PLA-6362, License Renewal Application, Station Blackout Scope Addition PLA-6362

License Renewal Application, Station Blackout Scope Addition PLA-6362

ML081420028
Person / Time
Site:	Susquehanna
Issue date:	05/07/2008
From:	Mckinney B Susquehanna
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
PLA-6362
Download: ML081420028 (23)

Text

Britt T. McKinney PPL Susquehanna, LLC Sr. Vice President & Chief Nuclear Officer 769 Salem Boulevard 13 0 Berwick, PA 18603 Tel. 570.542.3149 Fax 570.542.1504 MAY 70, % btmckinney@pplweb.com QD3 U. S. Nuclear Regulatory Commission Document Control Desk Mail Stop OP 1-17 Washington, DC 20555 SUSQUEHANNA STEAM ELECTRIC STATION UNITS 1 AND 2 LICENSE RENEWAL APPLICATION (LRA)

STATION BLACKOUT SCOPE ADDITION Docket Nos. 50-387 PLA-6362 and 50-388 References.: 1) PLA-6110, Mr. B. T. McKinney (PPL)to Document Control Desk (USNRC),

"Applicationfor Renewed OperatingLicense Numbers NPF-14 and NPF-22, dated September 13, 2006.

2) Letterfrom Ms. E. H. Gettys, (USNRC) to Mr. B. T McKinney (PPL), "Requestfor Additional Informationfor the Review of the SusquehannaSteam Electric Station, Units ] and 2 License Renewal Application, "dated July 30, 2007.

3) PLA-6261, Mr. B. T. McKinney (PPL)to Document Control Desk (USNRC),

"Requestfor Additional Information (RAI)for the Review of the SusquehannaSteam Electric Station Units I and 2, License Renewal Application (LRA) Section 2.5,"

dated August 23, 2007.

4) Memorandumfrom Ms. E. H. Gettys (USNRC) "Summary of Telephone Conference Call Held on October 3, 2007, Between the U.S. Nuclear Regulatory Commission and PPL Susquehanna,LLC, ConcerningRequest for Additional Information Pertainingto the Susquehanna Steam Electric Station, Units 1 and 2, License Renewal Application,"

dated November 16, 2007.

5) Letterfrom Mr. J. E. Dyer, (USNRC) to Mr. A. R. Pietrangelo(NEI),

dated April 1, 2008.

In accordance with the requirements of 10 CFR 50, 51, and 54, PPL' Susquehanna, LLC (PPL) requested the renewal of the operating licenses for the Susquehanna Steam Electric Station (SSES) Units 1 and 2 in Reference 1. The purpose of this letter is to amend the SSES License Renewal Application (LRA) to include additional systems, structures, and components (SSCs) within the scope of license renewal related to Station Blackout (SBO) recovery.

During the Nuclear Regulatory Commission (NRC) review of the SSES License Renewal Application, NRC staff determined that PPL did not identify all SSCs required to be included within the scope of license renewal in accordance with the requirements of 10 CFR 54.4(a)(3) for SBO. This issue was identified in Reference 2 as a Request for k2:(:?)

Document Control Desk PLA-6362 Additional Information (RAI) 2.5-1. PPL responded to this RAI in Reference 3, and a teleconference, documented in Reference 4, was held to discuss the PPL response.

This issue has also been addressed by the nuclear infdustry, and Reference 5 is the Nuclear Regulatory Commission (NRC) response to concerns raised by the Nuclear Energy Institute (NEI) regarding draft interim staff guidance (ISG) document LR-ISG-2008-01.

The draft ISG provides the NRC staff s rationale for including within the scope of license renewal additional SSCs in the SBO recovery path. Reference 5 also provides clarification by the NRC staff that, "The SBO recovery path scoping boundary ends at the line side of the switchyard breaker(s) at transmission system voltage." Based on the above NRC staff position, PPL has revised the LRA as shown in the Attachment to establish the scoping boundary at the line side of the switchyard breaker(s).

Although the additional SSCs are not part of the SSES Current Licensing Basis (CLB) for compliance with 10 CFR 50.63, "Loss of All Alternating Current Power," they are conservatively included within the scope of license renewal under 10 CFR 54.4(a)(3),

consistent with the NRC staff position.

There are no new regulatory commitments or changes to any existing regulatory commitments contained herein as a result of the additional LRA scope identified in the attachment.

If you have any questions, please contact Mr. Duane L Filchner at (610) 774-7819.

I declare, under penalty of perjury, that the foregoing is true and correct.

