PLA-6427, License Renewal Application (LRA) Amendments to Sections B.2.38, B.2.39, and B.2.47 in Response to NRC Regional Inspection PLA-6427: Difference between revisions

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=Text=
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{{#Wiki_filter:Britt T. McKinney               PPL Susquehanna, LLC Sr. Vice President & Chief Nuclear Officer                 769 Salem Boulevard
{{#Wiki_filter:Britt T. McKinney PPL Susquehanna, LLC Sr. Vice President & Chief Nuclear Officer 769 Salem Boulevard a
* lma Berwick, PA 18603     ,    , So Tel. 570.542.3149 Fax 570.542.1504 btmckinney@pplweb.com SEP 23       206                                         P   P14ý         TM U. S. Nuclear Regulatory Commission Document Control Desk Mail Stop OP1-17 Washington, DC 20555 SUSQUEHANNA STEAM ELECTRIC STATION UNITS 1 AND 2, LICENSE RENEWAL APPLICATION (LRA)
m l
AMENDMENTS TO SECTIONS B.2.38, B.2.39, AND B.2.47 IN RESPONSE TO NRC REGIONAL INSPECTION                                                 Docket Nos. 50-387 PLA-6427                                                                                         and 50-388
Berwick, PA 18603  
, So Tel. 570.542.3149 Fax 570.542.1504 btmckinney@pplweb.com SEP 23 206 P
P14ý TM U. S. Nuclear Regulatory Commission Document Control Desk Mail Stop OP1-17 Washington, DC 20555 SUSQUEHANNA STEAM ELECTRIC STATION UNITS 1 AND 2, LICENSE RENEWAL APPLICATION (LRA)
AMENDMENTS TO SECTIONS B.2.38, B.2.39, AND B.2.47 IN RESPONSE TO NRC REGIONAL INSPECTION Docket Nos. 50-387 PLA-6427 and 50-388


==Reference:==
==Reference:==
: 1) PLA-61]]0, Mr. B. T McKinney (PPL)to Document Control Desk (USNRC),
: 1) PLA-61))0, Mr. B. T McKinney (PPL) to Document Control Desk (USNRC),
                      "Applicationfor Renewed OperatingLicense Numbers NPF-14 and NPF-22,"
"Application for Renewed Operating License Numbers NPF-14 and NPF-22,"
dated September 13, 2006.
dated September 13, 2006.
In accordance with the requirements of 10 CFR 50, 51, and 54, PPL requested the renewal of the operating licenses for the Susquehanna Steam Electric Station (SSES)
In accordance with the requirements of 10 CFR 50, 51, and 54, PPL requested the renewal of the operating licenses for the Susquehanna Steam Electric Station (SSES)
Line 31: Line 34:
There are no new regulatory commitments contained herein as a result of the attached responses. However, license renewal commitment #34, in LRA Table A-i, is revised as indicated in the PPL Response to inspection issues related to AMP B.2.39.
There are no new regulatory commitments contained herein as a result of the attached responses. However, license renewal commitment #34, in LRA Table A-i, is revised as indicated in the PPL Response to inspection issues related to AMP B.2.39.
If you have any questions, please contact Mr. Duane L. Filchner at (610) 774-7819.
If you have any questions, please contact Mr. Duane L. Filchner at (610) 774-7819.
Document Control Desk PLA-6427 I declare, under penalty of perjury, that the foregoing is true and correct.
Document Control Desk PLA-6427 I declare, under penalty of perjury, that the foregoing is true and correct.
Executed on:     J/73 IZ&,Z B.   .        ney I
Executed on:
J/73 IZ&,Z B.
I ney


