PLA-6428, Licensee Renewal Application Amendments to Sections 2.1.1, B.2.14, B.2.22, B.2.28, B.2.28, B.2.31, and B.2.46 in Response to NRC Regional Inspection PLA-6428

Licensee Renewal Application Amendments to Sections 2.1.1, B.2.14, B.2.22, B.2.28, B.2.28, B.2.31, and B.2.46 in Response to NRC Regional Inspection PLA-6428

ML082950011
Person / Time
Site:	Susquehanna
Issue date:	09/30/2008
From:	Mckinney B Susquehanna
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
PLA-6428
Download: ML082950011 (13)

Text

Britt T. McKinney PPL Susquehanna, LLC Sr. Vice President & Chief Nuclear Officer 769 Salem Boulevard Berwick, PA 18603 t ,

Tel. 570.542.3149 Fax 570.542.1504 0a btmckinney@pplweb.com SEP 3 0 2008 T.

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 2.1.1, B.2.14, B.2.22, B.2.28, B.2.31, AND B.2.46 IN RESPONSE TO NRC REGIONAL INSPECTION Docket Nos. 50-387 PLA-6428 and 50-388

Reference:

1) PLA-6110, Mr. B. T. McKinney (PPL)to Document ControlDesk (USNRC),

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

dated September 13, 2006.

2) PLA-6391, Mr. B. T McKinney (PPL)to Document Control Desk (USNRC),

"Request or Additional Informationfor the Review of the SusquehannaSteam Electric Station Units 1 and 2, License Renewal Application (LRA) Sections B.2.23, B.2.24, B.2.26, B.2.27, B.2.28, B.2.31, "dated July 25, 2008.

3) PLA-6177, Mr. B. T McKinney (PPL)to Document Control Desk (USNRC),

"Applicationfor Renewed OperatingLicenses Numbers NPF-14 and NPF-22 Response to Scoping and Screening RAI's, "dated April 17, 2007.

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 10 CFR 54. 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 scoping methodology (2.1.1), and aging management programs (AMP) for closed cooling water chemistry (B.2.14), chemistry program effectiveness inspection (B.2.22), small bore class 1 piping inspection (B.2.3 1) and area-based NSAS inspection (B.2.46) 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. A

Document Control Desk PLA-6428 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

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-6428 PPL Responses to NRC's Regional Inspection

Enclosure to PLA-6428 Page 1 of 10 NRC Inspection Issue Related to Scoping of HPCI Suction Swap Cables:

PPL Response:

The fact that the safety-related cables associated with the Unit 2 HPCI suction swap from condensate storage tank to suppression pool are located partially in the turbine building is not discussed in the LRA. The LRA is amended as follows to address this situation.

2.1.1.2.2 Spatial Failures of Nonsafety-Related SSCs LRA Section 2.1.1.2.2 (page 2.1-6) is amended by addition (bold italics)to address the non-safety affecting safety aspects of the HPCI suction swap cables located in the Turbine Building.

An important aspect in the scope of spatial failures of nonsafety-related SSCs for SSES is the fact that, with one exception, there are no components located in the Turbine Building that either perform or would prevent a safety-related function from occurring.

This is documented in the current licensing bases and confirmed through evaluation for license renewal.

The exception is the safety-related cables associatedwith the High Pressure Coolant Injection (HPCI)System pump suction transferbetween the condensate storagetank and the suppressionpoolfor Unit 2. These cables are routed through the turbine building. However, an analysis concluded that the plant can achieve safe shutdown with the loss of these cables due to a high energy line break and singlefailure, which bounds the potential spatialinteractions. Accomplishment of a safety-relatedfunction (safe shutdown) will not be prevented or impairedby thefailure of nonsafety-related components in the Turbine Building.

This means that:

1) Nonsafety-related systems located only in the Turbine Building and not connected to safety-related systems do not satisfy the 10 CFR 54.4(a)(2) criterion and are not in the scope of license renewal.

