BSEP 06-0001, Comments on Draft Safety Evaluation Report for License Renewal

Comments on Draft Safety Evaluation Report for License Renewal

ML060310470
Person / Time
Site:	Brunswick
Issue date:	01/19/2006
From:	O'Neil E Progress Energy Carolinas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
BSEP 06-0001
Download: ML060310470 (13)

Text

aj Progress Energy January 19, 2006 SERIAL: BSEP 06-0001 10 CFR 54 U. S. Nuclear Regulatory Commission ATITN: Document Control Desk Washington, DC 20555-0001

Subject:

Brunswick Steam Electric Plant, Unit Nos. 1 and 2 Docket Nos. 50-325 and 50-324/License Nos. DPR-71 and DPR-62 Comments on Draft Safety Evaluation Report for License Renewal (NRC TAC Nos. MC4639 and MC4640)

References:

1. Letter from Cornelius J. Gannon to the U. S. Nuclear Regulatory Commission (Serial: BSEP 04-0006), "Application for Renewal of Operating Licenses," dated October 18, 2004 (ML043060406)

2. Letter from Frank P. Gillespie to James Scarola, "Safety Evaluation Report for Brunswick Steam Electric Plant, Units 1 and 2, License Renewal Application," dated December 20, 2005 (ML053550313)

Ladies and Gentlemen:

On October 18, 2004, Carolina Power & Light Company (CP&L), now doing business as Progress Energy Carolinas, Inc., requested the renewal of the operating licenses for Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2, to extend the terms of their operating licenses an additional 20 years beyond the current expiration dates.In a letter dated December 20, 2005, the NRC transmitted the draft Safety Evaluation Report (DSER) related to the License Renewal of the Brunswick Steam Electric Plant, Units 1 and 2, and requested that CP&L review the DSER, verify its accuracy, and provide comments to the NRC by February 20, 2006. CP&L's comments on the DSER are enclosed.Progress Energy Carolinas, Inc.Brunswick Nuclear Plant P.O. Box 10429 Southport, NC 28461 Document Control Desk BSEP 06-0001 / Page 2 Please refer any questions regarding this submittal to Mr. Mike Heath, Supervisor

-License Renewal, at (910) 457-3487.Sincerely, Edward T. O'Neil Manager -Support Services Brunswick Steam Electric Plant MJF/mhf

Enclosure:

Comments on Draft Safety Evaluation Report for License Renewal cc: U. S. Nuclear Regulatory Commission, Region II ATTN: Dr. William D. Travers, Regional Administrator Sam Nunn Atlanta Federal Center 61 Forsyth Street, SW, Suite 23T85 Atlanta, GA 30303-8931 U. S. Nuclear Regulatory Commission ATTN: Mr. S. K. Mitra (Mail Stop OWFN IlFl)11555 Rockville Pike Rockville, MD 20852-2738 U. S. Nuclear Regulatory Commission AITN: Ms. Alicia R. Williamson (Mail Stop OWFN 11F1)11555 Rockville Pike Rockville, MD 20852-2738 U. S. Nuclear Regulatory Commission ATTN: Mr. Eugene M. DiPaolo, NRC Senior Resident Inspector 8470 River Road Southport, NC 28461-8869 U. S. Nuclear Regulatory Commission (Electronic Copy Only)ATTN: Ms. Brenda L. Mozafari (Mail Stop OWEN 8G9)11555 Rockville Pike Rockville, MD 20852-2738 Ms. Jo A. Sanford Chair -North Carolina Utilities Commission P.O. Box 29510 Raleigh, NC 27626-0510 BSEP 06-0001 Enclosure Page 1 of 11 Comments on Draft Safety Evaluation Report for License Renewal On October 18, 2004, Carolina Power & Light Company (CP&L), now doing business as Progress Energy Carolinas, Inc., requested the renewal of the operating licenses for Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2, to extend the terms of their operating licenses an additional 20 years beyond the current expiration dates.In a letter dated December 20, 2005, the NRC transmitted a draft Safety Evaluation Report (DSER) related to the License Renewal of the Brunswick Steam Electric Plant, Units 1 and 2, and requested that CP&L review the DSER, verify its accuracy, and provide comments to the NRC. The following table provides the requested comments; both editorial comments and comments regarding technical accuracy are included.

