PLA-6430, License Renewal Application (LRA) Amendments to LRA and RAI Responses
| ML082950012 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 09/26/2008 |
| From: | Mckinney B Susquehanna |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| PLA-6430 | |
| Download: ML082950012 (27) | |
Text
Britt T. McKinney PPL Susquehanna, LLC
%
Sr..Vice President & Chief Nuclear Officer 769 Salem Boulevard Berwick, PA 18603 Tel. 570.542.3149 Fax 570.542.1504 btmckinney@pplweb.com ppI,'
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- TM SEP 26-M 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)
AMENDMENTS TO LRA AND RAI RESPONSES Docket Nos. 50-387 PLA-6430 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) PLA-6283, Mr. B. T McKinney (PPL)to Document ControlDesk (USNRC), "Request for AdditionalInformation (RAI)for the Review of the Susquehanna Steam Electric Station Units 1 and 2, License Renewal Application (LRA) Sections 4.2.3, 4.2.4, 4.2.5, 4.2.7, and 4.7.3, "dated October 18, 2007.
"Applicationfor Renewed OperatingLicenses Numbers NPF-14 and NPF-22 Requests for Additional Information - License Renewal Application (LRA) Section 2.3.3.13 RAI Follow-up, "dated October 24, 2007.
"Requestfor Additional Informationfor the Review of the SusquehannaSteam Electric Station Units 1 and 2, License Renewal Application (LRA) Sections B.2. 11, B.2.13, B.2.16, and B.2.17, "dated June 30, 2008
- 5) PLA-6397, Mr. B. T McKinney (PPL)to Document Control Desk (USNRC), "Request for Additional Informationfor the Review of the Susquehanna Steam ElectricStation Units 1 and 2, License Renewal Application (LRA) Sections B.3.1, 4.3, and 4.7,"
dated August 1, 2008.
- 6) PLA-6400, Mr. B. T McKinney (PPL)to Document ControlDesk (USNRC), "Request for AdditionalInformationfor the Review of the Susquehanna Steam Electric Station Units 1 and 2, License Renewal Application (LRA) Sections B.2.14, B.2.25, B.2.32, and B.2.33, " datedAugust 12, 2008.
- 7) PLA-6407, Mr. B. T. McKinney (PPL)to Document ControlDesk (USNRC), "Request for Additional Informationfor the Review of the Susquehanna Steam Electric Station Units 1 and 2, License Renewal Application (LRA) Sections B. 2.13, B. 2.17, 3.x, 3.2.2, 3.3.2, 3.4.2, and 3.5.2, "datedAugust 22, 2008 1 ow-~
Document Control Desk PLA-6430 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 enclosure to this letter provides amendments to various sections of the SSES License Renewal Application (LRA) and changes to RAI responses. These changes are due to inconsistencies that have been discovered and plant modifications that have been implemented subsequent to LRA submittal.
There are no new regulatory commitments contained herein. However, License Renewal commitments #26, #49, and #57 are revised as shown in the enclosure.
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:
Amendments to SSES License Renewal Application (LRA) and changes to RAI responses 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-6430 Amendments to SSES License Renewal Application (LRA) and Changes to RAI Responses
Enclosure to PLA-6430 Page 1 of 24 LRA Amendment Item 1 The LRA description of the "Thermal Aging and Neutron Embrittlement of Cast Austenitic Stainless Steel (CASS) Program" incorrectly lists a reference to ASME Code,Section XI, Subsection IWB, Category B-N-1. Category B-N-I applies to the interior of the reactor pressure vessel, which is not CASS.
The SSES LRA is amended as follows to delete this reference.
A.1.2 Aging Management Program and Activities
> Section A.1.2.48 (LRA page A-21) is revised by deletion (&ikethrough).
