ML021990516
| ML021990516 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 07/18/2002 |
| From: | Anand R Division of Regulatory Improvement Programs |
| To: | |
| Anand R, NRR/DRIP, 415-1146 | |
| References | |
| Download: ML021990516 (7) | |
Text
July 18, 2002 APPLICANT: Exelon Generation Company, LLC FACILITIES: Peach Bottom Atomic Power Station, Units 2 and 3
SUBJECT:
TELECOMMUNICATION WITH EXELON GENERATION COMPANY, LLC (EXELON) TO DISCUSS INFORMATION IN SECTION 2.5 SCOPING AND SCREENING RESULTS: ELECTRICAL AND INSTRUMENTATION AND CONTROL AND 3.6 AGING MANAGEMENT OF ELECTRICAL AND INSTRUMENTATION AND CONTROLS OF THE PEACH BOTTOM ATOMIC POWER STATION (PBAPS) LICENSE RENEWAL APPLICATION On January 23 and March 12, 2002, the NRC staff (hereafter referred to as the staff) issued request for additional Information (RAI) pertaining to Section 2.5 Scoping and Screening Results: Electrical and Instrumentation and Controls, and Section 3.6 Aging Management of electrical and Instrumentation and Controls, of the license renewal application (LRA). Exelon (hereafter referred to as the applicant) responded to this request by letters dated April 29, and May 22, 2002. On June 18 and July 15, 2002, conference calls were conducted between the staff and the applicant to discuss information provided to staff pertaining to Sections 2.5 and 3.6. The information discussed, the applicants responses, and the follow-up actions are provided below. Participants of the June 18 and July 15, 2002, conference calls are enclosed.
The subject discussed was Station Blackout System (SBO). The staff reviewed the applicant's response to RAI 2.5-1 Station Blackout System, provided in a letter dated March 12, 2002.
Specifically, the staff requested a description of the PBAPS recovery path for offsite power from its power sources to the 4 KV emergency buses. Staff also requested a compete and comprehensive table displaying aging management review results, including consideration of operating experience for electrical structures, systems, and components as identified in the LRA. The applicant agreed to supplement the additional information in a letter to the NRC.
The staff discussed the GALL Report, Program XI.E3, "Inaccessible Medium-Voltage Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements." The applicant elected to replace cables suspect to water-treeing. Since the replacement cables were suitable for use in a wet environment, the applicant believes that moisture is not an aging effect requiring management at PBAPS.
The applicant stated that the replacement program was initiated at PBAPS in 1995 and completed in 1999. The replacement cable was ethylene propylene Rubber (EPR) insulated cable, pink in color, with a poly-vinyl-chloride (PVC) jacket, suitable for use in wet or dry locations in conduit, underground duct systems, direct buried, or aerial installations.
Based on review of a paper entitled, "An Assessment of Field Aged 15KV and 35 KV Ethylene Propylene Rubber Insulated Cables," published in the 1994, T&D Conference Proceeding and review of the manufacturers data sheet, the applicant believes that the cables were suitable for use in a wet environment and that moisture is not an aging effect requiring management at PBAPS.
The staff stated that PBAPS responded to a series of non-safety related cable failures due to water trees between 1984 and 1991 with a cable replacement program that was completed in 1999. The staff acknowledges that the replacement cable (EPR insulation) is an improved formulation, which is more resistant to water-treeing. However, the staff does not accept the applicants position that moisture is not an aging effect requiring aging management for these cables. The staff believes that the discussion and conclusions in the "Assessment of Field Aged 15 KV and 35 KV Ethylene Propylene Ruber Insulated Cables" do not support the applicants position that moisture is not an aging effect requiring management at PBAPS. For example, this study concludes that aging of the EPR insulated cables can be characterized by an increase in moisture content, growth of water trees, drop in insulation elongation, increase in dissipation factor and decrease in ac and impulse voltage breakdown strength. Further, the data for water trees, elongation, dissipation factor, ac and impulse strength indicate that EPR insulated cable deterioration appears to result from moisture permeating the insulation of the cable. As such, the staff is concerned that the applicant has not provided a sufficient technical justification for not requiring an aging management program and, has not proposed to do what it can do to prevent cables from being exposed to significant moisture, such as inspecting for water collection in cable manholes and conduit, and draining water, as needed. The staff indicated that this issue will be a potential open item in the SER.
A draft of this telephone conversation summary was provided to the applicant to allow them the opportunity to comment on the contents of its input prior to the summary being issued.
/RA/
Raj K. Anand, Project Manager License Renewal and Environmental Impacts Program Division of Regulatory Improvement Programs Office of Nuclear Reactor Regulation Docket Nos. 50-277 and 50-278
Enclosure:
As stated cc w/enclosure: See next page
The staff stated that PBAPS responded to a series of non-safety related cable failures due to water trees between 1984 and 1991 with a cable replacement program that was completed in 1999. The staff acknowledges that the replacement cable (EPR insulation) is an improved formulation, which is more resistant to water-treeing. However, the staff does not accept the applicants position that moisture is not an aging effect requiring aging management for these cables. The staff believes that the discussion and conclusions in the "Assessment of Field Aged 15 KV and 35 KV Ethylene Propylene Ruber Insulated Cables" do not support the applicants position that moisture is not an aging effect requiring management at PBAPS. For example, this study concludes that aging of the EPR insulation cables can be characterized by an increase in moisture content, growth of water trees, drop in insulation elongation, increase in dissipation factor and decrease in ac and impulse voltage breakdown strength. Further, the data for water trees, elongation, dissipation factor, ac and impulse strength indicate that EPR insulation cable deterioration appears to result from moisture permeating the insulation of the cable. As such, the staff is concerned that the applicant has not provided a sufficient technical justification for not requiring an aging management program and, has not proposed to do what it can do to prevent cables from being exposed to significant moisture, such as inspecting for water collection in cable manholes and conduit, and draining water, as needed. The staff indicated that this issue will be a potential open item in the SER.
