PLA-6457, License Renewal Application (LRA) Amendments to LRS and RAI Responses

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License Renewal Application (LRA) Amendments to LRS and RAI Responses
ML083440316
Person / Time
Site: Susquehanna  Talen Energy icon.png
Issue date: 11/25/2008
From: Spence W
PPL Corp
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
PLA-6457
Download: ML083440316 (11)
v • d • e


Text

William H. Spence PPL Corporation  % %~g Executive Vice President and Two North Ninth Street

  • ilef Operating Officer/Clijef Nuclear Officer Allentown, PA 18101-1179 Tel. 610.774.3683 Fax 610.774.5019 Tel. 610.774.5151 Wbspenee@pplweb.com www.pplweb.conm

AMENDMENTS TO LRA AND RAI RESPONSES Docket Nos. 50-387 PLA-6457 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) PI*A-6370, Mr. B. T. McKinney (PPL)to Document Control Desk (USNRC), "Units 1 and 2 Licensee Renewal Application (LRA) Ainendment to Section 4.2.2, " dated June 09, 2008.
3) PLA-6397, Mr. B. T. McKinney (PPL)to Document ControlDesk (USNRC), "Request for Additional Informationfor the Review of the SusquehannaSteam Electric Station Units 1 and 2, License Renewal Application (LRA) Sections B.3.1, 4.3, and4.7," dated August 01, 2008.
4) PLA-6413, Mr. B. T. McKinney (PPL) to Document Control Desk (USNRC), "Request for Additional Informationfor the Review of the Susquehanna Steam Electric Station Units 1 and 2, License Renewal Application (LRA) Section 2.5," dated August 29, 2008.
5) PLA-6428, Mr. B. T. McKinney (PPL)to Document Control Desk (USNRC),

"Amendmnents 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," dated September 30, 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.

Document Control Desk PLA-6457 The enclosure to this letter provides amendments to various sections of the SSES License Renewal Application (LRA) and changes to previously submitted responses to Requests for Additional Information (RAI). These changes are necessary to ensure consistency between impacted LRA sections and to update previously submitted information.

There are no new regulatory commitments contained herein. However, License Renewal Commitments #9, #24 and #36 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: /,

W. H. Spence

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-6457 Amendments to SSES License Renewal Application (LRA) and Changes to RAI Responses

Enclosure to PLA-6457 Page 2 of 9 Therefore, the effects of neutron radiationhave been evaluated,and all RPVbeltline materialsfor Units I and 2 have been demonstratedto remain in compliance with Appendix G of 10 CFR 50 for the period of extended operation.

LRA Amendment Item 2 The SSES LRA was previously amended by Reference 5 to ensure the internal surfaces of the diesel generator starting air receivers are monitored for degradation. Page 4 of the enclosure to Reference 5 revised the "Scope of Program" element of the Supplemental Piping/Tank Inspection in LRA Section B2.28 (on LRA page B-88) to include the Diesel Generator starting air receiver tanks and E diesel compressor skid air receiver tanks. The corresponding change to LRA Appendix A, Table A-i, Item 24 was inadvertently omitted in the previous amendment. Therefore, the LRA is amended as follows to add the subject air receiver tanks to the scope of the Supplemental Piping/Tank Inspection in Appendix A, Table A-i, Item 24.

Enclosure to PLA-6457 Page 3 of 9

> The following line item in Appendix A, Table A-1, Item 24 (on LRA page A-42) is revised by addition (bold italics)to include the Diesel Generator starting air receiver tanks and E diesel compressor skid air receiver tanks, as follows:

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

24) Supplemental Program is a new one-time inspection. A.1.2.46 Within the 10-year Piping/Tank The Supplemental Piping/Tank Inspection is credited for managing loss of period prior to the Inspection material due to crevice adperiod and pitting corrosion on carbon steel surfaces at air- of extended operation.

