PLA-6427, License Renewal Application (LRA) Amendments to Sections B.2.38, B.2.39, and B.2.47 in Response to NRC Regional Inspection PLA-6427

License Renewal Application (LRA) Amendments to Sections B.2.38, B.2.39, and B.2.47 in Response to NRC Regional Inspection PLA-6427

ML083030165
Person / Time
Site:	Susquehanna
Issue date:	09/23/2008
From:	Mckinney B Susquehanna
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
PLA-6427
Download: ML083030165 (11)

Text

Britt T. McKinney PPL Susquehanna, LLC Sr. Vice President & Chief Nuclear Officer 769 Salem Boulevard

• lma Berwick, PA 18603 , , So Tel. 570.542.3149 Fax 570.542.1504 btmckinney@pplweb.com SEP 23 206 P P14ý TM U. S. Nuclear Regulatory Commission Document Control Desk Mail Stop OP1-17 Washington, DC 20555 SUSQUEHANNA STEAM ELECTRIC STATION UNITS 1 AND 2, LICENSE RENEWAL APPLICATION (LRA)

AMENDMENTS TO SECTIONS B.2.38, B.2.39, AND B.2.47 IN RESPONSE TO NRC REGIONAL INSPECTION Docket Nos. 50-387 PLA-6427 and 50-388

Reference:

1) PLA-61]]0, Mr. B. T McKinney (PPL)to Document Control Desk (USNRC),

"Applicationfor Renewed OperatingLicense Numbers NPF-14 and NPF-22,"

dated September 13, 2006.

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.

The License Renewal process includes an inspection by regional inspectors to verify the applicant's license renewal program is implemented in accordance with the requirements of 10CFR54. NRC conducted a regional inspection of the SSES LRA from August 11, 2008 through August 29, 2008. As a result of the inspection, the SSES LRA aging management programs (AMP) for masonry walls (B.2.38), structures monitoring program (B.2.39), and leak chase channel monitoring program (B.2.47) were determined to require revision. The LRA changes to resolve these inspection issues are identified in the enclosure.

There are no new regulatory commitments contained herein as a result of the attached responses. However, license renewal commitment #34, in LRA Table A-i, is revised as indicated in the PPL Response to inspection issues related to AMP B.2.39.

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

Document Control Desk PLA-6427 I declare, under penalty of perjury, that the foregoing is true and correct.

Executed on: J/73 IZ&,Z B. . ney I

Enclosure:

PPL Responses to NRC's Regional Inspection 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-6427 PPL Responses to NRC's Regional Inspection

Enclosure to PLA-6427 Page 2 of 9 NRC Inspection Issue Related to AMP B.2.38 - Masonry Wall Program:

PPL Response:

The SSES LRA is amended as follows to identify that masonry block walls are in scope and subject to aging management review for the ESSW Pumphouse.

2.4.3 Engineered Safeguards Service Water Pumphouse and Spray Pond Structure Description

• - Walls discussion (LRA page 2.4-11) is revised by addition (bold italics).

The ESSW Pumphouse consists of the following major structural components:

• Foundation Mat - The reinforced concrete foundation mat is founded on soil. The depth of soil below the mat foundation varies from 35 to 60 feet. The soil is predominantly sand, gravel, cobbles, and boulders.

• Floors - The operating floor is of reinforced concrete supported by steel beams. The mezzanine floor is composed of grating over steel beams.

" Roof - The roof is of reinforced concrete supported by steel beams.

• Walls - The bearing walls are of reinforced concrete and are designed as shear walls to resist lateral loads. Masonry block wall is installed at entryway for security reasons.

• Chambers - The pump intake chambers and the overflow weir chamber are continuously flooded by the spray pond.

Table 2.4-3, ESSW Pumphouse and Spray Pond Components Subject to Aging Management Review

> Table 2.4-3 (LRA page 2.4-14) is revised by addition (bold italics).