==Enclosure:==
==Enclosure:==
Line 43: Line 47:
PPL Response:
PPL Response:
The SSES LRA is amended as follows to identify that masonry block walls are in scope and subject to aging management review for the ESSW Pumphouse.
The SSES LRA is amended as follows to identify that masonry block walls are in scope and subject to aging management review for the ESSW Pumphouse.
2.4.3   Engineered Safeguards Service Water Pumphouse and Spray Pond Structure Description
2.4.3 Engineered Safeguards Service Water Pumphouse and Spray Pond Structure Description
*- Walls discussion (LRA page 2.4-11) is revised by addition (bold italics).
*- Walls discussion (LRA page 2.4-11) is revised by addition (bold italics).
The ESSW Pumphouse consists of the following major structural components:
The ESSW Pumphouse consists of the following major structural components:
* Foundation Mat - The reinforced concrete foundation mat is founded on soil. The depth of soil below the mat foundation varies from 35 to 60 feet. The soil is predominantly sand, gravel, cobbles, and boulders.
Foundation Mat - The reinforced concrete foundation mat is founded on soil. The depth of soil below the mat foundation varies from 35 to 60 feet. The soil is predominantly sand, gravel, cobbles, and boulders.
* Floors - The operating floor is of reinforced concrete supported by steel beams.       The mezzanine floor is composed of grating over steel beams.
Floors - The operating floor is of reinforced concrete supported by steel beams. The mezzanine floor is composed of grating over steel beams.
      "  Roof - The roof is of reinforced concrete supported by steel beams.
Roof - The roof is of reinforced concrete supported by steel beams.
* Walls - The bearing walls are of reinforced concrete and are designed as shear walls to resist lateral loads. Masonry block wall is installed at entryway for security reasons.
Walls - The bearing walls are of reinforced concrete and are designed as shear walls to resist lateral loads. Masonry block wall is installed at entryway for security reasons.
* Chambers - The pump intake chambers and the overflow weir chamber are continuously flooded by the spray pond.
Chambers - The pump intake chambers and the overflow weir chamber are continuously flooded by the spray pond.
Table 2.4-3, ESSW Pumphouse and Spray Pond Components Subject to Aging Management Review
Table 2.4-3, ESSW Pumphouse and Spray Pond Components Subject to Aging Management Review
>   Table 2.4-3 (LRA page 2.4-14) is revised by addition (bold italics).
> Table 2.4-3 (LRA page 2.4-14) is revised by addition (bold italics).
Table 2.4-3 ESSW Pumphouse and Spray Pond Components Subject to Aging Management Review Component Type                                                   Intended Function (as defined in Table 2.0-1)
Table 2.4-3 ESSW Pumphouse and Spray Pond Components Subject to Aging Management Review Intended Function Component Type (as defined in Table 2.0-1)
Masonry block walls                                               SNS
Masonry block walls SNS


Enclosure to PLA-6427 Page 3 of 9 3.5.2.1.3       Engineered Safeguards Service Water (ESSW) Pumphouse and Spray Pond
Enclosure to PLA-6427 Page 3 of 9 3.5.2.1.3 Engineered Safeguards Service Water (ESSW) Pumphouse and Spray Pond
>   Materials and Aging Management Programs discussions (LRA pages 3.5-5 and 3.5-6) are revised by addition (bold italics).
> Materials and Aging Management Programs discussions (LRA pages 3.5-5 and 3.5-6) are revised by addition (bold italics).
Materials ESSW Pumphouse and Spray Pond components subject to aging management review are constructed of the following materials:
Materials ESSW Pumphouse and Spray Pond components subject to aging management review are constructed of the following materials:
* Carbon Steel
Carbon Steel Concrete Concrete Blocks Earthen Galvanized Steel Stainless Steel Aging Management Programs The following programs are credited for managing the effects of aging on ESSW Pumphouse and Spray Pond components:
* Concrete
Fire Protection Program Masonry Wall Program Structures Monitoring Program RG 1.127Water-Control Structures Inspection
* Concrete Blocks
* Earthen
* Galvanized Steel
* Stainless Steel Aging Management Programs The following programs are credited for managing the effects of aging on ESSW Pumphouse and Spray Pond components:
* Fire Protection Program
* Masonry Wall Program
* Structures Monitoring Program
* RG 1.127Water-Control Structures Inspection


