L-11-153, Reply to Requests for Additional Information for the Review of License Renewal Application, Batch 2 and Batch 1, and License Renewal Application Amendment No. 7

Reply to Requests for Additional Information for the Review of License Renewal Application, Batch 2 and Batch 1, and License Renewal Application Amendment No. 7

ML11151A090
Person / Time
Site:	Davis Besse
Issue date:	05/24/2011
From:	Byrd K FirstEnergy Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-11-153
Download: ML11151A090 (280)

Text

FENOC Davis-Besse Nuclear Power Station 5501 N. State Route 2 FirstEnergyNuclearOperating Company Oak Harbor,Ohio 43449 May 24, 2011 L-11-153 10 CFR 54 ATTN: Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

Davis-Besse Nuclear Power Station, Unit No. 1 Docket No. 50-346, License Number NPF-3 Reply to Requests for Additional Information for the Review of the Davis-Besse Nuclear Power Station, Unit No. 1. License Renewal Application, Batch 2 and Batch 1 (TAC No. ME4640), and License Renewal Application Amendment No. 7 By letter dated August 27, 2010, (Agencywide Documents Access and Management System (ADAMS) Accession No. ML102450565), FirstEnergy Nuclear Operating Company (FENOC) submitted an application pursuant to Title 10 of the Code of Federal Regulations, Part 54 for renewal of Operating License NPF-3 for the Davis-Besse Nuclear Power Station (DBNPS), Unit Number 1. By letter dated April 20, 2011 (ADAMS Accession No. ML110980718), the Nuclear Regulatory Commission (NRC) requested additional information to complete its review of the License Renewal Application (LRA).

Also, by letter dated April 5, 2011 (ADAMS Accession No. ML110820490), the NRC requested additional information to complete its review of the LRA.

Attachment A provides the FENOC reply to 24 of the 31 NRC Batch 2 requests for additional information (RAIs) in NRC letter dated April 20, 2011. For those 24, the NRC request is shown in bold text followed by the FENOC response. The remaining seven requests (B.2.16-1, B.2.16-2, B.2.16-3, B.2.16-4, B.2.16-5, B.2.16-6 and B.2.16-7) were discussed with Mr. Brian Harris, NRC Project Manager, and the responses to these requests are deferred to a mutually-agreeable submittal date of June 1, 2011.

By letter dated May 5, 2011 (ADAMS Accession No. MLI 1131A073), FENOC responded to 19 of the 41 Batch 1 RAIs in NRC letter dated April 5, 2011. Twenty-one of the remaining 22 (of 41) RAls (B.2.22-1, B.2.22 2, B.2.22-3, B.2.22-4, B.2.23-1, B.2.25-1, B.2.25-2, B.2.25-3, B.2.25-4, B.2.25-5, B.2.25-6, B.2.27-1, B.2.39-1, B.2.39-2, B.2.39-3, B.2.39-4, B.2.39-5, B.2.39-6, B.2.39-7, B.2.39-8 and B.2.40-1) were discussed with Mr.

Brian Harris, NRC Project Manager, and upon mutual agreement, the responses to these requests were deferred to be submitted with this letter, and are contained herein.

Attachment B provides the FENOC reply to those previously deferred 21 Batch 1 RAls.

The NRC request is shown in bold text followed by the FENOC response. One RAI

Davis-Besse Nuclear Power Station, Unit No. 1 L-11-153 Page 2 (XI.S8-1) was discussed with Mr. Brian Harris, NRC Project Manager, and it was mutually agreed that the response to this request would be included with the responses to the next-received set of RAIs.

The Enclosure provides Amendment No. 7 to the DBNPS 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 May ,2011.

Sincerely, Kendall W. By Director, Site Performance Improvement

Attachment:

A Reply to Request for Additional Information for the Review of the Davis-Besse Nuclear Power Station, Unit No. 1 (DBNPS), License Renewal Application, Batch 2, Sections 3.3.2 and B.2 B Reply to Request for Additional Information for the Review of the Davis-Besse Nuclear Power Station, Unit No. 1 (DBNPS), License Renewal Application, Batch 1, Section B.2

Enclosure:

Amendment No. 7 to the DBNPS License Renewal Application cc: NRC DLR Project Manager NRC Region III Administrator cc: w/o Attachment or Enclosure NRC DLR Director NRR DORL Project Manager NRC Resident Inspector Utility Radiological Safety Board

Attachment A L-11-153 Reply to Request for Additional Information for the Review of the Davis-Besse Nuclear Power Station, Unit No. 1 (DBNPS), License Renewal Application, Batch 2 Sections 3.3.2 and B.2 Page 1 of 44 Question RAI Sampling 1.0 Prior to the audit, the staff provided the applicant with a sampling of thirty-five component, material and environment combinations that were selected from license renewal application (LRA) Table 3. These components were chosen at random, in order to give the staff assurance that the information provided in the aging management review results in the applicant's LRA was accurate. The staff notes that accurate identification and independent confirmation of material and environment combinations is necessary to support the applicant's aging management reviews.

During the Scoping and Screening audit, on January 25, 2011, the staff performed a walkdown to confirm if the selected component, material and environment combinations listed in the LRA were accurate. After the completion of the walkdown the staff noted the following:

1. An orifice (component ID DB-R04989) in the high-pressure injection system (LRA Table 3.2.2-5), exposed to an environment of lubricating oil (internal), was identified as being fabricated from steel. During the walkdown of the system and component, the staff noted that the material was incorrectly identified as steel.

2. Tubing (drain tubing from component ID DB-F86) in the station air system (LRA Table 3.3.2-29), exposed to an environment of air-indoor uncontrolled (external), was identified as being fabricated from steel.

During the walkdown of the system and component, the staff noted that the material was incorrectly identified as steel.

The staff requests the following information:

1. The staff requests that the applicant verify the material composition of the components described above and, if necessary, provide an updated aging management review, in accordance with 10 CFR 54.21(a)(1).

2. Based on the identification that the materials of these two components were incorrectly identified in the LRA, clarify the follow-up actions that have been or will be taken to ensure that the aging management review (AMR) results in the LRA are accurate.

Attachment A L-11-153 Page 2 of 44 RESPONSE RAI Sampling 1.0 Hiqh Pressure Injection (HPI) System A walkdown in support of the NRC Scoping and Screening Audit to verify the materials of the in-scope HPI System, shown on license renewal boundary drawing LR-M033A, found a material difference from that reported in LRA Table 3.2.2-5, "Aging Management Review Results - High Pressure Injection System." The applicable components are orifices R04986 and R04989 associated with the Lube Oil System for each of the HPI Pumps (1-1 and 1-2).

Rows 48 through 51, 56 and 57 of LRA Table 3.2.2-5 shows the orifice material as steel. As determined by walkdown, the orifice material is stainless steel.

Therefore, rows 48, 49, 56 and 57 of LRA Table 3.2.2-5 are revised to show the correct material and to provide the updated aging management review (AMR) results. Also, rows 50 and 51 are revised to show "Not Used," since existing rows 46 and 47 address the external environment of the subject stainless steel orifices. In addition, the further evaluation in LRA Section 3.2.2.2.3.4 is revised to include the stainless steel components of the HPI pump lube oil system.

Additional Follow-up Actions (HPI System)

As a follow-up to the incorrectly indentified HPI orifice material, a review of the AMR reports was conducted to determine if a similar incorrect identification of orifice material could have occurred. A review of the AMR reports found, other than for the subject HPI orifices, that orifices within the scope of license renewal are fabricated of stainless steel with the exception of the Fire Protection (FP) System orifices (DB-RO1 046, 1047, 1056A and 1056B). These FP System orifices are non-safety related and a search of records could not confirm the material of fabrication. A walkdown performed on May 21, 2009 also could not confirm the material of construction due to the subject orifices being completely enclosed by a housing that is painted over. Therefore, the subject FP System orifices were assumed to be fabricated from steel. This assumption is conservative since the FP System orifices have an external environment of Air-Indoor Uncontrolled and for stainless steel the aging effect requiring management (AERM) is "none", however for steel the AERM is "loss of material." The orifices have an internal environment of raw water and for both materials the AERM is "loss of material."

Station Air System A walkdown in support of the NRC Scoping and Screening Audit to verify the materials of the in-scope Station Air System, shown on license renewal boundary drawing LR-M01 5D, found a material difference from that reported in LRA Table 3.3.2-29, "Aging Management Review Results - Station Air System." The subject drain line of air filter DB-F86 is copper tubing with brass fittings and the AMR results are provided in rows 17 through 19 of LRA Table 3.3.2-29. However, there is no in-scope steel tubing with an

Attachment A L-11-153 Page 3 of 44 intended function of "Structural integrity" for the Station Air System as determined by walkdown and confirmed by drawing LR-MO15D. Therefore, LRA Table 3.3.2-29 is revised to delete rows 20 through 23.

Additional Follow-up Actions (Station Air System)

Relative to the copper tubing with brass fittings for the air filter DB-F86, no additional follow-up is required as the correct material was identified. However, during the walkdown it was noted by FirstEnergy Nuclear Operating Company (FENOC) that the filter housing for air filter DB-F86 was fabricated from plastic (polymer) versus steel as reported in the LRA. Therefore, rows 7 through 9 of LRA Table 3.3.2-29 are revised to show the material as polymer for the filter housing and to provide the updated AMR results.

In addition, it was noted by FENOC that Station Air System valves SA1 31, 132, 501 and 503, shown on license renewal boundary drawing LR-MO15D were fabricated from bronze (copper alloy) versus steel as reported in the LRA. As confirmed by the applicable plant design standard (piping classification sheets for the JBD line class) and the Master Valve List, the subject valve bodies are fabricated of bronze (copper alloy).

Therefore, rows 27 through 30 of LRA Table 3.3.2-29 are revised to show the material as copper alloy for the subject Station Air System valves and to provide the updated AMR results.

As an extent of condition, a review of the mechanical AMR reports was conducted to verify that no other material identification errors occurred when using the plant design standard (piping classification sheets) and the Master Valve List to determine valve materials. As a result of this review, an additional LRA change is required; LRA Table 3.3.2-19, "Aging Management Review Results - Makeup Water Treatment System," is revised to add gray cast iron valve bodies with an intended function of "Structural integrity," and to provide the updated AMR results.

See the Enclosure to this letter for the revision to the DBNPS LRA.

Section 3.3.2 Question RAI 3.3.2.2.5-1 In the LRA, the applicant lists at least 24 Table 2 AMR line items that address elastomeric components exposed to an air-indoor uncontrolled (internal and external), raw water (internal) or treated water >60°C (>140°F) (internal) being managed for hardening and loss of strength by the External Surfaces Monitoring Program supplemented by the One-Time Inspection Program or the One-Time Inspection Program. These line items include, but are not limited to:

Attachment A L-11-153 Page 4 of 44

• 3.2.2-1, Row 21;

• 3.3.2-6, Row 4; and

" 3.3.2-28, Row 5.

The applicant also lists several line items that address elastomeric components exposed to an air-outdoor, air-indoor, or soil environment being managed for cracking and change in material properties by the Structures Monitoring Program.

LRA Section B.2.15 states that the External Surfaces Monitoring Program consists of periodic visual inspections and surveillance activities. It also states that the acceptance criterion for elastomeric materials is no unacceptable visual indications of cracks or discoloration. LRA Section B.2.30 states that the One-Time Inspection Program will include visual and physical examination, such as manipulation and prodding, of elastomers (flexible connections).

For AMR line items addressing similar material, environment, and aging effects, the Generic Aging Lessons Learned (GALL) Report recommends a periodic inspection program.

Consistent with the GALL Report, one-time inspections are appropriate for managing loss of material where environments are consistent with time such as the fuel oil, lube oil, and water chemistry programs. Where environments may not be consistent with time, such as indoor air or outdoor air, the GALL Report recommends the performance of periodic inspections since a single inspection may not reflect, or predict, the existence of future degradation.

The staff has the following concerns:

It is not clear to the staff whether only the One-Time Inspection Program will be used to inspect elastomeric components exposed to an air-indoor uncontrolled (internal and external), or if both the External Surfaces Monitoring and One-Time Inspection Programs will be used. The staff noted that for the elastomeric components exposed to raw water and treated water >60°C (>140°F), only the One-Time Inspection Program is credited.

• The External Surfaces Monitoring Program and the Structures Monitoring Program do not include physical manipulation of elastomeric materials and therefore it may not be fully effective at determining if hardening or loss of strength has occurred.

• The staff lacks sufficient information (e.g., thickness of flexible connections and mechanical sealants) to determine whether the

Attachment A L-11-153 Page 5 of 44 inspection of the elastomeric components will detect hardening and loss of strength on the interior surfaces of the component.

The staff requests the following information:

1. Given that the One-Time Inspection Program would not be an effective program for managing hardening and loss of strength for elastomeric components exposed to an air-indoor uncontrolled (internal and external).

raw water (internal) or treated water >60°C (>140°F) (internal), provide details as to what alternative program will be applied to appropriately manage the aging for these material and environment combinations.

2. Provide an assessment of those Table 2 AMR line items containing similar material, environment, and aging effect combinations that might be similarly affected and revise these line items to ensure an appropriate aging management program.

3. If as a result of the response to requests (1) and (2), or due to existing AMR line items, the External Surfaces Monitoring Program or Structures Monitoring Program is used to manage aging of elastomeric components, revise the programs to include physical manipulation of elastomeric materials, or state how they would be effective at determining if hardening or loss of strength has occurred.

4. State the basis for how hardening and loss of strength occurring on the interior surfaces of elastomeric components will be effectively detected with only an inspection of the exterior surface of the component.

RESPONSE RAI 3.3.2.2.5-1

1. The LRA is revised to remove elastomers from the scope of the One-Time Inspection, and to include elastomers in a new plant-specific Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Program (new LRA Sections A.1.41 and B.2.41). This periodic inspection program will manage hardening and loss of strength for elastomeric components in the following environments:

air-indoor uncontrolled (internal or external), raw water (internal), and treated water > 600C (> 140'F) (internal).

2. An assessment of the LRA identified the following tables with line items containing elastomers; these LRA tables are revised so that the new plant-specific Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Program manages hardening and loss of strength of the internal surfaces of elastomers and supplements the

Attachment A L-11-153 Page 6 of 44 External Surfaces Monitoring Program for the external surfaces of elastomers.

" Table 3.2.2-1

" Table 3.3.1

" Table 3.3.2-1

" Table 3.3.2-6

" Table 3.3.2-12

° Table 3.3.2-13

• Table 3.3.2-14

• Table 3.3.2-15

• Table 3.3.2-21

• Table 3.3.2-28

• Table 3.3.2-30

3. The External Surfaces Monitoring Program supplemented by the Internal Surfaces in Miscellaneous Piping and Ducting Program is used to manage aging of elastomeric components. The new plant-specific Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Program will include physical manipulation of elastomers.

4. The External Surfaces Monitoring Program supplemented by the Internal Surfaces in Miscellaneous Piping and Ducting Program is used to manage aging of elastomeric components. The new plant-specific Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Program will include physical manipulation of elastomers.

See the Enclosure to this letter for the revision to the DBNPS LRA.

Question RAI 3.3.2.71-2 In the LRA, the applicant lists at least at 41 Table 2 AMR line items that address steel piping and piping components exposed to air (internal), condensation (internal), and moist air (internal) all with an aging effect of loss of material, and all assign the One-Time Inspection Program as the aging management program.

These line items include, but are not limited to:

• 3.3.2-12, Row 91,

• 3.3.2-1, Row 34, and

• 3.3.2-31, Row 25.

Attachment A L-11-153 Page 7 of 44 For AMR line items addressing similar material, environment, and aging effects, the GALL Report recommends a periodic inspection program such as the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program to manage aging effects for these component/material/environment combinations.

Consistent with the GALL Report, one-time inspections are appropriate for managing loss of material where environments are consistent with time such as the fuel oil, lube oil, and water chemistry programs. Where environments may not be consistent with time, such as indoor air or outdoor air, the GALL Report recommends the performance of periodic inspections since a single inspection may not reflect, or predict, the existence of future degradation. Therefore, it is unclear why the applicant has selected the One-Time Inspection Program to manage a loss of material aging effect instead of a program that conduct's periodic inspections.

The staff requests the following information:

1. Given that the One-Time Inspection Program would not be an effective program for managing a loss of material for steel piping and piping components exposed to air (internal), condensation (internal), and moist air (internal), provide details as to what alternative program will be applied to appropriately manage the aging for these material and environment combinations.

2. Provide an assessment of those Table 2 AMR line items containing similar material, environment, and aging effect combinations that might be similarly affected and revise these line items to ensure an appropriate aging management program.

RESPONSE RAI 3.3.2.71-2

1. The LRA is revised to include a new plant-specific Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Program (new LRA Sections A.1.41 and B.2.41) for Davis-Besse. The program will consist of inspections of the internal surfaces of aluminum, copper alloy (including copper alloy > 15% Zn), stainless steel, and steel (including gray cast iron) components exposed to air (including air-indoor uncontrolled and air outdoor), condensation, diesel exhaust, or moist air, and external cooling coil surfaces.

The periodic inspection program will manage loss of material, cracking of susceptible stainless steel components, and reduction in heat transfer of cooling coil tubes and fins in the above environments.