For convenience in identifying specific comment locations, a DSER, which included line numbers, was provided electronically by the NRC on January 3, 2006. The comment locations provided in the following table are based on that lined version of the DSER.Location 0 i Comment Page v, Line 16 The first three page 2-11 entries in the table of contents should be page 2-1.Page 1-3, Line 19 Change "scope of the review of" to "scope of the review on." Page 1-6, Lines 3 -4 It is stated that License Renewal Application (LRA) Sections 3 and 4 and Appendix B address the License Renewal (LR) requirements of 10 CFR 54.21(a), (b), and (c).However, 10 CFR 54.21(b) is addressed in LRA Section 1.4. Change "Sections 3 and 4" to "Sections 1, 3, and 4." Page 1-7, Table Interim Staff Guidance (ISG) issues in addition to those listed in the table are discussed in the DSER: ISG-9 in Sections 2.1.3.1.1 and 2.3.4.5.2; ISG-12 in Section 3.3.2.3.3; ISG-15 in Section 3.0.3.2.19; and ISG-16 in Section 4.3.3.1.Page 1-7, Table The reference sections for ISG-2 should include Section 2.1.3.1.1; for ISG 3, Section 3.5.2.3; for ISG-4, Sections 3.0.3.2.7 and 3.0.3.2.8; and for ISG-5, Sections 2.1.3.2.3 and 2.5.1.1.Page 1-9, Line 16, Correct the spelling of "September." Page 1-10, Line 5 Page 2-2, Line 2 Section 3.4 should be a separate bulleted item.Page 2-3, Line 43, Change UFSAR (i.e., Updated Final Safety Analysis Report) to FSAR (i.e., Final Page 2-11, Line 45 Safety Analysis Report); this discussion is based on Amendment 15 of the original FSAR for BSEP as noted in the response to Request for Additional Information (RAI)2.1-2 in BSEP letter (Serial: BSEP 05-0050), dated May 4, 2005.Page 2-5, Line 17 Section 2.1.1.3 should not be included in the list of document references for the sources of current licensing basis information.

The actual source of the list of documents is the response to RAI 2.1-1 in BSEP letter (Serial: BSEP 05-0050), dated May 4, 2005.Page 2-7, Line 40 Either delete the "(i)" from or add "(ii)" to 10 CFR 54.21(a)(i).

In the context of the discussion, both criteria 10 CFR 54.21(a)(i) and (ii) must be met.Page 2-8, Line 32, Change the "O" to a "0" in OENP-33.5.

Procedures that have a zero prefix are Page 2-9, Line 14 applicable to both BSEP Units.

BSEP 06-0001 Enclosure Page 2 of 11 Location Comment Page 2-11, Line 13 The statement seems to limit the sources of information to the Equipment Data Base (EDB). As noted in LR Application Section 2.1.1.2, other sources of information were used. It is recommended that the sentence be revised to state: "The applicant used the EDB quality classifications and a review of design and licensing basis information to identify NSR components that could be considered a potential source of damage to nearby SR components." Page 2-12, Line 2 The statement indicates that BSEP was built prior to issuance of Regulatory Guide (RG) 1.29. The original version of the RG was issued in June 1972 while BSEP was under construction.

It is recommended that the sentence be revised to state: "BSEP was designed prior to issuance of RG 1.29 which required NSR components with the potential to impact safety components to be seismically supported." Page 2-14, Line 37 BNP-LR-002 is given as a reference for scoping methodology; however, it is a screening-related calculation.

Abetter reference for scoping would be BNP-LR-010, License Renewal Project Scoping Calculation.

Page 2-15, Line 27, The phrase "During the audit" begins these paragraphs.

It is not clear which audit is Page 2-16, Line 4 being referenced.

Page 2-15, Line 42 It is stated that the reactor core isolation cooling system is an engineered safety features system; however, it is an auxiliary system in LRA Section 2.3.3.2. There is no need to identify the systems as engineered safety features.

Therefore, it is recommended that the sentence be revised to state: "A review of the mechanical component screening result calculations identified four systems (residual heat removal (RHR), high pressure coolant injection (HPCI), reactor core isolation cooling (RCIC), and the heating, ventilation, and air conditioning (HVAC) control building) as the primary systems that credit thermal insulation." Page 2-19, Line 27 The opening sentence of this paragraph lists references that apply to both scoping and screening.

Therefore, the sentence should state that the applicant described the methodology for scoping and screening.

In addition, it is recommended that BNP-LR-010 be added as a scoping methodology reference.

Page 2-21, Line 28 This sentence says that systems and structures that exist only in one unit are marked in the tables. It was not necessary to include this annotation in the LRA tables; therefore, this information is not marked on the tables. It is recommended that this sentence be deleted.Page 2-23, Line 38 It is not clear what is being modified by the parenthetical expression in this sentence.It is recommended that "(that don't require detailed boundary drawings)" be deleted.Page 2-26, Line 20 Regarding Low Pressure Core Spray (LPCS) components, the DSER states that the"nozzles (LPCS -Unit 2)" is a component of the reactor vessel and internals.

