L-08-263, Submittal of Revision to License Renewal Application Amendment No. 24
| ML082730717 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 09/25/2008 |
| From: | Sena P FirstEnergy Nuclear Operating Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| L-08-263, TAC MD6593, TAC MD6594 | |
| Download: ML082730717 (27) | |
Text
FENOC Beaver Valley Power P.O.Station Box 4
- , Shippingport, PA 15077 Company FirstEnergyNuclear Operating Peter P. Sena III 724-682-5234 Site Vice President Fax: 724-643-8069 September 25, 2008 L-08-263 10 CFR 54 ATTN: Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555-0001
SUBJECT:
Beaver Valley Power Station, Unit Nos. 1 and 2 BV-1 Docket No. 50-334, License No. DPR-66 BV-2 Docket No. 50-412, License No. NPF-73 License Renewal Application Amendment No. 24 (TAC Nos. MD6593 and MD6594)
The referenced letter provided the FirstEnergy Nuclear Operating Company (FENOC)
License Renewal Application (LRA) for the Beaver Valley Power Station (BVPS).
During the U.S. Nuclear Regulatory Commission (NRC) Region I Inspection Procedure IP-71002 License Renewal Inspection held the weeks of June 23 and July 14, 2008, FENOC identified necessary revisions to the BVPS LRA following questioning by the NRC Inspection Team. The Enclosure provides Amendment No. 24 to the BVPS LRA.
There are no regulatory commitments contained in this letter. If there are any questions or if additional information is required, please contact Mr. Clifford I. Custer, Fleet License Renewal Project Manager, at 724-682-7139.
I declare under penalty of perjury that the foregoing is true and correct. Executed on September'IF , 2008.
Sincerely, Peter P. Sena III
/4t'8
Beaver Valley Power Station, Unit Nos. 1 and 2 L-08-263 Page 2
Reference:
FENOC Letter L-07-113, "License Renewal Application," August 27, 2007.
Enclosure:
Amendment No. 24 to the BVPS License Renewal Application cc: Mr. K. L. Howard, NRC DLR Project Manager Mr. S. J. Collins, NRC Region I Administrator cc: w/o Enclosure Mr. B. E. Holian, NRC DLR Director Mr. D. L. Werkheiser, NRC Senior Resident Inspector Ms. N. S. Morgan, NRC DORL Project Manager Mr. D. J. Allard, PA BRP/DEP Director Mr. L. E. Ryan, PA BRP/DEP
ENCLOSURE Beaver Valley Power Station (BVPS), Unit Nos. 1 and 2 Letter L-08-263 Amendment No. 24 to the BVPS License Renewal ADplication Page 1 of 25 License Renewal Application Sections Affected Table 3.3.1 Table 3.3.2-27 Table 3.4.1 Table 3.3.2-28 Table 3.3.2-1 Table 3.3.2-29 Table 3.3.2-2 Table 3.3.2-30 Table 3.3.2-3 Table 3.3.2-31 Table 3.3.2-4 Table 3.4.2-1 Table 3.3.2-6 Table 3.4.2-2 Table 3.3.2-7 Table 3.4.2-3 Table 3.3.2-9 Table 3.4.2-4 Table 3.3.2-10 Table 3.4.2-5 Table 3.3.2-11 Table 3.4.2-10 Table 3.3.2-15 Appendix A Table of Contents Table 3.3.2-16 A.1.36 Table 3.3.2-17 Table B.1-1 Table 3.3.2-18 Table B.1-2 Table 3.3.2-21 Table B.1-3 Table 3.3.2-24 B.2.36 Table 3.3.2-26 The Enclosure identifies the correction by Affected License Renewal Application (LRA)
Section, LRA Page No., and Affected Paragraph and Sentence. The count for the affected paragraph, sentence, bullet, etc. starts at the beginning of the affected Section or at the top of the affected page, as appropriate. Below each section the reason for the change is identified, and the sentence affected is printed in italicswith deleted text lined-ou and added text underlined.
ft Enclosure L-08-263 Page 2 of 25 Affected Paragraph Affected LRA Section LRA Page No. and Sentence Table 3.3.1 Page 3.3-93 Item Number 3.3.1-84, Discussion Column Page 3.3-94 Item Number 3.3.1-85, Discussion Column In the Discussion column of referenced Item Numbers of the BVPS LRA, FENOC assigned the Selective Leaching of Materials Inspection (B.2.36) program.