Table 2.4-3 ESSW Pumphouse and Spray Pond Components Subject to Aging Management Review Component Type Intended Function (as defined in Table 2.0-1)

Masonry block walls SNS

Enclosure to PLA-6427 Page 3 of 9 3.5.2.1.3 Engineered Safeguards Service Water (ESSW) Pumphouse and Spray Pond

> Materials and Aging Management Programs discussions (LRA pages 3.5-5 and 3.5-6) are revised by addition (bold italics).

Materials ESSW Pumphouse and Spray Pond components subject to aging management review are constructed of the following materials:

• Carbon Steel

• Concrete

• Concrete Blocks

• Earthen

• Galvanized Steel

• Stainless Steel Aging Management Programs The following programs are credited for managing the effects of aging on ESSW Pumphouse and Spray Pond components:

• Fire Protection Program

• Masonry Wall Program

• Structures Monitoring Program

• RG 1.127Water-Control Structures Inspection

Enclosure to PLA-6427 Page 4 of 9 Table 3.5.2-3, Aging Management Review Results - Engineered Safeguards Service Water Pumphouse and Spray Pond LRA Table 3.5.2-3 (LRA page 3.5-88) is revised by addition (bold italics).

Table 3.5.2-3 Aging Management Review Results - Engineered Safeguards Service Water Pumphouse and Spray Pond Aging Effect Aging NUREG-Commodity Function 1 Material Environment Requiring Management Volume Table 1 Item Notes Comodty Funtin'Management Programs Voluem2 Masonry Concrete Protected Masonry Wall Block SNS Blocks from weather Cracking Program III.A6-10 3.5.1-43 A Walls Masonry Concrete Exposed to Masonry Wall Block SNS Blocks weather Cracking Program lll.A6-1O 3.5.1-43 A Walls

Enclosure to PLA-6427 Page 5 of 9 NRC Inspection Issue Related to AMP B.2.39 - Structures Monitoring Program:

PPL Response:

The SSES LRA is amended as follows to enhance the Monitoring and Trending, Acceptance Criteria, and Detection of Aging Effects elements of the existing SSES Structures Monitoring Program.

A.1.2.45 Structures Monitoring Program

> The discussion in Section A.1.2.45 (LRA pages A-19 to A-20) is revised by deletion

(&trikethrough) and addition (bold italics).

The Structures Monitoring Program is an existing program that manages age-related degradation of plant structures and structural components within its scope to ensure that each structure or structural component retains the ability to perform its intended function. Aging effects are detected by visual inspection of external surfaces prior to the loss of the structure's or component's intended function.

This program implements provisions of the Maintenance Rule, 10 CFR 50.65, that relate to structures, masonry walls, and water-control structures. Concrete and masonry walls that perform a fire barrier intended function are also managed by the Fire Protection Program.

Prior to the period of extended operation, the Structures Monitoring Program will be enhanced to include structures within the scope of license renewal. The program will be enhanced to specify inspections of a below grade structural wall or structural component that becomes accessible through excavation. The program will be enhanced to clarify the component types included as "structural components". The program will be enhanced and to specify degradation mechanisms for elastomer and earthen embankment inspection. The Structures Monitorng Program program will be enhanced to include RG 1.127 inspection elements for water-control structures. The program will be enhanced to include and requirements for review of site groundwater and raw water parameters. The program will also be enhanced to specify inspection requirements for masonry walls. The program will be enhanced to include direction for quantifying, monitoring and trending of inspection results, guidance for inspection reporting, data collection and documentation, acceptance criteria and critical parameters to monitor degradationand to trigger level of inspection and initiation of corrective action; and better alignment with referenced Industry codes, standards and guidelines. The program will be enhanced to include specific qualification requirementsfor the inspector.

Enclosure to PLA-6427 Page 6 of 9 Table A-1, SSES License Renewal Commitments The Commitment for Item Number 34) Structures Monitoring Program in Table A-1 (LRA pages A-45 to A-46) is revised addition (bold italics).

Table A-1 SSES License Renewal Commitments FSAR Enhancement Supplement or Commitment locat on Item Number Location Implementation (LRA App. A) Schedule

34) Structures Existing program is credited with the following enhancements: A.1.2.45 Prior to the period Monitoring

• Include additional structures requiring aging management for of extended Program license renewal to the scope of the inspections. operation.

