PLA-6484, Operating License No. NPF-14 License Conditions 2.c.(36)(B)2 and 2.c.(36)(B)4 and Unit 2 Operating License No. NPF-22 License Conditions 2.c.(20)(B)1 and 2.c.(20)(B)2. Enclosure 3
| ML090770446 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 02/27/2009 |
| From: | Spence W PPL Corp |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| PLA-6484 | |
| Download: ML090770446 (13) | |
Text
William H. Spence PPL Corporation Executive Vice President and Two North Ninth Street Chief Operating Officer/Chief Nuclear Officer Allentown, PA 18101-1179 Tel. 610.774.3683 Fax 610.774.5019 Tel. 610.774.5151 4f 0 Whspence@pplweb.com www.pplweb.com soft-bap FEB 2 7 2009 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Stop O-P1-17 Subinnitted Pursuant To Washington, DC 20555 10 CFR 2.390 SUSQUEHANNA STEAM ELECTRIC STATION UNIT 1 OPERATING LICENSE NO. NPF-14 LICENSE CONDITIONS 2.C.(36)(b)2 AND2.C.(36)(b)4 AND UNIT 2 OPERATING LICENSE NO. NPF-22 LICENSE CONDITIONS 2.C.(20)(b)1 AND 2.C.(20)(b)2 Docket Nos. 50-387 PLA-6484 and 50-388
Reference:
"SusquehannaSteam Electric Station, Units I and 2 - Issuance of Amendment Regardingthe 13-PercentExtended Power Uprate (TAC Nos. MD3309 and MD3310), "dated January 30, 2008.
"SusquehannaSteam Electric Station ProposedLicense Amendment No. 285for Unit 1 OperatingLicense No. NPF-14and ProposedLicense Amendment No. 253for Unit 2 OperatingLicense No. NPF-22 Constant PressurePower Uprate Application -
Supplement, " dated January25, 2008.
"SusquehannaSteam Electric Station ProposedLicense Amendment No. 285for Unit 1 OperatingLicense No. NPF-14 and ProposedLicense Amendment No. 253for Unit 2 OperatingLicense No. NPF-22 Extended Power UprateApplication regardingSteam Dryerand Flow Effects Request for Additional InformationResponses,"
dated April 27, 2007.
The purpose of this letter is to provide the information to satisfy the Susquehanna SES (SSES) Unit 1 license conditions (LC) 2.C.(36)(b)2 and 2.C.(36)(b)4 and Unit 2 license conditions 2.C.(20)(b)1 and 2.C.(20)(b)2 in Reference 1.
This information includes proprietary and non-proprietary versions of the updated dryer stress report and a revised main steam line (MSL) limit curve report and a listing of the dryer component worst case fatigue margin. Also included is the Unit 2 Power Ascension Test Plan (PATP). The following describes how the information provided satisfies each of the above license conditions. S(tllot
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Document Control Desk PLA-6484 Unit 1 LC 2.C.(36)(b)2 - "After the dryerstress analysis is benchmarked to the Unit ]
startup test data (Unit ] data taken up to 107% of 3489 MWt), the benchmark results and updated MSL limit curves shall be provided to the NRC 90 days prior to operationabove 107% of 3489 MWT. "
This condition is met by submittal of the updated dryer stress report and the revised MSL limit curve report. Unit 1 operation above 107% of 3489 MWt will not occur prior to the end of the Unit 1 refueling outage in 2010. (See Enclosures 1 and 2).
Unit 1 LC 2.C.(36)(b)4 - "After reaching 107% of CLTP, PPL shall obtain measurementsfrom the steam dryer instrumentationand establish the steam dryerflow-induced vibration loadfatigue marginfor the facility, update the dryer stress report, and re-establish the limit curve with the updated ACM load definition and revised instrument uncertainty, which will be provided to the NRC staff "
This condition is met by submittal of the updated dryer stress report and the revised MSL limit curve report. The acoustic load definition used to develop the revised limit curves is discussed in the updated dryer stress report. The revised instrument uncertainty is discussed in the updated dryer stress report. (See Enclosures 1 and 2).