A.1.2.48 Thermal Aging and Neutron Embrittlement of Cast Austenitic Stainless Steel (CASS) Program The Thermal Aging and Neutron Embrittlement of Cast Austenitic Stainless Steel (CASS)
Program augments the visual inspection of the reactor vessel internals done in accordance with the ASME Code,Section XI, Subsection IWB, Category B N naRd B-N-2. The inspection is augmented to detect the effects of loss of fracture toughness due to thermal aging and neutron irradiation embrittlement of cast austenitic stainless steel (CASS) reactor vessel internal components. The aging management program includes (a) identification of susceptible components determined to be limiting from the standpoint of thermal aging susceptibility (i.e.,
ferrite and molybdenum contents, casting process, and operating temperature) and/or neutron irradiation embrittlement (neutron fluence), and (b) for each potentially susceptible component, aging management is accomplished through either a supplemental examination of the affected component based on the neutron fluence to which the component has been exposed as part of the SSES 10-year Inservice Inspection (ISI) Program during the license renewal term, or a component-specific evaluation to determine its susceptibility to loss of fracture toughness.
B.2 Aging Management Programs B.2.10 Thermal Aging and Neutron Embrittlement of Cast Austenitic Stainless Steel (CASS) Program
> The Program Description discussion in Section B.2.10 (LRA page B-36) is revised by deletion Program Description The purpose of the Thermal Aging and Neutron Embrittlement of Cast Austenitic Stainless Steel (CASS) Program is to augment the visual inspection of the reactor vessel internals done in accordance with the American Society of Mechanical Engineers (ASME) Code,Section XI, Subsection IWB, Category B N 11ad B-N-2. The inspection is augmented to detect the effects of loss of fracture toughness due to thermal aging and neutron irradiation embrittlement of cast austenitic stainless steel (CASS) reactor vessel internal components. The aging management program (AMP) includes (a) identification of susceptible components determined to be limiting from the standpoint of thermal aging susceptibility (i.e., ferrite and molybdenum contents, casting process, and operating temperature) and/or neutron irradiation embrittlement (neutron
Enclosure to PLA-6430 Page 2 of 24 fluence), and (b) for each potentially susceptible component, aging management is accomplished through either a supplemental examination of the affected component based on the neutron fluence to which the component has been exposed as part of the SSES 10-year Inservice Inspection (ISI) Program during the license renewal term or a component-specific evaluation to determine its susceptibility to loss of fracture toughness.
LRA Amendment Item 2 LRA Section 2.1.2.4.5, Mechanical Sealants, states that mechanical sealants used in HVAC systems are subject to aging management review. However, the results of the evaluation of the mechanical sealants in HVAC systems were not included in the LRA.
The SSES LRA is amended as follows to include the evaluation of mechanical sealants for HVAC systems.
2.3 SCOPING AND SCREENING RESULTS: MECHANICAL SYSTEMS 2.3.3.5 Control Structure HVAC Systems Table 2.3.3-5, Control Structure HVAC Systems Components Subject to Aging Management Review Table 2.3.3-5 (LRA pages 2.3-47 to 2.3-49) is revised by addition (bold italics).
Table 2.3.3-5 Control Structure HVAC Systems Components Subject to Aging Management Review Intended Function Component Type (as defined in Table 2.0-1)
Mechanicalsealants PressureBoundary 3.3 AGING MANAGEMENT OF AUXILIARY SYSTEMS 3.3.2.1.5 Control Structure HVAC Systems The Materials discussion under Section 3.3.2.1.5 (LRA page 3.3-9) is revised by addition (bold italics)and deletion (,st4kethugeh).
Enclosure to PLA-6430 Page 3 of 24 Materials The materials of construction for the Control Structure HVAC Systems components/commodities are:
" Carbon Steel (including Aluminized Steel)
" Copper
- Copper Alloy (Brass and Red Brass)
" Elastomer (Neoprene/Asbestos, aR4 Neoprene/Fiberglass, and Synthetic Rubber)
" Galvanized Steel
" Stainless Steel
Enclosure to PLA-6430 Page 4 of 24 3.3 AGING MANAGEMENT OF AUXILIARY SYSTEMS 3.3.3 Conclusions Table 3.3.2-5, Aging Management Review Results - Control Structure HVAC Systems Table 3.3.2-5 (LRA page 3.3-142) is revised by addition (bold italics).
