PLA-6407, Response to Request for Additional Information for the Review of the License Renewal Application (LRA) Section 3.5.2.3.10 Follow-up to PLA-6407
| ML083190052 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 11/04/2008 |
| From: | Spence W Susquehanna |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| PLA-6407, PLA-6447 | |
| Download: ML083190052 (8) | |
Text
William H. Spence Executive Vice President and Chief Operating Officer/Chief Nuclear Officer Tel. 610.774.3683 Fax 610.774.5019 Whspence@pplweb.com NOV 0 4 2008 U. S. Nuclear Regulatory Commission Document Control Desk Mail Stop OP1-17 Washington, DC 20555 PPL Corporation Two North Ninth Street Allentown, PA 18101-1179 Tel. 610.774.5151 www.pplweb.com P
P SUSQUEHANNA STEAM ELECTRIC STATION REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE SUSQUEHANNA STEAM ELECTRIC STATION UNITS 1 AND 2, LICENSE RENEWAL APPLICATION (LRA)
SECTION 3.5.2.3.10 FOLLOW-UP TO PLA-6407 Docke PLA-6447 t Nos. 50-387 and 50-388
References:
"Application for Renewed Operating License Numbers NPF-14 and NPF-22, dated September 13, 2006.
"Request for Additional Information for the Review of the Susquehanna Steam Electric Station Units 1 and 2,LicenseRenewal Application (LRA) Sections B.2.13, B.2.17, 3.x, 3.2.2, 3.3.2, 3.4.2, and 3.5.2, " datedAugust22, 2008.
In accordance with the requirements of 10 CFR 50, 51, and 54, PPL requested the renewal of the operating licenses for the Susquehanna Steam Electric Station (SSES)
Units 1 and 2 in Reference 1.
On September 4, 2008 a teleconference between PPL and NRC identified the need to provide the NRC with additional information and clarification to PPL's response to RAI 3.5.2.3.10-1 contained in Reference 2.
The enclosure contains PPL's response to the RAI discussed during the teleconference.
There are no new regulatory commitments contained herein as a result of the attached response.
If you have any questions, please contact Mr. Duane L. Filchner at (610) 774-7819.
Document Control Desk PLA-6447 I declare, under penalty of perjury, that the foregoing is true and correct.
Executed on:
// - a W. H. Spence
Enclosure:
PPL Supplemental Response to RAI 3.5.2.3.10-1 Discussed During September 4, 2008 Telecon Copy: 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
Enclosure to PLA-6447 PPL Supplemental Response to RAI 3.5.2.3.10-1 Discussed During September 4, 2008 Telecon
Enclosure to PLA-6447 Page 1 of 5 In a teleconference between NRC anid PPL on Septemler 4, 2008 the staff requested clarification of information presented in LRA Table 3.5.2-10 regarding fire doors.
The LRA contains four line items in aging management review results Table 3.5.2-10 for steel and galvanized steel fire doors. Three of the line items identify Loss of Material as an Aging Effect Requiring Management. The line item for galvanized steel fire doors in a "protected from weather" environment does not identify Loss of Material as an Aging Effect Requiring Management. In addition this line item uses generic note "I" along with NUREG-1801 line item VII.G-3.
The staff requested justification for why loss of material due to wear is not an aging effect for galvanized steel fire doors in a protected from weather environment and why generic note "I" is used when a GALL Report line item is specified, since footnote "I" by definition implies it is not consistent with the GALL Report.
The following is provided as a supplemental response to RAI 3.5.2.3.10-1 based on the NRC / PPL teleconference on September 4, 2008.
PPL Response:
The SSES approach for determining which aging management review results table generic notes apply follows the guidance of NEI 95-10 "Industry Guideline for Implementing the Requirements of 10 CFR Part 54 the License Renewal Rule." Each combination of component type, material, environment and aging effect requiring management is compared with NUREG-1801 Volume 2 line items to identify consistencies. The material, environment, aging effect, and program (MEAP) comparison approach has been an accepted method for GALL item alignment. Stressors or aging mechanisms are not used in the alignment of generic notes; however, a plant specific note is used to supplement any plant specific evaluation or plant position.
As stated in response to RAI 3.5.2.3.10-1, the aging mechanism of wear for fire doors was determined not applicable for fire doors based on EPRI Report 1002950 "Aging Effects for Structures and Structural Components (Structural Tools)," Revision 1.
However, the SSES aging management review determined that loss of material due to general corrosion is an aging effect requiring management for steel fire doors. Therefore, the three line items in LRA Table 3.5.2-10 for steel fire doors in a protected from weather environment and steel and galvanized steel fire doors in an exposed to weather environment list loss of material (due to general corrosion) as an applicable aging effect and are aligned to the corresponding GALL item through the MEAP comparison process.