FENOC has changed that program to a plant-specific Selective Leaching of Materials Inspection Program. Table 3.3.1, Item Numbers 3.3.1-84 and 3.3.1-85, Discussion column, are revised as follows:
Item Number Discussion 3.3.1-84 Consistentwith NUREG- 1801, with additional Gomponontf and AMP eeptien&a plant-specificprogram and added components.
BVPS manages the aging effect for susceptible components using the plant-specific Selective Leaching of MaterialsInspection (B.2.36) Program.
Item Number Discussion 3.3.1-85 Consistent with NUREG- 1801, with additonal cornpononts and AM exeeptien6 a plant-specificpro-gram and added components.
BVPS manages the aging effect with-the for susceptible components using the plant-specific Selective Leaching of MaterialsInspection (B.2.36) Program.
Enclosure L-08-263 Page 3 of 25 Affected Paragraph Affected LRA Section LRA Page No. and Sentence Table 3.4.1 Page 3.4-33 Item Number 3.4.1-35, Discussion Column Page 3.4-34 Item Number 3.4.1-36, Discussion Column In the Discussion column of referenced Item Numbers of the BVPS LRA, FENOC assigned the Selective Leaching of Materials Inspection (B.2.36) program.
FENOC has changed that program to a plant-specific Selective Leaching of Materials Inspection Program. Table 3.4.1, Item Numbers 3.4.1-35 and 3.4.1-36, Discussion column, are revised as follows:
Item Number Discussion 3.4.1-35 Consistent with NUREG- 1801, with additional cornponents and AM eeptibns a plant-specificprogram and additionalcomponents.
BVPS manages the aging effect for susceptible components-by4he with the plant-specific Selective Leaching of MaterialsInspection (B. 2.36) Program.
Heat exchanger components are included.
Item Number Discussion 3.4.1-36 Consistent with NUREG-1801, with additional GOMPonents and AM eptibns a plant-specificpro-gram and additionalcomponents.
BVPS manages the aging effect for susceptible components with the plant-specific Selective Leaching of MaterialsInspection (B.2.36) Program.
Components, -inuding heat
,xGhange; Genpenents,-in the Building Services Hot Water Heating System and Glycol Heating System have been aligned to this item based on material, environment, aging effect, and program assignment, and include heat exchangercomponents.
ORIARS m1anages the aging effect fo; su.s.eptibl . oMPonents us.ng the Selective Loaching of Materias hnonOnfnnInspection4 82.36J P*o9g*am.
g Enclosure L-08-263 Page 4 of 25 Affected Paragraph Affected LRA Section LRA Page No. and Sentence Table 3.X.2-X [Listed Below] Row Nos. [Listed Below], Notes column The LRA Tables 3.X.2-X (listed below) require revision because FENOC has replaced the Selective Leaching of Materials Inspection (B.2.36) Program with the plant-specific Selective Leaching of Materials Inspection Program. Therefore the Notes column of the affected LRA Tables and rows is revised to read:
Table 3.3.2-1: Area Ventilation - Control Area Pages 3.3-108 Row Component Notes No.
54 Heat exchanger (waterbox) E E
Table 3.3.2-2: Area Ventilation System - Plant Areas Pages 3.3-128 Table 3.3.2-3: Boron Recovery and Primary Grade Water System Pages 3.3-165, 169 and 176 Row Component Notes No.
115 Piping (fitting) E Strainer body B 141 E
178 Valve body B E
Enclosure L-08-263 Page 5 of 25 Table 3.3.2-4: Building and Yard Drains System Pages 3.3-185, 186, 187, 190, 192, 193 and 194 Row Component Notes No.
6 Expansion joint E E
Piping B 16 E
Piping B 21 E
37 Pump casing E E
50 Tank 8 E
Valve body a 56 E,
60 Valve body B E
Table 3.3.2-6: Chilled Water System Pages 3.3-249, 250 and 254 Row Component Notes No.
