L-07-001, Clarification of Information Provided in Response to NRC Generic Letter 2007-01, Inaccessible or Underground Power Cable Failures That Disable Accident Mitigation Systems or Cause Plant Transients: Difference between revisions

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==REFERENCES:==
==REFERENCES:==
(a) Letter from J. M. Heffley (CEG) to Document Control Desk (NRC), dated May 7, 2007, 90-Day Response to Generic Letter 2007-01 (b) Letter from M. G. Kowal (NRC) to H. B. Barron (CENG), dated October 23, 2008, Calvert Cliffs Nuclear Power Plant, Unit Nos. 1 and 2; Nine Mile Point Nuclear Station, Unit Nos. 1 and 2; R.E. Ginna Nuclear Power Plant -Closeout of Generic Letter 2007-01, "Inaccessible or Underground Power Cable Failures that Disable Accident Mitigation Systems or Cause Plant Transients" (TAC Nos.MD4308, MD4309, MD4349, MD4350, and MD4331)This letter clarifies certain information that was provided in the Constellation Energy response to NRC Generic Letter (GL) 2007-01 as it pertains to Nine Mile Point Nuclear Station.By letter dated May 7, 2007 (Reference a), Constellation Energy submitted the 90-day response to GL 2007-01. The second request in the GL was to submit the following information: "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 1O CFR 50.65 (the Maintenance Rule)."
(a) Letter from J. M. Heffley (CEG) to Document Control Desk (NRC), dated May 7, 2007, 90-Day Response to Generic Letter 2007-01 (b) Letter from M. G. Kowal (NRC) to H. B. Barron (CENG), dated October 23, 2008, Calvert Cliffs Nuclear Power Plant, Unit Nos. 1 and 2; Nine Mile Point Nuclear Station, Unit Nos. 1 and 2; R.E. Ginna Nuclear Power Plant -Closeout of Generic Letter 2007-01, "Inaccessible or Underground Power Cable Failures that Disable Accident Mitigation Systems or Cause Plant Transients" (TAC Nos.MD4308, MD4309, MD4349, MD4350, and MD4331)This letter clarifies certain information that was provided in the Constellation Energy response to NRC Generic Letter (GL) 2007-01 as it pertains to Nine Mile Point Nuclear Station.By letter dated May 7, 2007 (Reference a), Constellation Energy submitted the 90-day response to GL 2007-01. The second request in the GL was to submit the following information: "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 1O CFR 50.65 (the Maintenance Rule)."
Document Control Desk October 21, 2011 Page 2 The response for Nine Mile Point Nuclear Station (NMPNS) in Reference (a) stated the following: "Manholes are inspected approximately every six months for water and, if water is found, it is removed. This preventive maintenance inspection routine was established to reduce the likelihood that underground power cables are exposed to a water environment or to reduce the length of exposure to water. Also, some manholes have installed sump pumps. These preventive measures do not detect degradation of inaccessible or underground power cables but they assist in eliminating or reducing the likelihood that these cables are subjected to a wet environment.
Document Control Desk October 21, 2011 Page 2 The response for Nine Mile Point Nuclear Station (NMPNS) in Reference (a) stated the following: "Manholes are inspected approximately every six months for water and, if water is found, it is removed. This preventive maintenance inspection routine was established to reduce the likelihood that underground power cables are exposed to a water environment or to reduce the length of exposure to water. Also, some manholes have installed sump pumps. These preventive measures do not detect degradation of inaccessible or underground power cables but they assist in eliminating or reducing the likelihood that these cables are subjected to a wet environment.
Since there is no history of failure and the exposure to moisture is reduced by routine pumping of manholes, NMPNS has not established inspection, testing, and monitoring programs specifically to detect degradation of inaccessible or underground power cables that are within the scope of 10 CFR 50.65 (the Maintenance Rule). However, some inaccessible and underground power cables that are within the scope of 10 CFR 50.65 are tested to ground with a meggar as part of the associated motor's routine maintenance." The NRC documented the results of its review of the Constellation Energy response to GL 2007-01 by letter dated October 23, 2008 (Reference b).As a result of discussions conducted during the most recent Component Design Basis Inspection (CDBI), NMPNS has determined that the above response needs to be clarified, for the following reasons:* Only Nine Mile Point Unit 2 (NMP2) has manholes containing power cables that are within the scope of the GL. Nine Mile Point Unit 1 (NMP1) does not have any such manholes." While some NMP2 manholes do have installed sump pumps, the NMP2 manholes containing in-scope power cables do not have installed sump pumps.Based on the above, NMPNS hereby clarifies the response to GL 2007-01 for NMP1 and NMP2 to state the following: "Nine Mile Point Unit 2 (NMP2) manholes containing power cables within the scope of GL 2007-01 are inspected approximately every six months for water and, if water is found, it is removed. This preventive maintenance inspection routine was established to reduce the likelihood that underground power cables are exposed to a water environment or to reduce the length of exposure to water. These preventive measures do not detect degradation of inaccessible or underground power cables but they assist in eliminating or reducing the likelihood that these cables are subjected to a wet environment.
Since there is no history of failure and the exposure to moisture is reduced by routine pumping of manholes, NMPNS has not established inspection, testing, and monitoring programs specifically to detect degradation of inaccessible or underground power cables that are within the scope of 10 CFR 50.65 (the Maintenance Rule). However, some inaccessible and underground power cables that are within the scope of 10 CFR 50.65 are tested to ground with a meggar as part of the associated motor's routine maintenance." The NRC documented the results of its review of the Constellation Energy response to GL 2007-01 by letter dated October 23, 2008 (Reference b).As a result of discussions conducted during the most recent Component Design Basis Inspection (CDBI), NMPNS has determined that the above response needs to be clarified, for the following reasons:* Only Nine Mile Point Unit 2 (NMP2) has manholes containing power cables that are within the scope of the GL. Nine Mile Point Unit 1 (NMP1) does not have any such manholes." While some NMP2 manholes do have installed sump pumps, the NMP2 manholes containing in-scope power cables do not have installed sump pumps.Based on the above, NMPNS hereby clarifies the response to GL 2007-01 for NMP1 and NMP2 to state the following: "Nine Mile Point Unit 2 (NMP2) manholes containing power cables within the scope of GL 2007-01 are inspected approximately every six months for water and, if water is found, it is removed. This preventive maintenance inspection routine was established to reduce the likelihood that underground power cables are exposed to a water environment or to reduce the length of exposure to water. These preventive measures do not detect degradation of inaccessible or underground power cables but they assist in eliminating or reducing the likelihood that these cables are subjected to a wet environment.