Attachment A L-11-153 Page 8 of 44 The Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Program will include opportunistic inspections, when components are opened for maintenance, repair, or surveillance to ensure that the existing environmental conditions are not causing material degradation that could result in a loss of component intended function during the period of extended operation.

Implementation of this program will ensure that the intended functions of susceptible components are maintained during the period of extended operation.

However, One-Time Inspection will still be used to confirm the absence of aging effects for components exposed to the moist air environment at air-water interfaces.

An appropriate aging management program (e.g., PWR Water Chemistry Program) is used to manage the surface below the respective interface, and the portion above the air-water interface is also managed by a periodic program. Therefore, while the fluid management program (e.g., PWR Water Chemistry Program) is expected to preclude aging effects at the air-water interface, One-Time Inspection will confirm the effectiveness of the associated programs.

2. LRA tables are revised based on the changes related to the new plant-specific Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program. During review of LRA line items for relevant changes, some components in LRA Tables 3.3.2-3, "Aging Management Review Results - Auxiliary Steam and Station Heating System," and 3.4.2-4, "Aging Management Review Results - Main Steam System," that were in an environment of condensed steam (from the secondary system, controlled by the PWR Water Chemistry program) were re-evaluated in a steam or treated water environment instead of condensation for a more accurate aging evaluation and a more consistent GALL comparison. As a result, some entries to Table 3.4.2-4 are deleted, and the Table 3.4.1, "Summary of Aging Management Programs for Steam and Power Conversion Systems Evaluated in Chapter VIII of NUREG-1801," item 3.4.1-30, discussion clarified. Additionally, 10 psig condensate tank (DB-T95) was originally assigned an internal environment of Air-indoor uncontrolled, and is now re-evaluated in the correct internal environment of steam.

Also during review of Table 3.3.2-3 line items for this response, it was identified that Copper Alloy >15% Zn Valve Bodies are present in a fluid environment without identification of Selective Leaching. A new row is added for this combination.

Furthermore, during review of Table 3.3.2-27, "Aging Management Review Results -

Spent Fuel Pool Cooling and Cleanup System," line items for this response, it was identified that plant-specific note 0313, and reference to it, warranted clarification. It was also identified that similar clarifications were needed for Table 3.3.2-4, "Aging Management Review Results - Boron Recovery System," and Table 3.3.2-5, "Aging Management Review Results - Chemical Addition System."

See the Enclosure to this letter for the revision to the DBNPS LRA.

Attachment A L-11-153 Page 9 of 44 Section B.2 Question RAI B.2.2-1 The "detection of aging effects" program element of GALL Report aging managemnent program (AMP) XI.M29 "Aboveground Steel Tanks" recommends that potential corrosion of in-scope tank bottoms be determined by conducting thickness measurements whenever the tank is drained and at least once within five years of entering the period of extended Operation. LRA Section B.2.2 states that volumetric examination of tank bottoms will be conducted prior to the period of extended operation and that the frequency tank bottom volumetric inspections will be based on the findings of the inspection performed prior to the period of extended operation. It is not clear to the staff that, as a minimum, in-scope tank bottom thickness measurements will be performed whenever the tanks are drained and at least once within five years of entering the period of extended operation.

The staff requests the following information:

1. State the minimum number of times each in-scope tank's bottom will be inspected for thickness during the period of extended operation.

2. Revise LRA Appendix A, "Updated Safety Analysis Report Supplement,"

Section A.1.2, "Aboveground Steel Tanks Inspection Program," to reflect the fact that in-scope tank bottom thickness measurements will be performed whenever the tanks are drained and at least once within five years of entering the period of extended operation.

RESPONSE RAI B.2.2-1

1. The minimum number of times each in-scope tank's bottom will be inspected for thickness during the period of extended operation is one (i.e., at least once within five years after entering the period of extended operation). Based on the results of the inspection, a set inspection frequency may be established, if warranted.

2. LRA Appendix A, "Updated Safety Analysis Report Supplement," Section A.1.2, "Aboveground Steel Tanks Inspection Program," is revised to include in-scope tank bottom thickness measurements whenever the tanks are drained and at least once within five years after entering the period of extended operation. Additional LRA sections are revised to include tank bottom thickness measurements, including LRA Table A-i, "Davis-Besse License Renewal Commitments," Commitment 1, and LRA Appendix B, Section B.2.2, "Aboveground Steel Tanks Inspection Program,"

subsections "Program Description" and "Enhancements".

Attachment A L-11-153 Page 10 of 44 See the Enclosure to this letter for the revision to the DBNPS LRA.

Question RAI B.2.2-2 LRA Table 3.2.2-4, row number 117 states that for the stainless steel borated water storage tank exposed to air-outdoor (external) there is no aging effect and no AMP is proposed. The on-site AMP walkdown revealed that the tank is coated with insulation material.

It is the staffs position that cracking due to stress corrosion cracking could occur for stainless steel piping, piping components, piping elements, and tanks exposed to certain outdoor air environments. Such environments include, but are not limited to, those within 1/2 mile of a highway which is treated with salt in the wintertime, areas in which the soil contains more than trace chlorides, plants having cooling towers where the water is treated with chlorine or chlorine compounds, and areas subject to chloride contamination from other agricultural or industrial sources. In addition, although updated final safety analysis report (UFSAR) Section 5.2.3.3 states that the insulation coating the stainless steel borated water storage tank is compatible with the material of construction, there is no information in the LRA or UFSAR on the susceptibility of the insulation to release chlorides which could result in cracking of the stainless steel tank material.

The staff requests the following information:

1. State why the air-outdoor environment will not result in an aging effect requiring management for the stainless steel borated water storage tank (e.g., exposure to chlorides in the atmosphere, road chemical treatments, soil containing more than trace chlorides, cooling tower chemical treatment, local agricultural or industrial sources that could result in chloride contamination).

2. Describe the insulation material applied on the external surface of the stainless steel borated water storage tank and state if it could release halides.

3. If the air-outdoor environment or leached compounds from the insulation could result in an aging effect requiring management, state how the aging effect will be managed.

Attachment A L-11-153 Page 11 of 44 RESPONSE RAI B.2.2-2

1. The conditions described in the RAI exist such that the air-outdoor environment may result in an aging effect requiring management for the stainless steel borated water storage-tank. The Aboveground Steel Tanks Inspection Program is revised and is now credited for management of the borated water storage tank (BWST) aging effects.

2. The insulation for the BWST is polyurethane foam on a base coat of epoxy-polyamide. The insulation then has an intermediate layer of butyl rubber and a top layer of aliphatic urethane. The epoxy-polyamide base coat is limited to leach less than 200 ppm chlorides (i.e., a halide). The polyurethane foam insulation is limited to leach less than 1000 ppm chlorides.

3. The Aboveground Steel Tank Inspection Program is revised to manage the effects of cracking due to stress corrosion cracking (SCC) of the stainless steel BWST that is exposed to an outdoor air environment that may contain contaminants. Through periodic visual inspections and volumetric examinations of the tank bottom, the Aboveground Steel Tank Inspection Program, which includes an assessment of the condition of the coating as an indication of a location for degradation of the underlying metal, will manage effects of aging of the BWST during the period of extended operation.

Following an extent of condition review, the External Surfaces Monitoring Program, the Decay Heat Removal and Low Pressure Injection System, the Emergency Diesel Generators System, and the High Pressure Injection System evaluation results are also revised to manage cracking and loss of material for all stainless steel components that are exposed to an outdoor air environment.

Additionally, the line items associated with the tanks managed by the Aboveground Steel Tanks Inspection Program are revised for consistency to clarify that both the Aboveground Steel Tanks Inspection Program and the External Surfaces Monitoring Program manage the effects of aging on the external surfaces of these tanks.

See the Enclosure to this letter for the revision to the DBNPS LRA.

Question RAI B.2.2-3 The "preventive actions" program element of GALL AMP XI.M29 "Aboveground Steel Tanks" states that sealant or caulking at the external interface between the tank and concrete or earthen foundation mitigates corrosion of the bottom surface of the tank by minimizing the amount of water and moisture penetrating the interface, which would lead to corrosion of the bottom surface. LRA Section B.2.2 does not state that sealant or caulking was utilized at the external interface between the tank and concrete or earthen foundation.

Attachment A L-11-153 Page 12 of 44 It is not clear to the staff whether the firewater storage tank, diesel fuel oil storage tanks, and borated water storage tank have sealant or caulking installed at the external interface between the tank and concrete or earthen foundation. It is also not clear to the staff what compensatory measures are being implemented by the applicant to effectively manage aging of the bottom surface of the tanks if sealant or caulking was not installed at the base.

The staff requests the following information:

1. State whether the firewater storage, diesel fuel oil storage, and borated water storage tanks have sealant or caulking installed at the external interface between the tank and concrete or earthen foundation.

2. If these tanks do not have sealant or caulking, revise LRA B.2.2 to state and justify this as an exception to GALL AMP XI.M29.

3. If the tanks do have sealant or caulking, how will their aging effects be managed?

RESPONSE RAI B.2.2-3

1. The fire water storage tank does not have sealant or caulking at the interface edge between the tank and the foundation. Instead, the tank rests on an oiled sand pad on top of granular fill, which slopes down from the tank center to the outside edge.

The bottom surface of the tank is raised 6 inches from the finished grade. This design precludes water accumulation around the tank bottom.

The diesel fuel oil storage tank has a sealant between the tank and the foundation and is raised approximately 5 inches above the finished grade, precluding water accumulation around the tank bottom.

The BWST has a sealant between the tank and the foundation and is raised approximately one foot from the finished grade, precluding water accumulation around the tank bottom.

2. The LRA Aboveground Steel Tanks Inspection Program is revised to state and justify as an exception to GALL AMP XI.M29, that the fire water storage tank does not have sealant or caulking at the interface edge between the tank and foundation.

As a result of the addition of an exception to the program, the generic notes for the fire water storage tank (LRA Table 3.3.2-14, "Aging Management Review Results -

Fire Protection System," row 106) and the diesel fuel oil storage tank (LRA Table 3.3.2-15, "Aging Management Review Results - Fuel Oil System," row 28) are revised from LR Note A to LR Note B.

Attachment A L-11-153 Page 13 of 44

3. Degradation of the sealant on the diesel fuel oil storage and borated water storage tanks will be managed by periodic system walkdowns to confirm that the sealant is intact. The program will also include volumetric wall-thickness examinations of the tank bottoms.

See the Enclosure to this letter for the revision to the DBNPS LRA.

Question RAI B.2.2-4 LRA Section B.2.2 states that an inspection of the exterior of the diesel oil storage tank in 2002 revealed rust and corrosion at the base flange of the tank and corroded bolted at the lower access plate at the base of the tank.

The applicant did not state the cause of corrosion on the external surface of the tank. State the cause(s) for the external tank surface corrosion that occurred in 2002 associated with the diesel oil storage tank and what extent of condition review was conducted. State how this plant-specific operating experience was incorporated into the Aboveground Steel Tanks Inspection program.

RESPONSE RAI B.2.2-4 The apparent cause of the corrosion at the base flange and lower access plate of the tank was due to degradation of the protective coatings. The degradation was identified during system health readiness walkdowns prior to unit restart. The condition report states that there was no operability concern, and the degradation was categorized as (R)ust Corrosion (P)aint Preservation and (H)ousekeeping. Based on the system health readiness review process used and the categorization of the degradation, no specific extent-of-condition review was necessary for the identified diesel oil storage tank corrosion. The work order system was used to address the identified issues, and the diesel oil storage tank and bolting corrosion was cleaned and the tank repainted.

The Aboveground Steel Tanks Inspection Program is effective in identifying surface corrosion and ensuring corrective action prior to loss of intended function. The program requires periodic walkdowns and uses performance monitoring and evaluation of operating experience to identify adverse trends and adjust inspection frequency, if necessary.

Attachment A L-11-153 Page 14 of 44 Question RAI B.2.4-1 GALL AMP XI.M18, "Bolting Integrity," recommends preventive actions and inspections for managing the aging of bolting within the scope of license renewal including: 1) safety-related bolting, 2) bolting for nuclear steam supply system (NSSS) component supports, 3) bolting for other pressure retaining components, including nonsafety-related bolting, and 4) structural bolting (actual measured yield strength > 150ksi). GALL AMP XI.M18 further states that other aging management programs also manage inspection of safety-related bolting and supplement this Bolting Integrity program.

LRA Section B.2.4, "Bolting Integrity," states that the Bolting Integrity program inspections are implemented through the following other aging management programs: Inservice Inspection - IWE; Inservice Inspection - IWF; and Structures Monitoring Program. LRA Sections B.2.22, "Inservice Inspection (ISI)

Program - IWE," B.2.23, "Inservice Inspection Program - IWF," and B.2.39, "Structures Monitoring Program," do not include bolting in their program descriptions.

The applicant's B.2.22, B.2.23, and B.2.39 program basis documents do not provide guidance for aging effects related to bolting, associated preventive actions, or recommended inspections. The applicant states in their LRA that the ISI - IWE, ISI - IWF, and Structures Monitoring programs supplement the Bolting Integrity program by implementing inspections of structural bolts.

However, neither the LRA nor the applicant's ISI - IWE, ISI - IWF, and Structures Monitoring program basis documents provide guidance for aging effects related to structural bolting, associated preventive actions, or recommended inspections. The lack of guidance in the LRA and program basis documents brings into question the ability of these programs to manage bolting related aging effects including loss of material, loss of preload, cracking and stress corrosion cracking.

Describe how GALL AMP XI.M18 recommendations in the "preventive actions,"

"parameters monitored," and "detection of aging effects" program elements are addressed for bolting in the ISI - IWE, ISI - IWF and Structures Monitoring Programs. Include the specific inspection technique utilized by each program to manage loss of material, loss of preload, cracking and stress corrosion cracking.

If volumetric or surface examinations are not conducted for SCC susceptible bolts, explain why it is unnecessary.

Attachment A L-11-153 Page 15 of 44 RESPONSE RAI B.2.4-1 As indicated in LRA Section A.1.4, "Bolting Integrity Program," the program includes, through the Inservice Inspection Program, Inservice Inspection (ISI) Program - IWE, Inservice Inspection (ISI) Program - IWF, Structures Monitoring Program, and External Surfaces Monitoring Program, the periodic inspection of bolting for indications of degradation such as leakage, loss of material due to corrosion, loss of preload, and cracking. With respect to structural connections, the Bolting Integrity Program includes inspection of NSSS component support bolting and other piping support bolting through the ISI Program - IWF and inspection of containment penetration bolting through the ISI Program - IWE. Inspection of other structural components outside the containment, including bolting, is addressed by the Structures Monitoring Program.

Bolting in the ISI-IWE, ISI-IWF and Structures Monitoring Programs related aging effects including loss of material and cracking are managed as follows:

Preventive Actions:

The Bolting Integrity Program provides the selection of bolting materials, use of proper lubricants and sealants, and proper torquing and assembly of bolted closures (joints);

they are in accordance with industry guidelines and manufacturer or vendor recommendations. As provided in the response to RAI B.2.4-3 (below), molybdenum disulfide (MoS 2 ) is an approved lubricant for use at Davis-Besse. As further provided in the response, the Bolting Integrity Program will be enhanced to select an alternate stable lubricant that is compatible with the fastener material and the environment and a specific precaution against the use of compounds containing sulfur (sulfide), including molybdenum disulfide (MoS 2 ), as a lubricant will be included in the program.

Maintenance practices and bolting replacement activities including proper gasket activation, preload, torquing, and fit-up of bolting are in accordance with manufacturer, vendor or industry recommendations.

Additional details regarding the preventative actions as discussed in Section 2 of the Research Council for Structural Connections "Specification for Structural Joints Using ASTM A325 or A490 Bolts" is provided in the FENOC response to RAI B.2.39-8 (see Attachment B to this letter).

Parameters monitored:

Visual inspections of NSSS component supports and other piping supports, including bolting, are performed per the ISI Program - IWF. Inspections of containment penetrations, including bolting, are performed per the ISI Program - IWE. Inspections of other structural components bolting are performed per the Structures Monitoring Program.

For the ISI Program - IWE and IWF, the visual inspection requirements for bolting requirements are defined in accordance the ASME Section Xl code (IWE-2500,

Attachment A L-11-153 Page 16 of 44 IWE-3515, IWF-2500, IWF-3410), therefore no enhancements to these program descriptions are necessary.

For the Structures Monitoring Program, the visual inspection requirements for bolting will be included in the implementing procedures as indicated in LRA Table A-i, item 20, fourth bullet, which states, "Clarify that a "structural component" for inspection includes each of the component types identified within the scope of license renewal as requiring aging management." Anchor bolts and anchorages/embedments are types of structural components within this commitment. Examples of structural component types related to piping and equipment supports are, but not limited to, component and piping supports, equipment component supports, expansion anchors, instrument line supports, and pipe supports. Structural bolting is monitored for loss of material, cracking, and other conditions indicative of degradation such as loose bolts, missing or loose nuts.

Detection of aging effects:

Structural bolting, including component support bolting, both inside and outside containment, is inspected by visual inspection through the ISI Program - IWF and Structures Monitoring Program. Containment penetration pressure retaining bolting is inspected by visual inspection through the ISI Program - IWE. If any degradation of these bolts and fasteners is identified, a closer inspection is performed to assess the extent of degradation. An appropriate technique (i.e., visual inspection or volumetric examination) is selected on the basis of the bolting application and the applicable code.