14 Heat exchanger (cooling coil) E E
Heat exchanger (header) D 18 E 43 Pump casing 8 E
Enclosure L-08-263 Page 6 of 25 Table 3.3.2-7: Compressed Air System Pages 3.3-270, 276, 286, 292 and 297 Row Component Notes No.
53 Heat exchanger (tube - diesel cooling water) E 80 Piping BE 134 Strainer body B E
137 Strainer body E B
Valve body B 167 E
Valve body B 169 E
Valve body B 185 E
Table 3.3.2-9: Containment Vacuum and Leak Monitoring System Pages 3.3-334 and 336 Row Component Notes No.
60 Pump casing B E
66 Strainer body B E
Table 3.3.2-10: Domestic Water System Pages 3.3-348 and 350 Row Component Notes No. ____
24 Strainer body B E
38' Valve body E B
Enclosure L-08-263 Page 7 of 25 Table 3.3.2-11: Emergency Diesel Generators and Air Intake and Exhaust System Page 3.3-356 Table 3.3.2-15: Emergency Diesel Generators-Lube Oil System Pages 3.3-403, 404 and 405 Row Component Notes No.
21 Heat exchanger (tube) E E
27 Heat exchanger (tube/core and tubesheet) E 32 Heat exchanger (tubesheet) D E
Enclosure L-08-263 Page 8 of 25 Table 3.3.2-16: Emergency Diesel Generators-Water Cooling System Pages 3.3-413, 415, 417, 418, 420 and 422 Row Component Notes No.
8 Heat exchanger (channel) E E
25 Heat exchanger (tube) D E
34 Heat exchanger (tubesheet) E 35 Heat exchanger (tubesheet) D
_E 43 Piping B E
61' Tubing B E
69 Valve body B E
72 Valve body B E
Table 3.3.2-17: Emergency Response Facility Substation System (Common)
Pages 3.3-428, 430 and 440 Row Component Notes No.
42 Heat exchanger (tube and tubesheet) E 50 Heat exchanger (tube) D E
127 Valve body B E
. t, Enclosure L-08-263 Page 9 of 25 Table 3.3.2-18: Fire Protection System Pages 3.3-446, 447, 449, 453, 458, 460, 465, 469, 472 and 473 Row Component Notes No.
B 29 Heat exchanger (jacket water - tube) E E
Heat exchanger (jacket water - tube) E 31 B
Heat exchanger (oil cooler - tube) E 39 49 Hose rack (water) B E
Piping (buried) B 80 E
Piping (buried) B 82 E
Pump casing B 118 E
120 Pump casing B E
136 Strainer body B E
Valve body (buried) B 172 E
174 Valve body (buried) B E
202 Valve body (hydrant) B E
205 Valve body (hydrant) B E
229 Valve body (water system) E E
235 Valve body (water system) 9 E
Enclosure L-08-263 Page 10 of 25 Table 3.3.2-21: Liquid Waste Disposal System Page 3.3-513 Row No. Component Notes 48 Pump casing E
Table 3.3.2-24: Primary Component and Neutron Shield Tank Cooling Water System Pages 3.3-571 and 572 Row Component Notes No.
146 Valve body 9 E
150 Valve body E
Table 3.3.2-26: Reactor Plant Sample System Pages 3.3-606 and 611 Row Component Notes No.
86 Pump casing B E
120 Valve body B E
Table 3.3.2-27: Reactor Plant Vents and Drains System Page 3.3-629
Enclosure L-08-263 Page 11 of 25 Table 3.3.2-28: River Water System (Unit I only)
Pages 3.3-653, 656, 664, 665, 666, 669, 673 and 674 Row Component Notes No.
16 Condenser (ACU waterbox/cover)
Piping B 34 E
B 77 Pump casing (submerged bowl) E B
80 Pump casing (submerged bowl) E Strainer body B 92 E
Valve body B 110 E
125 Valve body B E
129 Valve body B E
Table 3.3.2-29: Security Diesel Generator System (Common)
Pages 3.3-679, 680, 681 and 682 Row Component Notes No.
26 Heat exchanger (Oil cooler shell) E E
0E 33 Heat exchanger (Oil cooler tube) 38 Heat exchanger (Oil cooler tubesheet) E 44 Heater housing D E
N .