Revision as of 09:37, 30 April 2019

Clarification of Information Provided in Response to NRC Generic Letter 2007-01, Inaccessible or Underground Power Cable Failures That Disable Accident Mitigation Systems or Cause Plant Transients
ML11305A074
Person / Time
Site: Nine Mile Point  Constellation icon.png
Issue date: 10/21/2011
From: George Gellrich
Constellation Energy Nuclear Group, EDF Development, Nine Mile Point
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
GL-07-001, TAC MD4308, TAC MD4309, TAC MD4331, TAC MD4350
Download: ML11305A074 (3)
v • d • e


Text

George Gellrich P.O. Box 63 Vice President-Nine Mile Point Lycoming, New York 13093 315.349.5200 315.349.1321 Fax CENOSM a joint venture of Constellation 6'=eDF Energy*NINE MILE POINT NUCLEAR STATION October 21, 2011 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTENTION:

Document Control Desk

SUBJECT:

Nine Mile Point Nuclear Station Unit Nos. 1 and 2; Docket Nos. 50-220 and 50-4 10 Clarification of Information Provided in Response to NRC Generic Letter 2007-01, Inaccessible or Underground Power Cable Failures that Disable Accident Mitigation Systems or Cause Plant Transients

REFERENCES:

(a) Letter from J. M. Heffley (CEG) to Document Control Desk (NRC), dated May 7, 2007, 90-Day Response to Generic Letter 2007-01 (b) Letter from M. G. Kowal (NRC) to H. B. Barron (CENG), dated October 23, 2008, Calvert Cliffs Nuclear Power Plant, Unit Nos. 1 and 2; Nine Mile Point Nuclear Station, Unit Nos. 1 and 2; R.E. Ginna Nuclear Power Plant -Closeout of Generic Letter 2007-01, "Inaccessible or Underground Power Cable Failures that Disable Accident Mitigation Systems or Cause Plant Transients" (TAC Nos.MD4308, MD4309, MD4349, MD4350, and MD4331)This letter clarifies certain information that was provided in the Constellation Energy response to NRC Generic Letter (GL) 2007-01 as it pertains to Nine Mile Point Nuclear Station.By letter dated May 7, 2007 (Reference a), Constellation Energy submitted the 90-day response to GL 2007-01. The second request in the GL was to submit the following information: "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 1O CFR 50.65 (the Maintenance Rule)."