water interfaces. The inspection is also credited for managing loss of material due to microbiologically influenced corrosion (MIC) at the air-water interface with the mist eliminator loop seal, which is filled with raw water from the Service Water System, and galvanic corrosion at points of contact between the mist eliminator housing and the SGTS filter enclosure, where condensation and water pooling may occur. Additionally, the Supplemental Piping/Tank Inspection detects and characterizes whether, and to what extent, a loss of material due to crevice and pitting corrosion is occurring (or is likely to occur) for stainless steel surfaces at air-water interfaces. The Supplemental Piping/Tank Inspection also detects and characterizes 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 within the Diesel Generatorstartingairreceiver tanks andE diesel compressor skid air receiver tanks to determine whether, and to what extent, degradation is occurring (or is likely to occur).

Enclosure to PLA-6457 Page 4 of 9 LRA Amendment Item 3 The SSES LRA was previously amended by Reference 4 to expand the Station Blackout scoping boundary. Page 26 of Reference 4 revised the "Scope of Program" element of the Non-EQ Electrical Cables and Connections Visual Inspection Program in LRA Section B2.41 (on LRA page B-123) to include the cables and connections within the scope of license renewal located in the yard areas and control cubicles of the T10 230 kV Switchyard, the 500 kV Switchyard, and the 230 kV Switchyard. The corresponding change to LRA Appendix A, Table A-1, Item 36 was inadvertently omitted in the previous amendment. Therefore, the LRA is amended as follows to add the subject control circuits to the scope of the Non-EQ Electrical Cables and Connections Visual Inspection Program in Appendix A, Table A-I, Item 36.

Enclosure to PLA-6457 Page 5 of 9

> The following line item in Appendix A, Table A-1, Item 36 (on LRA page A-47) is revised by addition (bold italics)to include the cables and connections within the scope of license renewal located in the yard areas and control cubicles of the T1O 230 kV Switchyard, the 500 kV Switchyard, and the 230 kV Switchyard, as follows:

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

36) Non-EQ Program is new. A.1.2.35 Prior to the period Electrical Cables The Non-EQ Electrical Cables and Connections Visual Inspection Program of extended and Connections is credited with detecting aging effects from adverse localized environments operation.

Visual Inspection in non-EQ cables and connections at SSES. The program is applicable to Program non-EQ cables and connections found in the Reactor Buildings, Circulating Water Pumphouse and Water Treatment Building, Control Structure, Diesel Generator Buildings, Turbine Building, Engineered Safeguards Service Water Pumphouse, and various yard structures (manholes, duct banks, valve vaults, instrument pits, etc.). This program is also applicableto the cables and connections within the scope of license renewal locatedin the yard areasand control cubicles of the TIO 230 kVSwitchyard, the 500 kV Switchyard, and the 230 kV Switchyard.

Enclosure to PLA-6457 Page 6 of 9 LRA Amendment Item 4 PPL's response to RAI 4.3-4 submitted via Reference 3 included reference to BWRVIP-183. Because BWRVIP-183 has not been approved by the NRC, the staff has requested that the reference to it be removed from the RAI response. The following revised response is a complete replacement for the previous response submitted in Reference 3.

RAI 4.3.-4:

BWR Vessel Internals Program is credited to manage the effects of aging for the reactor vessel internals. However, this AMP only inspects the top guide for the first twelve years of period of extended operation. Top guide is subject to irradiation assisted stress corrosion cracking, state how this aging effect will be managed for the remainder for the period of extended operation.

PPL Response:

During the period of extended operation, the aging of the top guide will be managed by inspections conducted as part of the SSES BWR Vessel Internals Program. Since submittal of the SSES LRA in Reference 1, the SSES BWR Vessel Internals Program has been revised to include requirements to inspect the top guide. The SSES BWR Vessel Internals Program now requires that at least 10% of the grid beam cells containing control rod drives/blades will be inspected every twelve years with at least 5%,10 of the inspections being performed within the first six years of each twelve year interval. The top guide locations to be inspected are those subject to neutron fluence levels that exceed the IASCC threshold of 5.OE+20 n/cm 2. The inspections will be performed using the enhanced visual inspection technique, EVT-1.

