View source for L-PI-07-044, Response to NRC Generic Letter 2007-01: Inaccessible or Underground Power Cable Failures That Disable Accident Mitigation Systems or Cause Plant Transients

{{Adams
| number = ML071290142
| issue date = 05/08/2007
| title = Response to NRC Generic Letter 2007-01: Inaccessible or Underground Power Cable Failures That Disable Accident Mitigation Systems or Cause Plant Transients
| author name = Weinkam E
| author affiliation = Nuclear Management Co, LLC
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR/ADRO
| docket = 05000282, 05000306
| license number = DPR-042, DPR-060
| contact person = 
| case reference number = GL-07-001, L-PI-07-044
| document type = Letter type:L
| page count = 5
}}

=Text=
{{#Wiki_filter:Committed to Nuclear Excellence                                                   Prairie lsland Nuclear Generating Plant
                          /                                             Operated by Nuclear Management Company, LLC May 8,2007                                                                                        L-PI-07-044 10 CFR 50.54(f)
GL 2007-01 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Prairie Island Nuclear Generating Plant Units 1 and 2 Dockets 50-282 and 50-306 License Nos. DPR-42 and DPR-60 Response to NRC Generic Letter 2007-01: lnaccessible or Underground Power Cable Failures that Disable Accident Mitiqation Systems or Cause Plant Transients By letter dated February 7, 2007, the NRC issued Generic Letter (GL) 2007-01. This GL requires addressees to submit a written response within 90 days of this GL.
In accordance with the provisions of 10 CFR 50.54(f), Nuclear Management Company, LLC, (NMC) is hereby providing the response to NRC Generic Letter 2007-01:
"lnaccessible or Underground Power Cable Failures that Disable Accident Mitigation Systems or Cause Plant Transients," for the Prairie Island Nuclear Generating Plant (PINGP). to this letter provides the NMC response to NRC GL 2007-01 for PINGP.
Summaty of Commitments This letter contains no new commitments and no revisions to existing commitments.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on ~ a * , 2007 Director Nuclear Licensing and Regulatory Services Nuclear Management Company, LLC Enclosure (1) 1717 Wakonade Drive East  Welch, Minnesota 55089-9642 Telephone: 651.388.1 121

Document Control Desk Page 2 cc:    Administrator, Region Ill, USNRC Project Manager, Prairie Island, USNRC Resident Inspector, Prairie Island, USNRC

ENCLOSURE I NMC Response to NRC Generic Letter 2007-01 for PINGP:
Inaccessible or Underground Power Cable Failures that Disable Accident Mitigation Systems or Cause Plant Transients

==1.0     INTRODUCTION==

NRC design criteria require that cables, which are routed underground, be capable of performing their function when subjected to anticipated environmental conditions such as moisture or flooding. Further, the design should minimize the probability of power interruption when transferring power between sources. The cable failures that could disable risk-significant equipment are expected to have monitoring programs to demonstrate that the cables can perform their safety function when called on. However, the recent industry cable failure data indicates a trend in unanticipated failures of underground/inaccessible cables that are important to safety.
Some licensees have detected cable degradation prior to failures through techniques for measuring and trending the condition of cable insulation. Licensees can assess the condition of cable insulation with reasonable confidence using one or more of the following testing techniques: partial discharge testing, time domain reflectometry, dissipation factor testing, and very low frequency AC testing. Licensees can replace faulty cables during scheduled refueling outages prior to cable failure that would challenge plant safety.
2.0     REQUESTED INFORMATION Addressees are requested to submit the following information to NRC within 90 days of the date of this generic letter:
(1)     Provide a history of inaccessible or underground power cable failures for all cables that are within the scope of 10 CFR 50.65 (the Maintenance Rule) and for all voltage levels. Indicate the type, manufacturer, date of failure, type of service, voltage class, years of service, and the root causes for the failure.
(2)     Describe inspection, testing and monitoring programs to detect the degradation of inaccessible or underground power cables that support EDGs, offsite power, ESW, service water, component cooling water and other systems that are within the scope of 10 CFR 50.65 (the Maintenance Rule).
3.0     REQUIRED RESPONSE In accordance with 10 CFR 50.54(f), NMC is requested to submit written responses to this generic letter. This information is sought to verify NMC's compliance with the regulatory requirements listed in the Applicable Regulatory Requirements section of the Generic Letter. The Generic Letter discusses two response options:
3.1     Addressees may choose to submit written response providing the information requested above within the requested time period.
Page 1 of 3