Executed on:

B. T. McKinney

Attachment:

SBO Scope Addition - Revised LRA Sections 2.2, 2.4, 2.5, 3.5, 3.6 Copies to: NRC Region I Ms. E. H. Gettys, NRC Project Manager, License Renewal, Safety Mr. R. Janati, DEP/BRP Mr. F. W. Jaxheimer, NRC Sr. Resident Inspector Mr. A. L. Stuyvenberg, NRC Project Manager, License Renewal, Environmental Mr. B. L. Vaidya, NRC Project Manager

Attachment to PLA-6362 SBO Scope Addition Revised LRA Sections 2.2, 2.4, 2.5, 3.5, 3.6

Attachment to PLA-6362 Page 1 of 20 2.2 PLANT-LEVEL SCOPINGRESULTS Table 2.2-2, License Renewal Scoping Results for Structures The following portion of Table 2.2-2 (on LRA page 2.2-7) is revised by addition (bold italics) and deletion (strikethrough).

Table 2.2-2 (continued)

System Name In Scope? Screening Results Section Safety Parameter Display Yes 2.5 Security No Seismic Monitors No Shaft Voltage Detection No Switchyard NoYes 25 Thrust Wear Detection No Transient Monitoring No Turbine and Supervisory Instrumentation No

Attachment to PLA-6362 Page 2 of 20 Table 2.2-3, License Renewal Scoping Results for Structures The following portion of Table 2.2-3 (on LRA page 2.2-19) is revised by addition (bold italics) and deletion (strikethrough).

Table 2.2-3 Structure Name In Scope? Comments / Screening Results Section Station Blackout (SBO)

Component Foundations and Structures in the Yard (startup transformers T-10 and T-20 Yes 2.4.9.5 and associated disconnect switches, and ESS transformers, and Transmission Towers)

Attachment to PLA-6362 Page 3 of 20 Table 2.2-3, License Renewal Scoping Results for Structures The following portion of Table 2.2-3 (on LRA page 2.2-22) is revised by addition (bold italics) and deletion (strikethrough).

Table 2.2-3 Structure Name In Scope? Comments / Screening Results Section T-1 0230k V Switchyard Station Blackout (SBO)

Component Foundationsand Yes 2.4.9.8 Structures [located outside the securityfence]

23 Ok V Switchyard Station Blackout (SBO) Component Foundationsand Structures Yes 2.4.9.9

[located outside the security fence]

2.4.9.10 Located outside security fence.

Provides area and failities for- switchyard.

Fence arfea with single story commerceial Sationgrade 500 kVSwitcyard moedular- steel st~uctur-es and tower-s 500 kV Switchyard Station on...ncrete foundations.

Blackout (SBO) Component _____________L__________________

Foundationsand Structures No-Yes Stru.ture provides support and anchorage

[located outside the security for nonsafety related equipment a fence] (Switching Station) equipment not requir-ed to support r-egulated events. None of the mjrompoents inl thi stuctrepr~esenita seismic. 1W' situation.

The structure does not per-fei~an intended-ffincrtien delineated in 10 CF-R 54.4(a).

Attachment to PLA-6362 Page 4 of 20 2.4 SCOPING AND SCREENING RESULTS: STRUCTURAL 2.4.9 Yard Structures The following text under Section 2.4.9.5 (on LRA page 2.4-31) is revised by addition (bold italics) and deletion (strikethrough).

2.4.9.5 Station Blackout (SBO) Component Foundations and Structures in the Yard (Startup Transformers T-10 and T-20 and Associated Disconnect Switches, and-ESS Transformers, and Transmission Towers)

Structure Description The station blackout component foundations and structures in the yard (startup transformers T- 10 and T-20 and associated disconnect switches, and-Engineered Safeguards Systems (ESS) transformers, and transmissiontowers) are not seismic Category I structures. Startup transformers T-10 and T-20,-and associated disconnect switches (motor-operated air switches 1R105 and 2R105) and transmissiontowers define the physical bcndAy,th.at provides an offsite alternating current (AC) source for recovery from a station blackout (SBO) regulated event.

The startup transformers and associated disconnect switches, as well as the ESS Transformers, are supported by reinforced concrete pads. The disconnectswitches are supportedby steel frame structuresand the transmission conductors are supported by tapered steel transmission towers and relatedfoundations. Disc.nnect . witches ar.e su.pported by steel frame strctures, elect-rical cables are supported by tapered steel transmisscn towe r-s.

Reason for Scope Determination The station blackout component foundations and structures in the yard (startup transformers T- 10 and T-20 and associated disconnect switches, and ESS transformers) provide physical support for equipment relied upon to demonstrate compliance with the Station Blackout (10 CFR 50.63) regulated event. This meets the 10 CFR 54.4(a)(3) scoping criteria.

The transmissiontowers providephysical supportfor components included in scope based on guidance related to SBO scoping containedin NUREG-1800, Revision 1.