Unit 2 LC 2.C.(20)(b)1 - "PPL shallprovide to NRC the as-built dryer stress analysis and load limit curves 45 days prior to operation above 3489 MWt. "
- This condition is met for Unit 2 by Reference 2, which is the previous submittal of the as-built dryer stress analysis, and the revised MSL limit curve report. (The as-built dryer stress analysis previously submitted is applicable to both Units 1 and 2.) Unit 2 operation above 3489 MWt will not occur prior to the end of the Unit 2 refueling outage in late spring 2009. (See Reference 2 and Enclosure 2).
Unit 2 LC 2.C.(20)(b)2 - "After the dryer stress analysis is benchmarked to the Unit 1 startup test data (Unit ] data taken up to 107% of 3489 MWt), the benchmarked PATP and MSL limit curves shall be provided to the NRC 90 days priorto operation above 107% of 3489 MWt."
- This condition is met by submittal of the updated dryer stress report and the revised MSL limit curve report and the Unit 2 Power Ascension Test Plan (PATP). Unit 2 operation above 107% of 3489 MWt will not occur prior to the end of the Unit 2 refueling outage in late spring 2009. (See Enclosures 1, 2 and 3). contains the proprietary version of the GE-Hitachi (GEH) "Susquehanna Replacement Steam Dryer Updated Stress Analysis at Extended Power Uprate Conditions." This updated dryer stress report contains information obtained during the Unit 1 power ascension to the 3733 MWt Extended Power Uprate (EPU) operating
Document Control Desk PLA-6484 conditions. The report was prepared by GEH and it contains updated information originally submitted in Reference 2. contains the proprietary version of the GE-Hitachi (GEH) "Revised Susquehanna Replacement Steam Dryer Limit Curves - Main Steam Line Mounted Instrumentation." This report utilized data from Reference 2 to re-establish new main steam line limit curves, applicable to both Units 1 and 2, that will be used as the formal acceptance criteria for future SSES EPU power ascensions. contains the "Susquehanna Steam Electric Station Unit 2 Constant Pressure Power Uprate Flow Induced Vibration Power Ascension Test Plan" (PATP). The Unit 2 PATP contains information, which is similar to the Unit 1 PATP previously submitted in Reference 3. contains the proprietary version of the table "SSES Dryer Component Worst Case Fatigue Margin Under Projected EPU Conditions." This table reflects the worst case stress values and overall uncertainty. It was developed from data in Tables 5 and 7 of the updated stress report in Enclosure 1.
The information contained in Enclosures 1, 2, and 4 is proprietary as defined by 10 CFR 2.390. GEH as the owner of the proprietary information, has executed the enclosed affidavits, which identify that the enclosed proprietary information has been handled and classified as proprietary, is customarily held in confidence, and has been withheld from public disclosure. The proprietary information was provided to PPL in a GEH transmittal that is referenced by the affidavit. The proprietary information has been faithfully reproduced in the enclosed information such that the affidavit remains applicable. PPL hereby requests that the enclosed GEH proprietary information be withheld from public disclosure in accordance with the provisions of 10 CFR 2.390 and 9.17.
The header of each page in Enclosures 1, 2 and 4 carries the notation "GEH Proprietary Information" GEH proprietary information is identified by a dotted underline inside double square brackets. ((This sentence is an example. (3).)) In all cases, the superscript notation( 31 refers to Paragraph (3) of the GEH affidavit, which provides the basis for the proprietary determination. Specific information that is not so marked is not GEH proprietary. contains the non-proprietary version of the GE-Hitachi (GEH) "Susquehanna Replacement Steam Dryer Updated Stress Analysis at Extended Power Uprate Conditions."
Document Control Desk PLA-6484 contains the non-proprietary version of the GE-Hitachi (GEH) "Revised Susquehanna Replacement Steam Dryer Limit Curves - Main Steam Line Mounted Instrumentation." contains the non-proprietary version of the table "SSES Dryer Component Worst Case Fatigue Margin Under Projected EPU Conditions" contains a correlation of the references in the GEH updated stress report and the MSL limit curve report to other GEH and PPL references. contains the signed GEH affidavits associated with each of the proprietary documents.
If you have any questions or require additional information, 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: ,P 2 -;7e
_?
