ML081890576

Request for Additional Information, Review of License Renewal Application

ML081890576
Person / Time
Site:	Susquehanna
Issue date:	07/10/2008
From:	Gettys E H NRC/NRR/ADRO/DLR
To:	McKinney B T Susquehanna
Gettys Evelyn, NRR/DLR/RLRA 415-4029
References
Download: ML081890576 (9)

Text

July 10, 2008 Mr. Britt T. McKinney Sr. Vice President and Chief Nuclear Officer PPL Susquehanna, LLC 769 Salem Blvd., NUCSB3 Berwick, PA 18603-0467

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE SUSQUEHANNA STEAM ELECTRIC STATION, UNITS 1 AND 2, LICENSE RENEWAL APPLICATION

Dear Mr. McKinney:

By letter dated September 13, 2006, PPL Susquehanna, LLC submitted an application pursuant to Title 10 of the Code of Federal Regulation Part 54 (10 CFR Part 54), to renew the operating licenses for Susquehanna Steam Electric Station, Units 1 and 2, for review by the U.S. Nuclear Regulatory Commission (NRC or the staff). The staff is reviewing the information contained in the license renewal application and has identified, in the enclosure, areas where additional information is needed to complete the review. Further requests for additional information may be issued in the future.

Items in the enclosure were discussed with Duane Filchner, and a mutually agreeable date for the response is within 30 days from the date of this letter. If you have any questions, please contact me at 301-415-4029 or e-mail evelyn.gettys@nrc.gov. Sincerely, \RA\ Evelyn Gettys, Project Manager Projects Branch 1 Division of License Renewal Office of Nuclear Reactor Regulation Docket Nos. 50-387 and 50-388

Enclosure:

As stated cc w/encl: See next page

ML081890576 OFFICE LA:DLR PM:RPB1:DLR BC(A): RPB1:DLR NAME IKing EGettys BPham DATE 7/9/08 7/9/08 7/10/08 SUSQUEHANNA STEAM ELECTRIC STATION, UNITS 1 AND 2 LICENSE RENEWAL APPLICATION REQUEST FOR ADDITIONAL INFORMATION (RAI)

RAI B.2.14-1 The aging management program (AMP) B.2.14 Close Cooling Water (CCW) Chemistry Program takes the following exception to the "parameters monitored or inspected," "detection of aging effects," "monitoring and trending," and "acceptance criteria" program elements in the GALL Report AMP XI.M21 "Closed Coolant Water System."

"In lieu of performance monitoring/functional testing, program includes monitoring of corrosion in the emergency diesel generator jacket water subsystem and is supplemented by one time chemistry program effectiveness inspection." a) Clarify whether performance monitoring and functional testing are within the scope of the CCW Chemistry Program. If not, provide your basis why performance monitoring and functional testing do not need to be included within the scope of the CCW Chemistry Program.

b) Clarify whether the one-time inspection is being performed instead of the periodic inspections as recommended in the generic aging lessons learned (GALL) Report AMP XI.M21. If yes, please justify how a one-time inspection is capable of accomplishing the same tasks as the periodic inspections recommended by the GALL Report. Also, justify why a one-time inspection is considered to be capable of trending any corrosion data when only one round of inspections will be done on the components that are within the scope of the AMP.

RAI B.2.14-2 In the program description of AMP B.2.14, Closed Cooling Water Chemistry Program, it states that the CCW Chemistry Program is supplemented by an appropriate one-time inspection. The description mentions the AMP B.2.22 Chemistry Program Effectiveness Inspection and the AMP B.2.24 Heat Exchanger Inspection. Clarify whether the appropriate one-time inspection will be performed for all the aging management review (AMR) Table-2 line items credited with using the AMP B.2.14. Also, please identify which one-time inspection, if any, will be used for any applicable AMR Table-2 line items that credit the AMP B.2.14 for aging management.

RAI B.2.14-3 The "operating experience" program element for AMP B.2.14, Closed Cooling Water Chemistry Program states, in part that:

". . . some continuing problems with the effectiveness of the program with respect to diesel jacket water corrosion/microbiological control were identified and evaluated in 1999. Additionally, instances of degradation (e.g., corrosion of the corresponding components) were noted by inspections associated with a 20-year overhaul in the same time period. Corrective actions included flushing of the jacket water, retaining an industry expert, and consideration of different biocide/corrosion inhibitor treatments. The appropriate improvements to the Closed Cooling Water Chemistry Program, including installation of instantaneous corrosion probes to monitor actual corrosion rates, were successfully implemented, as supported by subsequent operating experience with the diesel jacket water subsystem."