The actual component is "nozzles (low pressure core spray (LPCS) -Unit 2)" as stated in the BSEP LRA, page 2.3-5.Page 2-26, Line 22 The DSER states that the "nozzles safe ends (LPCS)" is a component of the reactor vessel and internals.

The actual component is "nozzles safe ends (low pressure core spray (LPCS))" as stated in the BSEP LRA, page 2.3-5.Page 2-26, Line 39 The DSER states that the "thermal sleeves (LPCS)" is a component of the reactor vessel and internals.

The actual component is "thermal sleeves (low pressure core spray (LPCS))" as stated in the BSEP LRA, page 2.3-6.Page 2-26, Lines 44 -45 The following component has not been included -"core shroud and core plate (core shroud repair hardware)" that is included in the BSEP LRA on page 2.3-6.

BSEP 06-0001 Enclosure Page 3 of 11 Location Comment-Page 2-26, Line 46 The DSER states that the "core shroud and core plate (top guide)" is a component of the reactor vessel and internals.

The actual component is "reactor vessel internals (boiling water reactor) (top guide)" as stated in the BSEP LRA, page 2.3-6.Page 2-27, Line 30 The following components have not been included -"instrumentation (intermediate range monitor (IRM) dry tubes)" and "instrumentation (source range monitor (SRM)dry tubes)" that are included in the BSEP LRA, page 2.3-7.Page 2-29, Line 17 The sentence "LRA Section B.2.. ." should be "Section B.2. .." to accurately reflect the quotation from the response to RAI 2.3.1.1-4 transmitted by BSEP letter (Serial: BSEP 05-0050), dated May 4, 2005, Enclosure 1, page 11 of 87.Page 2-30, Line 3 The sentence "The .P/SLC vessel.. ." should be "The AP/SLC vessel.. ." to accurately reflect the quotation from the response to RAI 2.3.1.1-4 in BSEP letter (Serial: BSEP 05-0050), dated May 4, 2005, Enclosure 1, page 12 of 87.Page 2-48, Line 12 The Standby Gas Treatment System should also include the M-3 flow restriction intended function as shown on LRA Table 2.3.2-6. Include an additional bulleted item stating "provides flow restriction." Page 2-65, Line 31 The DSER states that the staff reviewed LRA Section 2.3.3.4 and UFSAR Section 9.2.1.2. The appropriate LRA Section is 2.3.3.6.Page 2-72, Line 8 This line contains an unnecessary line return.Page 2-73, Line 17 "Heat exchangers" is misspelled.

Page 2-73, Line 20 There are two line items in the LRA that were omitted from the list in the DSER:-Piping (Pipe, Fittings and Flanges,-Valves (Check, Hand, Control, Relief, Solenoid, and Containment Isolation)(Body and Bonnet).These are associated with the Penetration Cooling System which is a subsystem of the Reactor Building Closed Cooling Water System in LRA Section 2.3.3.8.Page 2-88, Lines 34 and D07077 sheet 3A should be designated as D-07077-LR sheet 3A.39 Page 2-88, Line 41 D-07077 sheet 3A and 3B should be designated as D-07077-LR sheet 3A and 3B.Page 2-90, Line 15 The word "driven" is misspelled.

Page 2-93, Line 27 "are" is misspelled.

Page 2-103, Line 35 The entry "piping (piping and fittings)" is repeated in the list.Page 2-119, Line 40 The quote from RAI 2.3.3.29-1 refers to line items on the following page; however, the line items were not included.

Refer to BSEP letter (Serial: BSEP 05-0071), dated June 14, 2005. It is recommended that this sentence be deleted.Page 2-124, Line 9 The abbreviation "UFASR" should be "UFSAR." Page 2-125, Line 13 The reviewed LRA Section should be Section 2.3.3.34.Page 2-128, Line 32 The reviewed LRA Section should be Section 2.3.4.3.Page 2-134, Line 10 The entry "Condensate lines (piping and fittings)" is repeated in the list.Page 2-136, Line 9 The referenced table should be Table 2.3.4-6.Page 2-138, Line 23 The reviewed LRA Section should be Section 2.3.4.10.Page 2-142, Line 28 The discussion of structures incorrectly refers to "mechanical SSCs;" replace"mechanical" with "civil." Page 2-151, Line 29 Change "with" to "within."