Enclosure L-08-263 Page 12 of 25 Table 3.3.2-30: Service Water System (Unit 2 only)
Pages 3.3-698 and 706 Row Component Notes No.
36 Piping E
8 79 Pump casing (Submerged bowl) E Pump casing (Submerged bowl) B 81 Table 3.3.2-31: Solid Waste Disposal System Page 3.3-722 Row Component Notes No.
39 Pump casing B E
Table 3.4.2-1: Auxiliary Feedwater System Page 3.4-40 Table 3.4.2-2: Auxiliary Steam System Page 3.4-71
Enclosure L-08-263 Page 13 of 25 Table 3.4.2-3: Building Services Hot Water Heating System Pages 3.4-85, 86, 90, 92 and 94 Row Component Notes No.
Heating coil D 23 E
Heating coil (Header) D 30 E
62 Pump casing E
Tank D 75 E
Trap body a 85 E
Table 3.4.2-4: Condensate System Page 3.4-101 Table 3.4.2-5: Glycol Heating System (Unit 1 only)
Pages 3.4-103, 104, 106 and 109 Row Component Notes No.
11 Heating coil D E
16 Heating coil (Header) D E
a 33 Pump casing E 54 Tank (Fitting) 9 E
Enclosure L-08-263 Page 14 of 25 Table 3.4.2-10: Water Treatment System Page 3.4-197
- 1 t
- Enclosure L-08-263 Page 15 of 25 Affected Paragraph Affected LRA Section LRA Page No. and Sentence Appendix A A-ii Table of Contents Item A.1.36 The LRA Appendix A Table of Contents requires revision because FENOC has replaced the Selective Leaching of Materials Inspection (B.2.36) Program with the plant-specific Selective Leaching of Materials Inspection Program. Therefore the program title needs changed to match the title in Appendix B. The table of contents line is revised to read:
A. 1.36 Selective Leaching of MaterialsInspection Program........ A. 1-16
Enclosure L-08-263 Page 16 of 25 Affected Paragraph Affected LRA Section LRA Page No. and Sentence A.1.36 A.1-16 Entire Section LRA Section A.1.36 requires revision because FENOC has replaced the Selective Leaching of Materials Inspection (B.2.36) Program with the plant-specific Selective Leaching of Materials Inspection Program. Section A.1.36 is revised in its entirety to read:
A. 1.36 SELECTIVE LEACHING OF MATERIALS INSPECTION PROGRAM The Selective Leaching of MaterialsInspection Programis a plant-specificprogram.
When performing the operatingexperience review for License Renewal, selective leaching was identified in buried gray cast iron fire protection piping. Therefore, for this set of components, the program performs periodictesting to ensure that selective leaching is identified before a loss of component intended function.
Forthe remainderof the components that credit the program, a one-time visual inspection and hardness examination of selected components that are susceptible to selective leaching is performed. This includes components and commodities (such as piping, pump casings, valve bodies and heat exchanger components) made of copper alloys with zinc content greaterthan 15% and gray cast iron exposed to a raw water, treated water, air,or condensationenvironment.
Should evidence of significant aging be revealed by the one-time inspection, the corrective action process is used for the unacceptableinspection findings. The resolution evaluates expansion of the inspection sample size, locations, and frequency.
The SelGetive Leaching of Material; Inspection Pro1grm includes a one fime visua, inspection and hardness examination Of Selected comgponents that are susceptible to selective leaching. The program scp Incudes components and cofmmodities (such as pupasings, valve bodies -andheat exchanger compenents,) made Of copper piping,9 ithzin cntet geatr han 1 5% OF gray Gast Weon which are exposed to a raw allys water-, treated water-, air, condensation, Or sodl environment.