Structural bolting materials used at Davis-Besse include A 36, A 276, A 307, A 325, A 449, A 490, and A 540, conforming to ASTM standards. Volumetric or surface examinations are not currently conducted for stress corrosion cracking susceptible bolts since no instances of failed bolting or bolted connections due to stress corrosion cracking had occurred at Davis-Besse. For stress corrosion cracking to occur in a susceptible high strength bolting material, a sustained tensile stress and a corrosive environment must be present. Visual examinations of structural assemblies will detect corrosion or conditions indicative of a corrosive environment that could lead to stress corrosion cracking in potentially susceptible high strength bolting, and will cause appropriate corrective action to be taken under the Corrective Action Program when necessary. Corrective action may include volumetric examination of affected bolts, hammer testing, or other actions appropriate for the condition. Therefore, visual examination, as described, will effectively manage the aging of installed structural high strength bolting.

LRA Table 3.5.2-13, "Aging Management Review Results - Bulk Commodities," rows 138, 140, 146, 149, 158, and 162 are consistent with NUREG-1801,Rev. 1, Volume 2 line item III.B.1.1-3, where cracking of anchor bolts is managed by the XI.M18, "Bolting Integrity," program. LRA Table 3.5.2-13 is revised to include a plant-specific note to clarify that the Bolting Integrity Program includes the Inservice Inspection (ISI)

Program - IWE, Inservice Inspection (ISI) Program - IWF, and Structures Monitoring Program for the management of structural bolting.

Attachment A L-11-153 Page 17 of 44 See the Enclosure to this letter for the revision to the DBNPS LRA.

Question RAI B.2.4-2 GALL AMP XI.M18, "Bolting Integrity," relies on recommendations for a comprehensive bolting integrity program as delineated in EPRI TR-104213, EPRI NP-5769 and NUREG-1339. LRA section B.2.4 states an exception to the GALL AMP XI.M18, indicating that the applicant does not explicitly address the guidelines outlined in EPRI NP-5769 and NUREG-1339. Instead, the applicant's Bolting Integrity Program only relies on the recommendations contained in EPRI TR-104213 and EPRI TR-111472.

The use of EPRI TR-111472 as guidance in place of the GALL recommended guidance delineated in EPRI NP-5769 and NUREG-1339 requires further clarification to determine how EPRI TR-111472 meets the intent of EPRI NP-5769 and NUREG-1339 as identified in GALL AMP XI.M18, and whether or not its usage will contradict the GALL guidance.

Provide clarification on the use of EPRI TR-111472 as guidance for this program.

Specifically, provide an explanation of any contradictions between EPRI TR-111472 and the GALL recommended guidance delineated in EPRI NP-5769 and NUREG-1339 that it is replacing and their impact on this program.

RESPONSE RAI B.2.4-2 EPRI document TR-1 11472 is a training module that is based on EPRI NP-5067 and EPRI TR 104213, and consolidated into a more usable form for plant maintenance and training. It is used as the basis for certain bolting activities in plant procedures. The use of these standards does not contradict the guidance for bolting integrity provided in NUREG-1339, EPRI NP-5769 or EPRI TR-104213 which are cited in NUREG-1801, XI.M18, "Bolting Integrity."

As indicated in LRA Section B.2.4, "Bolting Integrity Program," EPRI documents TR-104213, "Bolted Joint Maintenance & Application Guide," and TR-111472, "Assembling Bolted Connections Using Spiral-Wound Gaskets," along with manufacturer and vendor information, provide guidance for proper material selection, preload, and assembly, as well as for maintenance and inspection of safety-related bolting and other bolting.

EPRI NP-5769 and EPRI NP-5067 are very closely-related documents that cross-reference one another and reference NUREG-1339. An element-by-element comparison between EPRI NP-5067 and EPRI 5769 based on the recommendations

Attachment A L-11-153 Page 18of 44 found in NUREG 1801,Section XI.M18, has been previously performed by Dominion in response to an NRC open item (01-3.0.3.2.18-2) during the Millstone license renewal process (ML051020128). Based on this comparison, the NRC staff concluded that NP-5067 provided adequate guidance for addressing bolting integrity and therefore was consistent with the recommendations of NUREG-1801,Section XI.M18, and closed the open item as documented in the Safety Evaluation Report issued under NUREG-1838 (dated October 2005).

Most bolting has component-specific Original Equipment Manufacturer (OEM) recommendations that include bolt material specifications, torque patterns and values, lubrication requirements, gasket crush and bolt stretch requirements. The Davis-Besse Bolting Integrity Program provides specific instructions for performing bolted joint disassembly, inspection, and reassembly, as well as torque value and flange bolting pattern guidelines. The Davis-Besse Bolting Integrity Program follows EPRI TR-104213 and EPRI TR-1 11472 guidance.

According to NUREG-1339, the EPRI NP-5067, "Good Bolting Practices," reference manuals were developed by EPRI, and were intended for rapid-access use by utility personnel for assembly and disassembly of bolted joints, but were not intended for use by designers. The reference manuals correlate to the information in Section 8 of NP-5769, minus the design information.

In conclusion, the Davis-Besse Bolting Integrity Program meets the intent of the GALL Report recommendations. EPRI TR-104213 and TR-111472, and manufacturer and vendor information provide the recommendations for proper material selection, preload, and assembly, as well as for maintenance and inspection of safety-related bolting and other bolting. Correct bolting material is assured by the manufacturer and vendor information and the design change process. Correct gaskets, lubrication, torque sequence, and torque values are assured by manufacturer and vendor information, and the Davis-Besse Bolting Integrity Program.

Question RAI B.2.4-3 GALL AMP XI.M18 "Bolting Integrity" indicates that use of molybdenum disulfide (MoS 2 ) as a lubricant on closure bolting within the scope of license renewal is a potential contributor of stress corrosion cracking and should not be used. The applicant's Bolting Integrity program basis documents state that certain instances were identified where lubricants containing MoS 2 were approved for use, but the operating experience review did not show cases where lubricants had caused degradation.

The use of MoS 2 is known to be a contributor to stress corrosion cracking and should not be used. The extent of usage of MoS 2 as a lubricant on closure bolting

Attachment A L-11-153 Page 19 of 44 within the scope of license renewal is not clear. It is also not clear if the applicant will be replacing lubricants containing MoS 2 with an alternate lubricant for use on closure bolting within the scope of license renewal.

The staff requests the following information:

1. Identify the extent to which MoS 2 is currently used as a lubricant on closure bolts within the scope of license renewal.

2. Are there plans to replace MoS 2 with an alternate lubricant for use on closure bolting within the scope of license renewal? If no replacement is planned, the staff would consider this to be an exception to the recommendations of GALL AMP XI.M18 requiring an appropriate justification as to why stress corrosion cracking would not be of concern.

RESPONSE RAI B.2.4-3 Molybdenum disulfide (MoS 2) is an approved lubricant for use at Davis-Besse.

However, industry operating experience has shown that the use of MoS 2 as a lubricant is a potential contributor to stress corrosion cracking, and should not be used.

Therefore, a revision to the Bolting Integrity Program is required.

LRA Section B.2.4, "Bolting Integrity Program," is revised to include a new enhancement to the Bolting Integrity Program and a corresponding new license renewal future commitment in LRA Table A-1,to select an alternate stable lubricant that is compatible with the fastener material and the environment. A specific precaution against the use of compounds containing sulfur (sulfide), including molybdenum disulfide (MoS 2 ), as a lubricant is also included in the program.

See the Enclosure to this letter for the revision to the DBNPS LRA.

Question RAI B.2.7-1 LRA Section B.2.7 states that the Buried Piping and Tanks Inspection Program, is an existing program with no exceptions and eight enhancements, and is consistent with GALL AMP XI.M34. In light of recent industry operating experience, the staff is concerned about the continued susceptibility to failure of buried piping that is within the scope of 10 CFR 54.4 and subject to aging management for license renewal. Most of the events could have been avoided with the effective implementation of one or more preventive actions consisting of cathodic protection, effective coatings and quality of backfill. The staff integrated this operating experience into the recommendations contained in GALL AMP XI.

M41, "Buried and Underground Piping and Tank Inspections."

Attachment A L-11-153 Page 20 of 44 The staff identified the following issues:

1. In order to evaluate an applicant's buried pipe and underground piping inspection programs, the staff must be aware of plant-specific operating experience which might include examples beyond those listed in the LRA.

2. GALL AMP XI.M41 Sections 4.b.iii. and 4.c.iii. state that inspection locations should be risk informed based on susceptibility to degradation and consequence of failure. The staff does not have sufficient information to determine if the applicant will utilize risk informed criteria to inspection locations.

3. GALL AMP XI.M41 , Table 2a, states that buried in-scope steel piping should be cathodically protected. The LRA and UFSAR do not contain enough details to determine if the buried in-scope service water piping is cathodically protected. In addition, UFSAR 9.5.4.2 states, "Corrosion of the tanks [fuel oil storage] will be prevented by protective coatings, and by cathodic protection if necessary." Therefore it is not clear to the staff if the fuel oil tanks are cathodically protected. The LRA does not state the availability of the cathodic protection system and what periodic testing is conducted on the cathodic protection system.

4. GALL AMP XI.M41 , Table 2a, states that the backfill within six inches of buried in-scope steel piping should meet Section 5.2.3 of NACE SP0169-2007. The LRA does not describe the quality of the backfill in the vicinity of buried in-scope piping.

5. GALL AMP XI.M41 , Table 2a, states that steel piping should be coated; however, if a buried fire protection piping system was designed to NFPA-24 and is tested to NFPA-25, then the coating preventive measures of Table 2a does not apply. The staff noted that UFSAR, Table 9.4-1 states that the fire protection piping and components were installed to NFPA requirements, but it did not specify NFPA-24. The staff also noted that LRA Section B.2.1.18 (Fire Water Program) states that periodic flow testing is conducted in accordance with NFPA-25, but also states that some portions are not flow tested. The staff does not have sufficient information to determine that the buried in-scope fire protection piping was constructed to NFPA-24 and is periodically tested to the requirements of NFPA-25.

6. LRA Section B.2.7 describes two instances of coating degradation, a 1995 example associated with a fuel oil piping leak and a 2008 example associated with a condensate demineralizer backwash line. The applicant did not state the cause of the coating degradation. In addition, the LRA

Attachment A L-11-153 Page 21 of 44 describes the discovery of four different coating holidays. The staff needs to understand the causes of the failures in order to evaluate the effectiveness of the applicant's program.

7. Enhancements three through six state that one inspection of a buried in-scope coated and wrapped piping segment or tank, and one inspection of uncoated cast iron piping will be conducted in the ten-year period prior to extended operation and be repeated once in the first ten-year period of extended Operation. The sample size proposed by the applicant may not provide a reasonable basis for assurance that the piping will meet its intended license renewal function(s) if a piping system is not cathodically protected.

8. LRA Section B.2.7 and Commitment No. 3 state that approximately ten linear feet of piping will be exposed for inspections. The staff believes that a minimum inspection length should be established to ensure that an adequate length of piping is inspected.

9. The staff reviewed LRA Section A.1.7 and UFSAR Update for the Buried Piping and Tanks Inspection Program and noted that it does not state that preventive measures are in accordance with standard industry practice for maintaining external coatings and wrappings and cathodic protection.

10. Given that the LRA Section B.2.7 describes a 1995 fuel oil leak, 2002 holiday (i.e., location of missing coating) in a fuel oil line, 2008 fuel oil line holidays leading to pitting and minor corrosion, and a 2008 condensate demineralizer backwash line coating damage, it is not clear to the staff how the applicant is informing the number of required inspections based on plant-specific operating experience. GALL AMP XI.M41 , Section 4.f.iv.

states that if adverse conditions (e.g., leaks, material thickness less than minimum, presence of coarse backfill within six inches of the pipe that resulted in coating degradation, general or local degradation that resulted in exposure of the base material) are discovered during the inspection of in-scope buried pipe, that the sample size is doubled and if subsequent inspections find further adverse conditions that the inspection size continues to be doubled. LRA Section B.2.7 states that degradation or leakage found during inspections is entered into the corrective action program to ensure evaluations are performed and appropriate corrective actions are taken, but it does not state the expansion of scope size.

11. LRA Section B.2.20, Fuel Oil Chemistry Program, states that the effectiveness of the Fuel Oil Chemistry Program is verified by the One-Time Inspection program, which includes ultrasonic thickness measurement of a sample fuel oil tank bottom to ensure that significant degradation is not occurring. If the fuel oil tanks are cathodically

Attachment A L-11-153 Page 22 of 44 protected, the staff believes that to effectively detect aging effects of a buried tank each fuel oil tank should have a periodic internal visual inspection and if the visual inspection detects signs of degradation on the surfaces of the tank, a volumetric examination on the interior surfaces of the tank should be conducted.

12. LRA Table 3.3.2-12, row number 102, states that there is steel piping external exposed to soil. It is not clear whether the internal environment is fuel oil, lubricating oil, or air.

13. LRA Section B.2.15, External Surfaces Monitoring Program, states that, "Surfaces that are inaccessible or not readily visible during either plant operations or refueling outages, such as surfaces that are insulated, will be inspected opportunistically during the period of extended operation."

Based on a review of the LRA, it is not clear to the staff which systems have underground piping or tanks (i.e., below grade but are contained within a tunnel or vault such that they are in contact with air and are located where access for inspection is restricted) and the length of piping or number of tanks that are underground. GALL Report AMP X1.41 recommends a minimum number of inspections of underground piping based on material type and function of the piping (i.e., code class/safety-related, contains hazardous materials) and each steel tank.

Given the "opportunistic" statement in the LRA, it is not clear to the staff that the applicant's program will inspect an adequate sample of underground piping and tanks. In addition, GALL AMP XI.M41, Section 4.c.iv., states that underground piping is visually inspected to detect external corrosion and volumetrically examined to detect internal corrosion. The staff does not have sufficient information to determine if and to what extent the applicant will conduct volumetric examinations of underground piping.

14. GALL AMP XI.M41, Table 2b, states that underground piping should be coated in accordance with Table 1 of NACE SP0169-2007 or the applicant should justify the alternative coating methodology. The staff does not have sufficient information to determine if the applicant's coatings for underground piping meet Table 1 of NACE SP0169-2007 Table 1.

15. GALL AMP XI.M41, Section 6.c, states that, if coated or uncoated metallic piping or tanks show evidence of corrosion, the remaining wall thickness in the affected area is determined to ensure that the minimum wall thickness is maintained. LRA Section B.2.7 states that degradation found during inspections is entered into the corrective action program to ensure evaluations are performed and appropriate corrective actions are taken, but it does not state the remaining wall thickness in the affected area is determined to ensure that the minimum wall thickness is maintained.

Attachment A L-11-153 Page 23 of 44 The staff requests the following information:

1. Provide a list and brief summary, including cause, of any leaks or adverse conditions (e.g., leaks, material thickness less than minimum, presence of coarse backfill within six inches of the pipe that resulted in coating degradation, general or local degradation that resulted in exposure of the base material) which have occurred in buried piping or tanks at the station in the past five years that were entered in your corrective action program but are not included in your LRA.

2. State whether buried and underground in-scope piping inspection locations will be selected based on risk factors considering susceptibility to degradation and consequences of failure. If inspection locations are not risk informed, state how the inspections that are conducted will be representative of piping locations that are most susceptible to degradation and result in the worst adverse consequences.

3. For buried in-scope steel piping respond to the following:

i. State whether the service water system and emergency diesel generator fuel oil storage tanks are cathodically protected, including, if portions of a system are protected, what portions are not protected.

ii. State the availability of the cathodic protection system, and if portions of the system are not available 90% of the time or will be allowed to be out of service for greater than 90 days in any given year, state how the piping will meet or exceed the minimum design wall thickness throughout the period of extended operation.

iii. State whether annual ground potential surveys of the cathodic protection system are conducted and what acceptance criteria is utilized, or if annual ground potential surveys are not conducted, state how the piping will meet or exceed the minimum design wall thickness throughout the period of extended operation.

iv. State what cathodic protection system inspection/testing parameters will be trended and evaluated for adverse changes. If these parameters do not include potential difference and current measurements state how the effectiveness of the systems and/or coatings will be evaluated.

4. Based on plant-specific installation specifications and the results of inspections conducted to date, state if the backfill within six inches of

Attachment.A L-11-153 Page 24 of 44 buried in-scope steel piping meets NACE SP0169-2007. If the backfill does.

not meet NACE SP0169-2007, state how the buried pipe coatings will not be potentially damaged by the backfill..

5. State the following for buried in-scope uncoated fire protection cast iron piping:

L What specific NFPA code was used for the design and installation of the in-scope buried fire protection piping. If the design and installation code required that cast iron piping be coated, state why there is a reasonable assurance that the uncoated cast iron piping will meet its current CLB function(s) throughout the period of extended operation.

ii. State whether all portions of the buried in-scope fire protection piping will be periodically flow tested in accordance with NFPA-25.

If all or some portions of the buried in-scope fire protection piping will not be periodically flow tested in accordance with NFPA-25, state why there is a reasonable assurance that the uncoated cast iron piping will meet its current CLB function(s) throughout the period of extended operation.

6. State the cause for the coating degradation that occurred in a 1995 example associated with a fuel oil piping leak and a 2008 example associated with a condensate demineralizer backwash line. State the basis for having a reasonable assurance that planned inspections represent an adequate quantity to identify coating damage and holidays

• before leaks occur.