BSEP 06-0001 Enclosure Page 4 of 11 Location Comment Page 2-166, entire page, The RAI discussed on this entire page, RAI 2.4-5, is incorrectly associated with the Page 2-167, Lines 1 -4 Reactor Building rather than the Primary Containment.

This RAI discussion should be moved to Section 2.4.1.1.2 of the DSER, which addresses the Primary Containment.

The response to RAI 2.4-5 was provided in BSEP letter (Serial: BSEP 05-0055), dated May 11, 2005.Page 2-167, Line 5 RAI 2.4-5 is incorrectly identified; the RAI should be RAI 2.4-7. The response to RAI 2.4-7 was provided in BSEP letter (Serial: BSEP 05-0055), dated May 11, 2005.Page 2-168, Line 34 "Electrical" is misspelled.

Page 3-2, Line 32 "Brunswick" is misspelled.

Page 3-3, Line 24 The example systems listed here include a PWR system. To address BWR systems, it is recommended that the sentence state: "For example, the engineered safety features (ESFs) group contains tables specific to the high pressure coolant injection system, automatic depressurization system, and standby gas treatment system." Page 3-3, Line 28 "Component Type" should be changed to "Components/Commodities" if the BSEP table column headings are being quoted.Page 3-6, Line 34 The sentence would be clearer if "LRA supplements" was replaced by "RAI responses." Page 3-7, Table 3.0.3-1 The table has a column that refers to the associated aging management program (AMP) entitled "LRA Systems or Structures that Credit the AMP." The introduction to the table does not explain the purpose of this column. In addition, the information provided by this column does not appear to be useful in the subsequent evaluation of the programs.

Therefore, it is recommended that this column be deleted from the table.Page 3-9, Line 5 The Generic Aging Lessons Learned (GALL) Report Comparison column for the Protective Coating Monitoring and Maintenance Program should state "Consistent with exception and enhancements." Page 3-15, Line 18 Delete "NUREG-0313" from this line; it is properly included on Line 20.Page 3-21, Line 5 The DSER states "are in accordance with applicable the GALL report requirements." Suggest revising this to state "are in accordance with the applicable GALL report requirements." Page 3-21, Line 29 Pa in this case refers to containment design pressure, not to pressure in pascals.Replace "(one Newton per square meter)" with "(i.e., 49 psig)." Page 3-21, Line 32 "BN-TOP" should be "BN-TOP-1." Page 3-23, Line 25 "industrial" should be "industry." Page 3-25, Line 8 "USFAR" should be "UFSAR." Page 3-26, Line 25 "GALL AMP XI.EI " should be "GALL AMP X.El." Page 3-38, Line 22 The word "exception" should be plural.Page 3-48, Lines 27 -28 The word "selected" is duplicated in the first sentence, and "Operating" need not be capitalized in the second sentence.Page 3-52, Lines 18 -19 Include the docket number in the designation of Licensee Event Reports (LERs) as specified in the list of references for GALL Program XI.M2 1, i.e., LER 50-327/93-029-00 and LER 50-280191-019-00.

BSEP 06-0001 Enclosure Page 5 of 11 Location Comment u f Page 3-54, Line 25 The DSER states that the applicant plans to include the Turbine Building Bridge Crane and Heater Bay Gantry Crane in the Inspection of Overhead Heavy Load and Light Load Handling Systems Program. That statement is incorrect; LRA Section 2.4 specifically states the subject cranes were screened out as supporting no LR intended functions, and the AMP description in Section B.2.9 does not include the subject cranes. The response to RAI 2.4-11, in BSEP letter (Serial: BSEP 05-0055), dated May 11, 2005, also states the subject cranes support no LR intended functions.

Recommend removing the statements concerning inclusion of the subject cranes.Page 3-56, Line 7 Change NUREG-612 to NUJREG-0612.

Page 3-62, Line 38 Remove "it" following Fire Protection Program.Page 3-63, Line 30 The DSER indicates the LRA Section for Fire Water is B.2.10; it should be B.2.11.Page 3-64, Lines 9 -17 The DSER statement does not reflect latest docketed correspondence from BSEP letter (Serial: BSEP 05-0097), dated July 18, 2005, Enclosure 1, page 12, which states"Prior to the period of extended operation, Program administrative controls will be enhanced to require: (1) obtaining non-intrusive baseline pipe thickness measurements at various locations, and (2) replacing the remainder of the plant's sprinkler heads prior to 50 years of sprinkler head service life. The results of the non-intrusive Fire Water System piping thickness measurements will be trended throughout the extended period of operation; the specific measurement intervals will be determined by engineering evaluation performed after each inspection to detect degradation prior to the loss of intended function.