Ventilation None None Mechanical Pressure (Internal) Identified Required Sealants Boundary IndoorAir None None (External) Identified Required
Enclosure to PLA-6430 Page 5 of 24 2.3 SCOPING AND SCREENING RESULTS: MECHANICAL SYSTEMS 2.3.3.8 Diesel Generator Buildings HVAC Systems Table 2.3.3-8, Diesel Generator Buildings HVAC Systems Components Subject to Aging Management Review
> Table 2.3.3-8 (LRA pages 2.3-56 to 2.3-57) is revised by addition (bold italics).
Table 2.3.3-8 Diesel Generator Buildings HVAC Systems Components Subject to Aging Management Review C nIntended Function Component Type (as defined in Table 2.0-1)
Mechanicalsealants PressureBoundary 3.3 AGING MANAGEMENT OF AUXILIARY SYSTEMS 3.3.2.1.8 Diesel Generator Buildings HVAC Systems Materials
> The Materials discussion under Section 3.3.2.1.8 (LRA page 3.3-13) is revised by addition (bold italics)and deletion (st-ikethfugh).
The materials of construction for the Diesel Generator Buildings HVAC Systems components/
commodities are:
- Carbon Steel
" Elastomer (Neoprene, Neoprene/Asbestos, ard Neoprene/Fiberglass, and Synthetic Rubber)
" Galvanized Steel
- Stainless Steel
Enclosure to PLA-6430 Page 6 of 24 3.3 AGING MANAGEMENT OF AUXILIARY SYSTEMS 3.3.3 Conclusions Table 3.3.2-8, Aging Management Review Results - Diesel Generator Buildings HVAC Systems Table 3.3.2-8 (LRA page 3.3-170) is revised by addition (bold italics).
Ventilation None None Pressure (Internal) Identified Required Mechanical Sealants Boundary IndoorAir None None (External) Identified Required
Enclosure to PLA-6430 Page 7 of 24 2.3 SCOPING AND SCREENING RESULTS: MECHANICAL SYSTEMS 2.3.3.12 ESSW Pumphouse HVAC System Table 2.3.3-12, ESSW Pumphouse HVAC System Components Subject to Aging Management Review Table 2.3.3-12 (LRA pages 2.3-70) is revised by addition (bold italics).
Table 2.3.3-12 ESSW Pumphouse HVAC System Components Subject to Aging Management Review Component Type Intended Function (as defined in Table 2.0-1)
Mechanicalsealants Pressure Boundary 3.3 AGING MANAGEMENT OF AUXILIARY SYSTEMS 3.3.2.1.12 ESSW Pumphouse HVAC System
> The Materials discussion under Section 3.3.2.1.12 (LRA page 3.3-17) is revised by addition (bold italics).
Materials The materials of construction for the ESSW Pumphouse HVAC System components/commodities are:
- Carbon Steel
- Galvanized Steel
" Stainless Steel
- Elastomer(Synthetic Rubber)
Enclosure to PLA-6430 Page 8 of 24 3.3 AGING MANAGEMENT OF AUXILIARY SYSTEMS 3.3.3 Conclusions Table 3.3.2-12, Aging Management Review Results - ESSW Pumphouse HVAC System
> Table 3.3.2-12 (LRA page 3.3-227) is revised by addition (bold italics).
Ventilation None None Pressure (Internal) Identified Required Mechanical Sealants Boundary Indoor Air None None (Exte Ar Inied R ed VII.F1-7 3.3.1-11 (External) Identified Required I, 0318
Enclosure to PLA-6430 Page 9 of 24 2.3 SCOPING AND SCREENING RESULTS: MECHANICAL SYSTEMS 2.3.3.24 Reactor Building HVAC System Table 2.3.3-23 Reactor Building HVAC System Components Subject to Aging Management Review
> Table 2.3.3-23 (LRA pages 2.3-97 to 2.3-99) is revised by addition (bold italics).