7. For buried in-scope piping, respond to the following:

i. What minimum number of inspections of buried in-scope piping is planned during the 30 -40, 40 -50, and 50 -60 year operating period?

When describing the minimum number of planned inspections, differentiate between material, codelsafety-related piping, and potential to contain hazardous material category piping inspection quantities of buried in-scope piping.

ii. State which inspections will be conducted by excavated direct visual inspection of the buried piping.

iii. State the length of each buried in-scope piping system.

Attachment A L-11-153 Page 25 of 44 iv. If there are no planned inspections for piping containing hazmat materials, state why it is acceptable to not inspect in-scope pipe containing hazardous materials.

8. State the minimum inspection length of excavated buried piping inspections. If the length is shorter than ten feet, state the basis for why this length will provide an adequate representative length of piping.

Revise LRA Commitment No.3 to state the minimum inspection length of piping.

9. Revise LRA Section A.1.7 to state that preventive measures are in accordance with standard industry practice for maintaining external coatings/wrappings and cathodic protection, and state the number of inspections and frequency of buried in-scope piping.

10. State the sample size increase of the inspection in-scope buried pipe that will occur if adverse conditions (e.g., leaks, material thickness less than minimum, presence of coarse backfill within six inches of the pipe that resulted in coating degradation, general or local degradation that resulted in exposure of the base material) are discovered during inspections. If the inspection sample size is not initially doubled and then doubled again if adverse conditions are discovered in the initial and subsequent inspections, state why there is a reasonable assurance that the extent of condition has been discovered and evaluated.

11. For the buried in-scope steel fuel oil tanks state whether each fuel oil tank will have a periodic internal visual inspection and if the visual inspection detect signs of degradation on the surfaces of the tank, a volumetric examination on the interior surfaces of the tank will be conducted, or state why it is acceptable to not conduct these inspections. In addition, state the frequency of inspection of the tanks. If the frequency of tank inspections exceeds ten years, state the basis for why the test frequency provides a reasonable assurance that the tank will not leak or be able to meet its CLB function(s).

12. State whether the piping in LRA Table 3.3.2-12, row number 102, has an internal environment of fuel oil, lubricating oil, or air.

13. State the systems, function (e.g., safety related, Code required, contains hazmat material, nonsafety-related), material type and length of in-scope underground piping and state the number of underground steel tanks.

State how many and the extent of visual and volumetric inspections that will be conducted of underground piping and steel tanks.

Attachment A L1-1 53 Page 26 of 44

14. State whether underground piping and tanks are coated in accordance with Table 1 of NACE SP-0169-2007 or justify why the existing coating or lack of coating provides a reasonable assurance that the uncoated piping will meet its current CLB function(s) throughout the period of extended operation.

15. If coated or uncoated metallic piping or tanks show evidence of corrosion, state whether the remaining wall thickness in the affected area will be determined to ensure that the minimum wall thickness is maintained. If the remaining wall thickness will not be measured, state how there is reasonable assurance that the extent of corrosion is understood.

RESPONSE RAI B.2.7-1 LRA Sections A.1.7 and B.2.7, both titled "Buried Piping and Tanks inspection Program," are revised to incorporate industry operating experience and to include new and revised program enhancements. The corresponding license renewal future commitments are added to LRA Table A-I. Responses to the specific requests for additional information below are from the perspective of this updated aging management program.

1. FENOC conducted a review of the Davis-Besse plant specific operating experience for License Renewal. The results of this review did not identify any leaks or adverse conditions for in-scope buried piping or tanks which have occurred at the station in the past five years that are not included in the LRA.

2. The buried piping inspection locations are selected based on risk factors considering susceptibility to degradation and consequences of failure.

3. i. Upgrade of the cathodic protection system in accordance with NACE SP0169-2007 or NACE RP0285-2002 is in progress. As portions are completed, testing is performed to determine the effectiveness of the cathodic protection system and to make recommendations for additions or upgrades as necessary based upon the test results. Cathodic protection installed for the emergency diesel generator fuel oil piping was confirmed to be effective for the piping. The performance test associated with the installation did not evaluate cathodic protection for the tanks. The in-scope service water piping does not currently have cathodic protection in accordance with NACE SP0169-2007 or NACE RP0285-2002. LRA Table A-1 is revised to include a license renewal future commitment to confirm that the buried piping and tanks in the scope of license renewal are provided with cathodic protection in accordance with NACE SP0169-2007 or NACE RP0285-2002 prior to entering the period of extended operation.

Attachment A L-11-153 Page 27 of 44 ii. The cathodic protection for the emergency diesel generator fuel oil piping has been available 100% of the time since the last inspection was performed. LRA Table A-i is revised to include a license renewal future commitment to confirm that the buried piping and tanks in the scope of license renewal are provided with cathodic protection in accordance with NACE SP0169-2007 or NACE RP0285-2002 prior to entering the period of extended operation. The status of cathodic protection is taken into account for determining the number of directed buried steel pipe inspections to be performed as well as the affect on the risk-ranking of a given piping segment.

The program directs that the emergency diesel generator fuel oil storage tanks (DB-T1 53-1 and DB-T1 53-2) be inspected prior to entering the period of extended operation. Inspections include either a visual inspection of at least 25%,*o of each tank and include at least some portion of the tank top and bottom, or an internal volumetric inspection with at least one measurement per square foot of the surface of the tanks. These inspections are not required if it is demonstrated that the tanks are cathodically protected in accordance with NACE SP0169-2007 or NACE RP0285-2002.

iii. Annual ground potential surveys of the cathodic protection system will be conducted and the acceptance criteria are listed in NACE SP0169-2007 and NACE RP0285 2002.

iv. Cathodic protection voltage and current, will be monitored monthly to determine the effectiveness of cathodic protection systems and, thereby, the effectiveness of corrosion mitigation. Voltage, current, and ground potential readings will be trended and evaluated for adverse changes.

4. While installation specifications do not conform to ASTM D 448-08 size number 67, they do specify granularity size distribution and backfill process to avoid coating damage. Therefore, based on plant-specific installation specifications and the results of inspections conducted to date, backfill is installed in accordance with NACE SP0169-2007, Section 5.2.3. Directed and opportunistic inspections evaluate the condition of the pipe coatings and backfill. FENOC conducted a review of the Davis-Besse plant-specific operating experience for License Renewal. The results of this review did not identify mechanical damage to the coatings from the backfill.

5. i. NFPA-24-1968/73 was used for the design and installation of the in scope buried fire protection piping.

ii. LRA Table A-1 is revised to include a license renewal future commitment to monitor the activity of the jockey fire pump or equivalent parameter on at least a monthly interval. When unexplained changes in jockey pump activity or equivalent parameter are observed, a flow test will be conducted by the end of the next refueling outage.

Attachment A L-11-153 Page 28 of 44

6. The fuel oil piping leak documented in 1995 was associated with the non safety-related steel piping from the above ground diesel oil storage tank. The apparent cause was determined to be stray current corrosion. The protective coating on the top of the horizontal pipe had small breaks in it, possibly due to a welder standing on the pipe during installation. The corrosion was confined to the top surface of the pipe. The loss of cathodic protection in the area allowed the corrosion to continue, leading to leakage from the pipe. The damaged pipe was replaced and the cathodic protection repaired.

The 2008 example is a 3-inch pipe that is not within the scope of license renewal.

The original function of the 3-inch pipe was to allow transfer of non-radioactive resin slurry from the backwash receiving tank to the Settling Basin. The current function is discharge from the Condenser Pit sump pumps and flood pumps. The apparent cause of failure was external corrosion due to coating failure combined with an absence of cathodic protection. There had been numerous previous excavations in the area that may have initiated the coating failure.

To provide reasonable assurance of the integrity of buried piping, LRA Table A-1 is revised to include a license renewal future commitment to perform additional buried in-scope piping inspections prior to entering the period of extended operation. The selection of components to be examined is based on previous examination results, trending, risk ranking, and areas of cathodic protection failures or gaps.

7. i. The minimum number of buried in-scope piping inspections during the 30-40, 40-50, and 50-60 year operating periods is one steel safety-related piping segment and one steel piping segment containing hazardous material.

ii. Inspections will be conducted by excavated direct visual inspection of the buried piping.

iii. Emergency Diesel Generators (EDG) System - fuel oil subsystem, approximately 1400 feet.

Fire Protection System, approximately 8500 feet.

Service Water System, approximately 1500 feet.

iv. There are planned inspections for piping containing hazardous materials (i.e.,

fuel oil).

8. The minimum inspection length of excavated buried piping inspections is ten feet.

LRA Table A-i, Commitment 3, is revised to state the minimum inspection length of piping.

9. LRA Section A.1.7 is revised to include the requested statements.

Attachment A L-11-153 Page 29 of 44

10. If adverse indications are detected, additional buried in-scope piping inspections will be performed to provide reasonable assurance of the integrity of buried piping.

The selection of components to be examined will be based on previous examination results, trending, risk-ranking, and areas of cathodic protection failures or gaps, if applicable. Additional sampling continues until reasonable assurance of the integrity of buried piping is provided.

11. Each buried in-scope steel fuel oil tank will have a periodic internal visual inspection at a frequency not exceeding ten years. If the visual inspection detects signs of degradation on the surfaces of the tank, a volumetric examination on the interior surfaces of the tank will be conducted. These actions are directed by the Fuel Oil Chemistry program, which manages the internal surfaces of the tanks (see the FENOC response to RAI B.2.20-2 contained in FENOC letter L-11-134 dated May 5, 2011).

12. LRA Table 3.3.2-12, row number 102, has an internal environment of fuel oil.

13. The underground piping is shown on drawing LR-M033A. The piping is part of the Decay Heat Removal and Low Pressure Injection System. The function is to provide post-loss of coolant accident emergency core cooling from the BWST. The piping is safety related, stainless steel and located within the borated water piping trench. The piping is approximately 30 feet in length. The aging management review results for this piping are provided in LRA Table 3.2.2-4, "Aging Management Review Results - Boron Recovery System," rows 79 & 80. As shown, no aging effects requiring management were identified, however the program is enhanced to include a visual and volumetric inspection of this piping to confirm the absence of the aging effect. The enhancement requires that a visual and volumetric inspection of the underground piping within the borated water piping trench will be performed during each 10-year period beginning no sooner than 10 years prior to entering the period of extended operation. There are no underground steel tanks.

14. The underground piping is stainless steel, and no coating is required to protect stainless steel in an air environment.

15. If coated or uncoated metallic piping or tanks show evidence of corrosion, the remaining wall thickness in the affected area will be determined to ensure that the minimum wall thickness is maintained.

Based on the revised Buried Piping and Tanks Inspection Program and the responses provided for RAI B.2.7-1, above, LRA Table A-i, Commitment 3 is revised to include four deleted, one revised and six new license renewal future commitments for this program.

See the Enclosure to this letter for the revision to the DBNPS LRA.

Attachment A L-11-153 Page 30 of 44 Question RAI B.2.8-1 In the program description for LRA Section B.2.8, the applicant stated that the Closed Cooling Water Chemistry Program will be supplemented by the One-Time Inspection Program; however, in the exception for this program, the applicant stated that opportunistic inspections will be conducted. The GALL AMP XI.M21 "Closed-Cycle Cooling Water System" element 4 "detection of aging effects" states that the control of water chemistry does not preclude corrosion or stress corrosion cracking and that the extent and schedule of inspections and testing should assure detection of these aging effects before the loss of the intended function.

Based on the program description in LRA Section B.2.8, it is unclear to the staff whether the applicant will conduct a one-time inspection, periodic inspections of opportunity, or a combination of the two, as the description of the inspection activity differs within the program summary.

The guidance in the GALL Report maintains that one-time inspections should not be used for structures or components with known age-related degradation mechanisms or when the environment is not consistent with time. In these cases, periodic inspections are recommended where a single inspection may not reflect, or predict, the lack of degradation in the future. It is the staffs current position that inspections conducted in conjunction with the closed-cycle cooling water systems should be conducted whenever the system is opened and that a representative sample of piping and components should be inspected at an interval not to exceed ten years.

The staff requests the following information:

1. Confirm whether the program will include a one-time inspection, periodic inspections of opportunity, or a combination of the two.

2. If periodic inspections will not be conducted, provide technical justification for the selection of the One-Time Inspection Program rather than a program that uses periodic inspections.

3. If periodic inspections will be conducted, state whether the inspection results will be reviewed to ensure that a representative sample of piping and components has been inspected at an interval not to exceed ten years. Absent a minimum inspection interval, state how inspections of opportunity will provide assurance that corrosion or stress corrosion cracking will be detected before the component's loss of intended function.

Attachment A L-11-153 Page 31 of 44 RESPONSE RAI B.2.8-1

1. LRA Sections A.1.8 and B.2.8, both titled "Closed Cooling Water Chemistry Program," are revised to include an enhancement that requires documentation of the results of periodic inspections of opportunity, performed when components are opened for maintenance, repair, or surveillance.

These inspections will ensure that the existing environmental conditions are not causing material degradation that could result in a loss of component intended function during the period of extended operation. The One-Time Inspection will no longer supplement the Closed Cooling Water Chemistry Program.

2. As above, the Closed Cooling Water Chemistry Program will be enhanced to document the results of periodic inspections of opportunity, performed when components are opened for maintenance, repair, or surveillance.

These inspections will ensure that the existing environmental conditions are not causing material degradation that could result in a loss of component intended function during the period of extended operation. The One-Time Inspection program will no longer supplement the Closed Cooling Water Chemistry program.

3. The Closed Cooling Water Chemistry Program will be enhanced to ensure that a representative sample of piping and components will be inspected on a 10-year interval, with the first inspection taking place prior to entering the period of extended operation.

LRA Table A-1 is revised to include the enhancement as a new license renewal future commitment.

See the Enclosure to this letter for the revision to the DBNPS LRA.

Question RAI B.2.10-1 Standard Review Plan (SRP)-LR Rev. 2, Table 3.0-1, provides the recommended FSAR Supplement Description for GALL AMP XI.M23, "Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems." The SRP-LR recommends the following wording: "The number and magnitude of lifts made by the hoist or crane are also reviewed."

The Davis-Besse LRA Updated Safety Analysis Report Supplement Section A.1.10, "Cranes and Hoists Inspection Program" description does not address a review of the number and magnitude of lifts made by a hoist or crane.

Attachment A L-11-153 Page 32 of 44 Update the UFSAR Supplement wording to reflect the fact that the Cranes and Hoists Inspection Program includes a review of the number and magnitude of lifts made by a hoist or crane.

RESPONSE RAI B.2.10-1 LRA Sections A.1.10 and B.2.10, both titled "Cranes and Hoists Inspection Program,"

are revised to include the following sentence:

The program includes a review of the number and magnitude of lifts made by a crane, monorail or hoist.

See the Enclosure to this letter for the revision to the DBNPS LRA.

Question RAI B.2.10-2 GALL AMP XI.M23, "Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems," scope of program states that this program manages the effect of loss of preload of bolted connections. Bolted connections are also addressed in elements 3, 4, and 10 of this AMP.

During the audit, the staff reviewed the applicant's B.2.10 Cranes and Hoists Inspection Program and its references and found that although loss of preload of bolted connections for cranes and hoists is addressed in the program inspections and preventive maintenance procedures, it is not included in the LRA program description or other program elements nor are there any AMR line items addressing a loss of preload of bolted connections for overhead cranes and hoists.

The staff requests the following information:

1. If the Cranes and Hoist Inspection AMP is intended to be used to manage a loss of preload for bolted connections of cranes and hoists, revise the LRA and associated programs elements to reflect this.

2. Clarify why crane and hoist program inspections and preventive maintenance procedures discuss loss of preload as an aging effect despite the fact that there are currently no AMR line items related to a loss of preload for bolted connections for overhead cranes and hoists.

Attachment A L-11-153 Page 33 of 44 RESPONSE RAI B.2.10-2 FENOC provides the following new license renewal future commitment regarding management of loss of preload for bolted connections of cranes (including bridge, trolley, rails, and girders), monorails, and hoists within the scope of license renewal, in LRA Appendix A, "Updated Safety Analysis Report Supplement," Table A-i, "Davis-Besse License Renewal Commitments:"

Enhance the Cranes and Hoists Inspection Program to:

Include visual inspections for loose bolts and missing or loose nuts in crane, monorail and hoist inspection procedures at the same frequency as inspections of rails and structural components.

This enhancement will be implemented prior to entering the period of extended operation.

The following LRA sections are affected by the addition of loss of preload management for cranes, monorails and hoists and are revised accordingly:

• Table 2.4-13

• *Table 3.3.1

• Section 3.5.2.1.13

• Table 3.5.2-13

• Section A.1.10

• Table A-1

• Section B.2.10 See the Enclosure to this letter for the revision to the DBNPS LRA.

Question RAI B.2.18-1 GALL AMP XI.M27, "Fire Water System," states in the "scope of program" element that the Fire Water System Program manages loss of material due to corrosion, MIC or biofouling, and includes flow testing, visual inspections, and non-intrusive examinations to detect these aging effects. LRA Section B.2.18 states that the applicant's Fire Water Program will manage loss of material as well as cracking of susceptible materials. The applicant's program basis documents state that cracking due to stress corrosion cracking of copper alloy (greater than 15 percent zinc) will be managed by the same testing and inspection activities that identify and manage the loss of material. The staff noted that flow tests and visual inspections are not industry-accepted methods to detect cracking.