ENCLOSURE

Clarify whether or not the addition of alternative biocides or corrosion inhibitors was actually implemented as a corrective action for the diesel jack water system components that are exposed to closed cooling water. If so, clarify whether on not any supplemental inspections have been performed since the time of the change in the biocide control compound or corrosion inhibitor to verify the effectiveness of the biocide control compound or corrosion inhibitor in managing microbiological organism growth or corrosion of the component surfaces that are exposed to CCW. If a change in biocide control compound or corrosion inhibitors is planned but has not been implemented, clarify when the change in the biocide control compound or corrosion inhibitor will be performed and whether any supplement inspections are planned to confirm the effectiveness of the biocide control compound or corrosion inhibitor to mange microbiological organism growth or corrosion in the components.

RAI B.2.25-1 The license renewal application (LRA) credits the AMP B.2.25 Lubricating Oil Inspection and the AMP B.2.33 Lubricating Oil Analysis Program as two of the AMPs for managing the aging effects in plant systems that are exposed to lubricating oil, including components in the Emergency Diesel Generator System, Control Structures Chilled Water System, Residual CCW System, and High Pressure Coolant Injection System. Identify whether there are any other systems that are within the scope of license renewal and are exposed to lubricating oil.

RAI B.2.32-1 The "operating experience" program element for this AMP states that a review of operating experience revealed that component leakage, damage, and/or degradation are routinely identified by the system walk downs, and that subsequent timely corrective action were taken to correct these problems.

a) For those plant systems that are within the scope of the Systems Walkdown Program, identify the plant systems that have had problems with age related degradation in the past, and identify the specific age-related degradation problems that have occurred in these systems.

b) For those plant systems that are within the scope of the Systems Walkdown Program and have had age-related degradation issues in the past, clarify whether or not these age-related degradation issues have had any impact on the ability of the AMP's program elements to manage aging in these systems and whether the program elements for this program will need to be augmented or enhanced to ensure adequate management of aging in these systems.

c) Identify the corrective actions that have been taken to correct any issues with leakage, damage and degradation in those systems.

RAI B.2.32-2 The AMP B.2.32 System Walk down Program includes following enhancement:

"The governing procedure for system walk down program must be revised to add the listing of systems crediting the program for license renewal."

In addition, the AMP B.2.32 System Walkdowns Program indicates that Susquehanna Steam Electric Station may change the frequency of the system walkdowns in the future.

a) Identify the systems that are within the scope of the Systems Walkdown Program and that are subject to the stated enhancement.

b) Clarify what the current frequency is for performing these system walkdowns, or the current frequencies that are currently being used if the frequencies for the different plant systems in the scope of the program vary from one another.

c) Provide your basis for changing the frequency of the system walkdowns. Clarify the process that will be used to change the walkdown frequencies and whether or not any changes to the system walkdown frequencies will be subject for NRC approval.

RAI B.2.32-3 In the AMP B.2.19 Condensate and Refueling Water Storage Tanks Inspection Program, the applicant states that the scope of the AMP includes condition monitoring of paints, coatings, sealants and caulking, and condition monitoring of these tank materials will be accomplished through visual examinations that are implemented as part of the LRA AMP B.2.32 Systems Walkdown Program. The staff has verified that the program description of AMP B.2.32 Systems Walkdown Program does not indicate that these tank materials are within the scope of the AMP. Clarify whether paints, coatings, sealants, and caulking, including those for the condensate and refueling water storage tanks, are within the scope of the Systems Walkdown Program and if so, clarify the inspection techniques that will be credited to monitor for changes in material properties, such as, cracking, flaking, pealing, delamination, or other aging effects or loss of material that may be applicable to these materials. If these materials are not within the scope of the Systems Walkdown Program, justify how the Systems Walkdown Program can be credited for aging management of paints, coatings, sealants and caulking that are used in the fabrication or design of the condensate and refueling water storage tanks.

RAI B.2.32-4 In the AMP B.2.32 Systems Walkdown Program the applicant states that the AMP is credited to manage cracking in and/or change in material properties for elastomers (neoprene and rubber) and polymers (Teflon) that are exposed to indoor air or ventilation environments. The GALL Report AMP XI.M36 "External Surfaces Monitoring," pertains to the external surfaces of steel components in systems that are within the scope of license renewal and are subject to AMRs for loss of material and leakage. The GALL Report program does not apply to elastomeric components or to the management of cracking or material property changes (including hardening or loss of strength) in elastomeric or polymeric components. Justify your basis for crediting the External Surfaces Monitoring Program to manage cracking and changes in material properties that may occur in the external surfaces of in-scope components that are fabricated from either an elastomeric or polymeric material. Using a technical basis, clarify how a visual examination alone from the external surfaces of these materials would be capable of detecting the following aging effects: (1) a tightly configured crack that penetrates the external surface of the component, (2) a subsurface crack or a crack that only penetrates the internal surface of the materials, and (3) a change in a material property, such as a potential change in the hardness property or strength property for the elastomer or polymer material used to fabricate the component.