2) Nonsafety-related portions of systems that are directly connected to safety-related piping and in the Turbine Building are included in the scope of license renewal up to the first seismic restraint, or anchor to plant structure, beyond the seismic Category I structure, as described below.

Enclosure to PLA-6428 Page 2 of 10 NRC Inspection Issue Related to AMP B.2.14 - Closed Cooling Water Chemistry Program:

PPL Response:

The SSES LRA credits a one time inspection to confirm effectiveness of the Closed Cooling Water Chemistry Program instead of a periodic inspection, as recommended by GALL. The LRA is amended to identify this exception to GALL.

LRA Section B.2.14, Closed Cooling Water Chemistry Program (pages B-47 and B-48), is amended by addition (bold italics), as follows, to identify the one-time Chemistry Program Effectiveness Inspection as an exception to the periodic inspection recommended in GALL.

Exceptions to NUREG- 1801 Program Elements Affected:

• Parameters Monitored or Inspected (and Detection of Aging Effects, Monitoring and Trending, and Acceptance Criteria)

The Closed Cooling Water Chemistry Program does not include performance or functional testing since performance and functional testing verify that component active functions can be accomplished, but in most cases, provide little definitive information or value with respect to the condition of passive components. In lieu of performance monitoring/functional testing, the Closed Cooling Water Chemistry Program includes monitoring of corrosion in the emergency diesel generator jacket water subsystem and is supplemented by the one-time Chemistry Program Effectiveness Inspection, which includes closed cooling water system locations, and the one-time Heat Exchanger Inspection, which includes heat exchangers served by closed cooling systems, to confirm adequate mitigation in low flow and stagnant areas.

The Closed Cooling Water Chemistry Programdoes not include periodic inspections. However, consistent with the approach taken for the B WR Water Chemistry Program,theprogram is supplemented by the Chemistry Program Effectiveness Inspection to verify that the program is effective. Implementation of the Chemistry ProgramEffectiveness Inspection may, depending on the findings of the one-time inspection, result in the establishment ofperiodic inspection activities.

Enclosure to PLA-6428 Page 3 of 10 NRC Inspection Issue Related to AMP B.2.22 - Chemistry Program Effectiveness Inspection:

PPL Response:

The SSES LRA is amended to clarify that the Chemistry Program Effectiveness Inspection will be implemented consistent with the requirements of the ASME Code and 10 CFR 50 Appendix B.

LRA Section B.2.22, Chemistry Program Effectiveness Inspection (page B-69), is amended by addition (bold italics) as follows:

" Parameters Monitored or Inspected The parameters to be inspected by the Chemistry Program Effectiveness Inspection include wall thickness and visual evidence of internal surface

,degradation as measures of loss of material, or of cracking for stainless steel exposed to temperatures above 140'F. Inspections will be performed by qualified personnel using established nondestructive examination (NDE) techniques appropriate to the system/location being inspected andfollowing procedures consistent with the requirements of the ASME Code and 10 CFR 50, Appendix B.

" Detection of Aging Effects The Chemistry Program Effectiveness Inspection will use a combination of established volumetric and visual examination techniques (such as equivalent to VT-1 or VT-3) performed by qualified personnel following procedures consistent with the requirementsof the ASME Code and 10 CFR 50, Appendix B.

Inspections will be performed on a sample population of subject components to identify evidence of a loss of material, or cracking of stainless steel exposed to temperatures above 140'F, or to confirm a lack thereof. The results of the inspections will be applied to all of the components within the scope of the inspection activity.

Enclosure to PLA-6428 Page 4 of 10 NRC Inspection Issue Related to AMP B.2.28 - Supplemental Pipini/Tank Inspection:

PPL Response:

The Supplemental Piping/Tank Inspection AMP is revised to ensure the internal surfaces of the diesel generator starting air receivers are monitored for degradation.