Table 2.3.3-23 Reactor Building HVAC System Components Subject to Aging Management Review Component Type Intended Function (as defined in Table 2.0-1)
Mechanicalsealants PressureBoundary 3.3 AGING MANAGEMENT OF AUXILIARY SYSTEMS 3.3.2.1.23 Control Structure HVAC System
> The Materials discussion under Section 3.3.2.1.23 (LRA page 3.3-28) is revised by addition (bold italics).
Materials The materials of construction for the Reactor Building HVAC System components/commodities are:
0 Carbon Steel 0 Cast Iron 0 Copper 0 Copper Alloy (Brass, Bronze, and Copper-Nickel) 0 Galvanized Steel 0 Glass 0 Elastomer (Neoprene/Fiberglass and Synthetic Rubber) 0 Stainless Steel
Enclosure to PLA-6430 Page 10 of 24 3.3 AGING MANAGEMENT OF AUXILIARY SYSTEMS 3.3.2.2.5.1 Components of Heating and Ventilation Systems The Materials discussion in Section 3.3.2.2.5.1 (LRA page 3.3-42) is revised by addition (bold italics).
Materials Only the elastomers used in flexible connections and mechanicalsealants in the Reactor Building HVAC and the Primary Containment Atmosphere Circulation System were identified as requiring aging management. Levels of ionizing radiation in the Reactor Building and of ionizing radiation and thermal exposure inside Containment exceeded threshold levels for cracking and changes in material properties. Elastomers in HVAC systems in other buildings do not exceed threshold levels for radiation or temperature. The System Walkdown Program is credited for aging management of elastomers in the Reactor Building HVAC and Primary Containment Atmosphere Circulation systems.
Enclosure to PLA-6430 Page 11 of 24 3.3 AGING MANAGEMENT OF AUXILIARY SYSTEMS 3.3.3 Conclusions Table 3.3.2-23, Aging Management Review Results - Reactor Building HVAC System
> Table 3.3.2-23 (LRA page 3.3-302) is revised by addition (bold italics).
Ventilation None None (Internal) Identified Required Change in System Mechanical Pressure lastomer Material Walkdown VII.F3-7 3.3.1-11 A, 0336 Sealants Boundary Indoor Air Properties Program (External) System Cracking Walkdown VII.F3-7 3.3.1-11 A, 0336 Program
Enclosure to PLA-6430 Page 12 of 24 LRA Amendment Item 3 LRA Appendix B Section B.2.30, Buried Piping and Tanks Inspection Program, states that this new AMP will be consistent with NUREG-1801 (GALL),Section XI.M34. To be consistent with GALL, an additional inspection of buried piping within the first ten years of the period of extended operation is added.
The scope of the Buried Piping and Tanks Inspection Program as stated in the LRA includes managing loss of material due to several aging effects, including galvanic corrosion. The aging management review did not identify the presence of dissimilar metals for underground piping and tanks, therefore galvanic corrosion is not an aging effect requiring management. Therefore, galvanic corrosion is deleted as an aging effect being managed.
The SSES LRA is amended as follows to address the above concerns.
B.2 Aging Management Programs B.2.30 Buried Piping and Tanks Inspection Program Aging Management Program Elements
> The Scope of Program discussion under Aging Management Program Elements in Section B.2.30 (LRA pages B-94 and B-95) is revised by deletion (e4tikethrou.h).