PPL will continue to perform inspections on at least 10% of the top guide locations every twelve years during the period of extended operation.

Since the SSES BWR Vessel Internals Program has been revised to make it consistent with NUREG-1801, XI.M9, the enhancement to the BWR Vessel Internals Program described in the SSES LRA is not needed. The SSES LRA is amended to remove the enhancement from LRA Section A.1.2.10, LRA Table A-1 (Commitment #9), LRA Section B.2.9, and LRA Table B-2.

Enclosure to PLA-6457 Page 7 of 9 A.1.2.10 BWR Vessel Internals Program

> The discussion of the SSES BWR Vessel Internals Program in Section A.1.2.10 (LRA page A-8) is revised by deletion (strikethfeug) as follows:

I I _ A-t1_ _ TflrTfl * . .. 1 T I - _I

.. rier to tnc pe.o ....extenI. oper-t, .n, the WwIK v esset intemais wint i ,..g.a..

ennanee,

.. to require spe.m, erefanceea lvisupi examinatiens of top guide locations subjectcd to high neutron fluenece.

Table A-1 SSES License Renewal Commitments

> The commitment for the SSES BWR Vessel Internals Program in Table A-1, Item 9 (LRA A-35) is revised by addition (bold italics) and deletion (stfikethfough) as follows:

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

9) BWR Vessel Internals Existing program is credited. with the following enhaneem.nt:,. A.1.2.10 Prior- the Program requirements to inspet five per..ent

.Include .f top guide locatiens..

the .....

within si years allcr-entcr-ing the period of extended oper-ation and an xt~ende additional five perccent of the top nuide locations within twelve y'ears pfliB after-entering the period of extended epefatien. The top guide locationsOnog to be inspected are these subject to nieutroen fluenee levels that exceed theOgig IASCC threshold of 5.0&+/-20 fn/em2. The inspeetions shall be perfonrmed using the enhanced visual inspection technique, EVT 1. The extent of the examination and its frequency will be based on a ten perceent sample oe the total population, which includes all grid beam and beam to beam e~eiee-sAets __

Enclosure to PLA-6457 Page 8 of 9 B.2.9 BWR Vessel Internals Program

> The discussion under the NUREG-1 801 Consistency and Required Enhancements in LRA Section B.2.9 (LRA page B-34) is revised by addition (bold italics)and deletion (St)ikethreig as follows:

NUREG-1801 Consistency The BWR Vessel Internals Program is an existing SSES program that-, with enhancemien.t.,

will-be that is consistent with the 10 elements of an effective aging management program as described in NUREG-1801,Section XI.M9, "BWR Vessel Internals."

Exceptions to NUREG-1801 None.

Required Enhancements None.

Prior-to the period of extended operation the enhancements listed belo)w-will-be T-SeBonp oPien ogam The progr-am will include requirements to inspect five perceent of the-tep guide locations within six years after-entering the period of exteided-oper~ation anid aln additional five percent of the top guide locations within twelve years after entering the period of extended oper-ation. The top guide locations to be inspected are those subject to neutroen fluence levels that exceed the IASCC thfesheld of S.0E#

m'cm2. The inspections shall be per-fored using the enhanced- vsal ifspeetie~

teelmique, EVT- 1. The extent of the examination and its fiequeney will be based on a ten perceent sample of the total population, which includes alg-dba n beam to beam cr-evice slots.

Table B-2 Consistency of SSES Aging Management Programs with NUREG-1801

> LRA Table B-2 (LRA page B-14) is revised by addition (bold italics) and deletion (striketgfreug ) as follows:

Enclosure to PLA-6457 Page 9 of 9 Table B-2 Consistency of SSES Aging Management Programs with NUPEG-1801 New I Consistent Exceptions Plant- Enhancement Program Name Existing with NUREG- to NUREG-1801 1801 Specific Required BWR Vessel ID Attachment Welds Existing Yes --....

Program BWR Vessel Internals Program Existing Yes .... Yes--

BWR Water Chemistry Existing Yes .....

Program I I I I I

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