In addition, the station blackout component foundations and structures in the yard (startup transformers T-10 and T-20 and associated disconnect switches, and-ESS transformers, and transmission towers) are in the scope of license renewal because they contain:

• Structural components that are relied on during station blackout events.

• Structuralcomponents associatedwith SBO offsite power recovery per the guidance in NUREG-1800, Revision 1.

Attachment to PLA-6362 Page 5 of 20 2.4.9 Yard Structures

> The following new sections are added after Section 2.4.9.7 (on LRA page 2.4-33) and are revised by addition (bold italics).

2.4.9.8 T-10 230kVSwitchyard Station Blackout (SBO) Component Foundationsand Structures (located outside securityfence)

Structure Description Dead end structure and breakers (2S and 2T) support supplyingpowerfrom the T-10 230k V switchyard to the 13.8k V bus 10 providingoffsite AC sourcesfor recoveryfrom an SBO.

The dead end structure and breakers (2S and 2T) are supported by reinforcedconcrete foundations.

Reason for Scope Determination The dead end structure and breakersprovidephysical supportfor components included in scope based on guidance related to SBO scoping containedin NUREG-1800, Revision 1.

In addition, the T-10 230kVSwitchyard dead end structure and breakersare in the scope of license renewal because they contain:

• Structuralcomponents associatedwith SBO offsite power recoveryper the guidance in NUREG-1800, Revision 1.

2.4.9.9 230k VSwitchyard Station Blackout (SBO) Component Foundationsand Structures (located outside securityfence)

Structure Description Dead end structure and breakers (2T and 2W) support supplyingpower from the 230kV switchyard to the 13.8k V bus 20 providing offsite A C sourcesfor recoveryfrom an SBO.

The dead end structure and breakers (2T and 2 W) are supported by reinforcedconcrete foundations.

Reason for Scope Determination The dead end structure and breakersprovide physical supportfor components included in scope based on guidance related to SBO scoping containedin NUREG-1800, Revision 1.

In addition, the 230kVSwitchyard dead end structure and breakers are in the scope of license renewal because they contain:

• Structuralcomponents associatedwith SBO offsite power recoveryper the guidancein NUREG-1800, Revision 1.

Attachment to PLA-6362 Page 6 of 20 2.4.9.10 500kVSwitchyard Station Blackout (SBO) Component Foundationsand Structures (located outside "securityfence)

Structure Description 230kVdead end structure, 230k V capacitivecoupled voltage transformer (CCVT) and line trap, 230kV switch, 230kV currenttransformer,and 230kV breaker supportsupplying power from the 500kVswitchyard to the 13.8kV bus 20 providing offsite AC sourcesfor recovery from an SBO.

The 230kV dead end structure,230kV CCVT and line trap, 230kV switch, 230kV current transformer,and 230kV breaker are supported by reinforcedconcretefoundations and/orsteel piles.

Reason for Scope Determination The 230kVdead end structure,230kV CCVT and line trap, 230kV switch, 230kV current transformer,and 230kV breakerprovidephysical supportfor components included in scope based on guidance related to SBO scoping containedin NUREG-1800, Revision 1.

In addition, the 500kVSwitchyard 230k V dead end structure, 230k V CCVT and line trap, 230kVswitch, 230k V currenttransformer,and 230k V breaker are in the scope of license renewal because they contain:

• Structuralcomponents associatedwith SBO offsite power recoveryper the guidance in NUREG-1800, Revision 1.

Attachment to PLA-6362 Page 7 of 20 2.4.9 Yard Structures Table 2.4-9, Yard Structures, Components Subject to Aging Management Review Table 2.4-9 (on LRA page 2.4-35) is revised by addition (bold italics) and deletion (strikethrough).

Component Type Intended Function (as defined in Table 2.0-1)

Cooling Tower Basin outlet screen guides SRE Cooling Tower Basin outlet screens SRE Disconnect Switch / CCVT and Line Trap /Switch / Current EN,,SN&, SRE Transformer/BreakerSupport Structures (SBO)Disee'zeet sv'iteh support towers*

Manhole covers EN, MB, SNS, SRE Piles (5OOkVSwitchyard) (SBO) SRE Transmission Towers and Dead End Structures ENSNS, SRE (SBO)T..ansmis.ion to .er.s Valve vault and instrument pit hatches EN, MB, SNS, SRE, SSR Condensate Storage Tank (CST) retention basins FLB, SNS Cooling Tower Basins SRE Cooling Tower Basin outlet structures EN, SRE Diesel Generator (DG) Fuel Oil Tank foundations SRE, SSR Diesel Generator (DG) Fuel Oil Tank vaults EN, MB, SRE, SSR Duct banks EN, MB, SRE, SSR Manholes EN, MB, SRE, SSR Outdoor tank foundations: Condensate Storage Tank (CST), EN, SNS, SRE Clarified Water Storage Tank (CWST), Refueling Water Storage Tank (RWST)