Enclosure to PLA-6427 Page 4 of 9 Table 3.5.2-3, Aging Management Review Results - Engineered Safeguards Service Water Pumphouse and Spray Pond LRA Table 3.5.2-3 (LRA page 3.5-88) is revised by addition (bold italics).
Enclosure to PLA-6427 Page 4 of 9 Table 3.5.2-3, Aging Management Review Results - Engineered Safeguards Service Water Pumphouse and Spray Pond LRA Table 3.5.2-3 (LRA page 3.5-88) is revised by addition (bold italics).
Table 3.5.2-3       Aging Management Review Results - Engineered Safeguards Service Water Pumphouse and Spray Pond Aging Effect   Aging     NUREG-Commodity       Function 1     Material     Environment     Requiring   Management   Volume     Table 1 Item   Notes Comodty Funtin'Management                                       Programs   Voluem2 Masonry                       Concrete       Protected                 Masonry Wall Block           SNS         Blocks     from weather     Cracking     Program     III.A6-10   3.5.1-43       A Walls Masonry                     Concrete     Exposed to                 Masonry Wall Block             SNS         Blocks         weather       Cracking     Program     lll.A6-1O   3.5.1-43       A Walls
Table 3.5.2-3 Aging Management Review Results - Engineered Safeguards Service Water Pumphouse and Spray Pond Aging Effect Aging NUREG-Commodity Function 1 Material Environment Requiring Management Volume Table 1 Item Notes Comodty Funtin'Management Programs Voluem2 Masonry Concrete Protected Masonry Wall Block SNS Blocks from weather Cracking Program III.A6-10 3.5.1-43 A
Walls Masonry Concrete Exposed to Masonry Wall Block SNS Blocks weather Cracking Program lll.A6-1O 3.5.1-43 A
Walls


Enclosure to PLA-6427 Page 5 of 9 NRC Inspection Issue Related to AMP B.2.39 - Structures Monitoring Program:
Enclosure to PLA-6427 Page 5 of 9 NRC Inspection Issue Related to AMP B.2.39 - Structures Monitoring Program:
PPL Response:
PPL Response:
The SSES LRA is amended as follows to enhance the Monitoring and Trending, Acceptance Criteria, and Detection of Aging Effects elements of the existing SSES Structures Monitoring Program.
The SSES LRA is amended as follows to enhance the Monitoring and Trending, Acceptance Criteria, and Detection of Aging Effects elements of the existing SSES Structures Monitoring Program.
A.1.2.45   Structures Monitoring Program
A.1.2.45 Structures Monitoring Program
> The discussion in Section A.1.2.45 (LRA pages A-19 to A-20) is revised by deletion
> The discussion in Section A.1.2.45 (LRA pages A-19 to A-20) is revised by deletion
(&trikethrough) and addition (bold italics).
(&trikethrough) and addition (bold italics).
The Structures Monitoring Program is an existing program that manages age-related degradation of plant structures and structural components within its scope to ensure that each structure or structural component retains the ability to perform its intended function. Aging effects are detected by visual inspection of external surfaces prior to the loss of the structure's or component's intended function.
The Structures Monitoring Program is an existing program that manages age-related degradation of plant structures and structural components within its scope to ensure that each structure or structural component retains the ability to perform its intended function. Aging effects are detected by visual inspection of external surfaces prior to the loss of the structure's or component's intended function.
This program implements provisions of the Maintenance Rule, 10 CFR 50.65, that relate to structures, masonry walls, and water-control structures. Concrete and masonry walls that perform a fire barrier intended function are also managed by the Fire Protection Program.
This program implements provisions of the Maintenance Rule, 10 CFR 50.65, that relate to structures, masonry walls, and water-control structures. Concrete and masonry walls that perform a fire barrier intended function are also managed by the Fire Protection Program.
Prior to the period of extended operation, the Structures Monitoring Program will be enhanced to include structures within the scope of license renewal. The program will be enhanced to specify inspections of a below grade structural wall or structural component that becomes accessible through excavation. The program will be enhanced to clarify the component types included as "structural components".       The program will be enhanced and to specify degradation mechanisms for elastomer and earthen embankment inspection. The Structures Monitorng Program program will be enhanced to include RG 1.127 inspection elements for water-control structures. The program will be enhanced to include and requirements for review of site groundwater and raw water parameters. The program will also be enhanced to specify inspection requirements for masonry walls. The program will be enhanced to include direction for quantifying, monitoring and trending of inspection results, guidance for inspection reporting, data collection and documentation, acceptance criteria and critical parameters to monitor degradationand to trigger level of inspection and initiation of corrective action; and better alignment with referenced Industry codes, standards and guidelines. The program will be enhanced to include specific qualification requirementsfor the inspector.
Prior to the period of extended operation, the Structures Monitoring Program will be enhanced to include structures within the scope of license renewal. The program will be enhanced to specify inspections of a below grade structural wall or structural component that becomes accessible through excavation. The program will be enhanced to clarify the component types included as "structural components".
The program will be enhanced and to specify degradation mechanisms for elastomer and earthen embankment inspection.
The Structures Monitorng Program program will be enhanced to include RG 1.127 inspection elements for water-control structures.
The program will be enhanced to include and requirements for review of site groundwater and raw water parameters. The program will also be enhanced to specify inspection requirements for masonry walls.
The program will be enhanced to include direction for quantifying, monitoring and trending of inspection results, guidance for inspection reporting, data collection and documentation, acceptance criteria and critical parameters to monitor degradation and to trigger level of inspection and initiation of corrective action; and better alignment with referenced Industry codes, standards and guidelines. The program will be enhanced to include specific qualification requirements for the inspector.