This programq determines whether selective leaching isocrig for selecd compencnts. Should evidence of significan agin be revealed by the one tm inspectio orpeios operating experience, the Corrective Action Program is usedfo the unaccpal inpection finding. The resolution wil include evaluationfo expansio of the inspection sample size, locations, and frequency,4
Enclosure L-08-263 Page 17 of 25 Affected Paragraph Affected LRA Section LRA Page No. and Sentence Table B.1-1 B.1-7 Fourth content row of table Table B.1-1 requires revision because FENOC has replaced the Selective Leaching of Materials Inspection (B.2.36) Program with the plant-specific Selective Leaching of Materials Inspection Program. The fourth row of the table is revised to read:
I Aging Management Program Title Selective Leaching of Materials Inspection Affected Paragraph Affected LRA Section LRA Page No. and Sentence Table B.1-2 B.1-10 Eleventh content row of table (XI.M33)
New Row - Plant-Specific Program Table B.1-2 requires revision because FENOC has replaced the Selective Leaching of Materials Inspection (B.2.36) Program with the plant-specific Selective Leaching of Materials Inspection Program. The eleventh row of the table is revised to read:
NUREG- LRA 1801 NUREG-1801 Program BVPS Program Section Number XI.M33 Selective Leaching of Materials Not credited for aging management. See plant-specific -
Selective Leaching of Materials Inspection Program.
Solective Leaching of Matcrial Plant-Specific Programs NA Plant-specificProgram Selective Leaching of Materials B. 2.36 Inspection
Enclosure L-08-263 Page 18 of 25 Affected Paragraph Affected LRA Section LRA Page No. and Sentence Table B.1-3 B.1-16 Sixth content row of table Table B.1-3 requires revision because FENOC has replaced the Selective Leaching of Materials Inspection (B.2.36) Program with the plant-specific Selective Leaching of Materials Inspection Program. The sixth row of the table is revised to read:
NUREG-1801 Comparison Programs Programs with Program Name Plant- Consistent Programs with Exception(s) to Specific with Enhancement(s) NUREG-1801 NUREG-1801 Selective Leaching of Materials Yes -Yes Inspection
Enclosure L-08-263 Page 19 of 25 Affected Paragraph Affected LRA Section LRA Page No. and Sentence B.2.36 B.2-98 thru 100 All LRA Section B.2.36 requires revision because FENOC has replaced the Selective Leaching of Materials Inspection (B.2.36) Program with the plant-specific Selective Leaching of Materials Inspection Program. Section B.2.36 is revised in its entirety to read:
B.2.36 SELECTIVE LEACHING OF MATERIALS INSPECTION Pro-gramDescription The Selective Leaching of Materials Inspection Programis a new plant-specific program that will be implemented priorto the period of extended operation.
When performing the operating experience review for License Renewal, selective leaching was identified in buried gray cast iron fire protection piping. Therefore, for this set of components, the program will perform periodic testing to ensure that selective leaching is identified before a loss of component intended function.
Forthe remainderof the components that credit the program, a one-time visual inspection and hardnessexamination of selected components that are susceptible to selective leaching will be performed. This includes components and commodities (such as piping, pump casings, valve bodies and heat exchangercomponents) made of copper alloys with zinc content greaterthan 15% and gray cast iron exposed to a raw water, treated water, air,or condensationenvironment.
Should evidence of siqnificant aging be revealed by the one-time inspection, the corrective action process will be used for the unacceptableinspection findings. The resolution will evaluate expansion of the inspection sample size, locations, and frequency.
Aging Management Pro-gram Elements The results of an evaluation of each of the ten aging management program elements describedin NUREG-1801,Section XI.M33, are provided below.
- Scope of Program The scope of the program will include all components and commodities identified in the Aging Management Reviews as susceptible to loss of materialdue to selective leaching. This scope includes components and commodities (such as
Enclosure L-08-263 Page 20 of 25 piping, pump casings, valve bodies and heat exchanger components) made of gray cast iron and copperalloys with zinc content greaterthan 15% that are exposed to a raw water, treated water, air,condensation, or soil environment.
The program will determine a representative sample of components which are susceptible to selective leaching for examination. The representativesample size for components that are not buried gray cast iron fire protection piping will be based on Chapter4 of EPRI TR-107514, "Age-RelatedDegradationInspection Method and Demonstration:In Behalf of Calvert Cliffs Nuclear Power Plant License Renewal Application," which outlines a method to determine the number of inspections requiredfor 90% confidence that 90% of the populationdoes not experience degradation(90/90). Each group of components with the same material-environmentcombination is considered a separatepopulation. The sample population for buried gray cast iron fire protection piping will be based on test equipment limitations, piping configuration, and plant operatingexperience.