Piping trenches EN, MB, SNS, SRE, SSR Transformer/Disconnect Switch / CCVT and Line Trap / iN, , SRE Switch / Current Transformer/Breaker Foundations (SBO)Tr-ansformer/Disconnect switch foundations (SBO and Valve vaults and instrument pits EN, FLB, MB, SNS, SRE, SSR

Attachment to PLA-6362 Page 8 of 20 2.5 SCOPING AND SCREENING RESULTS: ELECTRICAL 2.5.5 Electrical/I&C Component Commodity Groups Requiring an Aging Management Review The following text under Section 2.5.5 (on LRA pages 2.5-6 and 2.5-7) is revised by addition (bold italics) and deletion (strikethrough).

2.5.5.3 High-Voltage Insulators A high-voltage insulator is a component uniquely designed to physically support a high-voltage conductor and to separate the conductor electrically from another conductor or object. The high-voltage insulators evaluated for license renewal at SSES include those used to support and insulate high-voltage electrical components (i.e., transmission conductors and connections, in particular those associated with the offsitepower supply tar Up Tr.ansformers T.-0 and T20).

There are two basic types of insulators: station post insulators and strain (or suspension) insulators. Station post insulators are large and rigid. They are used to support stationary equipment such as short lengths of transmission conductors and disconnect switches. Strain insulators are used in applications where movement of the supported conductor is expected and allowed. This includes maintaining tensional support of transmission conductors between transmission towers or other supporting structures.

At SSES, the high-voltage insulators within the license renewal scope are the station post insulators and strain insulatorsassociated with the offsite power supply.Start Up Transfermer-s TIO0 anad T-20 (to suppert the short lengths of tr-ansmission conducter-s connecting the startiup tF-Ans-feRinme-fs-to th-e moetor operated air brfeak. switches, and to support the motor operated air break switches iR105 and 2R105). High voltage insuilators in the switchyards are not in the liene~se- renewal scope.

The function of high-voltage insulators is to insulate and support an electrical conductor. High voltage insulators are passive, long-lived components. Therefore, high voltage insulators meet the criteria of 10 CFR 54.21(a)(1)(ii) and are subject to an aging management review.

2.5.5.4 Transmission Conductors and Connections Transmission conductors are category aluminum conductor steel reinforced (ACSR), stranded aluminum conductors wrapped around a steel core and are constructed of aluminum and steel.

They are uninsulated, high-voltage conductors used to carry loads in plant switchyards and in distribution applications. The transmission conductor connections are cast aluminum.

The sections of transmission-type conductors at SSES within the scope of license renewal are associated with the offsite power supply. ieeated-at The in-scope transmissionconductors are used to connect Start-Up Transformers T10 and T20; they connect the transformers with motor-operated air break switches 1RI05 and 2R105, to interconnect the motor-operatedair break switches with the switchyards (TIO Tap and 230-500kV Yard Tie), and to interconnect in scope equipment in the switchyards. The sections of*transmission codco are approaximately 22 fe and 12 feet long, r-espectively. These seetions-ef-transmission conductors are included to meet

Attachment to PLA-6362 Page 9 of 20 the guidance of Revision 1 of NUREG- 1800 with respect to off-site power restoration after a station blackout (SBO) event.

The function of transmission conductors is to provide electrical connection to specified portions of an electrical circuit to deliver voltage and current. Transmission conductors are passive, long-lived components. Therefore, transmission conductors and connections meet the criteria of 10 CFR 54.21(a)(1)(ii) and are subject to an aging management review.

Attachment to PLA-6362 Page 10 of 20 2.5.6 Evaluation Boundaries

> The following text under Section 2.5.6 (on LRA pages 2.5-7 through 2.5-9) is revised by addition (bold italics) and deletion (strikethrough).

2.5.6.2 Station Blackout Evaluation Boundaries 10 CFR 54.4(a)(3) requires that plant systems, structures, and components (SSCs) relied on for compliance with the 10 CFR 50.63 regulations on Station Blackout (SBO), be included in the scope of license renewal. The NRC issued additional guidance on the scoping of equipment relied on to meet the requirements of the Station Blackout rule in the form of an Interim Staff Guidance document (ISG-02). Subsequently, this guidance was incorporated into NUREG-1800, Revision 1.

Using the requirements of the License Renewal Rule, the guidance provided in NUREG-1800, the insights of ISG-02, and SSES design basis and current licensing basis documentation, the in-scope SSCs for SBO (and the appropriate SBO license renewal scoping boundary) were identified. The following paragraphs describe the SBO license renewal boundary definition for SSES.