• Specify that if a below grade structural wall or structural component becomes accessible through excavation; a follow-up action is initiated for the responsible engineer to inspect the exposed surfaces for age-related degradation.

• Clarify "structural component" for inspection includes each of the component types identified as requiring aging management.

" Include degradation mechanisms for elastomer and earthen embankment inspection.

" Include RG 1.127 inspection elements for water-control structure.

" Specify that the responsible engineer shall review site groundwater and raw water pH, chlorides, and sulfates results prior to inspection to validate that the below-grade or raw water environment remain non-aggressive during the period of extended operation.

Enclosure to PLA-6427 Page 7 of 9 Table A-1 SSES License Renewal Commitments FSAR Enhancement Supplement or Commitment locat on Item Number Location Implementation (LRA App. A) Schedule Specify that for each masonry wall, the extent of observed masonry cracking and/or degradation of steel edge supports/bracing are evaluated to ensure that the current evaluation basis is still valid. Corrective action is required if the extent of masonry cracking and steel degradation is sufficient to invalidate the evaluation basis.

Include additional direction for quantifying, monitoring and trending of inspection results; Include additionalguidance for inspection reporting, data collection and documentation; Specify acceptance criteria and criticalparameters to monitor degradationand to triggerlevel of inspection and initiation of corrective action; and provide better alignment with referenced Industry codes, standardsand guidelines.

• Include specific qualificationrequirementsfor the inspector.

Enclosure to PLA-6427 Page 8 of 9 B.2.39 Structures Monitoring Program Required Enhancements

The Required Enhancements discussion (LRA page B-117 to B-118) is revised by addition (bold italics). Bullets Monitoring and Trending, Acceptance Criteria and Detection of Aging Effects have been added.

Monitoringand Trending, Acceptance Criteria-The Structures Monitoring Program procedure will be enhanced to include the following:

> Additional direction for quantifying, monitoring and trending of inspection results.

> Additional guidance for inspectionreporting,data collection and documentation.

> Sufficient acceptance criteriaand critical parametersto monitor degradation and to triggerlevel of inspection and initiationof correctiveaction.

> Better alignment with referenced Industry codes, standards and guidelines regardingterminology and evaluation.

" Detection of Aging Effects -

The Structures Monitoring Program procedure will be enhanced to provide specific qualificationrequirements for the inspector.

Enclosure to PLA-6427 Page 9 of 9 NRC Inspection Issue Related to AMP B.2.47 - Leak Chase Channel Monitoring Activities:

PPL Response:

The SSES LRA is amended as follows to clarify that the scope of the SSES Leak Chase Channel Monitoring Activities is to detect loss of material aging effects for the spent fuel pool and fuel shipping cask storage pool liners.

B.2.47 Leak Chase Channel Monitoring Activities Aging Management Program Elements

> The Scope of Activity discussion (LRA page B-143) is revised by addition (bold italics)and deletion (sthiketheeugh).

Scope of Activity The Leak Chase Channel Monitoring Activities, which include periodic monitoring of the spent fuel pool and fuel shipping cask storage pool leak chase system, are credited for

.upplementing the BWR Water C-he,-*mistr, Program for managing detecting loss of material aging effects for the spent fuel pool and fuel shipping cask storage pool liners.

Conclusion

> The Conclusion discussion (LRA page B-145) is revised by addition (bold italics)and deletion (rikethFetg§).

The Leak Chase Channel Monitoring Activities include cycling the spent fuel pool and fuel shipping cask storage pool liner drain valves to detect potential leakage from the spent fuel pool and fuel shipping cask storage pool liners. The leak chase channel monitoring

-,uppler*net* the BVWR Water Chemiritny Program by detecting detects loss of material aging effect through leakage monitoring such that the spent fuel pool and fuel shipping cask storage pool liner's integrity and intended functions will be maintained consistent with the current licensing basis for the period of extended operation.

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