Scope of Program The scope of the Buried Piping and Tanks Inspection Program includes buried components that are within the scope of license renewal for SSES. The program is credited for managing loss of material due to crevice, ga"a*,4-,,general, and pitting corrosion and microbiologically influenced corrosion (MIC) for buried steel and cast iron piping components. In addition, the program is credited with managing loss of material for buried stainless steel piping components. The buried components within the scope of this program are in the Condensate Transfer and Storage System, Cooling Tower System, Diesel Fuel Oil System, Emergency Service Water System, Fire Protection System, Residual Heat Removal Service Water System, and Water Pretreatment System.
The Buried Piping and Tanks Inspection Program are also credited for managing loss of material due to general corrosion for buried steel tanks in the Diesel Fuel Oil System.
Enclosure to PLA-6430 Page 13 of 24
- The Detection of Aging Effects discussion under Aging Management Program Elements in Section B.2.30 (LRA pages B-95 and B-96) is revised by addition (bold italics).
Detection of Aging Effects Integrity of coatings and wrappings will be inspected when components are excavated for maintenance or other reasons. An inspection of buried piping will be performed within the 10-year period prior to entering the period of extended operation (i.e., between year 30 and year 40). If an opportunistic inspection has not occurred between year 30 and year 38, an excavation of a section of buried piping for the purpose of inspection will be performed before year 40. An additionalinspection of buried piping will be performed within 10 years afterentering the period of extended operation (i.e.,
between year 40 and year 50). The inspection location will be established based on evaluation of recent operating experience, the condition of buried piping as known based on results of internal inspections or other relevant information, and a risk-based evaluation.
Inspections of the uncoated Fire Protection System piping and uncoated stainless steel piping in the Condensate Transfer and Storage System will be performed when the piping is excavated for maintenance or other reasons. An inspection of the uncoated buried piping will be performed within the 10-year period prior to entering the period of extended operation (i.e., between year 30 and year 40). If an opportunistic inspection has not occurred between year 30 and year 38, an excavation of a section of the piping for the purpose of inspection will be performed before year 40. An additionalinspection of the uncoated buriedpiping will be performed within 10 years after entering the period of extended operation(i.e., between year 40 and year 50). The inspection location will be established based on evaluation of recent operating experience, the condition of buried piping as known based on results of internal inspections or other relevant information, and a risk-based evaluation.
Opportunistic inspections for buried piping are preferable, as the excavation of piping solely for purpose of inspection creates the risk of damaging an otherwise intact and functioning protective coating or of damaging the piping itself.
Enclosure to PLA-6430 Page 14 of 24 A.0 Final Safety Analysis Report Supplement A.1.4 License Renewal Commitment List Table A-1, SSES License Renewal Commitment List Commitment in Table A-1 for Buried Piping and Tanks Inspection Program (LRA page A-43) is revised by deletion (stFikethr-ogh).
Table A-1 SSES License Renewal Commitment List Item Number Commitment FSAR Enhancement or Supplement Implementation Location Schedule (LRA App. A)
- 26) Buried Piping Program is new. A.1.2.3 Prior to the period of and Tanks extended operation.
Inspection The scope of the Buried Piping and Tanks Inspection Program Program includes buried components that are within the scope of license renewal for SSES. The program is credited for managing loss of material due to crevice, galvain, general, and pitting corrosion and microbiologically influenced corrosion (MIC) for buried steel piping components. In addition, the program is credited with managing loss of material for buried stainless steel piping components. The Buried Piping and Tanks Inspection Program is also credited for managing loss of material due to general corrosion for buried steel tanks in the Diesel Fuel Oil System.
Enclosure to PLA-6430 Page 15 of 24 LRA Amendment Item 4 Engineering Change Order ECO 731009, "Reactor Building Permanent Shielding,"
added permanent shielding in the Reactor Building. This is a new Component Type that needs to be addressed in the LRA.
The SSES LRA is amended as follows:
2.4 SCOPING AND SCREENING RESULTS: STRUCTURES 2.4.2 Reactor Building Table 2.4-2, Reactor Building Components Subject to Aging Management Review Table 2.4-2 (LRA page 2.4-10) is revised by addition (bold italics).