Two independent offsite power sources are supplied to SSES via Start-Up Transformers T10 and T20 and are shared by both units. The source connected through transformer TlO is supplied from the T1O 230 kV switchyard located to the west of the plant. The offsite source connected through transformer T20 is supplied at 230 kV from the yard tie circuit between the Susquehanna 500 kV and 230 kV switchyards. The tie line runs from the 230 kV switchyard (located across the Susquehanna River from the plant) to the 500 kV switchyard (located south of the plant).

The 500 kV switchyard contains a 500/230 kV transformer (for the tie line). None of these switchyards are within the SSES site boundary (i.e., the owner controlled area). The switchyards are not under the control (operational or administrative) of SSES. See Figure 2.5-1 for further detail, and a simplified graphical representation of the SSES SBO license renewal boundary.

Per the guidance of NUREG-1800, the plant system portion of the offsite power system used to connect the plant to the offsite power source needs to be included in the scope of license renewal.

For SSES, the power sources supplied to the plant via Start-Up Transformers T10 and T20 provide the SBO recovery path from the offsite power system. To ensure inclusion of all the appropriate SSCs within the scope of license renewal, the boundary between the offsite power system (the grid) and the plant system portion of the offsite power system mustbe identified.

The boundary points for the SBO license renewal boundary were identifiedby beginning at the Start-Up Transformers andfollowing the offsite power supply circuitsaway from the plant until the first circuit breakersat transmissionsystem voltage were encountered. The SBO LR boundary is set at the terminationson the transmissionsystem side of these circuit breakers, such that the circuit breakers are the last component included within the scope of license renewal. In the TJO 230 kVSwitchyard, the SBO LR boundary is at circuitbreakers 2T and 2S. In the SSES 500 kVSwitchyard, the SBO LR boundary is at the 230 kV circuit breaker (designatedas "CB" in Figure2.5-1) on the East side of the switchyard. In the SSES 230 kV Switchyard, the SBO LR boundary is at circuit breakers 2T and 2W. These circuit breakers are shown in Figure 2.5-1.are the motor- operated air-break (MOAB) swit.hes, !RIOS n*,

2R1 05, located just downstream of Tr-ansformer~s T1O (switch iRlOS) and T-20 (switch 2R105).

Attachment to PLA-6362 Page 11 of 20 These switches were selected as the bounadary points because they are the last (and the only)

SBO r-ecover-y r-elated active components in the 230 kMI transmissio system that are under-the conitrol Of the plant controel rooem operator-. All other- SBO r-ecover-y related tr-ansmission system br-eaker-s'ana switches are under-the control ef1 oltsite agencies. T he motor- oper-atea air-br-eak switches are shown in Figure 2.5 1.

EG 1800 states that the boundary of the plant potion of the offsitc power- system i typically established at the circuit breakers in the switchyard. \qthile not at a circuit breaker- in NU~rG 1800 for- the following reasons.

At SSES, no tr-ansmission system switchyar-d equipment is included within the licenlse r-enewal SBO seoping bouindary. The Staff Up Tr-ansformer-s and associated MO0ABs are not located in the tr-ansmaiission system switchyards. A separ-ate tr-ansformer- yard inside the plant securityfec is provided for each of the Staff Up Transfrmers (T-10 and T20). The connection to the tr.ansmission system via the . . .AB in those tr*ansf*mer yards. All of the equipment is made needed to connect to the offsite transmission system (for SBO recovery) and .toprevi--

pr-otecation for-the Start Up Tr-ansformers*is in the scope of license renewal and is located in the transmission system switchyards mentioned above, in the transmission line corridorsbetween the plant and the switchyards, in the plantyard area, these transfMom er-yards, or inside plant buildings. Back feed through the unit main transformers is not credited as an SBO recovery path for SSES, so no transmission switchyard equipment is brought into the license renewal scope for this situation. Protective relays and associatedcables requiredto protect the Start-Up Transformers are within the scope of license renewal at SSES.

The MOPA~s (IRlOS and 2R105) ar~e equivalent to a caircutit breaker- in this application because ot their sen'vice rq irmnts. Under-SBO conditions and durfing offite poerAe r-estor-ation, these MOQA4s are not required to switch flal load currfent. Durfing an SBO, the off-site 230 kV poerv souirces will be de ener-gized, so the MOA43s 4o not need to switch load currfent. \When offsite power- is lost, breakers on the secondary side of the Start Up Tr-ansforerff-fis diconettemfrom their load. The proceedur-ally controlled proceess for r-econnecting the load r-equir-es that h MOP3B be closed prior-to r-econnecting the secondary5 side of the tr-ans~forerfl to its load. In this case, the MIOP3 is switching only transformer- ifwsh current and is oper-ating well vwithin; its the Od under- SBO co-nditionas and to controelwhen connections to the Od are r-e established, in order-to ensure protection of the Start Up Transformer-s and pr-eservmiato of the plant portion o the SBO frsever-y path. The cont-rol circutits for- the MOPA~s are power-ed from the plant 125 VDC system. All components (control relays, power- supplies, and cables) are within the scope of ienA 44se r-en e wal.