Following enhancement, the Fire Water System Program will be consistent with the corresponding program described in NUREG-1 801 and subsequent NRC interim staff guidance." These commitments are reiterated in BSEP letter (Serial: BSEP 05-0148), dated December 6, 2005.Page 3-65, Line 37, These paragraphs are redundant.

Page 3-66, Line 15 Page 3-67, Line 26 Change "BSEP RS 5.5.9" to "BSEP Technical Specifications 5.5.9." Page 3-78, Lines 31 -32 The commitment referenced should be Commitment Item #10. Also, the commitments provided with the original LR Application submittal letter were not numbered.

The commitments were numbered in the latest commitment list provided in BSEP letter (Serial: BSEP 05-0148), dated December 6,2005.Page 3-79, Lines 2 and 6 The commitment should be Commitment Item #10, and the date of the Final Safety Evaluation Report should be February 1, 2002.Page 3-80, Lines 17 -22 The license condition discussed here does not match the license condition on Page 1-10, Lines 15 -20. Section 3.0.3.2.10 only discusses the requirement for maintaining"standby" RV surveillance capsules.Page 3-81, Line 1 Recirculation coolant flow elements and main steam flow limiters, fabricated of cast austenitic stainless steel, have been removed from the One-Time Inspection Program.See the response to Audit Question 3.1-1 in BSEP letter (Serial: BSEP 05-0041), dated March 14,2005.

BSEP 06-0001 Enclosure Page 6 of 11 Location Comment Page 3-82, Line 19 This paragraph says "The applicant stated that the inspections will be scheduled during the mid-part of the fourth quarter of the current licensing period, and the results will be evaluated in accordance with site procedures." Delete the words "the mid-part of'from this sentence.

The formal response to Audit Question B.2.15-1 in BSEP letter (Serial: BSEP 05-0041), dated March 14, 2005, stated that inspections would be completed before the end of the current operating license, but would not be scheduled too early in the current operating term, which could raise questions regarding continued absence of aging effects prior to and near the extended period of operation.

The discussion beginning on line 38 of this page notes that 30 years of operational experience will have accumulated before inspections are performed, and that this time period will be sufficient for the aging effects to manifest themselves.

Hence, one time inspections can be scheduled subsequent to 30 years of operating experience, but before the end of the current operating license (i.e., anytime during the fourth quarter of the current licensing period). Therefore, requiring the scheduling of inspections to the mid-part of the fourth quarter of the current licensing period is not warranted.

Page 3-84, Lines 7 and 12 It is not necessary to make reference to 10 CFR 50.55a(c)(2) twice in this paragraph.

Page 3-84, Line 36 Add the word 'and" after ASME Section XI.Page 3-93, Line 3 The DSER should identify the LRA Section as B.2.19.Page 3-100, Line 29 The DSER includes "steel piles;" this should actually be "sheet piles." Page 3-108, Line 29 Add the word "staff" following "applicant's technical." Page 3-114, Lines 21 and "NUREG/CR 6260" should be "NUREG/CR-6260." 27 Page 3-119, Line 33 "B,2,28" should be "B.2.28." Page 3-120, Line 19 The Control Rod Drive (CRD) component "Penetrations (CRD stub tubes)" is not listed as a component managed by the Reactor Vessel and Internals Structural Integrity Program (RV&ISIP).

This is shown on page 3.1-35 of the BSEP LRA.Page 3-120, Line 34 The "core spray nozzle thermal" should be "core spray nozzle thermal sleeve." This is shown on page 3.1-46 of the BSEP LRA.Page 3-121, Line 9 Boiling Water Reactor Vessel and Internals Program (BWRVIP)-74 was submitted for NRC review and approval on September 21, 1999. This is documented in BWRVIP Letter 99-369.Page 3-121, Line 14 "October 18. 2001" should be "October 18, 2001." Page 3-121, Line 35 The NRC Final Safety Evaluation Report (FSER) for BWRVIP-41 is dated June 5, 2001, as documented in accession number ML011570460 and not ML011310322.

Page 3-122, Line 3 The NRC FSER for BWRVIP-86 is dated February 1, 2002, as documented in accession number ML020380691 (See Page 3-77, Line 15).