- Preventive Actions The program will be an evaluation and inspection program with no preventive actions to preclude or mitigate aging effects.
- ParametersMonitored/ Inspected Forburied gray cast iron fire protection piping, the program will consist of periodic testing of the sample population using a method capable of determining locations of piping or coating degradationwhich could be indicationsof selective leaching.
For the remainderof the components within the scope of the program, visual inspections and gualitative hardness examinations of internalsurfaces of susceptible components will be performed. These examinations will determine if loss of materialdue to selective leaching has occurred and if it will affect the component's intended function.
- Detection of Agingq Effects Forburied gray cast iron fire protection piping, the program will consist of periodic testing of the sample population using a method capable of determining locations of piping or coating degradationwhich could be indicationsof selective leaching. This testing will be performed priorto entering the period of extended operation, and periodicallythereafter. The frequency of this testing will be determined based on the results of the initial test, but the periodbetween tests shall not exceed ten years.
-, U Enclosure L-08-263 Page 21 of 25 For the remainderof the components within the scope of the program, a representative sample of components will be selected for inspection based on the specific plant component material/environmentcombinations. The representative sample size will be based on Chapter4 of EPRI TR-107514, "Age-RelatedDegradationInspection Method and Demonstration:In Behalf of Calvert Cliffs NuclearPower Plant License Renewal Application," which outlines a method to determine the number of inspections required for 90% confidence that 90% of the population does not experience degradation(90/90). Each group of components with the same material-environmentcombination is considered a separate population. Forthese components, a qualitative hardness examination, such as scrapingor chipping of internalsurfaces of susceptible components, will determine if loss of materialdue to selective leaching has occurred.
Monitoring and Trending Forburied gray cast iron fire protection piping, the results of the initialtest will be used to determine the frequency of testing for the period of extended operation.
However, the periodbetween tests shall not exceed ten years. The results of these tests will be documented and retainedin a retrievableform.
Forthe remainderof the components within the scope of the program, provisions for monitoringor trending are not included.
- Acceptance Criteria Any indicationsof degradationthat are detected during an inspection or test for selective leachinq will be evaluated usinq the corrective action program.
- Corrective Actions This element is discussed in Section B. 1.3.
- Confirmation Process This element is discussed in Section B. 1.3.
" Administrative Controls This element is discussed in Section B. 1.3.
ZI ý4
- Enclosure L-08-263 Page 22 of 25 Operating Experience The Selective Leaching of MaterialsInspection Programis a new program.
Industry operatingexperience that forms the basis for the program is describedin the operatingexperience element of the NUREG-1801 program description.
Industry and plant-specific operatingexperience will be consideredin the development and implementation of this program. As additionaloperating experience is obtained,lessons leamed will be appropriatelyincorporatedinto the program.
When performing the operating experience review for License Renewal, selective leaching was identified in buriedgray cast iron fire protection piping. Therefore, for this set of components, the program will perform periodic testing to ensure that selective leaching is identified before a loss of component intended function.
Forexample, in 2001., after a fire pump auto-started,water was reported to be coming from the ground due to a fire water piping failure. A condition report was written. A sample of the pipe materialwas sent to a laboratoryfor analysis. The failure analysis reportindicated that the pipe materialsuffered from graphitic corrosion attributedto breeching of the installedbituminous coating on the exteriorof the pipe. The iron had leached out of the gray cast iron, leaving mainly graphite, which was not capable of supporting the load on the pipe. Corrective actions included the replacement of the pipe with anothermaterialwhich was not susceptible to graphiticcorrosion.
Enhancements None Conclusion The implementation of the Selective Leaching of Materials Inspection Program will provide reasonableassurancethat the aging effects will be managed so that the systems and components within the scope of this program will continue to perform their intended functions consistent with the current licensing basis for the period of extended operation.
The Seleotive Le.aching of Materials Insection P-rogram is a new program that BVPS will km*plement prio to the per*id of extended operation.