The SE desigq does not r~ely on the MO0ABs for-inteffmption of fauflt currfent to proetect the Start Up Tr-ansformFer-s. Any tr-ansformer faults are detected by tr-ansgfomer- mounted inistmmnent or-protective r-elays located in the plant switchgear-rooems. As descr-ibed in the SSES FSA¶,

upon detection of a tr-ansformer- fa-ult, a trip of the approepr-iate tr-ansmission linie r-emo:-te bekr is initiated. Although this dir-ect transfer-trip is the pr-imary proetection scheme, Mtil r-eliance is not placed on this scheme to de energize the line. Backup proetection is provided by a high speed grouind switch located in the tr-ansformer. 'ar-d. ThIis switch closes a few; cycles after- the trasfomerfault is detected to place a positive fault on the 230 kMf tranmsmission line to ensur t-h.at the r-emote breakers trip to de ener-gize the line. The MO0AB automatically opens after-the

Attachment to PLA-6362 Page 12 of 20 230 kMV systemf is de energized to isolate the applicable Stadt Up Transfon~er- fromf th tr-ansmission system. The MO0AB is nct r-elied upon to diseoecfet the faulted Start UP Tr-ansfofmer- and the fault cunfent switching capability that wouild be proevided by a circutit breaker- is not r-equir-ed ini this application. The t-ransfofmer- proetective relays and the controals for the high speed joutnd switch are powered fromf the plant 125 VDC systeim. All of the components r-equir-ed to proetect the Stan Up Tr-ansfcmer-s tprotective r-elays, high speed wrOunfd switch, and assocaiated cables) are 'within the scope of licenise r-enewal at SSES.

Attachment to PLA-6362 Page 13 of 20 2.5.6.2 Station Blackout Evaluation Boundaries The following figure under Section 2.5.6.2 (on LRA page 2.5-10) is replaced. The text associated with Figure 2.5-1 (on LRA page 2.5-10) is revised by addition (bold italics) and deletion (strikethrough).

Figure 2.5-1 Graphical Representation of the SSES I SBO License Renewal Boundary T1O 230 KV SSES 500 KV SSES 230 KV SWITCHYARD SWITCHYARD SWITCHYARD

-21 2S XS XXXAj -- 2W 2T X

-X-Xj L-x-x-x-xJ I x-x-x-xJ LEGEND.

TRANSMISSION MEDIUM-VOLTAGE CABLE __ NON-SEGREGATED CONDUCTOR (PORTIONS UNDERGROUND) METAL ENCLOSED BUS

-X- SBO SCOPING BOUNDARY As is shown at the top of this figure, the SBO LR scoping boundary is at circuitbreakers located in the three switchyards. oee-,..ti.n

,d to the is made in the transformer. yards at switehes R105 and 2R105. All of the 230 kV compcnents in the plant pofian ef the effsite power-system are listed in the plant's equipment database as paft of the 13.8 kN1 elecstrical system.~

Attachment to PLA-6362 Page 14 of 20 3.5 AGING MANAGEMENT OF CONTAINMENTS, STRUCTURES, AND COMPONENT SUPPORTS Table 3.5.2-9, Aging Management Review Results - Yard Structures Table 3.5.2-9 (on LRA pages 3.5-105 through 3.5-109) is revised by addition (bold italics) and deletion (strikethrough).

Table 3.5.2-9 Aging Management Review Results - Yard Structures Intended Aging Effect Aging NUREG-Component/

Material Environment Requiring Management 1801 Volume Table 1 Item Notes Commodity Function' Management Programs 2 Item Cooling Structures E, Tower Basin Epsd to raw Outlet Screen SRE Stainless Steel Expose Loss of material Monitoring VII.H2-18 3.3.1-80 0520 ueSwater Program Guides Cooling d to rawStructures E, Tower Basin SRE Stainless Steel Expose r Loss of material Monitoring VI.112-18 3.3.1-80 Outlet Screens water Program 0520 Disconnect Exposed to Structures V

Switch Carbon Steel weather Loss of material Monitoring II.A3-12 3.5.1-25 A

/CCVT and Program Line Trap!