BSEP 06-0001 Enclosure Page 7 of 11 Location Comment Page 3-127, Lines 1 -5 The DSER states "examination of those top guide locations in the areas that are expected to achieve the highest neutron fluence exposures and that the sample size will be 10 percent of the affected susceptible areas with 50 percent of the inspections scheduled to be completed within 6 years of the issuance of the staff's FSER on BWRVIP-26 (December 7, 2000) and 100 percent of the inspected areas being completed within 12 years of issuance of the staff's FSER on BWRVIP-26." This statement from the DSER would require the first set of inspections to be completed by December 7, 2006.The BSEP LRA states "Prior to the period of extended operation, the Program will be enhanced to: (1) incorporate augmented inspections of the top guide using enhanced visual examination that will focus on the high fluence region and (2) establish inspection criteria for the VT-3 examination of the Core Shroud Repair Brackets." The timing of the inspections was not modified in response to RAls, and Commitment

1. 22, contained in BSEP letter (Serial: BSEP-05-0148), dated December 6, 2005, shows the implementation schedule as "Prior to the period of extended operation." This infers that these inspections will take place within six years of implementation of these augmented inspections within BSEP's RV&ISIP.Page 3-128, Lines 21 -24 The DSER states "The applicant's two responses to RAI B.2.28-5 clarify that the applicant's basis for managing stress relaxation in the Unit 2 spring-loaded core plate plugs will be to replace them with a welded configuration consistent with the core plate plug design in Unit 1 and that the replacement of the plugs is scheduled to be performed in the Unit 2 2011 refueling outage." BSEP did not commit to replacing the Unit 2 spring-loaded core plate plugs with a welded design.The initial response to RAI B.2.28-5 in BSEP letter (Serial: BSEP-05-0071), dated June 14, 2005, stated that "In the response to RAI 4.2.8- 1, Part A, and RAI 4.2.8-2 in BSEP letter to the NRC (Serial: BSEP 05-0050), dated May 4,2005, BSEP stated that the Reactor Vessel and Internals Structural Integrity Program, discussed in BSEP LRA Section B.2.28, will manage loss of preload due to stress relaxation of the spring-loaded core plate plugs installed in Unit 2 by replacement." The responses to several other RAls and Commitment Item #22 in BSEP letter (Serial: BSEP-05-0148), dated December 6, 2005, also indicate that BSEP will manage loss of preload due to stress relaxation of the spring-loaded core plate plugs installed in Unit 2 by replacement." Page 3-142, Line 8 There is a typographical error in the first sentence.Page 3-143, Line 17 "BWRVIP-03, 18, -25... " should be "BWRVIP-03, -18, -25..." Page 3-143, Line 25 This line states "spring-loaded core plate plugs by replacement of the plugs with a welded design..." See the above comment for Page 3-128, Lines 21 -24.Page 3-15 1, Line 28 "HPIC should be "HPCI." Page 3-151, Lines 31 -39 Regarding the Preventive Maintenance (PM) Program, it is suggested that the final sentence in this paragraph be revised to read "For example, PM activities will be created for sump pumps in the Service Water Building and Diesel Generator Building." Neither the Circulating Water Intake Structure sump pumps nor the structure itself is in scope of LR as discussed in LRA Section 2.4.2.7.Page 3-156, Line 31 "Sink" should be "shrink." Page 3-157, Line 18 "State" should be "stated."

BSEP 06-0001 Enclosure Page 8 of 11 Location Comment Page 3-165, Line 10 It is recommended that reference be made to Section 3.0.2.1 in order to initiate the discussion of the ten elements of an AMP.Page 3-165, Line 13 Branch Technical Position "IQMB-1" should be "RLSB-1." Page 3-166, Line 6, Section "Al.1" should be Section "A.1.I." Page 3-167, Lines 1 and 5 Page 3-167, Lines 1 and 5 Section "B1.3" should be Section "B.1.3." Page 3-167, Line 1 The second sentence in this paragraph is not complete.Page 3-17 1, Line 31 Section 3.1.X.X is referenced.

The correct reference is 3.1.2.1 as noted on Page 3-178 of DSER Section 3.1.2.1.3.

Page 3-171, Line 34 The staff evaluation should read "Not consistent with GALL (See Section 3.1.2.2)." The BSEP LRA specifies a different AMP, i.e., the RV&ISIP, that differs from the AMP specified in the GALL report, i.e., Feedwater nozzle; CRD return line nozzle.Page 3-175, Line 5 The DSER refers to Tables 3.1.2-1 through 3.1.2-4. The BSEP aging management Page 3-187, Line 24 reviews (AMRs) related to the reactor vessel, internals, and RCS components are in Page 3-187, Line 38 Tables 3.1.2-1 through 3.1.2-5.Page 3-201, Line 37 Page 3-202, Line 7 Page 3-18 1, Line 42 "M4" should be "M-4." See Table 2.0-1 of the BSEP LRA. This typographical error also appears on Page 2-56, Line 20, and Page 3-182, Line 16.Page 3-181, Line 44 "MI" should be "M-1." See Table 2.0-1 of the BSEP LRA. This typographical error also appears on Page 3-335, Line 28.Page 3-184, Lines 7, 8, The title of DSER Section 3.1.2.3.1 is "Reactor Vessel, Internals, and Reactor Coolant and 19 System -Summary of Aging Management Evaluation

