ML063600004

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Summary of the License Renewal Meeting Between the U.S. Nuclear Regulatory Commission Staff and the Nuclear Energy Institute Regarding Generic Aging Lessons Learned Aging Management Program XI.E6
ML063600004
Person / Time
Site: PROJ0690
Issue date: 01/26/2007
From: Hoffman S
NRC/NRR/ADRO/DLR/RLRB
To:
Nuclear Energy Institute
Hoffman, S T, NRR, 415-3245
References
Download: ML063600004 (7)


Text

January 26, 2007 ORGANIZATION: Nuclear Energy Institute

SUBJECT:

SUMMARY

OF THE LICENSE RENEWAL MEETING BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION STAFF AND THE NUCLEAR ENERGY INSTITUTE REGARDING GENERIC AGING LESSONS LEARNED AGING MANAGEMENT PROGRAM XI.E6 The U.S. Nuclear Regulatory Commission (NRC) staff and the Nuclear Energy Institute (NEI) met on November 30, 2006, to discuss the NRC staffs review of NEIs submittal regarding the need for Generic Aging Lessons Learned (GALL) Aging Management Program (AMP) XI.E6, Electrical Cable Connections Not Subject to Title 10 of the Code of Federal Regulation (10 CFR) 50.49 Environmental Qualification. NEIs position is contained in a white paper submitted by letter dated September 5, 2006 (ADAMS Accession No. ML062770100). provides a listing of the meeting participants and the meeting agenda is contained in Enclosure 2. The NRC staffs talking points are contained in Enclosure 3.

The NRC staff addressed each of the industry concerns as stated in the NEI white paper and two additional operating experiences that the staff identified. In search of operating experience, the staff has found that the majority of loose connections events was due to human errors or design deficiencies. Operating experience has not shown that failed connections due to aging are a significant cause of loss of safety related equipment and very few connection failures were related to aging. These operating experiences do not appear to support a periodic inspection as currently proposed in AMP XI.E6. The NRC staff will consider revising AMP XI.E6 to recommend a one time inspection on a sample basis to ensure that either aging of cable connections is not occurring or existing preventive maintenance programs are effective such that a periodic inspection is not required. NEI responded to the NRC staff proposal of a one time inspection for cable connections with comments regarding sample size and connections associated with control room equipment. Additionally, the industry wanted to take credit for periodic preventive maintenance programs involving cable connections. Based on discussions related to Enclosure 3, the NRC staff determined that if indications of any degradation are identified, corrective actions must be implemented, including sample size expansion and periodic inspection. The NRC staff indicated that it will issue an interim staff guidance to revise AMP XI.E6 to recommend a one time inspection for cable connections.

/RA/

Stephen T. Hoffman, Senior Project Manager License Renewal Branch B Division of License Renewal Office of Nuclear Reactor Regulation Project No. 690

Enclosures:

As stated cc w/encls: See next page

ML062770100). provides a listing of the meeting participants and the meeting agenda is contained in Enclosure 2. The NRC staffs talking points are contained in Enclosure 3.

The NRC staff addressed each of the industry concerns as stated in the NEI white paper and two additional operating experiences that the staff identified. In search of operating experience, the staff has found that the majority of loose connections events was due to human errors or design deficiencies. Operating experience has not shown that failed connections due to aging are a significant cause of loss of safety related equipment and very few connection failures were related to aging. These operating experiences do not appear to support a periodic inspection as currently proposed in AMP XI.E6. The NRC staff will consider revising AMP XI.E6 to recommend a one time inspection on a sample basis to ensure that either aging of cable connections is not occurring or existing preventive maintenance programs are effective such that a periodic inspection is not required. NEI responded to the NRC staff proposal of a one time inspection for cable connections with comments regarding sample size and connections associated with control room equipment. Additionally, the industry wanted to take credit for periodic preventive maintenance programs involving cable connections. Based on discussions related to Enclosure 3, the NRC staff determined that if indications of any degradation are identified, corrective actions must be implemented, including sample size expansion and periodic inspection. The NRC staff indicated that it will issue an interim staff guidance to revise AMP XI.E6 to recommend a one time inspection for cable connections.

/RA/

Stephen T. Hoffman, Senior Project Manager License Renewal Branch B Division of License Renewal Office of Nuclear Reactor Regulation Project No. 690

Enclosures:

As stated cc w/encls: See next page DISTRIBUTION: See next page ADAMS Accession No: ML063600004 DOCUMENT NAME:C:\\FileNet\\ML063600004.wpd OFFICE LA:DLR PM:RLRB:DLR BC:RLRC:DLR BC:RLRB:DLR NAME SFigueroa SHoffman KChang SHoffman for RAuluck DATE 12/27/06 01/26/07 01/26/07 01/26/07

ENCLOSURE 1 List of Participants for the Meeting Between the U.S. Nuclear Regulatory Commission Staff and the Nuclear Energy Institute November 30, 2006 PARTICIPANTS AFFILIATIONS Pao-Tsin (P. T.) Kuo U.S. Nuclear Regulatory Commission (NRC)