Switch/

Current Transformer! EN, SNS, SRE Breaker sed toStructures Support Galvanized Steel Exposer weatherPrga Loss of material Monitoring III.B2-7 3.5.1-50 C Structures Program (SBO) suppe4 Tewefs

Attachment to PLA-6362 Page 15 of 20 Table 3.5.2-9 Aging Management Review Results - Yard Structures Intended Aging Effect Aging NUREG-Component/

Function' Material Environment Requiring Management 1801 Volume Table 1 Item Notes Commodity Management Programs 2 Item lExposed to Structures Carbon Steel Loss of material Monitoring III.A3-12 3.5.1-25 A Manhole EN, MB, SNS, Program Covers SRE Structures Galvanized Steel Exposed to Loss of material Monitoring III.B2-7 3.5.1-50 C weather Program Structures Carbon Steel Below Grade Loss of material Monitoring N/A N/A Piles (500kV Program 0501 Switchyard) SRE Structures (SBO) Steel Below Grade Loss of material Monitoring N/A N/A S Program 0501 Structures Transmission Carbon Steel Exposed to Loss of material Monitoring III.A3-12 3.5.1-25 A Towers and weather Program DeadEnd EN,,SNS,, SRE Structures Exposed to Structures (SBO) Galvanized Steel weather Loss of material Monitoring II.B2-7 3.5.1-50 C Program

Attachment to PLA-6362 Page 16 of 20 Table 3.5.2-9 Aging Management Review Results - Yard Structures Component/

Commodity Intended Function 1 Material Environment Aging Effect Requiring Management Aging Management P

Programs NUREG-1801 Volume 2 Item Table 1 Item Notes Protected from Structures weatherPrga Loss of material Monitoring III.A3-12 3.5.1-25 A Program Carbon Steel Exposed to Structures Srcue Valve Vault Valvn V Exposedtor Loss of material Monitoring III.A3-12 3.5.1-25 A and EN, MB, SNS, weather Program Progra Instrument Pit SRE, SSR Hatches Protected from None None HII.B 1.1-7 3.5.1-58 C weather Galvanized Steel Structures Exposed to Loss of material Monitoring III.B2-7 3.5.1-50 C weather Program Condensate Storage Tank Exposed to Structures 1, (CST) FLB, SNS Concrete - weate None Monitoring N/A N/A Retention weather Program 0501 Basins Transformer/

Disconnect Switch/

CCVT and Line Trap! Structures I, SwitcW EN,, 9- SRE Concrete None Monitoring N/A N/A Current weather Program 0501 Transformer/

Breaker Foundations (SBO-a*d E99) I_)

Attachment to PLA-6362 Page 17 of 20 Table 3.5.2-9 Aging Management Review Results - Yard Structures Intended Aging Effect Aging NUREG-Component/

Material Environment Requiring Management 1801 Volume Table 1 Item Notes Commodity Function' Management Programs 2 Item Structures I, Below grade None Monitoring N/A N/A Program 0501 Protected from Structures 1, Valve Vaults weather None Monitoring Program N/A N/A 0501 Concrete Srutres and EN, FLB, MB, Instrument SNS, SRE, SSR Exposed to Structures N, Pits weather None Monitoring N/A N/A Program 0501 Loss of material Structures Exoer Monitoring III.A6-5 3.5.1-35 waterCracking Program 0521 1 Refer to Table 2.0-1 for intended function descriptions.

Attachment to PLA-6362 Page 18 of 20 3.6 AGING MANAGEMENT OF ELECTRICAL AND INSTRUMENTATION AND CONTROLS 3.6.2.2 Further Evaluation of Aging Management as Recommended by NUREG-1801

> The following text under Section 3.6.2.2 (on LRA pages 3.6-6 through 3.6-8) is revised by addition (bold italics) and deletion (strikethrough).

3.6.2.2.2 Degradation of Insulator Quality due to Presence of Any Salt Deposits and Surface Contamination, and Loss of Material due to Mechanical Wear There are no aging effects identified that require aging management for the high-voltage insulators subject to aging management review for SSES. Due to its inland location, salt spray from the ocean is not of concern at SSES. The rural location of SSES provides for minimal contamination from industrial effluents. The buildup of surface contaminants is gradual and is periodically washed away by rainfall. Therefore, contamination is not identified as an aging mechanism. The high voltage insulat.ors within the ,f scope liense renewal for- SSES ac connected to rigid components, such that significant movement is not considered as a stresser, and wear is not identified as an aging mechanism.,

Loss of materialdue to mechanical wear is an aging effect for certain strain insulators if they are subject to significantmovement. Movement of the insulators can be caused by wind blowing the supported transmission conductor, causingit to swing from side to side. If this swinging is frequent enough, it could cause wear on the metallic contact points of the insulatorstring and between an insulatorand the supporting hardware. Although this aging mechanism is possible, industry experience has shown that transmission conductors do not normally swing unless subjected to a substantialwind and they stop swinging shortly after the wind subsides. Wind loading that can result in conductorsway is consideredin the transmissionsystem design. Therefore, loss of materialdue to mechanical wear is not an aging effect requiringmanagementfor the high-voltage insulators.

