request (LAR) 2008-07 dated July 11, 2012.

2. NRC RAI email from Randy Hall (NRC) to Timothy D. Brown (Duke Energy) dated June 24, 2014.

On June 24, 2014 (Reference 2), additional follow-up questions were received from the NRC pertaining to the cabling aging management program (AMP) for all Protected Service Water (PSW)

System cables in duct banks, trenches, and manholes. Conference calls were held on June 26, 2014 and July 10, 2014 to gain understanding and clarification regarding the additional information requests. The RAI has been numbered sequentially, based on the last RAI that was previously submitted.

The NRC has had concerns with aging management of the PSW System cables located in duct banks, trenches, and manholes. To address this, the NRC suggested a license condition to include the PSW cables in an enhanced monitoring regimen per NUREG 1801, "Generic Aging Lessons Learned (GALL) Report", revision 2 and Regulatory Guide 1.218, "Condition Monitoring Techniques for Electric Cables Used in Nuclear Power Plants", April 2012. The response to this RAI is provided in the Enclosure. In addition, in lieu of a license condition, the UFSAR section 18.3.14 is

U. S. Nuclear Regulatory Commission July 24, 2014 Page 2 being revised to include specific inspections for the underground portions of the PSW 13.8 kV AC cables. The UFSAR revision is provided in Attachment 1.

If you have any questions in regard to this letter, please contact Timothy D. Brown, PSW Licensing Manager at (864) 873-3952.

I declare under penalty of perjury that the foregoing is true and correct. Executed on July 24, 2014.

Sincerely, Scott L. Batson Vice President Oconee Nuclear Station Enclosure Attachment 1: UFSAR Section 18.3.14.

U. S. Nuclear Regulatory Commission July 24, 2014 Page 3 cc: (w/enclosure/attachment)

Mr. James R. Hall, Project Manager (by electronic mail only)

U. S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation 11555 Rockville Pike Rockville, MD 20852 Mr. Victor M. McCree, Administrator, Region II U.S. Nuclear Regulatory Commission Marquis One Tower 245 Peachtree Center Ave., NE, Suite 1200 Atlanta, GA 30303-1257 Mr. Eddy Crowe NRC Senior Resident Inspector Oconee Nuclear Station Ms. Susan E. Jenkins, Manager Radioactive & Infectious Waste Management SC Dept. of Health and Environmental Control 2600 Bull St.

Columbia, SC 29201

ENCLOSURE Request for Additional Information Protected Service Water Cabling Aging Management Program

ENCLOSURE: Request for Additional Information, PSW Cabling AMP July 24, 2014 Page 1 ENCLOSURE Requests for Additional Information Protected Service Water Cabling Aging Management Program On June 24, 2014 (Reference 2), additional follow-up questions were received from the NRC pertaining to the cabling aging management program (AMP) for all Protected Service Water (PSW) System cables in duct banks, trenches, and manholes. Conference calls were held on June 26, 2014 and July 10, 2014 to gain understanding and clarification regarding the requests for additional information (RAI).

RAI 195 The NRC suggested an additional license condition to address their aging management concerns regarding the PSW System cables located in duct banks, trenches, and manholes.

The suggested license condition is as follows:

The licensee should consider implementing an aging management program in accordance with GALL AMP Xl. E3, Revision 2 and Regulatory Guide 1.218, "Condition Monitoring Techniques for Electric Cables Used in Nuclear Power Plants" for all PSW system cables in duct banks, trenches, and manholes, prior to declaring the PSW system operable."

Duke Energy Response:

The NRC suggested a proposed license condition to include the PSW cables in an enhanced monitoring program per NUREG 1801, "Generic Aging Lessons Learned (GALL) Report",

Revision 2 and Regulatory Guide 1.218, "Condition Monitoring Techniques for Electric Cables Used in Nuclear Power Plants", April 2012. Oconee Nuclear Station (ONS) has implemented a Cabling Aging Management Program (AMP) per License Renewal Commitments as defined in NUREG 1723, "License Renewal Safety Evaluation Report", dated March, 2000. The ONS License Renewal SE was issued prior to the GALL report; therefore, ONS has no commitments pertaining to GALL, Revision 2. However, in an effort to prepare for the License Renewal Inspection, ONS performed a gap analysis against GALL, Revision 2, specifically Section XI.E3.

The gap analysis was documented in the ONS corrective action program and appropriate actions were taken to address each concern where a gap was identified.