Enclosure to PLA-6427 Page 6 of 9 Table A-1, SSES License Renewal Commitments The Commitment for Item Number 34) Structures Monitoring Program in Table A-1 (LRA pages A-45 to A-46) is revised addition (bold italics).
Enclosure to PLA-6427 Page 6 of 9 Table A-1, SSES License Renewal Commitments The Commitment for Item Number 34) Structures Monitoring Program in Table A-1 (LRA pages A-45 to A-46) is revised addition (bold italics).
Table A-1 SSES License Renewal Commitments FSAR       Enhancement Supplement           or Commitment                                 locat             on Item Number Location     Implementation (LRA App. A)     Schedule
Table A-1 SSES License Renewal Commitments FSAR Enhancement Supplement or Item Number Commitment locat on Location Implementation (LRA App. A)
: 34)   Structures   Existing program is credited with the following enhancements:           A.1.2.45   Prior to the period Monitoring
Schedule
* Include additional structures requiring aging management for                   of extended Program         license renewal to the scope of the inspections.                               operation.
: 34)
Structures Existing program is credited with the following enhancements:
A.1.2.45 Prior to the period Monitoring
* Include additional structures requiring aging management for of extended Program license renewal to the scope of the inspections.
operation.
* Specify that if a below grade structural wall or structural component becomes accessible through excavation; a follow-up action is initiated for the responsible engineer to inspect the exposed surfaces for age-related degradation.
* Specify that if a below grade structural wall or structural component becomes accessible through excavation; a follow-up action is initiated for the responsible engineer to inspect the exposed surfaces for age-related degradation.
* Clarify "structural component" for inspection includes each of the component types identified as requiring aging management.
* Clarify "structural component" for inspection includes each of the component types identified as requiring aging management.
                    " Include degradation mechanisms         for elastomer and earthen embankment inspection.
" Include degradation mechanisms for elastomer and earthen embankment inspection.
                    " Include RG 1.127 inspection elements for water-control structure.
" Include RG 1.127 inspection elements for water-control structure.
                    " Specify that the responsible engineer shall review site groundwater and raw water pH, chlorides, and sulfates results prior to inspection to validate that the below-grade or raw water environment remain non-aggressive during the period of extended operation.
" Specify that the responsible engineer shall review site groundwater and raw water pH, chlorides, and sulfates results prior to inspection to validate that the below-grade or raw water environment remain non-aggressive during the period of extended operation.


Enclosure to PLA-6427 Page 7 of 9 Table A-1 SSES License Renewal Commitments FSAR     Enhancement Supplement         or Commitment                                     locat           on Item Number Location   Implementation (LRA App. A)   Schedule Specify that for each masonry wall, the extent of observed masonry     cracking   and/or   degradation     of steel     edge supports/bracing are evaluated to ensure that the current evaluation basis is still valid. Corrective action is required if the extent of masonry cracking and steel degradation is sufficient to invalidate the evaluation basis.
Enclosure to PLA-6427 Page 7 of 9 Table A-1 SSES License Renewal Commitments FSAR Enhancement Supplement or Item Number Commitment locat on Location Implementation (LRA App. A)
Include additional direction for quantifying, monitoring and trending of inspection results; Include additionalguidance for inspection reporting, data collection and documentation; Specify acceptance criteria and criticalparameters to monitor degradationand to triggerlevel of inspection and initiation of corrective action; and provide better alignment with referenced Industry codes, standardsand guidelines.
Schedule Specify that for each masonry wall, the extent of observed masonry cracking and/or degradation of steel edge supports/bracing are evaluated to ensure that the current evaluation basis is still valid.
* Include specific qualificationrequirementsfor the inspector.
Corrective action is required if the extent of masonry cracking and steel degradation is sufficient to invalidate the evaluation basis.
Include additional direction for quantifying, monitoring and trending of inspection results; Include additional guidance for inspection reporting, data collection and documentation; Specify acceptance criteria and critical parameters to monitor degradation and to trigger level of inspection and initiation of corrective action; and provide better alignment with referenced Industry codes, standards and guidelines.
* Include specific qualification requirements for the inspector.