> LRA Section B.2.28, Supplemental Piping/Tank Inspection (pages B-88 and B-89), is amended by addition (bold italics) to add the diesel generator starting air receivers to the inspection population as follows:

Scope of Program The Supplemental Piping/Tank Inspection also detects and characterizes relative to the following to determine whether, and to what extent, degradation is occurring (or is likely to occur):

- Loss of material due to crevice, galvanic, general, and pitting corrosion on internal carbon steel surfaces within the scram discharge volume (piping and valve bodies) of the Control Rod Drive Hydraulic System, and within the air space of the condensate storage tanks and the Diesel Generatorstartingair receiver tanks and E diesel compressorskid airreceiver tanks.

" Detection of Aging Effects For components exposed to a moist air internal environment, the sample population should include the following locations:

- Scram discharge volume piping or valve bodies in the Control Rod Drive Hydraulic System

- Suppression chamber spray header piping in the RHR System

- Starting air receiver tanks and E diesel compressorskid air receiver tanks in the Diesel GeneratorsSystem (the sample will include at least 2 of the starting air receiver tanks)

Enclosure to PLA-6428 Page 5 of 10 The following line item in Table 3.3.1 (on LRA page 3.3-95) is revised by addition (bold italics) to credit the Supplemental Piping/Tank Inspection for inspection of the internal surfaces of the air receiver tanks, as follows:

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 3.3.1-98 Steel, stainless steel, and None None NA - No AEM or Consistent with NUREG-1 801.

copper alloy piping, piping AMP components, and piping Although no aging effects are elements exposed to dried air identified as requiring management, the Fire Water System Program will include replacement of sprinkler heads (with 50 years in service/place),

regardless of whether aging effects require management.

No aging effects are identified for the Diesel Generator starting airreceiver tanks.

However, the Supplemental Piping/TankInspection is credited to verify that aging is not occurringon the internal surfaces.

Enclosure to PLA-6428 Page 6 of 10 The following line item in Table 3.3.2-9 (on LRA page 3.3-209) is revised by addition (bold italics) and deletion (sikethfough) to credit the Supplemental Piping/Tank Inspection for inspection of the internal surfaces of the air receiver tanks, as follows:

Table 3.3.2-;9 Aging Management Review.Results -Diesel Generators System',.

Aging Effect Aging NUREG-Component Intended Requiring Management 1801 Volume Table 1 Commodity Function Material Environment Management Programs 2 Item Item Notes NGRe Reque4 Air-Gas None Supplemental VII.J-22 3.3.1-98 A- E, Tanks, Air Pressure (Internal) Identified Piping/Tank 0362 Receiver (0T535A - E)

Pressure Boundary Carbon Steel Inspection Indoor Air Loss of System Walkdown VII.I-8 3.3.1-58 A (External) Material Program

Enclosure to PLA-6428 Page 7 of 10 The following line item in Table 3.3.2-9, added to the LRA via PPL Letter PLA-6177 (Reference 3) in response to RAI 2.1-3, is revised by addition (bold italic) and deletion (str)kethfetg to credit the Supplemental Piping/Tank Inspection for inspection of the internal surfaces of the air receiver tanks, and to make the generic note associated with the "External" environment consistent with that used for other air receiver tanks (0T535A-E), as follows:

Table 3.3.2-9 Aging Management Review Results - Diesel'Generators System Aging Effect Aging NUREG-Component I Intended Requiring Management 1801 Volume Table 1 Commodity Function Material Environment Management Programs 2 Item Item Notes NG4R8 Req~e4 Air-Gas None Supplemental VII.J-22 3.3.1-98 E Tanks, Air Structural (Internal) Identified Piping/Tank 0362 Receiver Strutu Carbon Steel Inspection (E DG Skid) Indoor Air Loss of System (External) Material Walkdown VII.I-8 3.3.1-58 -C- A

Enclosure to PLA-6428 Page 8 of 10

• The following line item in the table of Plant-Specific Notes (on LRA page 3.3-35 1) added to the LRA via PPL Letter PLA-6177 (Reference 3) in response to RAI 2.1-3 is revised by addition (bold italic) and deletion (stfikethr-eugh) to credit the Supplemental Piping/Tank Inspection for inspection of the internal surfaces of the air receiver tanks, as follows:

1' Plant-Specific Notes:

Air in the DG starting air system that is downstream of the dryers (such as the air receiver tanksfe9--the--EDG) is dry and no 0362 aging mechanisms are present, whereas general corrosion is possible in components upstream of the dryers. Although no aging effects are identified, the Supplemental Piping/TankInspection is credited for inspection of the internal surfaces of the airreceiver tanks.