A draft of this telephone conversation summary was provided to the applicant to allow them the opportunity to comment on the contents of its input prior to the summary being issued.
/RA/
Raj K. Anand, Project Manager License Renewal and Environmental Impacts Program Division of Regulatory Improvement Programs Office of Nuclear Reactor Regulation Docket Nos. 50-277 and 50-278
Enclosure:
As stated cc w/enclosure: See next page DISTRIBUTION:
See next page DOCUMENT NAME: C:\ORPCheckout\FileNET\ML021990516.wpd OFFICE PM:RLEP:DRIP LA:DRIP DE SC:RLEP:DRIP NAME RAnand HBerilla PShemanski SLee DATE 07/ 17/02 07/17/02 07/18/02 07/18 /02 OFFICIAL RECORD COPY
DISTRIBUTION: Telecommunication with Exelon, Dated: July 18, 2002 HARD COPY RLEP RF E-MAIL:
PUBLIC J. Johnson W. Borchardt D. Matthews F. Gillespie RidsNrrDe R. Barrett E. Imbro G. Bagchi K. Manoly W. Bateman J. Calvo C. Holden P. Shemanski H. Nieh G. Holahan H. Walker S. Black B. Boger D. Thatcher G. Galletti C. Li J. Moore R. Weisman M. Mayfield A. Murphy W. McDowell S. Droggitis T. Kobetz RLEP Staff
TELECOMMUNICATION PARTICIPANTS NRC STAFF Paul Gill Paul Shemanski James Lazevnick Amar Pal Raj Anand EXELON Erach Patel Al Fulvio Paul Thomas Kevin Muggleston Jerry Phillabaum Enclosure
Peach Bottom Atomic Power Station, Units 2 and 3 cc:
Mr. Edward Cullen Correspondence Control Desk Vice President & General Counsel Exelon Generation Company, LLC Exelon Generation Company, LLC 200 Exelon Way, KSA 1-N-1 300 Exelon Way Kennett Square, PA 19348 Kennett Square, PA 19348 Rich Janati, Chief Mr. J. Doering Division of Nuclear Safety Site Vice President Bureau of Radiation Protection Peach Bottom Atomic Power Station Department of Environmental Protection 1848 Lay Road Rachel Carson State Office Building Delta, PA 17314 P.O. Box 8469 Harrisburg, PA 17105-8469 Mr. G. Johnston Plant Manager Board of Supervisors Peach Bottom Atomic Power Station Peach Bottom Township 1848 Lay Road R. D. #1 Delta, PA 17314 Delta, PA 17314 Mr. D. A. Henry Public Service Commission of Maryland Regulatory Assurance Manager Engineering Division Peach Bottom Atomic Power Station Chief Engineer 1848 Lay Road 6 St. Paul Center Delta, PA 17314 Baltimore, MD 21202-6806 Resident Inspector Mr. Richard McLean U.S. Nuclear Regulatory Commission Power Plant and Environmental Peach Bottom Atomic Power Station Review Division P.O. Box 399 Department of Natural Resources Delta, PA 17314 B-3, Tawes State Office Building Annapolis, MD 21401 Regional Administrator, Region I U.S. Nuclear Regulatory Commission Dr. Judith Johnsrud 475 Allendale Road National Energy Committee King of Prussia, PA 19406 Sierra Club 433 Orlando Avenue Mr. Roland Fletcher State College, PA 16803 Department of Environment Radiological Health Program Manager-Financial Control & Co-Owner 2400 Broening Highway Affairs Baltimore, MD 21224 Public Service Electric and Gas Company P.O. Box 236 Hancocks Bridge, NJ 08038-0236
Peach Bottom Atomic Power Station Units 2 and 3 cc:
Mr. Jeffrey A. Benjamin Vice President-Licensing Exelon Generation Company, LLC 4300 Winfield Road Downers Grove, IL 60515 Mr. Michael P. Gallagher Director - Licensing Mid-Atlantic Regional Operating Group Exelon Generation Company, LLC 200 Exelon Way, KSA 3-E Kennett Square, PA 19348 Mr. Charles Pardee Senior Vice President Mid-Atlantic Regional Operating Group Exelon Generation Company, LLC 200 Exelon Way, KSA 3-N Kennett Square, PA 19348 Mr. John Skolds Chief Operating Officer Exelon Generation Company, LLC 4300 Winfield Road Downers Grove, IL 60515 Mr. William Bohlke Senior Vice President, Nuclear Services Exelon Generation Company, LLC 4300 Winfield Road Downers Grove, IL 60515 Mr. Jim Meister Senior Vice President, Operations Support Exelon Generation Company, LLC 4300 Winfield Road Downers Grove, IL 60515 Mr. Frederick W. Polaski Manager License Renewal Exelon Corporation 200 Exelon Way Kennett Square, PA 19348