Enclosure to PLA-6427 Page 8 of 9 B.2.39     Structures Monitoring Program Required Enhancements
Enclosure to PLA-6427 Page 8 of 9 B.2.39 Structures Monitoring Program Required Enhancements The Required Enhancements discussion (LRA page B-117 to B-118) is revised by addition (bold italics). Bullets Monitoring and Trending, Acceptance Criteria and Detection of Aging Effects have been added.
The Required Enhancements discussion (LRA page B-117 to B-118) is revised by addition (bold italics). Bullets Monitoring and Trending, Acceptance Criteria and Detection of Aging Effects have been added.
Monitoring and Trending, Acceptance Criteria -
Monitoringand Trending, Acceptance Criteria-The Structures Monitoring Program procedure will be enhanced to include the following:
The Structures Monitoring Program procedure will be enhanced to include the following:
        > Additional direction for quantifying, monitoring and trending of inspection results.
> Additional direction for quantifying, monitoring and trending of inspection results.
        > Additional guidance for inspectionreporting,data collection and documentation.
> Additional guidance for inspection reporting, data collection and documentation.
        >   Sufficient acceptance criteriaand critical parametersto monitor degradation and to triggerlevel of inspection and initiationof correctiveaction.
> Sufficient acceptance criteria and critical parameters to monitor degradation and to trigger level of inspection and initiation of corrective action.
        > Better alignment with referenced Industry codes, standards and guidelines regardingterminology and evaluation.
> Better alignment with referenced Industry codes, standards and guidelines regarding terminology and evaluation.
      " Detection of Aging Effects -
" Detection of Aging Effects -
The Structures Monitoring Program procedure will be enhanced to provide specific qualificationrequirements for the inspector.
The Structures Monitoring Program procedure will be enhanced to provide specific qualification requirements for the inspector.


Enclosure to PLA-6427 Page 9 of 9 NRC Inspection Issue Related to AMP B.2.47 - Leak Chase Channel Monitoring Activities:
Enclosure to PLA-6427 Page 9 of 9 NRC Inspection Issue Related to AMP B.2.47 - Leak Chase Channel Monitoring Activities:
PPL Response:
PPL Response:
The SSES LRA is amended as follows to clarify that the scope of the SSES Leak Chase Channel Monitoring Activities is to detect loss of material aging effects for the spent fuel pool and fuel shipping cask storage pool liners.
The SSES LRA is amended as follows to clarify that the scope of the SSES Leak Chase Channel Monitoring Activities is to detect loss of material aging effects for the spent fuel pool and fuel shipping cask storage pool liners.
B.2.47       Leak Chase Channel Monitoring Activities Aging Management Program Elements
B.2.47 Leak Chase Channel Monitoring Activities Aging Management Program Elements
> The Scope of Activity discussion (LRA page B-143) is revised by addition (bold italics)and deletion (sthiketheeugh).
> The Scope of Activity discussion (LRA page B-143) is revised by addition (bold italics) and deletion (sthiketheeugh).
Scope of Activity The Leak Chase Channel Monitoring Activities, which include periodic monitoring of the spent fuel pool and fuel shipping cask storage pool leak chase system, are credited for
Scope of Activity The Leak Chase Channel Monitoring Activities, which include periodic monitoring of the spent fuel pool and fuel shipping cask storage pool leak chase system, are credited for
        .upplementing the BWR Water C-he,-*mistr, Program for managing detecting loss of material aging effects for the spent fuel pool and fuel shipping cask storage pool liners.
.upplementing the BWR Water C-he,-*mistr, Program for managing detecting loss of material aging effects for the spent fuel pool and fuel shipping cask storage pool liners.
Conclusion
Conclusion
>   The Conclusion discussion (LRA page B-145) is revised by addition (bold italics)and deletion (rikethFetg§).
> The Conclusion discussion (LRA page B-145) is revised by addition (bold italics) and deletion (rikethFetg§).
The Leak Chase Channel Monitoring Activities include cycling the spent fuel pool and fuel shipping cask storage pool liner drain valves to detect potential leakage from the spent fuel pool and fuel shipping cask storage pool liners. The leak chase channel monitoring
The Leak Chase Channel Monitoring Activities include cycling the spent fuel pool and fuel shipping cask storage pool liner drain valves to detect potential leakage from the spent fuel pool and fuel shipping cask storage pool liners. The leak chase channel monitoring
          -,uppler*net* the BVWR Water Chemiritny Program by detecting detects loss of material aging effect through leakage monitoring such that the spent fuel pool and fuel shipping cask storage pool liner's integrity and intended functions will be maintained consistent with the current licensing basis for the period of extended operation.
-,uppler*net* the BVWR Water Chemiritny Program by detecting detects loss of material aging effect through leakage monitoring such that the spent fuel pool and fuel shipping cask storage pool liner's integrity and intended functions will be maintained consistent with the current licensing basis for the period of extended operation.
                                                                    .1}}
.1}}