Table 2.4-2 Reactor Building Components Subject to Aging Management Review Component Type Intended Function (as defined in Table 2.0-1)
PermanentReactorBuilding Shielding SHD, SNS 3.5 AGING MANAGEMENT OF CONTAINMENTS, STRUCTURES, AND COMPONENT SUPPORTS 3.5.2 Results 3.5.2.1.2 Reactor Building The Materials discussion under Section 3.5.2.1.2 (LRA page 3.5-4) is revised by addition (bold italics).
Materials Reactor Building components subject to aging management review are constructed of the following materials:
" Aluminum
- Boral
- Carbon Steel
- Concrete
" Concrete blocks
Enclosure to PLA-6430 Page 16 of 24
- Galvanized Steel
" Lead
- Stainless Steel Materials for bulk commodity components are addressed in Section 3.5.2.1.10.
Enclosure to PLA-6430 Page 17 of 24 3.5 AGING MANAGEMENT OF CONTAINMENTS, STRUCTURES, AND COMPONENT SUPPORTS 3.5.3 Conclusions Table 3.5.2-2, Aging Management Review Results - Reactor Building
, The following line Item in Table 3.5.2-2 (LRA page 3.5-81) is revised by addition (bold italics)
Enclosure to PLA-6430 Page 18 of 24 LRA Amendment Item 5 Engineering Change EC 850930, "B.5.b Pumper Building aka Fire Brigade Garage,"
added a new structure at SSES that will house the B.5.b Pumper Truck and Staged Equipment required for implementing the B.5.b strategies.
The SSES LRA is amended as follows:
2.2 PLANT LEVEL SCOPING RESULTS Table 2.2-3, License Renewal Scoping Results for Structures
> Table 2.2-3 (LRA pages 2.2-8 to 2.2-22) is revised by addition (bolditalics).
Table 2.2-3 License Renewal Scoping Results for Structures Structure Name In Scope? Comments / Screening Results Section On-site facility to house the B.5.b Pumper Truck and Staged Equipment requiredforlmplementing the B. 5.b strategies. Single soryo6commercial-grade modular steel structure on a concrete foundation.
Fire Brigade Garage NoNo sp
- Structure provdes support f.r for...
(aka, B.5.b Storage Facility) nonsafety-relatedequipment and equipment not required tosupport regulated events. None of the major
'components in this structureI present a seismic /I/Isituation. The structure does notperform an intended function delineated in 10 CFR 54.4(a).
Enclosure to PLA-6430 Page 19 of 24 LRA Amendment Item 6 LRA Table A-I Commitment #49, Lubricating Oil Inspection, is inconsistent with other LRA sections. This Table A-I item is revised for consistency.
The SSES LRA is amended as follows:
A.0 Final Safety Analysis Report Supplement A.1.4 License Renewal Commitment List Table A-1, SSES License Renewal Commitment List
> The entries under the Commitment and the Enhancement or Implementation Schedule headings in Table A-1 for the Lubricating Oil I
Inspection Program (LRA page A-54) are revised by addition (bold italics).
Table A-1 SSES License Renewal Commitment List Item Number Commitment FSAR Enhancement or Supplement Implementation Location Schedule (LRA App. A)
- 49) Lubricating Oil Program is a new one-time inspection. A.1.2.29 Within the 10- year Inspection period prior period of to the extended The Lubricating Oil Inspection detects and characterizes the condition of materials in systems and components for operation.
which the Lubricating Oil Analysis Program is credited with aging management. The inspection provides direct evidence as to whether, and to what extent, a loss of material or a reduction in heat transfer due to fouling has occurred.
Enclosure to PLA-6430 Page 20 of 24 LRA Amendment Item 7 In Reference 4, PPL added a new license renewal commitment for the "Preventive Maintenance Activities - Main Turbine Casing" AMP, in response to RAI B.2. 11-1. The Table A-I "Item Number" and "A. 1.2 Subsection Number" assigned to this commitment were duplicated via other RAI responses. The LRA is changed to correct these inconsistencies.