Attachment A L-11-153 Page 34 of 44 It is unclear to the staff what technique the applicant plans to use in its Fire Water System Program that will adequately manage cracking of susceptible copper alloy (greater than 15 percent zinc) components.

In light of the fact that flow tests and visual inspections are not industry accepted methods to detect cracking, provide additional information regarding the technique to be used to detect cracking of copper alloy (greater than 15 percent zinc) fire water system components.

RESPONSE RAI B.2.18-1 The aging management review for the Davis-Besse Fire Protection System was conducted with the guidance provided in EPRI Technical Report 1010639, "Non-Class 1 Mechanical Implementation Guideline and Mechanical Tools," Revision 4 (the Mechanical Tools). In accordance with the Mechanical Tools, cracking due to stress corrosion cracking (SCC) is an aging effect requiring evaluation for copper and copper alloys exposed to a raw water environment. The relevant conditions (mechanism applicability criteria) required for cracking of copper alloys to occur are that

1) susceptible materials contain greater than 15% zinc or greater than 8% aluminum (aluminum bronze), and 2) the raw water environment contains ammonia or ammonium salts.

For the susceptible components of the Fire Protection System (spray nozzles, strainer screens, and valve bodies), the absence of ammonia in the raw water environment (resulting primarily from organic decay in Lake Erie) could not be verified, and the Mechanical Tools do not specify.a threshold concentration of ammonia below which cracking would not be a concern. Therefore, the aging management review determined that cracking due to SCC is an aging effect requiring management.

However, the conclusion drawn from a review of industry and plant-specific operating experience is that cracking of copper alloy components due to SCC is not expected to occur in a raw water environment. And, though the Mechanical Tools include no threshold in the applicability criteria, the technical references upon which the Mechanical Tools are based cite instances of cracking of copper alloys only when they are exposed to aqueous solutions of ammonia or to vaporous ammonia concentrating in moist environments, and not to the trace amounts of ammonia that might be present in natural fresh water environments, such as lakes and rivers.

The Davis-Besse One-Time Inspection, as described in LRA Section B.2.30, is used to address situations where an aging effect is not expected to occur, but there is insufficient data to completely rule it out. Therefore, LRA Section B.2.30 and Table A-i, Commitment 13, are revised to include a program enhancement to perform enhanced visual and/or volumetric inspections prior to entering the period of extended operation to detect and characterize cracking of copper alloy > 15% zinc exposed to raw water. The

Attachment A L-11-153 Page 35 of 44 one-time inspections will provide direct evidence as to whether, and to what extent, cracking has occurred. Cracking of copper alloy > 15% zinc exposed to raw water is not addressed by another aging management program. The LRA Fire Water Program is revised to remove cracking as an aging effect that is managed.

See the Enclosure.to this letter for the revision to the DBNPS LRA.

Question RAI B.2.24-1 GALL AMP XI.M1 states that the components described in Subsections IWB-1220, IWC-1220, and IWD-1220 are exempt from the volumetric and surface examination requirements, but not exempt from visual exam requirements of ASME Code Section Xl, Subsections IWB-2500, IWC-2500, and IWD-2500.

During its audit, the staff noted that the applicant's program basis document for the Inservice Inspection Program states that the components described in ASME Section XI Subsections IWB-1 220, IWC-1 220, and IWD-1 220 are exempt from the examination requirements of Subsections IWB-2500, IWC-2500, and IWD-2500 per the Third Ten-Year Inservice Inspection Program Plan.

Based on the applicant's program basis document, the Third Ten-Year Inservice Inspection Program exempts visual inspection for components described in ASME Section XI Subsections IWB-1220, IWC-1220, and IWD-1220, which is not consistent with the recommendations in the GALL Report. The staff also noted that the applicant did not provide an "exception" to GALL AMP XI.M1, with sufficient justification, for exempting visual inspections of the components described above.

Clarify if the components described in ASME Section XI Subsections IWB-1220, IWC-1220, and IWD-1220 are exempt from the visual inspections requirements of Subsections IWB-2500, IWC-2500, and IWD-2500. Provide sufficient justification for this "exception" to the recommendations of GALL AMP XI.M1 which requires visual examinations of the components described in ASME Section XI Subsections IWB-1220, IWC-1220, and IWD-1220. If these components are not exempt from GALL AMP XI.M1, provide sufficient information demonstrating that visual inspections are conducted for these components.

RESPONSE RAI B.2.24-1 As provided in LRA Section B.2.24, "Inservice Inspection Program," the applicable ASME Code for the current (third) ten year inspection interval for Davis-Besse is ASME Section XI, 1995 Edition, through the 1996 Addenda, as modified by 10 CFR 50.55a or relief granted in accordance with 10 CFR 50.55a. In addition, the Inservice Inspection

Attachment A L-11-153 Page 36 of 44 Program meets the inservice inspection requirements specified by the ASME B&PV Code,Section XI, as modified by 10 CFR 50.55a. In accordance with the requirements of ASME Section Xl, 1995 Edition through 1996, components described in Subsections IWB-1220 and IWC-1220 are exempted from the volumetric and surface examination requirements of IWB-2500 and IWC-2500. In addition, components described in Subsection IWD-1220 are exempted from the VT-1 visual examination requirements of IWD-2500.

However, the Davis-Besse program basis document for the Inservice Inspection Program was not clear in that it did not specify the type of examinations and therefore, requires a change. The Davis-Besse program basis document for the Inservice Inspection Program is revised to read as follows:

In accordance with the requirements of ASME Section Xl, 1995 Edition through 1996, components described in Subsections IWB-1220 and IWC-1220 are exempted from the volumetric and surface examination requirements of IWB-2500 and IWC-2500. In addition, components described in Subsection IWD-1220 are exempted from the VT-1 visual examination requirements of IWD-2500.

No revision to the LRA is required.

Question RAI B.2.31-1 GALL AMP XI.M20, "Open-Cycle Cooling Water System," states that this program addresses the aging effects of loss of material, fouling due to micro-or macro-organisms, and various corrosion mechanisms generally found in the open cycle cooling water system. The GALL Report AMP does not address cracking, and although it was not identified as an exception or enhancement; the LRA states that copper alloy (with greater than 15 percent zinc) will be managed for cracking by the Open-Cycle Cooling Water Program. The LRA also states that the program consists of inspections, surveillances, and testing to detect and evaluate aging effects including cracking, and it is combined with chemical treatments and cleaning activities to minimize aging effects including cracking.

The LRA does not describe the inspection, surveillance, or testing method(s) that will be used to detect and evaluate cracking of the copper alloy (with greater than 15 percent zinc) components exposed to open cycle cooling water. In addition, the LRA does not describe the chemical treatments and cleaning activities that will be used to minimize cracking.

The staff requests the following information:

1) Describe the aging management activities in the Open-Cycle Cooling Water Program that will be used to manage cracking of the copper alloy

Attachment A L-11-153 Page 37 of 44 (with greater than 15 percent zinc) components with greater than 15 percent zinc that are exposed to raw water.

2) If the Open-Cycle Cooling Water Program will remain, the program used to manage cracking of copper alloy (with greater than 15 percent zinc) components, then the LRA should be updated to reflect this as an exception to GALL AMP XI.M20.

RESPONSE RAI B.2.31-1

1) LRA Sections A.1.31 and B.2.31, both titled "Open-Cycle Cooling Water Program,"

are revised to delete cracking of copper alloy > 15% zinc components that are exposed to raw water as an aging effect managed by the program.

2) The Open-Cycle Cooling Water Program is no longer credited to manage cracking of copper alloy > 15% zinc components. The One-Time Inspection will be used to manage cracking of the copper alloy > 15% zinc components exposed to raw water.

See the Enclosure to this letter for the revision to the DBNPS LRA.

Question RAI B.2.33-1 The GALL AMP XI.M2, "Water Chemistry," states in program element 3, "Parameters Monitored/Inspected," that the applicant should utilize the EPRI water chemistry guidelines to determine the concentrations of corrosive impurities monitored to mitigate loss of material, cracking, and reduction in heat transfer. The GALL AMP XI.M2 Program Description references EPRI 1016555 (PWR Secondary Water Chemistry Guidelines -Revision 7). The applicant's basis document states that its pressure water reactor (PWR) Water Chemistry Program is consistent with the Revision 5 of the EPRI guidelines concerning secondary water chemistry. The applicant's basis documents further states that the program is periodically updated to the latest guidelines. The applicant's 2009 self-assessment of its secondary water chemistry guidelines states that program documents should be revised based on the EPRI Revision 7 document on PWR Secondary Water Chemistry.

It appears to the staff that the applicant's Water Chemistry Program implementing procedures and basis documents have not been updated to reflect the updated EPRI PWR Secondary Water Chemistry Guidelines, Revision 7, despite the information in the Program Description for GALL AMP XI.M2 and despite the recommendations from the applicant's own 2009 self-assessment of its secondary water chemistry guidelines. Clarify if and/or when the Water Chemistry Program implementing procedures and basis documents will be updated to

Attachment A L-11-153 Page 38 of 44 reflect the requirements of EPRI's PWR Secondary Water Chemistry Guidelines, Revision 7. If these procedures and documents will not be updated, provide a justification supporting the continued use of Revision 5 of EPRI's PWR Secondary Water Chemistry Guidelines as it relates to determining the concentrations of corrosive impurities monitored to mitigate loss of material, cracking, and reduction in heat transfer.

RESPONSE RAI B.2.33-1 The Davis-Besse August 2009 self-assessment performed a comparison of Revision 7 of EPRI 1016555, "Pressurized Water Reactor Secondary Water Chemistry Guidelines," issued February 2009, against the applicable Davis-Besse secondary water chemistry implementing procedures. The Davis-Besse implementing procedure that establishes the operational chemical control limits was revised, effective August 2009, for alignment with Revision 7 of EPRI 1016555. In addition, the self-assessment determined that the Davis-Besse secondary chemistry strategic water plan contained the necessary elements as described in Chapter 4 of EPRI 1016555. However, the self-assessment recommended that some clarifications and table format changes should be made to be more in-line with the examples provided in Chapter 4 of EPRI 1016555. The Davis-Besse secondary chemistry strategic water plan was revised, effective June 2010, to incorporate the recommendations.

In addition, the License Renewal basis document for the program evaluation of the Davis-Besse PWR Water Chemistry Program was revised to address the updated secondary water chemistry procedures and Revision 7 of EPRI 1016555.

The Program Description of LRA Section B.2.33, "PWR Water Chemistry Program," is revised to reference Revision 7 of EPRI 1016555, "Pressurized Water Reactor Secondary Water Chemistry Guidelines."

See the Enclosure to this letter for the revision to the DBNPS LRA.

Question RAI B.2.36-1 Because selective leaching is a slow acting corrosion process, the "detection of aging effects" program element of GALL AMP XI.M33, "Selective Leaching,"

recommends the inspection be conducted within the last five years prior to the period of extended operation. LRA Section B.2.36 states that selective leaching inspection activities will be conducted "before the beginning of the period of extended operation."

The description of the timing of the performance of selective leaching inspections in LRA Section B.2.36 does not ensure these inspections will be conducted within

Attachment A L-11-153 Page 39 of 44 the last five years prior to the period of extended operation, as suggested GALL AMP XI.M33.

The staff requests the following information:

1. In light of the fact that selective leaching is a slow acting process, clarify the planned timing of the conduct of selective leaching inspections relative to the beginning of the period of extended operation.

2. Revise LRA Appendix A, "Updated Safety Analysis Report Supplement,"

Section A.1.36, "Selective Leaching Inspection," to reflect the fact that inspections required by this program will be conducted within the last five years prior to the period of extended operation.

RESPONSE RAI B.2.36-1

1. The selective leaching inspections will be performed within the five years prior to entering the period of extended operation.

2. LRA Section A.1.36, "Selective Leaching Inspection," is revised tostate that inspections required by this program will be conducted within the five years prior to entering the period of extended operation.

See the Enclosure to this letter for the revision to the DBNPS LRA.

Question RAI B.2.36-2 The "detection of aging effects" program element of GALL AMP XI.M33, "Selective Leaching," recommends that the inspection includes a representative sample (e.g., 20 percent of the population with a maximum sample of 25) of the system population with focus on the components most susceptible to aging due to time in service, severity of operating conditions, and lowest design margin.

Otherwise, a technical justification of the methodology and sample size used for selecting components should be included as part of the program's documentation. LRA Section B.2.36 states that the selective leaching inspection activities include determination of the sample size based on an assessment of materials of fabrication, environment/conditions, time in service, and operating experience, as well as identification of the inspection locations in the susceptible system or component.

It is not clear to the staff whether the extent and scope of the selective leaching inspection activities are consistent with the GALL AMP XI.M33 recommendation.

Attachment A L-11-153 Page 40 of 44 The staff requests the following information:

1. Revise LRA Section B.2.36 to indicate that a representative sample (e.g., 20 percent of the population with a maximum sample of 25) of the system population will be selected for inspection to demonstrate the absence of selective leaching.

2. Describe the methodology used to ensure the representative sample focuses on the components most susceptible to aging due to time in service, severity of operating conditions, and lowest design margin.

3. As an alternative to Requests I and 2 above, update LRA Section B.2.36 to include a technical justification for the methodology and sample size used for selecting components.

RESPONSE RAI B.2.36-2 The "detection of aging effects" program element of LRA Section B.2.36, "Selective Leaching Inspection," is revised to state the inspection includes a representative sample of the system population and focuses on the bounding or lead components most susceptible to aging due to time in service, severity of operating conditions, and lowest design margin. Twenty percent of the population with a maximum sample of 25 constitutes a representative sample size.

See the Enclosure to this letter for the revision to the DBNPS LRA.

Question RAI B.2.36-3 SRP Section A.1.2.3.10.3 states that the applicant should commit to a review of future plant-specific and industry operating experience for new programs to confirm their effectiveness. LRA Section B.2.36 describes the Selective Leaching Inspection Program as a new one-time inspection that will be consistent with the 10 elements of an effective aging management program as described in NUREG-1801. LRA Section B.2.36 also states that a review of Davis-Besse operating experience did not identify any instances of loss of material due to selective leaching, graphitization, or dezincification for any in-scope components.

The "operating experience" program element of LRA Section B.2.36 does not include substantive operating experience examples confirming the effectiveness of the new Selective Leaching Inspection Program nor does the applicant otherwise commit to a review of future plant-specific and industry operating experience to confirm the program's effectiveness.

Attachment A L-11-153 Page 41 of 44 Revise LRA Table A-1, "Davis-Besse License Renewal Commitments," Item 18, to include the performance of a review of future plant-specific and industry operating experience to confirm the effectiveness of the new Selective Leaching Inspection Program.

RESPONSE RAI B.2.36-3 The Selective Leaching Inspection Program does not manage an aging effect; rather, the inspection confirms the absence of an aging effect. The program does not consist of ongoing activities, but will end upon completion of one-time inspections of the sample set of components. Therefore, a future confirmation of program effectiveness is not applicable to the Selective Leaching Inspection. If plant-specific operating experience indicates the potential for selective leaching after program completion, it will be addressed using the Corrective Action Program.

Question RAI B.2.37-1 GALL AMP XI.M35 states that the program is applicable to systems that have not experienced cracking of ASME Code Class 1 small-bore piping. This program can also be used for systems that experienced cracking but have implemented design changes to effectively mitigate cracking. For systems that have experienced cracking and operating experience indicate that design changes have not been implemented to effectively mitigate cracking, periodic inspection is proposed, as managed by a plant-specific AMP.

The applicant stated in LRA Section B.2.37, "Small Bore Class 1 Piping Inspection Program," that two instances of small bore piping cracking related-to stress corrosion cracking have been identified at Davis-Besse. The staff noted that, since the applicant has plant-specific operating experience for cracking in its small-bore piping at its site, a one-time inspection program may not be applicable.

Based on the plant-specific operating experience, justify the use of a one-time inspection program to manage cracking in ASME Code Class 1 small-bore piping.

Otherwise, in lieu of a justification, provide a plant-specific program to perform periodic inspections of ASME Code Class I small-bore piping.

Attachment A L-11-153 Page 42 of 44 RESPONSE RAI B.2.37-1 Davis-Besse, with over 30 years of operating experience, has experienced two instances of cracking of small bore Class 1 piping, and in both cases, design changes were implemented to effectively mitigate the cracking. Therefore, the one-time inspection is applicable to Davis-Besse.

The first instance of cracking due to stress corrosion cracking was found in the reactor vessel closure gasket leakage monitoring line. It was determined that the stress corrosion cracking was promoted by chlorides left after water evaporated in the line.

The issue was evaluated using the Corrective Action Program and it was determined that these lines are not indicative of other small bore piping. The affected piping was replaced and the procedure was changed to require draining of the line after use.

The second instance of cracking was an axial indication found on the RCS Loop 1 cold leg drain line 1-1 nozzle-to elbow weld (dissimilar metal weld) during the Cycle 14 refueling outage. The probable cause is extensive localized weld repair during initial construction. This repair either resulted in a latent flaw or a crack initiation site. The residual stresses from the construction weld repair, combined with the environment in the reactor coolant system and the susceptibility of Alloy 600 material, established the presence of the three key elements for the development of primary water stress corrosion cracking in spite of the low susceptibility in cold leg drain lines. This cracking was due to an event (local weld repair) and is not indicative of general aging in small bore lines. Corrective action during the Cycle 14 refueling outage included a full structural weld overlay repair of the subject dissimilar metal weld (Alloy 82/182 weld).