Document Control Desk October 21, 2011 Page 2 The response for Nine Mile Point Nuclear Station (NMPNS) in Reference (a) stated the following: "Manholes are inspected approximately every six months for water and, if water is found, it is removed. This preventive maintenance inspection routine was established to reduce the likelihood that underground power cables are exposed to a water environment or to reduce the length of exposure to water. Also, some manholes have installed sump pumps. These preventive measures do not detect degradation of inaccessible or underground power cables but they assist in eliminating or reducing the likelihood that these cables are subjected to a wet environment.

Since there is no history of failure and the exposure to moisture is reduced by routine pumping of manholes, NMPNS has not established inspection, testing, and monitoring programs specifically to detect degradation of inaccessible or underground power cables that are within the scope of 10 CFR 50.65 (the Maintenance Rule). However, some inaccessible and underground power cables that are within the scope of 10 CFR 50.65 are tested to ground with a meggar as part of the associated motor's routine maintenance." The NRC documented the results of its review of the Constellation Energy response to GL 2007-01 by letter dated October 23, 2008 (Reference b).As a result of discussions conducted during the most recent Component Design Basis Inspection (CDBI), NMPNS has determined that the above response needs to be clarified, for the following reasons:* Only Nine Mile Point Unit 2 (NMP2) has manholes containing power cables that are within the scope of the GL. Nine Mile Point Unit 1 (NMP1) does not have any such manholes." While some NMP2 manholes do have installed sump pumps, the NMP2 manholes containing in-scope power cables do not have installed sump pumps.Based on the above, NMPNS hereby clarifies the response to GL 2007-01 for NMP1 and NMP2 to state the following: "Nine Mile Point Unit 2 (NMP2) manholes containing power cables within the scope of GL 2007-01 are inspected approximately every six months for water and, if water is found, it is removed. This preventive maintenance inspection routine was established to reduce the likelihood that underground power cables are exposed to a water environment or to reduce the length of exposure to water. These preventive measures do not detect degradation of inaccessible or underground power cables but they assist in eliminating or reducing the likelihood that these cables are subjected to a wet environment.

Nine Mile Point Unit 1 (NMP1) does not have any manholes containing power cables that are within the scope of GL 2007-01.Since there is no history of failure and, for NMP2, the exposure to moisture is reduced by routine pumping of manholes, NMPNS has not established inspection, testing, and monitoring programs specifically to detect degradation of inaccessible or underground power cables that are within the scope of 10 CFR 50.65 (the Maintenance Rule). However, some inaccessible and underground power cables that are within the scope of 10 CFR 50.65 are tested to ground with a meggar as part of the associated motor's routine maintenance."

Document Control Desk October 21, 2011 Page 3 This letter does not contain any regulatory commitments.

Should you have any questions regarding the information in this letter, please contact John J. Dosa, Director Licensing, at (315) 349-5219.Very truly yours, STATE OF NEW YORK TO WIT: COUNTY OF OSWEGO I, George Gellrich, being duly sworn, state that I am Vice President-Nine Mile Point, and that I am duly authorized to execute and file this revised response on behalf of Nine Mile Point Nuclear Station, LLC.To the best of my knowledge and belief, the statements contained in this document are true and correct.To the extent that these statements are not based on my personal knowledge, they are based upon information provided by other Nine Mile Point employees and/or consultants.

Such information has been reviewed in accordance with company practice and I believe it to be reliable.Subscribed and sworn before me, a Notary Public in and for the State of New York and County of nm, this 01- day of (. 2011.WITNESS my Hand and Notarial Seal: AOo,.. i,/ iA.)Notary Public My Commission Expires: 9//,/J~I anbeKLDoran Date "Ooftft lose s of Nw%*GG/DEV My o W12=O*cc: Regional Administrator, Region I, NRC Project Manager, NRC Resident Inspector, NRC A. L. Peterson, NYSERDA

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