The p*oga*m includes a one time visual inpection and hardness examination o.
selcctd components that are susceptible to selective leaching. The p*rg*am scope
Enclosure L-08-263 Page 23 of 25 includes components and commodities (SUch as pi9,';n, pump asingW, valve bodie, and heat exchanger components,) made Of copper alloys w4th zincyontent greater than 15% or gray cast iron which arc exposed to a raw water-, treated water-,ar condensation, OF soil environmentL.
This programq w#il determine whether selective leaching is occurring for sietede comgponents. Should evidence of significant aging bc rovealed by the one tm inspection orpevs operating ex-perience, the Corrective Action Program wiY be use for the unacpal inspection findings. The resolution will include evaluation forF exanio of the inspection sample isize, locations-, and frequency, NUREG-1801 Con.~iStenc consistent with NUREG 1801,Section XI.M3, Selective Leaching of Materials, wt e*oeption-.
Exceptions to NUREG-1801 Pýgamm-ElementAffedte4 Dctection of Aging EffctG 9 VPS takes exception to Brinell hardness testing as described in NUREG 1801.
Examinations-, other-than Brinell hardness teisting, wil be used to identit the presence of selective leaching. A qualitative determination of selective leachiny will be used in fie of Srinel hardneiss testing for-comonet witin the scope of this program. The exception is justified, because (4) Brinoll hardness testing may not be feasible for-most comgponents due to form and configuration (i e., hea exc-hanger tubes), and (2 other-mechanical mean&, such as scrain o chippingL, provide an equally valid method of identification Enhancemen None Agin Mnagmn rG~mEements The results of an evaluation of each of the 10 aging management program elements9 described in NUREG 1801, Section AI.M33, are provided as follows.
Enclosure L-08-263 Page 24 of 25
-Scopc of Program program will include alc TheIscope of theyomponents and commodities identIicd sclcetive leaching. This includeS com~ponents and com~modities (such as, piping, PUMP casings, valve bodies and heat exchanger com~ponents m~ade of gay cs iron and coppor-allys with zinc content greater than 15% that are exposed to a raw water-, treated water-, air-, condensation, or-so#l environment.
The progrmR will determine amrpresentative sample of components that are susceptible to selective leachingfor examination.
- Prc'.'cntivc Actions The program will be an evaluation and inspection,porMwt no preventv
, P-arametcr: Monitored!/nspected The program Will consist of visual inspections and qualitative hardness examinations of internal surfaces of suseptible components. These examinations will determine if loss of material due to selective leaching has occurred and if it will affect the component's intended function.
. Dteci~nGfAging-Effects A r-epresentative samiple Of components wilg be selected forinsection based On the specifi pln copoent mgaterial/environment combinations. At le-ast onne copoen Ieach of mate~ri-al type (gray cast iron and copper-alloy-s> 15% Zn) wl be included an inspIete in themrpresentative sample. A qualitative hardness examinationR, such-as scraping Or chipping of internal surfaces of susceptibl
. Monitoring and Trendin The program consists of one time inspections only. it therefoem does not include provisions for monitoring and trending.
. Accei~tance Criteri Any indications of degradation that are detected during an inspection for
4O e Enclosure L-08-263 Page 25 of 25
, Cr*fr.ti Actions
,,
This clement is discussed i;n Secfin B. 4*3.
, Confirmation Procs This element is discussed in Section B.1.3.
, Administrativc Control This element is discussed in Section B. 1.3.
, Opcrating Expcricnce The Scloctive Leaching of Materials Insection Programsane pr-ogram;-
therefore, there is no plant spec~ifi program operating ex ine for-progrmm effectiveness. Industry operating ex*perience that fob...ms tebasis for-the program is de;scribed in the operating experience elemgent of the NUREG 1801 progrm description. Indu~str and plant specific operatig experience wil be evaluated in the development and implementation of this program. As additinal operating exprieceis obtained, lessons learned wil be appropriatel incorporaqted into-Conclusion The im4plementation of the Selective Leaching of Materials Insection Program wl provide reasonable assurance that the aging effects wiY be managed so that the structures and components within the scope of this prga wil cntinue to pefbFrm.
their-inended functions consistent with the curenat ilensn ai for the period of extended operation.