ENCLOSURE I NMC Response to NRC Generic Letter 2007-01 for PINGP:
Inaccessible or Underground Power Cable Failures that Disable Accident Mitigation Systems or Cause Plant Transients 3.2       Addressees who choose not to provide information requested or cannot meet the requested completion dates are required to submit written responses within 30 days of the date of this generic letter. The responses must address any alternative course of action proposed, including the basis for the acceptability of the proposed alternative course of action.
4.0      NMC RESPONSE FOR PRAIRIE ISLAND NUCLEAR GENERATING PLANT NMC is providing the response as described in Option 3.1 above for PINGP.
4.1       Provide a history of inaccessible or underground power cable failures for all cables that are within the scope of 10 CFR 50.65 (The Maintenance Rule) and for all voltage levels. Indicate the type, manufacturer, date of failure, type of service, voltage class, years of service, and the root causes for the failure.
NMC Response:
History of Inaccessible/Underqround Power Cable Failures at PINGP The list of power cable failures that have occurred at PINGP for cables within the scope of the Maintenance Rule is provided in the table below:
lnsulationl                                   Voltage Years of     Root Cause of Manufacturer                  Date of Failure Type of Service Description           No.                     Jacket Material                                  Class  SeMce             Failure Cable                                                                                                         Testing Failure:
3 - 1/c                                                                                          Low megger 24402-2                                         EPR 1                          4.16 kV1 350MCM         Okonite                       9/27/2003                      5 kV     30         reading during 22 Circulating                                  NEOPRENE                         Continuous Unshielded                                                                                            routine Water Pump maintenance Cable C-70                                                                                                      In Service Failure:
A Phase 13.8 kV                                                                                                         Attributed to Feed to Cooling       6-C /I                                                                                         lightning strike T w e r 13.8kV                                                                    13.8 kV1                          causing rise in 1000MCM        Anaconda    EPI NEOPRENE        8/1/2002                      15 kV    29 BUSCT1 (offsite       Shielded                                                     Continuous                        shield potential source to SR busses)
In Service Failure:
Water intrusion Cable C-61                                                                                                     between jacket and A Phase 13.8                                                                                                    insulation migrated kV Feed to         6 - 1/C                                                                                           to pothead Cooling Tower                                                                      13.8 kV/
1000MCM        Anaconda    EP/ NEOPRENE       7/26/2003                      15 kV    30           resulting in a 13.8kV Bus CT2        Shielded                                                     Continuous ground fault. All (offsite source to                                                                                                   13.8kV feeds to SR busses)                                                                                                         Cooling Tower busses were replaced in 2005 Page 2 of 3

ENCLOSURE 1 NMC Response to NRC Generic Letter 2007-01 for PINGP:
Inaccessible or Underground Power Cable Failures that Disable Accident Mitigation Systems or Cause Plant Transients 4.2   Describe inspection, testing and monitoring programs to detect the degradation of inaccessible or underground power cables that support EDGs, offsite power, ESW, service water, component cooling water and other systems that are within the scope of 10 CFR 50.65 (The Maintenance Rule)
NMC Response:
Inspection, Testing and Monitoring Programs at PINGP At PINGP, power cables are routinely tested under preventive maintenance procedures for their loads. As a matter of practice, motors and heaters are meggered from the bus end of their supply cables. This action allows PINGP staff to determine insulation deterioration in either the cables or the load by further testing after disconnecting the load, which eliminates the need to disconnect at the load for performing PMs.
As part of a NMC fleet initiative to enhance the site's ability to monitor undergroundlinaccessible power cable degradation, PINGP intends to implement an "Underground Cable Maintenance Program" by the end of 2007. This action is contained in the PINGP Corrective Action Program.
Page 3 of 3}}