W. H. Spence - Proprietary Version - "Susquehanna Replacement Steam Dryer Updated Stress Analysis at Extended Power Uprate Conditions". - Proprietary Version - "Revised Susquehanna Replacement Steam Dryer Limit Curves - Main Steam Line Mounted Instrumentation." - "Susquehanna Steam Electric Station Unit 2 Constant Pressure Power Uprate Flow Induced Vibration Power Ascension Test Plan" (PATP) - Proprietary Version - "SSES Dryer Component Worst Case Fatigue Margin Under Projected EPU Conditions" - Non Proprietary Version - "Susquehanna Replacement Steam Dryer Updated Stress Analysis at Extended Power Uprate Conditions". - Non Proprietary Version - "Revised Susquehanna Replacement Steam Dryer Limit Curves - Main Steam Line Mounted Instrumentation."
Document Control .Desk PLA-6484 - Non Proprietary Version - "SSES Dryer Component Worst Case Fatigue Margin Under Projected EPU Conditions" - Cross Reference of GEH Documents - Affidavits Copy: NRC Region I Mr. R. R. Janati, DEP/BRP Mr. F. W. Jaxheimer, NRC Sr. Resident Inspector Mr. B. K. Vaidya, NRC Project Manager
Enclosure 3 to PLA-6484 "Susquehanna Steam Electric Station Unit 2 Constant Pressure Power Uprate Flow Induced Vibration Power Ascension Test Plan" (PATP)
SUSQUEHANNA STEAM ELECTRIC STATION I UNIT 2 CONSTANT PRESSURE POWER UPRATE FLOW INDUCED VIBRATION POWER ASCENSION TEST PLAN (PATP) 1 INTRODUCTION AND PURPOSE The Unit 2 Susquehanna Steam Electric Station (SSES) Constant Pressure Power Uprate (CPPU) Flow Induced Vibration (FIV) Power Ascension Test Plan (PATP) describes the planned course of action for monitoring and evaluating the performance of the Steam Dryer as well as the Main Steam and Feedwater piping systems during power ascension testing and operation above 100% of the previously licensed thermal power level (3489 MWth). The PATP covers power ascension up to the full CPPU condition to verify acceptable performance and steam dryer and piping system integrity. Through the establishment of operating limits, data collection and analysis, and any subsequent actions, the PATP will ensure that the integrity of the steam dryer and piping systems will be maintained in an acceptable state. This PATP is a portion of the overall CPPU start-up testing described in Attachment 8 of PPL's CPPU License Amendment Request (Reference 1).
The plan includes specific hold points and durations during power ascension above 3489 MWth; activities to be accomplished during hold points; data to be collected; required inspections and walk downs; data evaluation methods; and acceptance criteria for monitoring and trending plant parameters. Detailed procedures are developed to implement this plan. These procedures are submitted to the NRC in accordance with the license conditions specified in Reference 2 of this enclosure.
2 POWER ASCENSION TEST PLAN (PATP) SCOPE This PATP assesses steam dryer and selected piping system performance for the Susquehanna Steam Electric Station (SSES) Unit 2 CPPU start-up power ascension process. The PATP will also perform confirmatory steam dryer inspections for a period of time following initial and continued operation at uprated power levels. Power ascension above 3489 MWth will be achieved in a series of 3.5% power step increases.
There are three main elements of the PATP:
- 1) Slow and deliberate power ascension with defined hold points and durations, allowing time for monitoring and analysis.
- 2) A detailed power ascension monitoring and analysis program to trend steam dryer and critical piping system performance through the monitoring of Main Steam Line (MSL) strain gauges, piping accelerometers, and moisture carryover.
- 3) An inspection and analysis program to verify steam dryer and piping system performance above 3489 MWth operations.
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SUSQUEHANNA STEAM ELECTRIC STATION UNIT 2 CONSTANT PRESSURE POWER UPRATE FLOW INDUCED VIBRATION POWER ASCENSION TEST PLAN (PATP) 2.1 Power Ascension Detailed test procedures are developed for the implementation of the actual power ascension testing evolutions. The SSES Unit 2 power ascension will occur over a period of time with gradual increases in power, hold periods, and engineering analysis of monitored data prior to subsequent power increases. The PATP includes (but is not limited to):
- 1) Collection of baseline data at 3489 MWth;
- 2) Power ascension rate of- 1%/hr above 3489 MWth;
- 3) Data evaluated at every 3.5% power step increase against acceptance criteria.