Latest revision as of 14:35, 14 January 2025

License Renewal Application (LRA) Amendments to Sections B.2.38, B.2.39, and B.2.47 in Response to NRC Regional Inspection PLA-6427
ML083030165
Person / Time
Site: Susquehanna  Talen Energy icon.png
Issue date: 09/23/2008
From: Mckinney B
Susquehanna
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
PLA-6427
Download: ML083030165 (11)


Text

Britt T. McKinney PPL Susquehanna, LLC Sr. Vice President & Chief Nuclear Officer 769 Salem Boulevard a

m l

Berwick, PA 18603

, So Tel. 570.542.3149 Fax 570.542.1504 btmckinney@pplweb.com SEP 23 206 P

P14ý TM U. S. Nuclear Regulatory Commission Document Control Desk Mail Stop OP1-17 Washington, DC 20555 SUSQUEHANNA STEAM ELECTRIC STATION UNITS 1 AND 2, LICENSE RENEWAL APPLICATION (LRA)

AMENDMENTS TO SECTIONS B.2.38, B.2.39, AND B.2.47 IN RESPONSE TO NRC REGIONAL INSPECTION Docket Nos. 50-387 PLA-6427 and 50-388

Reference:

1) PLA-61))0, Mr. B. T McKinney (PPL) to Document Control Desk (USNRC),

"Application for Renewed Operating License Numbers NPF-14 and NPF-22,"

dated September 13, 2006.

In accordance with the requirements of 10 CFR 50, 51, and 54, PPL requested the renewal of the operating licenses for the Susquehanna Steam Electric Station (SSES)

Units 1 and 2 in Reference 1.

The License Renewal process includes an inspection by regional inspectors to verify the applicant's license renewal program is implemented in accordance with the requirements of 10CFR54. NRC conducted a regional inspection of the SSES LRA from August 11, 2008 through August 29, 2008. As a result of the inspection, the SSES LRA aging management programs (AMP) for masonry walls (B.2.38), structures monitoring program (B.2.39), and leak chase channel monitoring program (B.2.47) were determined to require revision. The LRA changes to resolve these inspection issues are identified in the enclosure.

There are no new regulatory commitments contained herein as a result of the attached responses. However, license renewal commitment #34, in LRA Table A-i, is revised as indicated in the PPL Response to inspection issues related to AMP B.2.39.

If you have any questions, please contact Mr. Duane L. Filchner at (610) 774-7819.

Document Control Desk PLA-6427 I declare, under penalty of perjury, that the foregoing is true and correct.

Executed on:

J/73 IZ&,Z B.

I ney

Enclosure:

PPL Responses to NRC's Regional Inspection Copy: NRC Region I Ms. E. H. Gettys, NRC Project Manager, License Renewal, Safety Mr. R. Janati, DEP/BRP Mr. F. W. Jaxheimer, NRC Sr. Resident Inspector Mr. A. L. Stuyvenberg, NRC Project Manager, License Renewal, Environmental

Enclosure to PLA-6427 PPL Responses to NRC's Regional Inspection

Enclosure to PLA-6427 Page 2 of 9 NRC Inspection Issue Related to AMP B.2.38 - Masonry Wall Program:

PPL Response:

The SSES LRA is amended as follows to identify that masonry block walls are in scope and subject to aging management review for the ESSW Pumphouse.

2.4.3 Engineered Safeguards Service Water Pumphouse and Spray Pond Structure Description

  • - Walls discussion (LRA page 2.4-11) is revised by addition (bold italics).

The ESSW Pumphouse consists of the following major structural components:

Foundation Mat - The reinforced concrete foundation mat is founded on soil. The depth of soil below the mat foundation varies from 35 to 60 feet. The soil is predominantly sand, gravel, cobbles, and boulders.