For PSW specifically, Duke Energy is proposing to revise the Cabling AMP in the Updated Final Safety Analysis Report (UFSAR) to address the NRCs aging management concerns. The accessible PSW 13.8 kV cable will be added to the lists of insulated cables and connections that are inspected every ten years. The PSW drainage system of the trenches and manholes that contain the PSW 13.8 KV cables shall be inspected annually to detect and manage exposure of these cables to significant moisture. The inaccessible 13.8 kV cables from the Keowee Hydroelectric Station to the PSW Building and from the PSW substation to the PSW Building (FANT line) shall be electrically tested prior to declaring the entire PSW system operable and every 6 years thereafter using techniques provided in RG 1.218.

ENCLOSURE: Request for Additional Information, PSW Cabling AMP July 24, 2014 Page 2 Revising UFSAR section 18.3.14 to include these cables provides a similar level of commitment as adding a new License Condition to the Facility Operating License. Incorporating the 13.8 KV AC PSW cables aging management inspections and testing into the Cabling AMP allows Duke Energy to manage these commitments as they do all other License Renewal commitments.

The revised page of UFSAR section 18.3.14 is provided in Attachment 1.

1 ATTACHMENT page 18.3.14 revised UFSAR Section

Oconee Nuclear Station UFSAR Chapter 18 Industry Codes and Standards - EPRI TR-109619, Guideline for the Management of Adverse Localized Equipment Environments will be used as guidance in implementing this program.

Frequency - Accessible insulated cables and connections including Protected Service Water (PSW) 13.8 kV cables installed in adverse, localized environments will be inspected at least once every 10 years. Water collection in manholes containing in-scope, medium-voltage cables will be monitored at a frequency adequate to prevent the cables from being exposed to significant moisture. The PSW drainage system of the trenches and manholes containing the PSW 13.8 kV cables shall be inspected annually to detect exposure of these cables to significant moisture. The periodic inspections shall include video imaging of the drainage systems of the trench and manholes. If significant moisture is detected, actions shall be taken to correct this condition.

Inaccessible or direct-buried, medium-voltage cables exposed to significant moisture and significant voltage will be tested at least once every 10 years. The PSW system inaccessible 13.8 kV insulated power cables from the Keowee Hydroelectric station to the PSW building and from the PSW substation to the PSW building (Fant Line) shall be periodically electrically tested. The initial PSW 13.8 kV cable testing shall be performed prior to declaring the entire PSW system operable and thereafter at a 6 year frequency. The electrical tests shall follow the cable condition monitoring methods and testing techniques provided in Regulatory Guide 1.218 (April 2012).

Acceptance Criteria or Standard - The acceptance criteria is different for accessible insulated cables and connections and for inaccessible or direct-buried medium-voltage cables.

For accessible insulated cables and connections installed in adverse, localized environments, the acceptance criteria is no unacceptable, visual indications of jacket surface anomalies, which suggest that conductor insulation applicable aging effect may exist, as determined by engineering evaluation. An unacceptable indication is defined as a noted condition or situation that, if left unmanaged, could lead to a loss of the license renewal intended function. In-scope, medium-voltage cables in manholes found to be exposed to significant moisture will be tested as described for inaccessible cables under Method, Frequency and Acceptance Criteria of this program.

For inaccessible or direct-buried, medium-voltage cables exposed to significant moisture and significant voltage, the acceptance criteria for the test will be defined by the specific type of test to be performed and the specific cable to be tested.

Corrective Action - Further investigation by engineering will be performed on accessible and inaccessible insulated cables and connections when the acceptance criteria is not met in order to ensure that the license renewal intended functions will be maintained consistent with the current licensing basis. Corrective actions may include, but are not limited to, testing, shielding or otherwise changing the environment, relocating or replacement. Specific corrective actions will be implemented in accordance with the Problem Investigation Process. The Problem Investigation Process applies to all structures and components within the scope of the Insulated Cables and Connections Aging Management Program. When an unacceptable condition or situation is identified, a determination will be made as to whether this same condition or situation could be applicable to other accessible or inaccessible cables and connections.

Timing of New Program or Activity - Following issuance of a renewed operating licenses for Oconee Nuclear Station, the initial inspections and tests will be completed by February 6, 2013 (the end of the initial license term for Oconee Unit 1).

Regulatory Basis - Duke response to SER Open Item 3.9.3 [Reference 24] and Final SER [Reference 2].

(Date) 18.3 - 13