2.2 Monitoring and Analysis The assessment of the system/component performance and integrity will be completed through the analysis of both main steam line and feedwater instrumentation and dryer moisture carryover data.
Power ascension above 3489 MWth will be achieved via the following methodology:
- 1) Obtain baseline observations at 3489 MWth;
- 2) Maximum hourly power increase restriction -1 % per hour (-34.8 MWt)
- 3) Each 3.5% power ascension step (-122 MWt)
- Compare vibration data to acceptance criteria
- Obtain & evaluate moisture carryover data
" Perform plant walk downs
" Review data evaluation and walk down results The duration of the individual 3.5% power ascension steps will be determined by the time required to obtain the specified data, completion of data evaluation, determination of the acceptability to proceed, and a 96 hour0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> hold period in accordance with the license conditions specified in Reference 2 of this enclosure.
As noted, system performance and integrity will be evaluated based on the review and analysis of both MSL strains and moisture carryover values. For both the strain and moisture carryover elements, acceptance criteria is established for use in the subject analysis. Data evaluation / analyses will be performed by comparing actual obtained Page 3 of 8
SUSQUEHANNA STEAM ELECTRIC STATION UNIT 2 CONSTANT PRESSURE POWER UPRATE FLOW INDUCED VIBRATION POWER ASCENSION TEST PLAN (PATP) data against the acceptance criteria. Both the strain and moisture carryover criteria will provide two action levels, which are used in determining the acceptability of the continuance of power ascension increases. The following information further defines the action levels for both the piping and MSL strains and moisture carryover analyses:
2.2.1 Pipe Stress Evaluation Data evaluation / analysis will be performed by comparing accelerometer data obtained at each 3.5% power ascension step over 3489 MWth against the acceptance criteria.
The subject acceptance criteria as derived from plant specific analyses, which are based on actual piping geometries, will provide two action levels. The development of vibration acceptance criteria is discussed in Section 6, Attachment 9 of Reference 1.
The action levels and the required actions are:
Level 1: Allowable Stress Exceeded
- Action - Reduce power to previous acceptable level Level 2: Low Margin to Allowable Stresses
- Action - Hold at current power level and re-evaluate 2.2.2 Steam Dryer Monitoring/Evaluation Steam dryer stress for all Unit 2 steps will be monitored using main steam line strain readings. Evaluation of the strain gauge data will be by comparison against the limit curves developed in the updated limit curves report, which is provided as Enclosure 2 to PPL Letter PLA-6484. The action levels and the required actions are:
Level 1: Allowable Stress Exceeded
- Action - Reduce power to previous acceptable level Level 2: Low Margin to Allowable Stresses 0 Action - Hold at current power level and re-evaluate Page 4 of 8
SUSQUEHANNA STEAM ELECTRIC STATION UNIT 2 CONSTANT PRESSURE POWER UPRATE FLOW INDUCED VIBRATION POWER ASCENSION TEST PLAN (PATP) 2.2.3 Moisture Carryover Evaluation Data evaluation / analysis will be performed by comparing moisture carryover data obtained at each 3.5% power ascension step over 3489 MWth against the predetermined acceptance criteria. The subject acceptance criteria and the required action upon failure are:
Level 1: N/A
- Action - None Level 2: Moisture carryover *<0.1% by weight 0 Action - Hold at current power level and re-evaluate 2.2.4 Data Collection Methods and Locations A. Pipe / Component Stress
- 1. Piping Inside the Drywell Main Steam and Feedwater piping inside the drywell will be monitored using accelerometers with data recorded on a Data Acquisition System (DAS) located outside of the drywell. Monitoring locations were established based on detailed analysis of the SSES piping which identified the optimal quantity and locations of the subject sensors. Instrumentation to be used for monitoring piping flow induced vibration is discussed in Section 7, Attachment 9 of Reference 1.
- 2. Components Inside the Drywell Individual components inside the drywell will be monitored using accelerometers with data recorded on a DAS located outside of the drywell.
Locations have been chosen based upon recent industry experience with component failures during CPPU conditions in conjunction with engineering judgment as to the susceptibility of the components. Two (2)
Main Steam Safety Relief Valves (SRVs) per unit have been selected for monitoring. A complete list of components is provided in the Appendices of Attachment 9 of Reference 1.