-Reactor Vessel and Internals

-Page 3-191, Line 17 Table 3.1.2-1" and not "RV Internal Components." Page 3-190, Lines 30 and The terms "anionic impurities" and "ionic impurities" seem to be used interchangeably 36 throughout the DSER. BWRVIP-79 usually refers to "ionic impurities." Anionic is usually associated with discussions of "anionic species." The discussions may need to be revised.Page 3-194, Lines 3 and 6 "RAI 3.1.2.2.1.2-1" should be "RAI 3.1.2.3.1.2-1" as shown in BSEP letter (Serial: BSEP 05-0071), dated June 14, 2005.Page 3-196, Line 24 The DSER section for the review of the Water Chemistry Program should be 3.0.3.2.1 Page 3-200, Line 2 not 3.0.3.1.Page 3-205, Line 13 Page 3-207, Line 11 Page 3-208, Line 35 Page 3-210, Line 31 Page 3-211, Line 23 Page 3-214, Line 13 Page 3-215, Line 38 Page 3-207, Line 2 The RV&ISIP is not evaluated in DSER Section 3.0.3.1 but in Section 3.0.3.3.1.

Page 3-208, Line 26 The One-Time Inspection Program is not evaluated in DSER Section 3.0.3.1 or Page 3-211, Line 14 3.0.3.11 but in 3.0.3.2.11.

Page 3-214, Line 43 Page 3-216, Line 16 Page 3-212, Line 25 The Bolting Integrity Program is not evaluated in DSER Section 3.0.3.1 but in 3.0.3.2.3.

BSEP 06-0001 Enclosure Page 9 of 11 Location Comment Page 3-219, Table 3.2-1, In LRATable 3.2.1, line item 3.2.1-10 deals with external surfaces of components.

Lines 18 -46 This line has been omitted from the table in the DSER. As a result, the reference line Page 3-220, Table 3.2-1, numbers in column one are out of sequence by one in subsequent rows.Lines 1 -16 Page 3-222, Line 16 "Standby gast" should be "Standby gas." Page 3-352, Line 22 The time-limited aging analyses (TLAA) evaluation item erroneously refers to Section 4.3; it should refer to Section 4.6.Page 3-353, Lines 15, The referenced DSER section for further evaluation should be Section 3.5.2.2.1.

21, 26, and 29 Page 3-354, Lines 4, The referenced DSER section for further evaluation should be Section 3.5.2.2.1.

23, and 26 Page 3-354, Line 7 The referenced DSER section for further evaluation should be Section 4.6.Page 3-355, Lines 11 and The referenced DSER section for further evaluation should be Section 3.5.2.2.2.

17 Page 3-355, Line 35 The referenced DSER section for further evaluation should be Section 3.5.2.2.1.

Page 3-356, Line 12 The DSER identifies this line item as a TLAA; however, the LRA states that it is not a TLAA because there are no fatigue analyses applicable to component supports.

Refer to LRA Section 3.5.2.2.3 which states that Cumulative Fatigue Damage is not a TLAA because no applicable fatigue analyses exist. It is recommended that the Staff Evaluation for this line item be revised to state: "Not applicable." Also, refer to the comment on Page 3-370, Line 32, below.Page 3-365, Line 22 The correct reference is Section 3.5.2.2.1.4.

Page 3-366, Line 12 The DSER refers to Section 4.3 for the TLAA evaluation; the reference should be to Section 4.6.Page 3-370, Line 32 Cumulative fatigue is identified as a TLAA; however, the LRA, in Section 3.5.2.2.3, states that it is not a TLAA because there are no fatigue analyses applicable to component supports.

It is recommended that the cumulative fatigue discussion be revised to state: "There are no fatigue analyses applicable to component supports in the current licensing basis; therefore, cumulative fatigue damage of component supports is not a TLAA as defined in 10 CFR 54.3." Also, refer to the comment on Page 3-356, Line 12, above.Page 3-380, Line 2 The applicable DSER sections are 3.0.3.3.5 and 4.7.2.Page 3-388, Line 18 In this case, DC refers to "Dow Corning" instead of "direct current." Page 3-390, Line 21 The words "staffs" should be "staff," and "provde" should be "provide." Page 4-1, Line 21 The current licensing basis documents listed should reflect the list in Section 4.1.1 of the LR Application.