Floors - The operating floor is of reinforced concrete supported by steel beams. The mezzanine floor is composed of grating over steel beams.

Roof - The roof is of reinforced concrete supported by steel beams.

Walls - The bearing walls are of reinforced concrete and are designed as shear walls to resist lateral loads. Masonry block wall is installed at entryway for security reasons.

Chambers - The pump intake chambers and the overflow weir chamber are continuously flooded by the spray pond.

Table 2.4-3, ESSW Pumphouse and Spray Pond Components Subject to Aging Management Review

> Table 2.4-3 (LRA page 2.4-14) is revised by addition (bold italics).

Table 2.4-3 ESSW Pumphouse and Spray Pond Components Subject to Aging Management Review Intended Function Component Type (as defined in Table 2.0-1)

Masonry block walls SNS

Enclosure to PLA-6427 Page 3 of 9 3.5.2.1.3 Engineered Safeguards Service Water (ESSW) Pumphouse and Spray Pond

> Materials and Aging Management Programs discussions (LRA pages 3.5-5 and 3.5-6) are revised by addition (bold italics).

Materials ESSW Pumphouse and Spray Pond components subject to aging management review are constructed of the following materials:

Carbon Steel Concrete Concrete Blocks Earthen Galvanized Steel Stainless Steel Aging Management Programs The following programs are credited for managing the effects of aging on ESSW Pumphouse and Spray Pond components:

Fire Protection Program Masonry Wall Program Structures Monitoring Program RG 1.127Water-Control Structures Inspection

Enclosure to PLA-6427 Page 4 of 9 Table 3.5.2-3, Aging Management Review Results - Engineered Safeguards Service Water Pumphouse and Spray Pond LRA Table 3.5.2-3 (LRA page 3.5-88) is revised by addition (bold italics).

Table 3.5.2-3 Aging Management Review Results - Engineered Safeguards Service Water Pumphouse and Spray Pond Aging Effect Aging NUREG-Commodity Function 1 Material Environment Requiring Management Volume Table 1 Item Notes Comodty Funtin'Management Programs Voluem2 Masonry Concrete Protected Masonry Wall Block SNS Blocks from weather Cracking Program III.A6-10 3.5.1-43 A

Walls Masonry Concrete Exposed to Masonry Wall Block SNS Blocks weather Cracking Program lll.A6-1O 3.5.1-43 A

Walls

Enclosure to PLA-6427 Page 5 of 9 NRC Inspection Issue Related to AMP B.2.39 - Structures Monitoring Program:

PPL Response:

The SSES LRA is amended as follows to enhance the Monitoring and Trending, Acceptance Criteria, and Detection of Aging Effects elements of the existing SSES Structures Monitoring Program.

A.1.2.45 Structures Monitoring Program

> The discussion in Section A.1.2.45 (LRA pages A-19 to A-20) is revised by deletion

(&trikethrough) and addition (bold italics).

The Structures Monitoring Program is an existing program that manages age-related degradation of plant structures and structural components within its scope to ensure that each structure or structural component retains the ability to perform its intended function. Aging effects are detected by visual inspection of external surfaces prior to the loss of the structure's or component's intended function.

This program implements provisions of the Maintenance Rule, 10 CFR 50.65, that relate to structures, masonry walls, and water-control structures. Concrete and masonry walls that perform a fire barrier intended function are also managed by the Fire Protection Program.

Prior to the period of extended operation, the Structures Monitoring Program will be enhanced to include structures within the scope of license renewal. The program will be enhanced to specify inspections of a below grade structural wall or structural component that becomes accessible through excavation. The program will be enhanced to clarify the component types included as "structural components".

The program will be enhanced and to specify degradation mechanisms for elastomer and earthen embankment inspection.

The Structures Monitorng Program program will be enhanced to include RG 1.127 inspection elements for water-control structures.

The program will be enhanced to include and requirements for review of site groundwater and raw water parameters. The program will also be enhanced to specify inspection requirements for masonry walls.

The program will be enhanced to include direction for quantifying, monitoring and trending of inspection results, guidance for inspection reporting, data collection and documentation, acceptance criteria and critical parameters to monitor degradation and to trigger level of inspection and initiation of corrective action; and better alignment with referenced Industry codes, standards and guidelines. The program will be enhanced to include specific qualification requirements for the inspector.