Rajender Auluck NRC Kenneth Chang NRC Stephen Hoffman NRC Eric Benner NRC Duc Nguyen NRC Amar Pal NRC George Morris NRC Noel Dudley NRC Om Chopra NRC Ngoc Le NRC Roy Matthews NRC James Ross Nuclear Energy Institute Mike Stroud Entergy Nuclear Arden Aldridge Strategic Teaming and Resource Sharing (STARS)

Chalmer Myer Southern Nuclear Company (SNC)

Cary Martin SNC Fred Polaski Exelon Deb Spamer Exelon Charles Sorrell Dominion Don Duncan Dominion Joseph Ruether NMC Larry Seamans NMC - Palisades Dave Flyte PPL Susquehanna Mike Heath Progress Energy Joseph Tweddell First Energy Roger Rucker First Energy/Excel Services Bill Horin Winston & Strawn Mike Fallin

  • Constellation Gary Warner
  • APS Steve Schellin *
  • By telephone

ENCLOSURE 2 Agenda NRC Staff Meeting with NEI to Discuss Aging Management Program (AMP) XI.E6 November 30, 2006

1. Address NEIs White Paper on GALL AMP XI.E6 NRC
2. Discuss Additional Operating Experiences NRC
a. LER Number 3051984014, Kewaunee Reactor Trip Due to a Loss of Power on Instrument Bus IV
b. Fitzpatrick Root Cause Analysis Report, Degraded Motor Leads Residual Heat Removal Pump Motors 10P3A(M) and 10P-3C(M), DER-02-01362.
3. Proposed Resolution to GALL AMP XI.E6 NRC
4. Industry Comments on Proposed Resolution NEI
5. Public Participation All
6. Closing NRC

PROPOSED INSPECTION OF ELECTRICAL CABLE CONNECTIONS NOT SUBJECT TO 10 CFR 50.49 ENVIRONMENTAL QUALIFICATION REQUIREMENT GALL Aging Management Program (AMP) XI.E6 will be revised to recommend inspection once in the extended period of operation for electrical cable connections.

The inspection of a sample of electrical cable connections is to verify that loose connections are not occurring due to thermal cycling, ohmic heating, electrical transients, vibration, chemical contamination, corrosion, or oxidation.

This inspection will provide additional assurance that either aging of metallic cable connections is not occurring or existing the maintenance program is effective such that a specific AMP is not warranted.

The inspection should include thermography, resistance measurements, or other appropriate testing methods.

The inspection is applicable only to nuclear power plants that have not experienced loose connections due to aging.

The applicant should provide an acceptable sample size of cable connections.

If indications of any degradation are identified, corrective action must be implemented including sample size expansion.

Should evidence of significant aging be revealed by this inspection or previous operating experience, a plant specific AMP will have to be developed and periodic inspection implemented by the applicant with NRCs approval.

ENCLOSURE 3

Letter to NEI, from Stephen Hoffman, dated January 26, 2007

SUBJECT:

SUMMARY

OF THE LICENSE RENEWAL MEETING BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION STAFF AND THE NUCLEAR ENERGY INSTITUTE REGARDING GENERIC AGING LESSONS LEARNED AGING MANAGEMENT PROGRAM XI.E6 DISTRIBUTION:

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NUCLEAR ENERGY INSTITUTE Project No. 690 cc:

Ms. Christine S. Salembier, Commissioner State Liaison Officer Department of Public Service 112 State St., Drawer 20 Montipelier, VT 05620-2601 Mr. James Ross Nuclear Energy Institute 1776 I St., NW, Suite 400 Washington, DC 20006-3708 Mr. Frederick W. Polaski Manager License Renewal Exelon Corporation 200 Exelon Way Kennett Square, PA 19348 Mr. Clifford I. Custer Project Manager, License Renewal FirstEnergy Nuclear Operating Company P.O. Box 4 Route 168 (Mail Stop SIM-2)

Shippingport, PA 15077 Mr. David Lochbaum Union of Concerned Scientists 1707 H St., NW, Suite 600 Washington, DC 20006-3919 Mr. Paul Gunter, Director Reactor Watchdog Project Nuclear Information & Resource Service 6930 Carroll Avenue, Suite 340 Takoma Park, MD 20912 Mr. Hugh Jackson Public Citizen's Critical Mass Energy &

Environment Program 215 Pennsylvania Ave., SE Washington, DC 20003 Mary Olson Nuclear Information & Resource Service Southeast Office P.O. Box 7586 Asheville, NC 28802 Mr. Garry G. Young Manager, License Renewal Services 1448 SR 333, N-GSB-45 Russellville, AR 72802 Robert A. Vincent Licensing Lead - License Renewal Project Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, MI 49043 Lorrie Bell, Project Manager Wolf Creek Nuclear Operating Corporation P.O. Box 411 Burlington, KS 66839 Roger Stewart Progress Energy Carolinas, Inc.

3581 West Entrance Road RNP A9 Hartsville, SC 29550 Michael H. Crowthers, Supervisor Nuclear Regulatory Affairs PPL Susquehanna, LLC Two North Ninth Street (GENPL4)

Allentown, PA 18101-1179