ML081830664

Lr Hearing - Draft Telecon Summary of 5-19-08 on Submerged Cable Draft RAIs

ML081830664
Person / Time
Site:	Indian Point
Issue date:	06/20/2008
From:	Office of Nuclear Reactor Regulation
To:
References
Download: ML081830664 (8)

Text

IPRenewal NPEmails From: Kimberly Green Sent: Friday, June 20, 2008 1:44 PM To: STROUD, MICHAEL D; Tyner, Donna

Subject:

Draft Telecon Summary of 5-19-08 on Submerged Cable Draft RAIs Attachments: Telecon Summary 05-19-08 Submerged Cable.doc Mike and Donna, Attached is the draft telecon summary from the call on May 19, 2008. Please review and let me know if any corrections are needed.

Thanks, Kimberly Green Safety PM (301) 4151627 kimberly.green@nrc.gov 1

Hearing Identifier: IndianPointUnits2and3NonPublic_EX Email Number: 132 Mail Envelope Properties (Kimberly.Green@nrc.gov20080620134300)

Subject:

Draft Telecon Summary of 5-19-08 on Submerged Cable Draft RAIs Sent Date: 6/20/2008 1:43:33 PM Received Date: 6/20/2008 1:43:00 PM From: Kimberly Green Created By: Kimberly.Green@nrc.gov Recipients:

"STROUD, MICHAEL D" <MSTROUD@entergy.com>

Tracking Status: None "Tyner, Donna" <dtyner@entergy.com>

Tracking Status: None Post Office:

Files Size Date & Time MESSAGE 297 6/20/2008 1:43:00 PM Telecon Summary 05-19-08 Submerged Cable.doc 75258 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

Recipients Received:

LICENSEE: Entergy Nuclear Operations, Inc.

FACILITY: Indian Point Nuclear Generating Unit Nos. 2 and 3

SUMMARY

OF TELEPHONE CONFERENCE CALL HELD ON MAY 19, 2008, BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION AND ENTERGY NUCLEAR OPERATIONS, INC., RELATED TO THE INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3, LICENSE RENEWAL APPLICATION SUBMERGED CABLES The U.S. Nuclear Regulatory Commission (NRC or the staff) and representatives of Entergy Nuclear Operations Inc (Entergy) held a telephone conference call on May 19, 2008, to discuss and clarify the staffs draft request for additional information (D-RAI) concerning the Indian Point Nuclear Generating Unit Nos. 2 and 3, license renewal application. The telephone conference call was useful in clarifying the intent of the staffs D-RAI. provides a listing of the participants and Enclosure 2 contains a listing of the D-RAI items discussed with the applicant, including a brief description on the status of the items.

The applicant had an opportunity to comment on this summary.

Kimberly Green, Safety Project Manager Projects Branch 2 Division of License Renewal Office of Nuclear Reactor Regulation Docket Nos. 50-247 and 50-286

Enclosure:

List of Participants cc w/encl: See next page

G:\ADRO\DLR\RPB2\Indian Point\Safety Review\Telecon Summaries\Telecon Summary 05-19-08 Submerged Cable.doc OFFICE LA:DLR PM:RPB2:DLR BC:RPB2:DLR NAME KGreen RFranovich DATE 06/ /08 06/ /08 06/ /08 TELEPHONE CONFERENCE CALL INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3 LICENSE RENEWAL APPLICATION LIST OF PARTICIPANTS MAY 19, 2008 PARTICIPANTS AFFILIATIONS Kim Green U.S. Nuclear Regulatory Commission (NRC)

Duc Nguyen NRC Raj Auluck NRC Roy Mathew NRC Mike Stroud Entergy Nuclear Operations, Inc. (Entergy)

Roger Rucker Entergy Alan Cox Entergy John Curry Entergy Charlie Caputo Entergy Herb Robinson Entergy ENCLOSURE 1

INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3 LICENSE RENEWAL APPLICATION REQUEST FOR ADDITIONAL INFORMATION INACCESSIBLE OR UNDERGROUND POWER CABLES MAY 19, 2008 D-RAI 3.6.2.3-1 In LRA Table 3.6.2-1, the applicant states that 138kV direct burial insulated transmission cables (passive electrical for SBO recovery) have no aging effects requiring management and indicates (by Note J) for material, environment, aging effect, and AMP that neither the component nor the material and environment combination is evaluated in GALL Report for meeting the components electrical intended function. The plant-specific Note 602 for this item in LRA Table 3.6.2-1 states that it is not subject to water treeing, since it is designed for continuously wet conditions. Industry and plant operating experience has not provided any information on failures of this type of cable. In addition, in response to the audit team's question concerning the qualification of this cable for continuous submerge condition, the applicant stated that the aging effects caused by moisture and voltage stress are not applicable to this cable because the lead sheath prevents moisture intrusion without providing any technical justifications.