Enclosure to PLA-6427 Page 6 of 9 Table A-1, SSES License Renewal Commitments The Commitment for Item Number 34) Structures Monitoring Program in Table A-1 (LRA pages A-45 to A-46) is revised addition (bold italics).

Table A-1 SSES License Renewal Commitments FSAR Enhancement Supplement or Item Number Commitment locat on Location Implementation (LRA App. A)

Schedule

34)

Structures Existing program is credited with the following enhancements:

A.1.2.45 Prior to the period Monitoring

operation.

  • Specify that if a below grade structural wall or structural component becomes accessible through excavation; a follow-up action is initiated for the responsible engineer to inspect the exposed surfaces for age-related degradation.
  • Clarify "structural component" for inspection includes each of the component types identified as requiring aging management.

" Include degradation mechanisms for elastomer and earthen embankment inspection.

" Include RG 1.127 inspection elements for water-control structure.

" Specify that the responsible engineer shall review site groundwater and raw water pH, chlorides, and sulfates results prior to inspection to validate that the below-grade or raw water environment remain non-aggressive during the period of extended operation.

Enclosure to PLA-6427 Page 7 of 9 Table A-1 SSES License Renewal Commitments FSAR Enhancement Supplement or Item Number Commitment locat on Location Implementation (LRA App. A)

Schedule Specify that for each masonry wall, the extent of observed masonry cracking and/or degradation of steel edge supports/bracing are evaluated to ensure that the current evaluation basis is still valid.

Corrective action is required if the extent of masonry cracking and steel degradation is sufficient to invalidate the evaluation basis.

Include additional direction for quantifying, monitoring and trending of inspection results; Include additional guidance for inspection reporting, data collection and documentation; Specify acceptance criteria and critical parameters to monitor degradation and to trigger level of inspection and initiation of corrective action; and provide better alignment with referenced Industry codes, standards and guidelines.

  • Include specific qualification requirements for the inspector.

Enclosure to PLA-6427 Page 8 of 9 B.2.39 Structures Monitoring Program Required Enhancements The Required Enhancements discussion (LRA page B-117 to B-118) is revised by addition (bold italics). Bullets Monitoring and Trending, Acceptance Criteria and Detection of Aging Effects have been added.

Monitoring and Trending, Acceptance Criteria -

The Structures Monitoring Program procedure will be enhanced to include the following:

> Additional direction for quantifying, monitoring and trending of inspection results.

> Additional guidance for inspection reporting, data collection and documentation.

> Sufficient acceptance criteria and critical parameters to monitor degradation and to trigger level of inspection and initiation of corrective action.

> Better alignment with referenced Industry codes, standards and guidelines regarding terminology and evaluation.

" Detection of Aging Effects -

The Structures Monitoring Program procedure will be enhanced to provide specific qualification requirements for the inspector.

Enclosure to PLA-6427 Page 9 of 9 NRC Inspection Issue Related to AMP B.2.47 - Leak Chase Channel Monitoring Activities:

PPL Response:

The SSES LRA is amended as follows to clarify that the scope of the SSES Leak Chase Channel Monitoring Activities is to detect loss of material aging effects for the spent fuel pool and fuel shipping cask storage pool liners.

B.2.47 Leak Chase Channel Monitoring Activities Aging Management Program Elements

> The Scope of Activity discussion (LRA page B-143) is revised by addition (bold italics) and deletion (sthiketheeugh).

Scope of Activity The Leak Chase Channel Monitoring Activities, which include periodic monitoring of the spent fuel pool and fuel shipping cask storage pool leak chase system, are credited for

.upplementing the BWR Water C-he,-*mistr, Program for managing detecting loss of material aging effects for the spent fuel pool and fuel shipping cask storage pool liners.

Conclusion

> The Conclusion discussion (LRA page B-145) is revised by addition (bold italics) and deletion (rikethFetg§).

The Leak Chase Channel Monitoring Activities include cycling the spent fuel pool and fuel shipping cask storage pool liner drain valves to detect potential leakage from the spent fuel pool and fuel shipping cask storage pool liners. The leak chase channel monitoring

-,uppler*net* the BVWR Water Chemiritny Program by detecting detects loss of material aging effect through leakage monitoring such that the spent fuel pool and fuel shipping cask storage pool liner's integrity and intended functions will be maintained consistent with the current licensing basis for the period of extended operation.

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