RAI B.2.33-1 In the LRA AMP B.2.33 Lube Oil Analysis Program, the applicant takes an exception to the "parameters monitored or inspected" program element in the GALL AMP XI.M39, Lubricating Oil Analysis," and for particulate counting, credits "direct read ferrography" testing in lieu of the lubricating oil analysis testing that is recommended in the "parameters monitored or inspected" program element in the GALL Report AMP XI.M39. Justify why "direct read ferrography" is an acceptable alternative to performance of periodic particular content

counting of the samples taken from the lubricating oil inventory. In your justification, discuss the techniques that "direct read ferrography" will use to monitor for particulates in the lubricating oil samples and clarify why these techniques are considered to provide for acceptable alternative monitoring of particulates in the lubricating oil inventory.

Letter to B. McKinney from E. Gettys, dated July 10, 2008 DISTRIBUTION

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE SUSQUEHANNA STEAM ELECTRIC STATION, UNITS 1 AND 2, LICENSE RENEWAL APPLICATION HARD COPY: DLR RF E-MAIL: PUBLIC RidsNrrDlr RidsNrrDlrRlra RidsNrrDlrRlrb RidsNrrDlrRlrc RidsNrrDlrReba RidsNrrDlrRebb RidsNrrDciCvib RidsNrrDciCpnb RidsNrrDraAfpb RidsNrrDeEmcb RidsNrrDeEeeb RidsNrrDssSrxb RidsNrrDssSbpb RidsNrrDssScvb RidsOgcMailCenter --------------- EGettys FJaxheimer Susquehanna Steam Electric Station, Units 1 and 2 cc: Cornelius J. Gannon Vice President - Nuclear Operations PPL Susquehanna, LLC 769 Salem Blvd., NUCSB3 Berwick, PA 18603-0467

Robert M. Paley General Manager - Plant Support PPL Susquehanna, LLC 769 Salem Blvd., NUCSB2 Berwick, PA 18603-0467 Rocco R. Sgarro Manager - Nuclear Regulatory Affairs PPL Susquehanna, LLC Two North Ninth Street, GENPL4 Allentown, PA 18101-1179

Supervisor - Nuclear Regulatory Affairs PPL Susquehanna, LLC 769 Salem Blvd., NUCSA4 Berwick, PA 18603-0467

Michael H. Crowthers Supervisor - Nuclear Regulatory Affairs PPL Susquehanna, LLC Two North Ninth Street, GENPL4 Allentown, PA 18101-1179

Ronald E. Smith General Manager - Site Preparedness and Services PPL Susquehanna, LLC 769 Salem Blvd., NUCSA4 Berwick, PA 18603-0467 Michael H. Rose Manager - Quality Assurance PPL Susquehanna, LLC 769 Salem Blvd., NUCSB2 Berwick, PA 18603-0467 Joseph J. Scopelliti Community Relations Manager, Susquehanna PPL Susquehanna, LLC 634 Salem Blvd., SSO Berwick, PA 18603-0467

Bryan A. Snapp, Esq. Associate General Counsel PPL Services Corporation Two North Ninth Street, GENTW3 Allentown, PA 18101-1179

Document Control Services PPL Susquehanna, LLC Two North Ninth Street, GENPL4 Allentown, PA 18101-1179

Richard W. Osborne Allegheny Electric Cooperative, Inc. 212 Locust Street P.O. Box 1266 Harrisburg, PA 17108-1266

Director, Bureau of Radiation Protection Pennsylvania Department of Environmental Protection Rachel Carson State Office Building P.O. Box 8469 Harrisburg, PA 17105-8469 Senior Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 35, NUCSA4 Berwick, PA 18603-0035 Regional Administrator, Region 1 U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Susquehanna Steam Electric Station, Units 1 and 2 cc: Board of Supervisors Salem Township P.O. Box 405 Berwick, PA 18603-0035 Dr. Judith Johnsrud National Energy Committee Sierra Club 443 Orlando Avenue State College, PA 16803