Based on the initial review of the licensee's responses to Generic letter 2007-01, "Inaccessible or Underground Power Cable Failures that Disable Accident Mitigation Systems or Cause Plant Transients," the staff notes that several licensees have identified failures of XLPE cables in low and medium voltage applications. The high voltage cables could also have the same failure mechanisms if the underground cables are susceptible to moisture, water, and condensation environment or have manufacturing defects or damages caused by shipping and installation, or exposure to electrical transients and abnormal operating conditions. The likelihood of failure from any of these causes increases over time as the cable insulation degrades.

10 CFR 54.21(a)(3) requires that components within the scope of license renewal and subject to an AMR must be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation. Therefore, the staff requests the applicant to provide technical justification of why an aging management program is not required to manage the potential loss of dielectric strength leading to reduced insulation resistance and electrical failure due to aging mechanisms such as moisture intrusion, water treeing, elevated operating temperature, voltage stress, and galvanic corrosion. Therefore, in order to complete our review, the staff requires responses to the following additional information.

1. Explain why an aging management program is not required to manage the potential loss of dielectric strength leading to reduced insulation resistance and electrical failure due to aging mechanisms such as moisture and water intrusion, water treeing, elevated operating temperature, voltage stress, galvanic corrosion, manufacturing defects, and potential damages caused by shipping and installation.

Discussion: Based on the discussion with the applicant, the staff agreed to revise this question to remove references to mechanisms that are not age-related. The revised question will be sent as a formal RAI.

Explain why an AMP is not required to manage the potential loss of dielectric strength leading to reduced insulation resistance and electrical failure due to aging mechanisms ENCLOSURE 2

such as moisture and water intrusion, water treeing, elevated operating temperature, voltage stress, and galvanic corrosion. The operating experience has shown that manufacturing defects, and damage caused by shipping and installation are contributing causes resulting in water treeing and insulation breakdown.

2. Describe any testing that was performed on the cable during receipt and post-installation (include the type of testing that was performed on the cable). Describe the capabilities of the testing method performed on the cable. Describe the testing results, and state if the testing identified any problems. Describe if a current testing or maintenance program exists for this cable system.

Discussion: Based on the discussion with the applicant, the staff agreed to revise this question as follows. The revised question will be sent as a formal RAI.

State whether if any testing was performed on the cable during receipt and post-installation (include the type of testing that was performed on the cable). If so, describe the capabilities of the testing method performed on the cable, the testing results, and state if the testing identified any problems. State whether a current testing or maintenance program exists for this cable system, and if so, describe that program.

3. Provide details of the original cable specification including procurement specification (include all applicable references) to support that the subject cable is comparable to submarine cable and/or the cable is supplied with a moisture barrier or water sealant swelling material applied under the lead sheath as specified in your letter dated October 11, 2007, in response to the LRA audit team's question. Also, describe in detail the differences between the subject cable and a submarine cable.

Discussion: The applicant indicated that the question is clear. This D-RAI will be sent as a formal RAI.

4. Provide documentation showing that the cable can operate for the duration of the period of extended operation in submerged and wet conditions. If no periodic testing is proposed for this cable, explain how you plan to monitor the degradation of the cable or the condition of the conductor insulation (loss of dielectric strength) to preclude any potential cable failure such that the cable will perform its intended function for the period of extended operation as required by 10 CFR 54.21 (a)(3).

Discussion: The applicant indicated that the question is clear. This D-RAI will be sent as a formal RAI.

5. Describe AEIC or other specification that is applicable to the IP2/IP3 lead sheath power cables that are designed to be installed in wet environments for extended periods. Also, describe the conditions for which the cable was tested in accordance with specification AEIC CS7 with respect to operability in wet/submerged/humid conditions.

Discussion: The applicant indicated that the question is clear. This D-RAI will be sent as a formal RAI.

6. Identify the material, environment, aging mechanism, and aging effect for the pot assembly (termination ends) for this cable. Identify details of periodic visual inspections and walkdowns performed to date or planned for the period of extended operation to monitor for oil leakage and 2

check pothead bolt torque, oil testing performed or any indications or alarms provided in the control room to indicate the potential loss of oil. Explain how you manage the aging effect (loss of dielectric strength) during the period of extended operation.

Discussion: Based on the discussion with the applicant, the staff agreed to revise this question remove checking pothead bolt torque since it is performed via the maintenance rule. The revised question will be sent as a formal RAI.

Identify the material, environment, aging mechanism, and aging effect for the pot assembly (termination ends) for this cable. Identify details of periodic visual inspections and walkdowns performed to date or planned for the period of extended operation to monitor for oil leakage, oil testing performed or any indications or alarms provided in the control room to indicate the potential loss of oil. Explain how effects of aging will be managed during the period of extended operation.

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