- 3. Piping Outside the Drywell Process piping will be monitored via walk downs and inspections to the extent practical. If unexpected conditions are observed, vibration levels will be quantified and evaluated using ASME O/M-S/G Part 3 guidelines.
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SUSQUEHANNA STEAM ELECTRIC STATION UNIT 2 CONSTANT PRESSURE POWER UPRATE FLOW INDUCED VIBRATION POWER ASCENSION TEST PLAN (PATP)
B. Steam Dryer
- 1. Moisture Carryover Moisture Carryover data collection will be completed via the implementation of existing station operating procedures.
- 2. Main Steam Line Strain Gauges Strain Gauge locations as discussed in Attachment 10 of Reference 1 will be monitored. Data obtained from the strain gauges will be recorded on a DAS located outside of the drywell.
2.2.5 Inspections and Walk Downs As discussed in Attachment 9 of Reference 1, piping, valves and other related components outside the drywell will be monitored visually, either by walk down or cameras at each test power level. If visual observation indicates significant vibration, the noted condition will be evaluated in more detail.
2.2.6 Other Monitoring Plant data that may be indicative of off-normal steam dryer and or piping system performance will be monitored during power ascension (e.g. reactor water level, steam flow, feed flow, steam flow distribution between the individual steam lines). Plant data can provide an early indication of unacceptable steam dryer/system performance. The enhanced monitoring of selected plant parameters will be controlled by test procedure.
2.2.7 NRC Communication PPL Letter PLA-6408 (Reference 3) provided a written report following completion of Unit 1 power ascension testing. Subsequent written reports will be provided following completion of power ascension testing after CPPU implementation outages. These reports will outline the evaluations or corrective actions that were required to obtain satisfactory steam dryer performance. Additionally, they will include relevant data collected at each power step, comparisons to performance criteria (design predictions),
and evaluations performed in conjunction with steam dryer structural integrity monitoring.
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SUSQUEHANNA STEAM ELECTRIC STATION UNIT 2 CONSTANT PRESSURE POWER UPRATE FLOW INDUCED VIBRATION POWER ASCENSION TEST PLAN (PATP) 3 POST CPPU MONITORING & INSPECTION PROGRAM Monitoring of various plant parameters, potentially indicative of steam dryer / system failure will be continued after completion of the test program. Monitoring results will be made available to the NRC Staff. The following inspections will be performed:
3.1 Moisture Carryover Station operating procedures will be used to monitor operating moisture carryover conditions. Results will be reviewed / evaluated on a defined basis to monitor moisture carryover conditions.
3.2 Strain Gauge / Accelerometer Monitoring As the previously installed main steam line strain gauges and accelerometers remain operable, future data collection will be performed as deemed appropriate during the remainder of the operating cycles following CPPU implementation. The Unit 1 steam dryer instrumentation is expected to be rendered non-functional for the third and fourth power ascension steps.
3.3 Steam Dryer Monitoring and Inspection The steam dryer inspection and the monitoring of plant parameters, potentially indicative of steam dryer failure, will be conducted. Future steam dryer non-destructive examinations during refueling outages will be conducted in accordance with BWRVIP- 13 9 and GE-Hitachi Nuclear Energy (GEH) recommendations regarding the new dryer weld configurations.
3.4 Inspections and Walk Downs During the subsequent refueling outage or other outage that provides access for inspection, piping, valves and other related components inside and outside the drywell will be monitored visually by walk down. If visual observation indicates significant vibration, the noted condition will be documented in the corrective action program and evaluated in more detail.
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SUSQUEHANNA STEAM ELECTRIC STATION UNIT 2 CONSTANT PRESSURE POWER UPRATE FLOW INDUCED VIBRATION POWER ASCENSION TEST PLAN (PATP) 4 REFERENCES
- 1) PPL Letter PLA-6076, B.T. McKinney (PPL) to USNRC, "Proposed License Amendment Numbers 285 for Unit 1 Operating License No.NPF-14 and 253 for Unt 2 Operating License No. NPF-22 Constant Pressure Power Uprate",
dated October 11, 2006
"Susquehanna Steam Electric Station, Units 1 and 2 - Issuance of Amendment Regarding the 13-Percent Extended Power Uprate (TAC Nos.
MD3309 and MD33 10)," dated January 30, 2008.