During the Cycle 16 refueling outage, full structural weld overlays were installed for the other equivalent dissimilar metal welds in RCS Cold Leg Drain lines 1-2, 2-1 and 2-2 to preemptively mitigate primary water stress corrosion cracking (PWSCC). As provided in LRA Section B.2.28, the Nickel-Alloy Management Program manages PWSCC and stress corrosion cracking / intergranular attack (SCC/IGA) for nickel-alloy pressure boundary components, other than reactor vessel closure head nozzles and steam generator tubes, exposed to reactor coolant.

LRA Sections A.1.37 and B.2.37, both titled "Small Bore Class 1 Piping Inspection," are revised to include the above discussion as appropriate.

See the Enclosure to this letter for the revision to the DBNPS LRA.

Question RAI B.2.37-2 LRA Section B.2.37, "Small Bore Class 1 Piping Inspection Program," states that the program will be implemented "prior to period of extended operation." In addition, Commitment No. 19 in LRA Table A-1 states that this program will be implemented on April 22, 2017. However, GALL AMP XI.M35 states that the one-time inspection should be completed within the six-year period prior to the period

Attachment A L-11-153 Page 43 of 44 of extended operation. The specified six-year time frame is to ensure timely completion of the inspections and to allow a more realistic assessment of material conditions prior to entering the period of extended operation.

Based on LRA Section B.2.37, it is not clear to the staff when the applicant's Small Bore Class 1 Piping Inspection Program will be implemented at this site, and if this implementation of the program is consistent with the recommendations of GALL AMP XI.M35 which requires the completion of the one-time inspections within the six-year period prior to the period of extended operation.

Clarify the implementation schedule of the one-time inspections to be performed by the Small Bore Class 1 Piping Inspection Program. If the implementation schedule is not consistent with the recommendations in GALL AMP XI.M35, justify why the one-time inspections do not need to be completed within the six-year period prior to the period of extended operation. Amend the LRA and Commitment No.19, as needed, in response to this RAI.

RESPONSE RAI B.2.37-2 LRA Table A-i, Commitment 19, is revised to show the implementation schedule as "Completed within the six year period prior to April 22, 2017." In addition, the "Program Description" and the "Detection of Aging Effects" program element for LRA Section B.2.37 are revised to include the following:

The Small Bore Class 1 Piping Inspection is a new one-time inspection that will be completed within the six year period prior to entering the period of extended operation.

See the Enclosure to this letter for the revision to the DBNPS LRA.

Question RAI B.2.37-3 GALL AMP XI.M35 provides specific guidance regarding small bore piping inspection sampling. LRA Section B.2.37, "Small Bore Class 1 Piping Inspection Program," states that the program will perform volumetric examinations of a representative sample of small bore piping locations that are susceptible to cracking.

The staff noted that the applicant has not provided specific information regarding the small bore piping weld population, or the inspection sampling size. This information is needed to evaluate consistency of the applicant's program with the recommendations of GALL AMP XI.M35.

Attachment A L-1 1-153 Page 44 of 44 Clarify the total population of Class 1 small bore butt welds and socket welds such that the sample size is described as a percentage of welds for each type. In addition, justify the adequacy of the sampling methodology in the Small Bore Class 1 Piping Inspection Program if the percentage is less than the sampling guidelines, as described in GALL AMP XI.M35.

RESPONSE RAI B.2.37-3 The Davis-Besse Small Bore Class 1 Piping Inspection will consist of volumetric examination of a statistically significant sample of small bore piping locations (full penetration welds and socket welds) that are susceptible to cracking. Location selection will be based on susceptibility, inspectability, dose considerations, operating experience, and limiting locations of the total population of ASME Code Class 1 small bore piping (less than NPS 4 and greater than or equal to NPS 1). A statistically significant sample size will consist of 10% of the weld population or a maximum of 25 welds of each weld type (e.g., full penetration or socket weld) using a methodology to select the most susceptible and risk-significant welds. For socket welds, opportunistic destructive examination may be performed in lieu of volumetric examination. Because more information can be obtained from a destructive examination than from nondestructive examination, each destructive examination will be considered equivalent to having volumetrically examined two welds. The ASME Code Class 1 piping weld population (less than NPS 4 and greater than or equal to NPS 1) for Davis-Besse consist of approximately 179 full penetration welds and 437 partial penetration (socket) welds.

LRA Sections A.1.37 and B.2.37 are revised to include the above discussion as appropriate.

See the Enclosure to this letter for the revision to the DBNPS LRA.

Attachment B L-11-153 Reply to Request for Additional Information for the Review of the Davis-Besse Nuclear Power Station, Unit No. 1 (DBNPS), License Renewal Application, Batch. 1 Section B.2 Page 1 of 28 Section B.2 Question RAI B.2.22-1 GALL AMP XI.S1, "ASME Section Xl, Subsection IWE," element 6, recommends that the areas that are found to be suspect during visual examination require an engineering evaluation or require correction by repair or replacement.

During the AMP audit at DBNPS, the staff interviewed the applicant staff and reviewed documentation about the ground water seepage in different plant structures. The staff found that there is history of ground water infiltration into the annular space between the concrete shield building and steel containment.

During the audit, the staff also reviewed documentation (CR 10-72660) that indicated the presence of standing water in the annulus sand pocket region. The standing water appears to be a recurring issue of ground water leakage and areas of corrosion were observed on the containment vessel. In addition, during the audit the staff reviewed photographs that indicate peeling of clear coat on the containment vessel annulus area, and degradation of the moisture barrier, concrete grout, and sealant in the annulus area that were installed in 2002-2003.

The staff requests the following information:

1. Plans and schedule to perform nondestructive examinations, such as ultrasonic testing (UT) of the steel containment in the sand pocket region including the area below and above the grout.

2. The condition of the drains located in the sand pocket region, and if the water exiting from these drains is monitored.

3. Plans and schedule to remove/replace/repair degraded grout, moisture barrier, and sealant.

4. Corrosion rate in the inaccessible area of the steel containment that can be reasonably inferred from UT examinations or from representative samples in similar operating conditions, materials, and environments.

Attachment B L-11-153 Page 2 of 28

5. Using the established corrosion rate, demonstrate that the steel containment will have sufficient thickness to perform its intended function through the PEO.

RESPONSE RAI B.2.22-1

1. FirstEnergy Nuclear Operating Company (FENOC) plans to perform nondestructive testing (NDT) of the steel containment in the sand pocket region and complete the evaluation of the NDT results prior to entering the period of extended operation.

FENOC plans to perform NDT at a minimum of three representative locations. At each location FENOC plans to include the areas below and above the grout. Based on the NDT results, FENOC will use the Corrective Action Program to evaluate the need for and frequency of future NDT to monitor the extent of aging of the steel containment in the sand pocket region for areas where water seepage is identified.

2. The drains located in the sand pocket region are functional. The water exiting from the drains is not monitored locally.

3. FENOC plans to continue to minimize water seepage into the sand pocket area by continuing to inspect and maintain the accessible materials in the annulus sand pocket area. FENOC plans to inspect the annulus sand pocket area during each plant refueling outage when the annulus is accessible. FENOC plans to continue to maintain the accessible materials in the annulus so as to continue to direct water seepage away from the grout-containment vessel interface.

4. FENOC had a thorough containment vessel corrosion evaluation conducted in July of 2002. The report of that evaluation concluded that the integrity of the containment vessel will be maintained with negligible additional corrosion in the future. The planned NDT described in the response to item 1 above will confirm the conclusion stated in the report of the 2002 evaluation.

5. The planned NDT-described in the response to item 1 above will determine the current steel containment thickness. The actual thickness will be evaluated to ensure that the steel containment will have sufficient thickness to perform its intended function through the period of extended operation, or the FENOC Corrective Action Program will be used to identify and track remedial actions.

LRA Table A-i, "Davis-Besse License Renewal Commitments," is revised to include new license renewal future commitments for the responses to items 1 and 3, above.

See the Enclosure to this letter for the revision to the DBNPS LRA.

Attachment B L-11-153.

Page 3 of 28 Question RAI B.2.22-2 GALL AMP XI.S1, "ASME Section XI, Subsection IWE," element 1, states that 10 CFR 50.55a(b) (2)(ix) specifies additional inspection requirements for inaccessible areas. It states that the licensee is to evaluate the acceptability of inaccessible areas when conditions exist in accessible areas that could indicate the presence of or result in degradation to such inaccessible areas.

During the site audit, the NRC staff reviewed documentation that indicated borated water leakage into the East/West and Incore instrumentation tunnels from the refueling cavity. The borated water leaks from the reactor cavity floor through the construction joint at the base of 4-foot thick East/West tunnel wall (elevation 550'-6"). The borated water has degraded the concrete wall coating, and corroded the conduits, piping, and supports in the East/West tunnel and Incore instrumentation tunnel.

There are approximately 2 feet of concrete between the reactor cavity floor and steel containment. Based on the observed leakage from a 4-foot thick wall, it is likely that borated water has also leaked on the top embedded steel containment and may cause its degradation/corrosion.

Provide details of actions planned to examine the inaccessible portion of the steel containment. Specifically, provide details of any plans to remove concrete at the bottom of normal sump (approximate elevation 536) to expose and inspect steel containment for degradation. In addition, provide details and plans for a study to determine the effect of the loss of thickness in the steel containment due to exposure to borated water over the PEO. The study should also address the potential of borated Water flowing on top of the steel containment and leaking through the concrete into the normal sump. The staff needs this information to verify that the effects of aging on the intended function of the steel containment plate will be adequately managed for the PEO.

RESPONSE RAI B.2.22-2 Prior to entering the period of extended operation, FENOC plans to access the inside surface of the embedded steel containment. Access will allow verification of whether or not borated water has come in contact with the steel containment vessel. If there is evidence of the presence of borated water in contact with the steel containment vessel,.

then FENOC will conduct non-destructive testing to determine what effect, if any, -the borated water has had on the steel containment vessel. If there is evidence that borated water has. come in contact with the steel containment vessel, then FENOC will perform a study to determine the effect through the period of extended operation of the loss of thickness in the steel containment due to exposure to borated water. LRA Table A-i,

Attachment B L-11-153 Page 4 of 28 "Davis-Besse License Renewal Commitments," is revised to include this information as a new license renewal future commitment.

See the Enclosure to this letter for the revision to the DBNPS LRA.

Question RAI B.2.22-3 GALL AMP XI.S1, "ASME Section Xl, Subsection IWE," element 10, recommends that steel containment corrosion concerns described in the NRC generic communications should be considered. In addition, GALL AMP XI.S1 states that ASME Section Xl, Subsection IWE requires examination of coatings that are intended to prevent corrosion.

It is not clear from the review of the LRA if the applicant's ASME Section XI, IWE AMP requires examination of coatings that are intended to prevent corrosion.

Please clarify if the ASME Section Xl, IWE AMP inspects and credits coating on the inside surface of the steel containment for corrosion protection.

RESPONSE RAI B.2.22-3 The steel Containment Vessel is inspected by the Inservice Inspection (ISI)

Program - IWE in accordance with GALL AMP XI.S1, "ASME Section XI, Subsection IWE." The program does inspect surfaces that are coated, but the coating is not credited for corrosion protection as part of the aging management review (AMR).

However, degradation of the protective coating is indicative of a location for corrosion of the underlying metal. The acceptance criteria for flaws found during the inspection are in accordance with IWE-3000, specifically IWE-3510 for Containment surfaces.

IWE-3510.2 of the 1995 Edition through 1996 Addenda of American Society of Mechanical Engineers (ASME)Section XI states that the inspected area, when painted or coated, shall be examined for evidence of flaking, blistering, peeling, discoloration, and other signs of distress and that areas that are suspect shall be accepted by engineering evaluation or corrected by repair or replacement.

Question RAI B.2.22-4 DBNPS LRA Section 4.6.2 states a search of the DBNPS current licensing basis did not identify any pressurization cycles or fatigue analyses for containment penetration assemblies.

Attachment B L-11-153 Page 5 of 28 Containment piping penetration sleeves examination is included in the scope of the GALL AMP XI.S1 ASME Section XI, Subsection IWE. In addition, DBNPS steel penetration sleeves, dissimilar metal welds, bellows, and steel components are subject to cyclic loading during plant operation. In absence of a fatigue analysis, these components are required to be monitored for cracking. It is not clear to the staff if steel penetration sleeves, dissimilar metal welds, and steel components are included in the scope of the program and monitored for cracking.

Please clarify if the ASME Section Xl, IWE AMP monitors steel penetration sleeves, dissimilar metal welds, bellows, and steel components for cracking due to cyclic loading.

RESPONSE RAI B.2.22-4 In accordance with 10 CFR 50.55a(b)(2)(ix), the examinations of the Category E-B pressure retaining welds and Category E-F pressure retaining dissimilar metal welds are not scheduled since these examinations are optional. However, the Inservice Inspection (ISI) - IWE Program does include the Category E-A examinations of Containment surfaces. Additionally, the 10 CFR Part 50, Appendix J Program detects evidence of leakage as part of the Category E-P examinations. These examinations monitor for cracking. Examination results that do not meet the acceptance standards identified in Table IWE-2500-1 are accepted by repair, replacement, or engineering evaluation. When an engineering evaluation is used to accept examination results, the area containing the flaw or degradation is placed into Examination Category E-C and examined in accordance with its requirements. When examination results do not meet the acceptance standards identified in Table IWE-2500-1, additional examinations are conducted in accordance with IWE-2430.

Question RAI B.2.23-1 GALL AMP XI.S3, "ASME Section XI, Subsection IWF," element 5, "monitoring and trending," states that for IWF examinations of component supports, if a component's present condition is discovered to be different from its previous condition identified in prior examination, such changes in condition should be documented in accordance with ASME IWA-6230. The staff reviewed program element 5, "monitoring and trending," of the DBNPS in-service inspection (ISI) program -IWF basis documents and did not identify a reference to ASME IWA-6230 for documenting newly discovered changes in condition.

Attachment'B L-11-153 Page 6 of 28 Provide information on the procedure by which changes in condition are documented in the IWF program in accordance with the provisions of ASME IWA-6230. If changes in condition are not currently being documented, explain how changes of condition from prior examination will be documented as part of the IWF AMP in accordance with ASME IWA-6230.

RESPONSE RAI B.2.23-1 The Davis-Besse Administrative Procedure for the Inservice Inspection (ISI) Program specifies that a Summary Report shall be created in accordance with the requirements of American Society of Mechanical Engineers (ASME) Section Xl, article IWA-6000, which includes paragraph IWA-6230.

As indicated in LRA Section B.2.23 and in the Davis-Besse Administrative Procedure for the Inservice Inspection (ISI) Program, the Davis-Besse Inservice Inspection (ISI)

Program - IWF is in accordance with the requirements of the ASME Code,Section XI, 1995 Edition through the 1996 Addenda. Therefore, in accordance with the Davis-Besse Administrative Procedure for the Inservice Inspection (ISI) Program, verified changes of conditions from prior Inservice Inspection (ISI) Program - IWF examinations, are documented as part of the ISI Program in accordance with ASME Section XI paragraph IWA-6230.

Question RAI B.2.25-1 SRP-LR Section A.1.2.3.1 and Table A.1, state that the "scope of program,"

program element should include the specific structures and components of which the program manages the aging. In LRA B.2.25 the applicant states that the Leak Chase Program will monitor borated water leakage from the spent fuel pool, the fuel transfer pit, and the cask pit stainless steel liners due to age-related degradation. In its "scope of program," program element, the LRA states that the Leak Chase Monitoring Program is credited with detecting loss of material in the liners and further focuses the program on the integrity of the liner welds. In its "operating experience," program element, the LRA reviews the impact the leakage had on the leak chase system (channels, valve bodies, etc.) and on the contiguous concrete structures. It also states that borated water is evidenced in the Auxiliary Building but there are no concerns regarding the strength or integrity of the-concrete structure. The same program element discusses monitoring of the tell-tale drains and the effort made to unclog the drains. Finally, LRA Table 3.5.2-2, titled "Aging Management Review Results -Auxiliary Building,"

identifies three programs to manage the aging effects of the spent fuel pool liner:

Attachment B L-11-153 Page 7 of 28 the PWR Water Chemistry Program, the Davis-Besse Tech Specs, and the Leak Chase Program.

It is not clear to the staff the extent of the scope of the Leak Chase Program. LRA Section B.2.25 discusses not only monitoring of borated water leakages but also monitoring and detection of aging effects for the leak chase system, its components, and the associated concrete structures.

Identify the full scope of the program. Does the AMP track only the borated water leakages or does it also expand to manage aging effects for the entire leak chase system, including its materials, components, and structures exposed to borated water? If the program includes components of the leak chase system, where in the AMR Results Tables does the applicant address the management of aging effects for the wall/floor channels, tubes, trenches, and valve casings?