The SSES LRA is amended as follows:
LRA Section A. 1.2.49, Fatigue Monitoring Program, remains as added by Reference 5.
The "Preventive Maintenance Activities - Main Turbine Casing" program description added by Reference 4 is renumbered to Section A. 1.2.50.
Appendix A TABLE OF CONTENTS A.1.2 Aging Management Program and Activities The Table of Contents is revised by addition (bold italics).
A. 1.2.48 Thermal Aging and Neutron Embrittlement of Cast Austenitic Stainless Steel (C A S S ) P rogram ................................................................... 2 1 A.1.2.49 Fatigue Monitoring Program ............................ 21 A.1.2.50 Preventive MaintenanceActivities - Main Turbine Casing......... 21 A.1.2 Aging Management Program and Activities The LRA section number for the Preventive Maintenance Activities - Main Turbine Casing program description in Appendix A of the LRA (page A-21) is revised by addition (bold italics) and deletion (6trikethpeugh).
A.1.2.50 Preventive Maintenance Activities- Main Turbine Casing The Preventive Maintenance Activities - Main Turbine Casing is an existing program that manages loss of material due to flow-accelerated corrosion on the internal surfaces of the high pressure casing for the main turbine.
The Preventive Maintenance Activities - Main Turbine Casing is a condition monitoring program detect aging and age-related degradation.
Prior to the period of extended operation, the Preventative Maintenance Activities - Main Turbine Casing will be enhanced to specify that the inspection of the high pressure turbine shell will consist of a VT-3 or equivalent visual inspection of accessible surfaces and an ultrasonic examination of selected locations for wall thickness.
Enclosure to PLA-6430 Page 21 of 24 License renewal commitments #55 and #56 remain as added to LRA Table A-1 by Reference 2.
The "Preventive Maintenance Activities - Main turbine Casing" commitment added by reference 4 is renumbered to #57.
A.1.4 License Renewal Commitment List
> Table A-1 line item for the "Preventive Maintenance Activities - Main Turbine Casing" AMP (LRA page A-55) is revised by addition (bold italics)and deletion (strikethFOUgh).
Table A-1 SSES License Renewal Commitments FSAR Enhancement Supplement or Commitment loca tion Item Number Location Implementation (LRA App. A) Schedule 5-)57) Preventive Existing program is credited with the following enhancement: A.1.2.50 Prior to the period Maintenance Activities- Specify that the inspection of the high pressure turbine shell will 2.'o9n. of extended oAp. a Main Turbine consist of a visual inspection (VT-3 or equivalent) of accessible operation.
surfaces and an ultrasonic examination of selected locations for Casing wall thickness.
The program is plant-specific.
Enclosure to PLA-6430 Page 22 of 24 LRA Amendment Item 8 In Reference 6, PPL revised LRA Table A-I commitment #48 in response to RAI B.2.25-1. The corresponding change should have also been made to LRA section A. 1.2.28, Lubricating Oil Analysis Program. For clarity, changes made previously to this section via Reference 3 in response to RAI 2.3.3.13-5 are also shown.
The SSES LRA is amended as follows:
A.1.2 Aging Management Program and Activities
> Section A.1.2.28 (LRA page A-14) is revised by addition (bold italics).
A.1.2.28 Lubricating Oil Analysis Program The Lubricating Oil Analysis Program is an existing program that mitigates damage due to loss of material and reduction of heat transfer due to fouling for plant components that are within the scope of license renewal and exposed to lubricating oil. The program manages the relevant conditions that could lead to the onset and propagation of a loss of material, or reduction in heat transfer for heat exchanger tubes, through proper monitoring consistent with manufacturer's recommendations, the equipment's importance to safe plant operation, equipment accessibility and American Society for Testing of Materials (ASTM) standards for lubricating oil. The relevant conditions are specific parameters including particulate and water concentrations, viscosity, neutralization number, and flash point that could lead to, or are indicative of, conditions for age-related degradation of susceptible materials. The Lubricating Oil Analysis Program is a mitigation program.