I

Enclosure to PLA-6428 Page 9 of 10 NRC Inspection Issue Related to AMP B.2.31 - Small Bore Piping:

PPL Response:

Some of the program elements in LRA Section B.2.31 include discussions of past small bore piping failures that were attributed to vibrational fatigue. The vibrational fatigue failures are not relevant to AMP B.2.3 1, because vibrational fatigue is a design issue and not an aging effect. Therefore, no discussion of vibrational fatigue in LRA Section B.2.31 is warranted, because the Small Bore Class 1 Inspection does not manage vibrational fatigue or cracking due to vibrational fatigue.

The SSES LRA is revised by deleting references to vibrational fatigue in the program elements of Section B.2.31.

B.2.31 Small Bore Class 1 Piping Inspection The discussion under Aging Management Program Elements in Section B.2.31 (LRA page B-99) is revised by deletion (st-ikethfeugh). Previous changes from Attachment 3 of Reference 2 have been incorporated.

Detection of Aging Effects SSES has not experienced cracking of small bore class 1 piping due to stress corrosion or thermal and mechanical loading; therefore, this inspection is appropriate. This inspection will perform volumetric examinations on selected weld locations. 99=9 has found c*rak like indication due, to m,,b*,at,,-al fatigue of small bore p*png* anrd has performed addlitional inspect*oRn for ibratiRnal fatigue through aulmlntatGn* *f the SSES Insemce InspecP.-tinr ProgFam.

Monitoring and Trending The SSES inspection will include a representative sample of the system population, and, where practical, will focus on the bounding or lead components most susceptible to aging due to time in service, severity of operating conditions, and lowest design margin. Actual inspection locations will be based on physical accessibility, exposure levels, available non-destructive examination (NDE) techniques, and operating experience. Nondestructive volumetric examinations will be performed by qualified personnel following procedures that are consistent with Section XI of ASME Code and 10 CFR 50, Appendix B. Inspections already perfoFrmed by augmentation Of the S-SEMS lnseR~ice Inspection Pro~gram for vib-r-ation-al fatigue of small bore piping, will be factored into the sample determination for th Small Bere Class I PiPi*g IlnspeGtio.

Enclosure to PLA-6428 Page 10 of 10 Unacceptable inspection findings will be evaluated by the SSES corrective action process. The SSES Small Bore Class 1 Piping Inspection will require an increased sample size in response to unacceptable inspection findings. Evaluation of indications may lead to the creation of a plant-specific AMP.

NRC Inspection Issue Related to AMP B.2.46 - Area Based NSAS Inspection:

PPL Response:

LRA Section B.2.46, Area-Based NSAS Inspection (on page B-140), is revised by addition (bold Italic) and deletion (strilethfeugh) to delete the evaluation for ammonia as a criteria in determining the population of copper to be inspected for cracking as follows:

Scope of Activity In addition, conditions in non radioacti. e qument/a-ea drainage water-, potable water-, and raw water envir-onments will1. be, evaluatead -for.the pr-esence of ammonao amm.niu. c ounds and, if found, a representative sample of nonsafety-related copper alloy components in non-radioactiveequipment/areadrainagewater, potable water, and raw water environments will be examined for evidence of cracking due to stress corrosion cracking (SCC).

Parameters Monitored or Inspected The parameters inspected by the Area-Based NSAS Inspection will include wall thickness and/or visual evidence of internal surface degradation as a measure of loss of material of components exposed to non-radioactive equipment/area drainage water or potable water; and. if eters ins.......b* the A Based NSA Inspection will also include visual or volumetric evidence of internal surface degradation as a measure of cracking of copper alloy components exposed to non-radioactive equipment/area drainage water, potable water, or raw water (eentai**ug amnar ammnium compounds).