=Text=
{{#Wiki_filter:Committed to Nuclear Excellence                                                   Prairie lsland Nuclear Generating Plant
                          /                                             Operated by Nuclear Management Company, LLC May 8,2007                                                                                        L-PI-07-044 10 CFR 50.54(f)
GL 2007-01 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Prairie Island Nuclear Generating Plant Units 1 and 2 Dockets 50-282 and 50-306 License Nos. DPR-42 and DPR-60 Response to NRC Generic Letter 2007-01: lnaccessible or Underground Power Cable Failures that Disable Accident Mitiqation Systems or Cause Plant Transients By letter dated February 7, 2007, the NRC issued Generic Letter (GL) 2007-01. This GL requires addressees to submit a written response within 90 days of this GL.
In accordance with the provisions of 10 CFR 50.54(f), Nuclear Management Company, LLC, (NMC) is hereby providing the response to NRC Generic Letter 2007-01:
"lnaccessible or Underground Power Cable Failures that Disable Accident Mitigation Systems or Cause Plant Transients," for the Prairie Island Nuclear Generating Plant (PINGP). to this letter provides the NMC response to NRC GL 2007-01 for PINGP.
Summaty of Commitments This letter contains no new commitments and no revisions to existing commitments.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on ~ a * , 2007 Director Nuclear Licensing and Regulatory Services Nuclear Management Company, LLC Enclosure (1) 1717 Wakonade Drive East  Welch, Minnesota 55089-9642 Telephone: 651.388.1 121

Document Control Desk Page 2 cc:    Administrator, Region Ill, USNRC Project Manager, Prairie Island, USNRC Resident Inspector, Prairie Island, USNRC

ENCLOSURE I NMC Response to NRC Generic Letter 2007-01 for PINGP:
Inaccessible or Underground Power Cable Failures that Disable Accident Mitigation Systems or Cause Plant Transients

==1.0     INTRODUCTION==

NRC design criteria require that cables, which are routed underground, be capable of performing their function when subjected to anticipated environmental conditions such as moisture or flooding. Further, the design should minimize the probability of power interruption when transferring power between sources. The cable failures that could disable risk-significant equipment are expected to have monitoring programs to demonstrate that the cables can perform their safety function when called on. However, the recent industry cable failure data indicates a trend in unanticipated failures of underground/inaccessible cables that are important to safety.
Some licensees have detected cable degradation prior to failures through techniques for measuring and trending the condition of cable insulation. Licensees can assess the condition of cable insulation with reasonable confidence using one or more of the following testing techniques: partial discharge testing, time domain reflectometry, dissipation factor testing, and very low frequency AC testing. Licensees can replace faulty cables during scheduled refueling outages prior to cable failure that would challenge plant safety.
2.0     REQUESTED INFORMATION Addressees are requested to submit the following information to NRC within 90 days of the date of this generic letter:
(1)     Provide a history of inaccessible or underground power cable failures for all cables that are within the scope of 10 CFR 50.65 (the Maintenance Rule) and for all voltage levels. Indicate the type, manufacturer, date of failure, type of service, voltage class, years of service, and the root causes for the failure.
(2)     Describe inspection, testing and monitoring programs to detect the degradation of inaccessible or underground power cables that support EDGs, offsite power, ESW, service water, component cooling water and other systems that are within the scope of 10 CFR 50.65 (the Maintenance Rule).
3.0     REQUIRED RESPONSE In accordance with 10 CFR 50.54(f), NMC is requested to submit written responses to this generic letter. This information is sought to verify NMC's compliance with the regulatory requirements listed in the Applicable Regulatory Requirements section of the Generic Letter. The Generic Letter discusses two response options:
3.1     Addressees may choose to submit written response providing the information requested above within the requested time period.
Page 1 of 3