RESPONSE RAI B.2.25-1 FENOC credits the Leak Chase Monitoring Program with management of loss of material for the spent fuel pit liner, cask pit liner and fuel transfer pit liner, as described in LRA Table 3.5.2-2, "Aging Management Review Results - Auxiliary Building," rows 8, 14 and 28, and LRA Section B.2.25, "Leak Chase Monitoring Program," "Scope" element. The program does not manage aging effects for the leak chase system. The leak chase channels are carbon steel, stitch-welded to the vertical liner plates. The liner plates, with the leak chase channels attached, were used as formwork for pouring the concrete walls of the spent fuel pool. Therefore, the leak chase channels are embedded in concrete and are considered carbon steel embedments, which are structural bulk commodities as shown on rows 1 and 2 of LRA Table 3.5.2-13, "Aging Management Review Results - Bulk Commodities." The collector tubes are assumed to be carbon steel and are considered bulk commodities for the same reason as are the leak chase channels. As stated in LRA Section B.2.25, the purpose of the program is to monitor leakage of the liners. The piping and valves correspond to stainless steel piping and valves in the Spent Fuel Pool Cooling and Cleanup System, managed by the PWR Water Chemistry Program and One-Time Inspection, and the cask pit, fuel transfer pit and spent fuel pit concrete structures, which includes the unlined trenches, are presented in LRA Table 3.5.2-2, managed by the Structures Monitoring Program.

Operating experience was provided in the LRA to describe relevant history related to the program, not to define the program scope.

Attachment B L-11-153 Page 8 of 28 Question RAI B.2.25-2 SRP-LR Section A.1.2.3.3 and Table A.1-1, state that the "parameters monitored or inspected," program element recommends the identified parameters to be linked to the degradation of the particular structures and components intended function(s). For a condition monitoring program, the parameters monitored or inspected should detect the presence and extent of aging effects which according to the GALL Report and SRP-LR are loss of material due to pitting and crevice corrosion and cracking due to SCC of the spent fuel pool, the fuel transfer pit, and the cask pit stainless steel liners.

In LRA B.2.25 "parameters monitored or inspected," program element, the applicant states that the program monitors the amounts and rate of leakage accumulated in the leak chase system and collected from each of the zone valves. In Table 3.5.2-2 of the LRA, titled "Aging Management Review Results - Auxiliary Building," the applicant further states that weekly, it also monitors the spent fuel pool water, per DBNPS Tech Specs, Section 3.7.14, titled "Spent Fuel Pool Water Level."

The LRA "parameters monitored or inspected," program element states that it only monitors the amount of borated water leakage through the tell-tale drains linked to the zone valves. There is no discussion of the weekly surveillance of the water level in spent fuel pool and how that is correlated to the collected leakage.

There is also no discussion of water evaporation during the lengthy monthly accumulations of borated water in the leak chase system which could lead to increasingly acidic water that could accelerate the aging effects on channels, tubes, trenches, valve bodies, etc and faulty readings in boron concentrations.

It is not clear to the staff what kind/type of materials make up the leak chase drainage system, how these are impacted by the acidic leakage, and how the applicant tracks the variation in the acidity of the borated water. It is also not clear to the staff what additional parameters the applicant monitors for this degradation so that the leak chase drainage system will continue to perform adequately during the PEO.

The staff requests the following information:

1. Identify the material used (e.g., carbon steel, A36) for each of the following:

leak chase channels, collector tubes, zone drains, leak trenches, and for any other component (other than the liners) that the leak chase system uses for drainage of borated water.

2. How does the applicant relate the leakage of the borated water to observed degradations, if any, of the leak chase system materials and components (liners, liner weldments, channels, tubes, trenches, valve bodies, etc.) and to the level of water in the spent fuel pool?

Attachment B L-11-153 Page 9 of 28

3. In addition to the monitoring of the boron concentration in the leakage and the water level in the spent fuel pool, does the applicant monitor the concentration of any other elements (e.g., Fe) or the acidity (i.e., pH) of the collected leakage or additional parameters that could be related to aging effects of the leak chase system and its components? If other parameters are measured, discuss the acceptance criteria for each measured parameter.

RESPONSE RAI B.2.25-2

1. The spent fuel pool leak chase system is part of the Spent Fuel Pool Cooling and Cleanup System. Piping and valves associated with the leak chase system are fabricated of stainless steel. The leak chase channels are carbon steel. The leak chase channels are stitch-welded to the vertical liner plates. The liner plates, with the leak chase channels attached, were used as the formwork for pouring the concrete walls of the spent fuel pool. Therefore, the leak chase channels are embedded in concrete and are considered carbon steel embedments, which are structural bulk commodities as shown in rows 1 and 2 of LRA Table 3.5.2-13, "Aging Management Review Results - Bulk Commodities." The collector tubes are assumed to be carbon steel and are considered bulk commodities for the same reason as are the leak chase channels. The leak trenches (channels) beneath the liner floor plates are unlined concrete.

2. There has been no observed degradation of the leak chase components, which are either structural components or part of the Spent Fuel Cooling and Cleanup System.

Boric acid clogging of leak monitoring lines has previously resulted in leakage water migrating through the channel sealant tape between stitch welds, and into the concrete, as noted by boric acid residue on the opposite (accessible) face of the concrete. However, it was determined that this condition did not cause degradation of the concrete (See the FENOC response to RAI B.2.39-2, below). There is no relationship between leakage observed from the leak chase monitoring system and the level of water in the fuel pool. Pool water level is normally maintained within a 5-inch level band (1 inch corresponds to approximately 660 gallons), and the leak rate from the spent fuel pool monitoring channels is very small, typically ranging from zero to a few milliliters per minute (on the order of one gallon per day). As such, leakage monitoring is not related to the maintenance of water level in the 300,000 gallon spent fuel pool, but to monitoring long-term changes in the condition of the liner.

3. No. The implementing procedure does not specify other parameters for routine monitoring.

Attachment B L-11-153 Page 10 of 28 Question RAI B.2.25-3 SRP-LR Section A.1.2.3.4 and Table A.1-1, in "detection of aging effects,"

program element state that detection of aging effects should occur before there is a loss of structure or a component's intended function(s). The program element should address aspects such as method or technique (i.e., visual, volumetric, surface inspection), frequency, sample size, data collection used and the timing of new/one-time inspections to ensure timely detection of aging effects. Aging effects/mechanisms to detect, according to SRP-LR and the GALL Report, are loss of material and SCC. Timing for the detection of aging effects is based on plant-specific or industry-wide operating experience.

In LRA B.2.25, the applicant states in the "scope of program," program element that the program is credited for detection of loss of material in the liners, while in its "detection of aging effects," program element it states the detection is done on a monthly basis by recording the amount of accumulated borated water in the zone drain valves of the spent fuel pool, the fuel transfer pit, and the cask pit liners. Monthly collected leakages from any valve in excess of 10 milliliters are labeled, further analyzed for boron content, and the results documented in the work order system. The LRA also states that this type of monitoring supports early determination and localization of leakages. In LRA Table 3.5.2-2, titled "Aging Management Review Results -Auxiliary Building," it further states that there are three programs in place set to manage the aging effects of the spent fuel pool liner: the PWR Water Chemistry Program, the DBNPS Tech Specs, and the Leak Chase Program.

It is not clear to the staff, how the applicant correlates the monthly collected information of the borated water leakage and its analysis to the weekly Tech Specs surveillance of the spent fuel pool water level. The LRA does not state how this information collectively provides timely detection and localization of leakages in the leak chase system and its associated components and structures, including cracking due to SCC and loss of material due to pitting and crevice corrosion. It is also not clear to the staff if the applicant uses any additional detection techniques capable of identifying the continued functionality of the system during the PEO.

The staff requests the following information:

1. Elaborate on how the Tech Specs and Leak Chase Program can collectively identify detection for loss of material and SCC aging effects in the liners and leak chase system.

2. Since condition monitoring programs are based on either visual or volumetric inspections, what detection method(s) (e.g., boroscopes, fiber optics, etc.), other than monitoring the amount of the leaked borated water,

Attachment B L-11-153 Page 11 of 28 does the applicant employ to ascertain the integrity and functionality of the leak chase channels (i.e., these remain unclogged and intact, devoid of rust and accumulated boric acid) during the PEO?

RESPONSE RAI B.2.25-3

1. Because the Davis-Besse spent fuel pool water temperature is kept below 1400 F, the stress corrosion cracking aging effect is not applicable to the Spent Fuel Pool liner. Therefore, FENOC does not credit the Technical Specifications level surveillance or the Leak Chase Program for the detection of the stress corrosion cracking aging effect. FENOC credits the PWR Water Chemistry Program, the DBNPS Technical Specifications and the Leak Chase Monitoring Program for managing the loss of material aging effect for the spent fuel pool liner. FENOC credited the Technical Specification surveillance for spent fuel pool water level for consistency with NUREG-1 801 aging evaluation table Ill.A5, row 13. Monitoring the leakage from the liners provides indications of the condition of the liner and associated structural elements. Changes in the observed leakage rate may indicate the need for evaluation and potential corrective actions. (see the FENOC response to RAI B.2.25-5, below). FENOC agrees with the NRC staff's position (as noted on page 156 of NUREG/CR-1 833) that it is appropriate to use the DBNPS Technical Specifications surveillance collectively with the monitoring of leakage from the leak chase channels for verification that the PWR Water Chemistry Program manages the loss of material aging effect for the spent fuel pool liner. The basis for the Technical Specification level surveillance for spent fuel pool water level is to ensure that sufficient water depth is available to remove 99% of the assumed 10% iodine gap activity released from the rupture of an irradiated fuel assembly. The volume of the spent fuel pool is approximately 300,000 gallons. The leak rate from the spent fuel pool monitoring channels is very small, typically ranging from zero to a few milliliters per minute (on the order of one gallon per day). As such, the leakage monitoring is not related to the maintenance of water level in the 300,000 gallon spent fuel pool, but to monitoring long-term changes in the condition of the liner or other associated structural materials. FENOC does not credit the Leak Chase Monitoring Program for aging effects in the leak chase system.

2. Previous operating experience indicated that leakage monitoring lines with very low leak rates may become clogged with boric acid due to evaporation of the water within the leak monitoring lines. A corrective action for this condition was to maintain the isolation valves closed for leakage monitoring lines that had indicated leakage that was too low to be measured in milliliters per minute. The program specifies periodic monitoring of leakage rate, which is determined visually. No other examination techniques (e.g., boroscopes, fiber optics, etc.) are specified by the monitoring program.

Attachment B L-11-153 Page 12 of 28 Question RAI B.2.25-4 SRP LR Section A 1.2.3.5 and Table A 1-1, in "monitoring and trending," program element state that the element should provide predictability of the extent of degradation allowing timely response for corrective or mitigative actions and that aging indicators quantitative or qualitative, should be quantified, to the extent possible, to allow trending. The SRP-LR and the GALL Report, also state that monitoring should be done both for the spent fuel pool water level according to the plant Tech Specs and the level of fluid in the leak chase channels. In LRA B.2.25, the applicant stated in the "monitoring and trending," program element that the Leak Chase Monitoring Program routinely monitors the leak chase valves. A leak rate then is calculated based on the recorded monthly leakage. When the collected leakage from any drain valve exceeds 10 milliliters, then the sample is analyzed for boron concentration. The recorded data is reviewed by the spent fuel pool system engineer. Adverse conditions are documented in the Corrective Action Program and summarized in System Health Reports.

In a letter dated July 31, 2006, to the "Industry Groundwater Protection Initiative Questionnaire," FENOC states that monitoring in its Beaver Valley Station is performed daily, while in the Perry Nuclear Power Plant it is done weekly. It is not clear to the staff how the monthly leakage monitoring activities at DBNPS could be compared and trended to the industry standards and the weekly plant-specific requirements of the spent fuel pool water level surveillance. It is also not clear to the staff how the applicant would trend a degrading or compromising liner environment and/or leak chase drainage system. Finally, the LRA does not state how the monthly activities of leakage collection, analysis, and recording could provide a timely prediction of the extent of liner degradation or forward trending of anticipated leakages from the spent fuel pool which is a Class I structure.

The staff requests the following information:

1. Justify the basis for selecting monthly checking of leakages at DBNPS.

2. Explain how monthly monitoring provides adequate information for trending leakage rates and boron concentrations to predict the integrity of the leak chase system including the liner of the Class I structure.

Attachment B L-11-153 Page 13 of 28 RESPONSE RAI B.2.25-4

1. The leak rate from the spent fuel pool monitoring channels is very small, typically ranging from zero to a few milliliters per minute (on the order of one gallon per day).

As such, the leakage monitoring is not related to the maintenance of water level in the 300,000 gallon spent fuel pool, but to monitoring long-term changes in the condition of the liner or other structural materials. FENOC is unaware of any industry standard for such monitoring frequency, which may differ from site-to-site due to configuration and status. If no leakage were present, absence of drainage could be checked during operator tours by verifying the drain outlets dry. With some small leakage present, visual observation is an insufficient method of monitoring leakage status. A monthly monitoring frequency is judged to be sufficient to identify long-term changes in the structures that affect, or are affected by, leakage.

2. As above, leak rates are very small. A monthly monitoring frequency is judged to be sufficient to identify long-term changes in the liner or leak chase system that warrant investigation or corrective actions.

Question RAI B.2.25-5 SRP LR Section A.1.2.3.6 and Table A.1-1 state that the acceptance criteria of the program and their basis, according to the referenced "acceptance criteria" program element, should be described so that the need for corrective actions is evaluated. Acceptance criteria should be specific and quantifiable to ensure that the structures and components' intended function(s) remain under all CLB design conditions during the PEO. The program should include a methodology for analyzing the results against applicable acceptance criteria. In LRA B.2.25 the "acceptance criteria," program element states that adverse trends are documented in the Corrective Action Program. The LRA also states that adverse trends are those with continued increases of leak rates on a particular zone valve.

Although the SRP-LR guidance recommends sound quantitative or qualitative acceptance criteria for the periodic inspections, the LRA in its "acceptance criteria," program element does not indicate what specific numerical values of increasing leak rates would be considered to trigger the need for corrective actions. The acceptance criteria are neither specific nor quantifiable but rather subjective depending on the review of the collected data by the responsible system engineer. It is also not clear to the staff what constitutes "abnormal" data.

Nor does the applicant state what kind of methodology it uses to analyze such results against industry applicable acceptance criteria. The acceptance criteria should provide for timely corrective action before loss of intended function(s),

thus meeting the criteria set under CLB.

Attachment B L-11-153 Page 14 of 28 The staff requests the following information:

1. Is there a threshold of an unacceptable/adverse increase in leakage rates of borated water that would constitute the basis to trigger corrective actions?

What would the corrective actions be?

2. Is there a drain zone that is permitted to have more leakage than others?

RESPONSE RAI B.2.25-5

1. LRA Table A-1 is revised to include a new license renewal future commitment to enhance the Leak Chase Monitoring Program "Acceptance Criteria" element such that measurement of leakage from any monitoring line exceeding 15 milliliters per minute will be documented in the FENOC Corrective Action Program for evaluation and potential corrective actions. Repair of hardware is one possible disposition of a condition identified through the Corrective Action Program. If necessary, corrective actions may also be assigned to prevent recurrence.

2. No. Each drain zone will have the same leakage acceptance criteria.

See the Enclosure to this letter for the revision to the DBNPS LRA.

Question RAI B.2.25-6 SRP-LR Revision 2, Tables 3.0-1 and 3.5-2 state that plant-specific AMPs should contain information associated with the bases for determining that aging effects, in this case loss of material and SCC in stainless steel liners, will be managed during the PEO. LRA Appendix A, titled "Updated Final Safety Analysis Report,"

in paragraph A 1.25, titled "Leak Chase Monitoring Program," states that the program is a periodic condition monitoring program focusing on observations and activities for early detection of leakage from the spent fuel pool, the fuel transfer pit, and the cask pit liners due to age-related degradation.

There is no description in the Updated Final Safety Analysis Report (UFSAR) of what aging effects the program manages. The program also does not state or give a brief description of its activities.

Identify the aging effects being managed and summarize the activities involved.

Attachment B L-11-153 Page 15 of 28 RESPONSE RAI B.2.25-6 LRA Table 3.5.2-2, "Aging Management Review Results - Auxiliary Building," rows 8, 14 and 28; and LRA Section B.2.25, "Leak Chase Monitoring Program," "Scope" element indicate that the program manages loss of material for the spent fuel pool, the fuel transfer pit, and the cask pit liners. LRA Section A.1.25, "Leak Chase Monitoring Program," states that the program consists of "observation and activities to detect leakage from the spent fuel pool, the fuel transfer pit, and the cask pit liners due to age-related degradation." The same section states that "Periodic monitoring of leakage from the leak chase system permits early determination and localization of leakage." FENOC believes that the level of detail provided in LRA Section A. 1.25 is consistent with that identified in NUREG-1800, "Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants," Revision 2, Table 3.0-1, "FSAR Supplement for Aging Management of Applicable Systems," and Table 3.5-2, "Aging Management Programs Recommended for Containments, Structures, and Component Supports," to provide the basis for determining that aging of the liners will be managed, and briefly describe the program activities (i.e., leakage monitoring).

Question RAI B.2.27-1 GALL AMP XI.S5 element 6, "acceptance criteria," states that corrective actions should be taken if the extent of cracking or steel degradation is sufficient to invalidate the evaluation basis.

The applicant's Masonry Wall Inspection procedures do not provide guidance or acceptance criteria for what level of degradation leads to a reevaluation of the existing evaluation basis.

Describe the acceptance criteria that are used to trigger corrective actions, including reevaluating the existing evaluation basis. Provide technical justification for the adequacy of the acceptance criteria.