According to the GALL and EPRI Report 1002950, galvanized steel in a protected from weather environment requires no aging management or aging management program.
Therefore, the fourth line item in LRA Table 3.5.2.10 for galvanized steel fire doors in a protected from weather environment lists "none" in the "Aging Effect Requiring
Enclosure to PLA-6447 Page 2 of 5 Management" column. Note'i was used to indicate thdatlthe aging effect (loss of material) is not applicable for this component. In addition to Note I, Plant Specific Note 0501 committed the Fire Protection Program and the Structures Monitoring Program to confirm the absence of significant aging effects for the period of extended operation.
The discussion for Item Number 3.3.1-63 in SSES LRA Table 3.3.1 provides a plant specific position that for galvanized steel exposed to air - indoor uncontrolled, no aging effects were identified as requiring management; however, the Fire Protection Program in conjunction with the Structures Monitoring Program are credited to manage aging.
Since the GALL item alignment process is through the MEAP comparison method, the aging effect "loss of material" was considered as a match in the aforementioned three cases and not in the other one case.
The LRA is amended as follows to clarify the fire door line items in LRA Tables 3.3.1 and 3.5.2-10 to alleviate confusion.
Enclosure to PLA-6447 Page 3 of 5 Table 3.3.1, Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of the GALL Report LRA Table 3.3.1 (LRA page 3.3-83) is revised by addition (bold italics) and deletion (stuiket~thF-h).
Table 3.3.1 Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of the GALL Report Item Component/Commodity Aging Aging Management Further Discussion Number Effect/Mechanism Programs Evaluation Recommended 3.3.1-63 Steel fire rated doors exposed Loss of material Fire Protection No Consistent with NUREG-1 801 to air - outdoor or air - indoor due to Wear with exceptions. The exception uncontrolled is that the aging mechanism wear is not considered as an aging effect for fire doors based on EPRI Report 1002950 "Aging Effects for Structures and Structural Components (Structural Tools)," Revision 1.
The aging mechanism general corrosion was not specified in this GALL item. SSES has concluded loss of material due to general corrosion is an aging effect requiring management for fire doors.
For galvanized steel exposed to air-indoor uncontrolled, no aging effects were identified as requiring management; however, the Fire Protection Program in conjunction with the Structures Monitoring Program are credited to confirm the absence of significant wear of fire doors and loss of material due to general corrosion-mapa" a§iFgg. Refer to Table 3.5.2-10.
Enclosure to PLA-6447 Page 4 of 5 Table 3.5.2-10, Aging Management Review Results - Bulk Commodities LRA Table 3.5.2-10 (LRA pages 3.5-117 and 3.5-118) is revised by addition (bold italics) and deletion (stFilkthreUgh).
Table 3.5.2-10 Aging Management Review Results - Bulk Commodities Aging Effect Aging NUREG-Component/
Intended ing1801 Table Item Notes Commodity Function1 Material Environment Requiring Managements Volume 2 Item Fire Protection VII.G-3 3.3.1-63 B,
Program 0529 Protected from Loss of material weather Structures Moitrig1l.B4-10 3.5.1-39 C
Monitoring Fire Doors FB, SNS, SRE, Carbon Steel Program SSR Fire Protection VII.G-4 3.3.1-63 B,
Program 0529 Exposed to Loss of material weatherStructures Monitorin III.B4-10 3.5.1-39 C
Monitoring Program Fire Protection
.G4 3.3.
3 1,
Program N/A N/A 0501 Protected from None weather Structures MoitrigIl.B4-5 3.5.1-58 C
Monitoring Fire Doors FB, SNS, SRE, Galvanized Program SSR Steel Fire Protection VII.G-4 3.3.1-63 B,
Program 0529 Exposed to Loss of material weather Structures MoitrigIl.B4-7 3.5.1-50 C
Monitoring Program
Enclosure to PLA-6447 Page 5 of 5
> Plant Specific Notes (LRA page 3.5-138) is revised by addition (bold italics).
Plant-Specific Notes:
0529 Loss of material due to wear is not an aging effect requiring management for fire doors based on EPRI Report 1002950 "Aging Effects for Structures and Structural Components (Structural Tools)," Revision 1. Loss of material due to general corrosion is an aging effect requiring management. However, the GALL item identifying loss of material for fire doors does not specify general corrosion as an aging mechanism. Although the aging mechanism is not the same, Generic Note B was used to align to the GALL item since the material, environment, aging effect, and program (MEAP) matches. The identified AMPs will be used to manage loss of material due to general corrosion and will confirm the absence of significant wear of fire doors for the period of extended operation. The Fire Protection Program inspects for excessive wear of latches, strike plates, hinges, sills, and closing devices, and proper clearances (gaps) between the door, frame, and threshold.