The list in the DSER includes categories of documents that are not current licensing basis documents.

It is recommended that the sentence containing the list be revised to state: "The CLB includes the Technical Specifications, the updated final safety analysis report (UFSAR), docketed licensing correspondence, design basis documents, and applicable vendor reports." Page 4-1, Line 28 The list of applicable TLAAs should not include "Concrete containment tendon prestress" as confirmed by LR Application Table 4.1-1.Page 4-2, Line 40 A reference to Commitment Item #27 should be added to this sentence.Page 4-12, Lines 31 and There is an extra line break after RG 1.99.32 BSEP 06-0001 Enclosure Page 10 of 11 Location Comment Page 4-20, Lines 34 and The "2' in "n/cm2" should be a superscript.

37 Page 4-22, Line 10 The quoted text from page 4.2-7 of the BSEP LRA is incorrect. "The ... [RT NDT]...of the limiting beltline material..

." should be "The ART of the limiting beltline material..." Page 4-22, Line 15 The quoted text from page 4.2-7 of the BSEP LRA is incorrect, in that "hydrostatic pressure tests and leak tests, ...[2)] .. .non-nuclear heat-up/cooldown and low level..." should be "hydrostatic pressure tests and leak tests, non-nuclear heat-up/cooldown and low level..." Page 4-22, Line 16 The quoted text from page 4.2-7 of the BSEP LRA is incorrect, in that "physics tests, and ... [3)] .. .core critical operation..." should be "physics tests, and core critical operation..." Page 4-23, Lines 32 -33 There is an extra line break after "is equal to." Page 4-25, Lines 49 -50 There is an extra line break after "the NRC's." Page 4-27, Line 1, "(c. Terry)" should be "(C. Terry)." Page 4-35, Line 5 Page 4-35, Line 48 The DSER states "as consistent with the analysis provided in Section 4.2.9 of the LRA." The correct reference is Section 4.2.5.Page 4-45, Lines 1 -3 These lines are in a different font then the rest of the DSER.Page 4-45, Lines 30 -31 There is an extra line break after 4.17 x 102' n/cm 2.Page 4-47, Line 2 The DSER states "In LRA Section 4.2.7." However, the correct reference should be Section 4.2.8.Page 4-55, Lines 7 -8 There is an extra line break after "The applicant calculated the..." Page 4-55, Line 15 Section 4.2.9 of the DSER evaluates the TLAA for the core shroud repair clamps;however, the DSER states "Based on this analysis, the staff found that the TLAA for the core plate plugs." The correct components under evaluation are the core shroud repair clamps.Page 4-58, Line 4 The DSER states "the threshold of 1.0 x 10" n/cm 2 (E > 1.9 MeV)." It should use an energy level of E > 1.0 MeV.Page 4-70, Line 36 The DSER states "the applicant also determined a design CUF of 0.15 for the condensation oscillation loads". The 0.15 CUF is for chugging loads not condensation oscillation loads as shown on LRA Table 4.6-1.Page 4-76, Lines 26 -29 The DSER states "the applicant plans to perform the lift-off testing every five years during the current license, and during the extended period of operation, as described by the applicant in LRA Section B.2.32." However, LRA Section B.2.32 does not state every five years, it states "on a frequency commensurate with MWL", which for a two-unit plant is based on IWL-2421.

It is suggested that the wording be revised to state"the applicant plans to perform the lift-off testing on a frequency commensurate with ASME Section XI, Subsection IWL during the current license term and during the extended period of operation, as described by the applicant in LRA Section B.2.32."

BSEP 06-0001 Enclosure Page 11 of 11 Location Comment Page 4-77, Lines 37 -38 For the various in-scope cranes and refueling platforms, the DSER states that based on Page 4-78, Lines 16 -17 the estimation of projected load cycles and "the applicant's commitment that, Page 4-78, Lines 33 -34 consistent with GALL AMP XI.M23, the number and magnitude of lifts made by the Page 4-79, Lines 11 -12 crane will be reviewed... " The statement regarding a commitment to review the Page 4-79, Lines 28 -29 number and magnitude of lifts should be removed. The review of the number and magnitude of lifts was performed as part of the TLAA evaluation of load handling equipment, and the cyclic load limits were found to be acceptable for the period of extended operation.

Although it is normal operating practice to review the number and magnitude of lifts, no specific commitment was made. Refer to Commitment Item #6 associated with the Overhead Load and Light Load Handling Systems Program.Page A-3, Commitments There appears to be an extra set of numbers in the "Item No." column header.List