Prior to the period of extended operation, the Lubricating Oil Analysis Program will be enhanced to include sampling of the lubricating oil from the Control Structure Chiller, Reactor Building Chiller,and Diesel Engine Driven Fire Pump when the oil is changed. The oil will be tested for water and for particle count.
The Lubricating Oil Analysis Program is supplemented by the Lubricating Oil Inspection which provides verification of the effectiveness of the Lubricating Oil Analysis Program in mitigating the effects of aging.
Enclosure to PLA-6430 Page 23 of 24 RAI Response Correction Item 1 Correct typographical error in PPL Letter PLA-6407 (Reference 7) response to RAI 3.x.2. l-1. Text should read as NUREG-1801, not NUREG 1081.
The PPL Response to RAI 3.x.2.1-1 is revised as follows:
RAI 3.x.2.1-1:
For aging management review (AMR) Table-2 line items that reference NUREG1801 Volume 2 Items V.B-1 and VII.F3-3, the generic aging lessons learned (GALL) Report recommends that the GALL Report aging management program (AMP) XI.M38 Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components be used to inspect the internal surfaces of steel ducting and components for loss of material. However Susquehanna Steam Electric Station (SSES) has credited the System Walkdown Program for aging management of the internal surfaces of steel ducting and components for loss of material in the Standby Gas Treatment and Primary Containment Atmosphere Circulation System. The Systems Walkdown Program is the AMP that is analogous to the GALL Report AMP XI.M36 External Surfaces Monitoring which is limited to only visual examinations of alloy steel components on their external surfaces. Provide your basis for crediting the System Walkdown Program, for aging management of loss of material on the internal surfaces of these steel components in the standby gas treatment and primary containment atmosphere circulation system, particularly when there will be no inspections of the internal component surfaces.
PPL Response:
PPL Response is revised by addition (bold italics)and deletion (&tsikethmugh).
The "Scope of Program" element of the GALL Report AMP XI.M36 External Surfaces Monitoring states:
"The program may also be credited with managing loss of material from internal surfaces, for situations in which material and environment combinations are the same for internal and external surfaces such that external surface condition is representative of internal surface condition."
NUREG-1801 item V.B-1 is compared to the results for the ventilation (internal) environment in the Standby Gas Treatment System for steel fan and filter housings, filter unit enclosures, piping, plenums, and valve bodies. For the aging management review results that credit the System Walkdown Program, the internal ventilation environment is considered to be equivalent to the environment for the external surfaces because the system is normally in a standby mode with the same relative conditions of temperature and humidity. The Supplemental Piping/Tank Inspection is identified to provide verification of the effectiveness of the System Walkdown Program for internal surfaces where a different environment is expected at the air/water interface of the mist eliminator loop seals. Therefore, inspection of external surfaces for indications of loss of material is considered to be representative of the condition of the internal surfaces and a one-time inspection is specified where the conditions may be different.
Enclosure to PLA-6430 Page 24 of 24 NUREG..0-11801 item VII.F3-3 is compared to the results for the ventilation (internal) environment in the Primary Containment Atmosphere Circulation System for steel fan housings and unit cooler housings. For the aging management review results that credit the System Walkdown Program, the internal ventilation environment is considered to be equivalent to the environment for the external surfaces because the system functions to circulate air within the containment. Condensation, if it occurs, is expected to form on the external surfaces of the components. Therefore, inspection of the external surfaces for indications of loss of material will be conservatively representative of the condition of the internal surfaces. The Cooling Units Inspection is identified to provide verification of the effectiveness of the System Walkdown Program for internal surfaces where internal condensation may occur. Therefore, inspection of external surfaces for indications of loss of material is considered to be representative of the internal surface conditions and a one-time inspection is specified where the conditions may be different.