3.6.2.2.3 Loss of Material due to Wind-Induced Abrasion and Fatigue, Loss of Conductor Strength due to Corrosion, and Increased Resistance of Connection due to Oxidation or Loss of Pre-Load There is no switchyard bus within the scope of license renewal for SSES. For the transmission conductors and connections subject to aging management review for SSES, there are no aging effects identified that require aging management. The, effecsof wRid do n4t Yrequire. ... i;g management as the sections of tr-ansmission conductor-in the scope of license r-ene'wal are short in length, r-igid, and connected to r-igid comnponents-.

Wind-induced abrasion andfatigue are not aging effects applicableto in scope transmission conductors. Industry experience has shown that transmissionconductors do not normally swing unless subjected to a substantialwind and they stop swinging after a shortperiodonce the wind subsides. Because the transmissionconductors are not normally moving, loss of

Attachment to PLA-6362 Page 19 of 20 materialdue to wind-induced abrasionandfatigue is not an aging effect requiring management.

Loss of conductor strength due to corrosion of the transmission conductor is not identified as an aging effect due to ample design margin and a minimal corrosion process at the rural location of SSES. Connection resistance is not identified as a stressor based on the use of good bolting I

practices and review of site operating experience.

EPRI 1003057, the License Renewal Electrical Handbook, concludes that the most prevalent aging mechanism contributing to loss of conductor strength of ACSR (aluminum conductor steel reinforced) transmission conductors is corrosion. For ACSR conductors, degradation begins as a loss of zinc from the galvanized steel core wires. Corrosion rates depend largely on air quality, which involves suspended particles in the air, SO 2 concentration, rain, fog chemistry, and other weather conditions. Corrosion of ACSR conductors is a very slow process that is even slower in rural areas with less air pollution. SSES is located in a rural area in north-central Pennsylvania where airborne particle concentrations are comparatively low.

Tests performed by Ontario Hydroelectric showed a 30% composite loss of conductor strength for an 80 year-old sample of an ACSR conductor (due to corrosion). With respect to the Ontario Hydroelectric study, the National Electrical Safety Code (NESC) requires that tension on installed conductors be a maximum of 60% of the ultimate conductor strength and that consideration for ice, wind, and temperature be included in the design. The discussion in EPRI 1003057 demonstrates that with a 30% loss of conductor strength, there is still margin between the NESC requirements and the actual conductor strength. Because the SSES transmission conductor design and installation meet the NESC requirements, the Ontario Hydroelectric study is considered to bound the SSES configuration.

Therefore, based on the expected low corrosion rates due to plant location and the margins included' in the design, corrosion of the transmission conductors is not considered a significant aging effect for the period of extended operation.

Increased connection resistance is not identified as an aging effect requiring management.

Bolted connections associated with the transmission conductors employ the use of good bolting practices consistent with the recommendations of EPRI 1003471, "Electrical Connector Application Guidelines." Bolting hardware is selected to be compatible with the lugs used on the transmission conductors and Belleville washers are used to compensate for temperature changes and to maintain proper tightness. The review of site operating experience revealed no bolted connection failures associated with transmission conductors at SSES.

Attachment to PLA-6362 Page 20 of 20 Table 3.6.2-1, Aging Management Review Results - Electrical and I&C Components The following text for Plant-Specific Notes associated with Table 316.2-1 (on LRA pages 3.6-22 and 3.6-23) is revised by addition (bold italics) and deletion (strikethrough).

Plant-Specific Notes:

The evaluation in Section 3.6.2.2.3 concludes there are no aging-effects that requiremanagementfor the transmission conductors identified as in the license renewal scope at SSES. ar*ev...' sh.-t segments (appro.ximately 1-2 22 feet) w..e 0605neect the Start Up Tr-ansformer-s Ti10 and T20 te their- r-espet mtr-operated air-break switches !RIO05 and 2R1 05.

065These switehes constituate the baundai~' points fo-r thee 3BO" license renewal boundafy. The segments of transmission conductor: are net subjeet to aging mnanagement bea~s they dc not exhibit aging meehanisms/effeets. An aging management program at SSES is not required.

Regarding the aging mechanisms for the high-voltage insulators: salt spray on the high-voltage insulators is not of concern at SSES, due to its inland location. There is minimal contamination due to industrial effluents because of the rural location of SSES. The buildup of surface contaminants is gradual and is washed away by rainfall. Therefore, 0609 contamination is not identified as an aging mechanism. The high-voltage insulators identified within the scope of license-renewal for-SSES do not normally move unless the transmission conductorsare subjected to high wind.

Because the movement stops shortly after the wind subsides, mechanicalare cec.... ted to rigid compne*nt.s, suc.h that signific*an movement is not consider-ed a stressor, and wear is not identified as an aging mechanism.