ENCLOSURE I NMC Response to NRC Generic Letter 2007-01 for PINGP:
Inaccessible or Underground Power Cable Failures that Disable Accident Mitigation Systems or Cause Plant Transients 3.2       Addressees who choose not to provide information requested or cannot meet the requested completion dates are required to submit written responses within 30 days of the date of this generic letter. The responses must address any alternative course of action proposed, including the basis for the acceptability of the proposed alternative course of action.
4.0      NMC RESPONSE FOR PRAIRIE ISLAND NUCLEAR GENERATING PLANT NMC is providing the response as described in Option 3.1 above for PINGP.
4.1       Provide a history of inaccessible or underground power cable failures for all cables that are within the scope of 10 CFR 50.65 (The Maintenance Rule) and for all voltage levels. Indicate the type, manufacturer, date of failure, type of service, voltage class, years of service, and the root causes for the failure.
NMC Response:
History of Inaccessible/Underqround Power Cable Failures at PINGP The list of power cable failures that have occurred at PINGP for cables within the scope of the Maintenance Rule is provided in the table below:
lnsulationl                                   Voltage Years of     Root Cause of Manufacturer                  Date of Failure Type of Service Description           No.                     Jacket Material                                  Class  SeMce             Failure Cable                                                                                                         Testing Failure:
3 - 1/c                                                                                          Low megger 24402-2                                         EPR 1                          4.16 kV1 350MCM         Okonite                       9/27/2003                      5 kV     30         reading during 22 Circulating                                  NEOPRENE                         Continuous Unshielded                                                                                            routine Water Pump maintenance Cable C-70                                                                                                      In Service Failure:
A Phase 13.8 kV                                                                                                         Attributed to Feed to Cooling       6-C /I                                                                                         lightning strike T w e r 13.8kV                                                                    13.8 kV1                          causing rise in 1000MCM        Anaconda    EPI NEOPRENE        8/1/2002                      15 kV    29 BUSCT1 (offsite       Shielded                                                     Continuous                        shield potential source to SR busses)
In Service Failure:
Water intrusion Cable C-61                                                                                                     between jacket and A Phase 13.8                                                                                                    insulation migrated kV Feed to         6 - 1/C                                                                                           to pothead Cooling Tower                                                                      13.8 kV/
1000MCM        Anaconda    EP/ NEOPRENE       7/26/2003                      15 kV    30           resulting in a 13.8kV Bus CT2        Shielded                                                     Continuous ground fault. All (offsite source to                                                                                                   13.8kV feeds to SR busses)                                                                                                         Cooling Tower busses were replaced in 2005 Page 2 of 3

ENCLOSURE 1 NMC Response to NRC Generic Letter 2007-01 for PINGP:
Inaccessible or Underground Power Cable Failures that Disable Accident Mitigation Systems or Cause Plant Transients 4.2   Describe inspection, testing and monitoring programs to detect the degradation of inaccessible or underground power cables that support EDGs, offsite power, ESW, service water, component cooling water and other systems that are within the scope of 10 CFR 50.65 (The Maintenance Rule)
NMC Response:
Inspection, Testing and Monitoring Programs at PINGP At PINGP, power cables are routinely tested under preventive maintenance procedures for their loads. As a matter of practice, motors and heaters are meggered from the bus end of their supply cables. This action allows PINGP staff to determine insulation deterioration in either the cables or the load by further testing after disconnecting the load, which eliminates the need to disconnect at the load for performing PMs.
As part of a NMC fleet initiative to enhance the site's ability to monitor undergroundlinaccessible power cable degradation, PINGP intends to implement an "Underground Cable Maintenance Program" by the end of 2007. This action is contained in the PINGP Corrective Action Program.
Page 3 of 3}}