RESPONSE RAI B.2.27-1 Visual examination of masonry walls is performed to identify indications of masonry cracking and degradation of steel support system components. The responsible engineer identifies problems with structural performance and uses the Corrective Action Program or the work order system for evaluation or correction of the-problems, as necessary. Acceptable structures are capable of performing their structural functions, including the protection and support of systems, structures, and components that are in

Attachment B L-11-153 Page 16 of 28 scope for license renewal, and are free of deficiencies or degradation which could lead to possible failure. Unacceptable structures are those which are damaged or degraded such that they are not capable of performing their structural intended functions.

Acceptance criteria are established such that corrective actions are initiated prior to loss of function.

Masonry walls are inspected for the cracking aging effect. Inspection criteria are as follows:

Minor crack size less than 1/16 inch in the mortar joint between the masonry units for the reinforced block walls usually do not impact the structural integrity of the walls. Masonry walls with through thickness cracks require further investigation.

Additionally, as indicated in LRA Table A-i, Commitment 12, the Masonry Wall Inspection will be enhanced to specify that for each masonry wall, the extent of observed masonry cracking or degradation of steel edge supports or bracing is evaluated to ensure that the current evaluation basis is still valid.

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

Question RAI B.2.39-1 A review of program basis documentation related to program element 10, "operating experience," noted that during Maintenance Rule Evaluation of Structures Inspections boric acid deposits had been observed over a large surface area of the Containment Incore Instrumentation Tunnel walls and the under-vessel area that are indicative of refueling canal leakage. This included numerous boric acid indications on the concrete and on structural members below the elevation of the refueling cavity. It was also noted that the leakage was coming through the reinforced concrete construction joints and shrinkage cracks, running down the wall to the floor, and in some places under the grating in the tunnel.

It is unclear to the staff that the effects of refueling cavity leakage on the containment internal concrete structures have been adequately addressed and that the possible aging effects will be properly managed during the PEO.

The staff requests the following information:

Attachment B L-11-153 Page 17 of 28

1. Provide background information and/or data to demonstrate that the concrete and embedded steel reinforcement potentially exposed to the prior borated water leakage has not been degraded. If experimental results will be used as part of the assessment, provide evidence that the test program is representative of the materials and conditions that exist.

2. Discuss any remedial actions or repairs that are planned to address refueling cavity leakage and when they will be implemented. In the absence of a commitment to stop the refueling cavity leakage, explain how the structures monitoring program, or other plant-specific program, will address the refueling cavity leakage to ensure that resulting aging effects, especially in any inaccessible areas, will be effectively managed during the PEO.

RESPONSE RAI B.2.39-1

1. There was an extensive investigation conducted of the refueling canal leakage that was completed in 2003. The investigation is documented in a report entitled "Engineering Assessment Report - Refuel Canal Leakage." This report describes the investigation, including the destructive testing (i.e., five core drills), used to evaluate the condition of the refueling canal concrete and reinforcing steel.

Nondestructive testing and visual observations were also used. The locations for the core samples were selected at areas where nondestructive examinations had determined those zones to be the most affected by borated water. There is no concern with the structural integrity of the concrete and embedded steel reinforcement potentially exposed to prior borated water leakage.

2. During the Cycle 16 refueling outage (Spring 2010) staged fill and hold of the water.

level at various elevations in the refueling canal was performed to identify potential leak areas. This evolution found the leakage to appear within a 10-foot elevation range. Currently a vendor is developing a plan to perform vacuum box testing of the canal during the Cycle 17 Midcycle Outage (Fall 2011). The plan will be presented to plant management to determine if it will be included in the work planned for the Cycle 17 Midcycle outage. If the testing is successful, then a repair plan will be developed to mitigate the leakage. LRA Table A-1 is revised to include a new license renewal future commitment to continue to reduce or mitigate the refueling canal leaks inside containment prior to entering the period of extended operation.

See the Enclosure to this letter for the revision to the DBNPS LRA.

Attachment B L-11-153 Page 18 of 28 Question RAI B.2.39-2 A review of program basis documentation related to program element 10, "operating experience," noted that during Maintenance Rule Evaluation of Structures inspections, water had been noted to leak from the Spent Fuel Pool and travel through the surrounding concrete. The leakage has been active periodically into the ECCS pump room #1. Indications of cracking and staining on the underside of the Spent Fuel Pool and Transfer Pit (ceiling of Room 109) were also observed during a plant walkdown.

Investigation and evaluation of the periodic spent fuel pool leak indicated that six of the twenty-one leak chase channels were blocked. The leak chase channels were un-clogged releasing a significant amount of trapped fluid in several of the blocked leak chase channels. After un-clogging, the leak collection isolation valves were cleaned. Since that time, leak detection activities have been performed monthly with intermittent small quantities of fluid having been captured from several leak chase channels. Recent results indicate that two of the leak chases drains are exhibiting continual small leakage. It is unclear to the staff that the concrete and steel reinforcement of the spent fuel pool have not been impacted by the borated water.

The staff requests the following information:

1. Provide historical data on the leakage occurrence and volume, and available results from chemical analysis performed on the leakage.

2. Provide the root cause analysis that was performed to identify the source of leakage, including information on the path of the leakage and structures that could potentially be affected by the presence of the borated water. If the analysis indicates that the current leakage is completely contained within the leak chase channels, provide a technical justification for this assumption and explain how it will continue to be validated during the period of extended operation.

3. Provide background information and data to demonstrate that concrete and embedded steel reinforcement potentially exposed to the borated water have not been degraded. If experimental results will be used as part of the assessment, provide evidence that the test program is representative of the materials and conditions that exist. If a concrete sampling program (e.g., obtaining cores in region affected) will not be implemented, please explain why this is not feasible or not necessary.

4. Discuss any remedial actions or repairs that are planned to address concrete cracking such as observed on the underside of the spent fuel pool and when they will be implemented. In the absence of a commitment

Attachment B L-11-153 Page 19 of 28 to repair the concrete cracking prior to the PEO, explain how the structures monitoring program, or other plant-specific program, will address the concrete cracking to ensure that aging effects, especially in any inaccessible areas, will be effectively managed during the PEO.

RESPONSE RAI B.2.39-2

1. Historically, the leakage that was not collected by the leak chase system was observed as dripping, dampness or boron crystals on walls and associated components. Therefore, estimates of leakage volume are not precise. The historical leakage was observed for several years at different times and at least at one location other than leakage into ECCS Pump Room 1. The currently available information is provided below. The chemical analyses typically evaluated boron concentration and iron concentration, if detectable. One example is the following compilation of data from 1996, based on evaluation of dried boron deposits removed from the cask wash pit wall:

Date interval Total amount of Grams of boron Total amount of Grams of iron boron, grams per day iron, grams per day 1/12 - 2/23/96 10.96 0.26 2.1 E-3 5.0 E-5 2/23 - 3/28/96 5.01 0.15 4.8 E-4 1.4 E-5 4/26 - 6/28/96 3.96 0.06 7.2 E-4 1.1 E-5 6/28 - 8/1/96 3.63 0.11 2.6 E-4 7.9 E-6 8/1 - 9/24/96 2.56 0.05 9.63 E-5 1.8 E-6 In 1989, an analysis of a sample of boric acid crystals from the wall of ECCS Pump Room No. 1 determined the iron content to be 20 parts per billion.

In 1999, boric acid crystals and weepage were found on the south wall and ceiling adjacent to the catwalk in the ECCS Pump Room No. 1. There were several update reports made to follow-up on this leakage. In 2001, it was noted that this leakage had stopped after a work order was completed that opened up clogged leak chase piping. The final update on June 27, 2002, noted that the flow from this leak had been 0.2 gallons per day, and that when the iron content of the leakage water was analyzed it was determined to be 25 ppm. The water leakage from the spent fuel pool was clear in color and there were no rust stains on the ECCS Pump Room wall.

A review of the ECCS Pump Room No. 1 wall indicated that it had not exhibited any deterioration due to the pool leak.

2. Based on information in Condition Report 02-02303, the "apparent cause" of the leakage into ECCS Pump Room No. 1 was the clogged leak detection piping for the spent fuel pool. The leakage outside of the leak chase system has been into and

Attachment B L-11-153 Page 20 of 28 through walls or floors adjacent to the spent fuel pool. The current leakage appears to be contained within the leak chase channels. A small amount of leakage into Room 109 from the ceiling of the room was identified in 2007. Based on six documented inspections from January 25, 2007, through February 4, 2009, this leak appears to be dormant. Continued monitoring of the presence of flow from the identified leakage monitoring pathways combined with the absence of evidence of leakage on the opposite concrete surfaces provides indication that the collection pathways are not clogged, such that borated water does not build backpressure to drive leakage through the concrete structure. FENOC plans to use the investigation and testing discussed below in accordance with the Corrective Action Program to drive future analysis of the leakage and its source.

3. Core bores of the ECCS Pump Room No. 1 wall and the Room 109 ceiling will be performed prior to entering the period of extended operation. The results of evaluation of the core bores will be used to assess the condition of the concrete and embedded steel reinforcement potentially exposed to the borated water.

4. The concrete cracking observed on the underside of the spent fuel pool will be further evaluated. The evaluation will include knowledge gained from the core bores described in the response to item 3 above. If necessary, based on the evaluation, FENOC plans to repair the crack prior to entering the period of extended operation.

LRA Table A-1 is revised to include two new license renewal future commitments related to spent fuel pool leakage.

See the Enclosure to this letter for the revision to the DBNPS LRA.

Question RAI B.2.39-3 The GALL Report notes that for plants with aggressive ground water/soil (pH < 5.5, chlorides > 500 ppm, and sulfates > 1500 ppm) and/or where the concrete structural elements have experienced degradation, a plant-specific AMP accounting for the extent of degradation experienced should be implemented to manage concrete aging during the PEO. In Revision I of the GALL Report, this recommendation is provided in item T-05, while in Revision 2 it is captured in the guidance for GALL AMP XI.S6, "Structures Monitoring," and XI.S7, "Inspection of Water-Control Structures."

Program element 3, "parameters monitored or inspected," of the DBNPS Structures Monitoring Program basis document notes that the chemical parameters for DBNPS groundwater are considered to be aggressive (i.e., chlorides = 2780 ppm (max) and sulfates = 1700 ppm (max)). Program element 10, "operating experience," notes that the Turbine Building has active water in-leakage and evidence of water in-leakage was observed in several

Attachment B L-11-153 Page 21 of 28 locations in the floor and walls of the Turbine Building by the NRC audit team during the plant walkdown. Also, program basis documentation has identified groundwater intrusion into ECCS Pump Room and ECCS cooler, the East Condenser Pit through various joints and seams in the east wall below the condensate storage tank, efflorescence in the south and east exterior walls of Room 121 of the Auxiliary Building, and the annulus sand pocket. Indications of in-leakage of ground water were also observed at an overhead joint in the service water tunnel during a plant walkdown.

LRA Section B.2.39 states that the DBNPS Structures Monitoring Program will be enhanced to require the responsible engineer to review the raw water chemistry for unusual trends during the PEO, raw water chemistry will be collected at least once every five years with data collection staggered to account for seasonal variations, and monitoring of below-grade inaccessible concrete components will be implemented before the PEO. However, it is unclear to the staff that inaccessible concrete components have not been adversely impacted by the aggressive ground water and when an examination of an inaccessible concrete component will be conducted.

The staff requests the following information:

1. Provide background information and data to demonstrate that the concrete and steel reinforcement subjected to aggressive groundwater is not degrading. If an inspection of an effected inaccessible concrete component will be conducted prior to the PEO, provide details about the inspection, including the proposed schedule and how the inspection will demonstrate the acceptability of effected concrete throughout the plant. If a concrete sampling program (e.g., obtaining cores in an affected region) will not be implemented, explain why this is not feasible or not necessary.

2. Explain how the structures monitoring program, or other plant-specific program, will address aggressive groundwater infiltration to ensure that resulting aging effects, especially in any inaccessible areas, will be effectively managed during the PEO

Attachment B L-11-153 Page 22 of 28 RESPONSE RAI B.2.39-3 There is no evidence that the aggressive groundwater at Davis-Besse has contributed to structural degradation. However, to address NRC requests 1 and 2, LRA Table A-1 is revised to include a new license renewal future commitment to enhance the Structures Monitoring Program to monitor concrete aging effects:

The Structures Monitoring Program will be enhanced to obtain and evaluate for degradation a concrete core bore from a representative inaccessible concrete component of an in-scope structure subjected to aggressive groundwater prior to entering the period of extended operation. Based on the results of the initial core bore sample, evaluate the need for collection and evaluation of representative concrete core bore samples at additional locations that may be identified during the period of extended operation as having aggressive groundwater infiltration. Select additional core bore sample locations based on the duration of observed aggressive groundwater infiltration. Require the use of the FENOC Corrective Action Program for identified concrete or rebar degradation.

See the Enclosure to this letter for the revision to the DBNPS LRA.

Question RAI B.2.39-4 GALL AMP XI.S6, "Structures Monitoring Program," element 4, notes that inspector qualifications are to be commensurate with industry codes, standards, and guidelines. ACI 349.3R-96 and ANSI/ASCE 11-90 are identified as providing an acceptable basis for addressing inspector qualifications.

Program element 4, "detection of aging effects," of the DBNPS Structures Monitoring Program notes that the structures are periodically monitored to identify degradation that could impair the functional performance of the structure.

Visual inspection is the method used for monitoring the structural degradation.

The inspections are performed by Maintenance Rule Walkdown Teams consisting of at least two individuals that are degreed engineers, or equivalent, and have at least five years experience in civil/structural engineering activities, or as determined by the Mechanical/Structural supervisor. At least one member of the Maintenance Rule Walkdown Team is a licensed Professional Engineer. It is unclear to the staff that personnel performing the inspections are commensurate with industry codes, standards, and guidelines for inspectors.

Provide qualifications of the personnel performing the structural inspections and show that they are commensurate with industry codes, standards, and guidelines (e.g., Section 7 of ACI 349.3R).

Attachment B L-11-153 Page 23 of 28 RESPONSE RAI B.2.39-4 As stated GALL XI.S6, under Detection of Aging Effects:

"Inspector qualifications should be consistent with industry guidelines and standards and guidelines for implementing the requirements of 10 CFR 50.65. Qualifications of inspection and evaluation personnel specified in ACI 349.3R are acceptable for license renewal."

LRA Table A-1 is revised to include a new license renewal future commitment to enhance the Structures Monitoring Program to require that personnel performing the structural inspections meet qualifications that are commensurate with ACI 349.3R, "Evaluation of Existing Nuclear Safety-Related Concrete Structures."

See the Enclosure to this letter for the revision to the DBNPS LRA.

Question RAI B.2.39-5 Based on recent operating experience and recent NRC reviews, the staff has determined that structures within the scope of license renewal should be monitored on a frequency not to exceed five years. This current staff position is captured in GALL Report Revision 2, AMPs XI.S5 "Masonry Walls," and XI.S6, "Structures Monitoring Program."

Program element 4, "detection of aging effects," of the DBNPS Structures Monitoring and Masonry Wall Programs note the programs periodically monitor the structures through visual inspections to identify degradation that could impair the functional performance of the structure. The standard interval between periodic assessments for a particular structure is four years, but the frequency can vary between two and ten years depending on the location and environment, susceptibility to degradation, and the age of the structure. It is unclear to the staff that the inspection frequency meets the requirements of the GALL Report.

Identify the structures and masonry walls that will be inspected on a frequency greater than five years, along with their environments and a summary of past degradation. Include a technical justification for the longer interval.

RESPONSE RAI B.2.39-5 LRA Section B.2.27, "Masonry Wall Inspection," Section B.2.39, "Structures Monitoring Program," and Table A-1 are revised to include an enhancement and a new license renewal future commitment to specify that structures and masonry walls be inspected at

Attachment B L-11-153 Page 24 of 28 least once every five years. The Structures Monitoring Program procedure will be enhanced to include the 5-year monitoring frequency recommendation from NUREG-1801, Chapters XI.S5 and XI.S6, "Detection of Aging Effects" element, prior to entering the period of extended operation. The Structures Monitoring Program implementing procedures will be enhanced to establish a monitoring frequency not to exceed once every five years. As indicated in LRA Section B.2.27, the Masonry Wall Inspection is implemented as part of the Structures Monitoring Program, conducted for the Maintenance Rule.

See the Enclosure to this letter for the revision to the DBNPS LRA.

Question RAI B.2.39-6 Based on recent operating experience and recent NRC reviews, the staff has determined that inspection programs for structures within the scope of license renewal should include quantitative limits for characterizing degradation.

Chapter 5 of ACI 349.3R provides adequate acceptance criteria for concrete structures. Applicants that are not committed to ACI 349.3R and/or elect to use plant-specific criteria for concrete structures should describe the criteria and provide a technical basis for deviations from those in ACI 349.3R.

The applicant's inspection criteria used to assess the condition of structures and structural components are found in Maintenance Rule evaluation procedure for the Maintenance Rule Evaluation of Structures. Evaluation criteria follow guidance contained in NEI 96-03. Plant basis documentation identifies acceptance criteria as: Y (structure/area/room acceptable, no design basis violation, housekeeping may or may not be required), W (structure/area/roomr acceptable with deficiencies), and N (structure/area/room unacceptable). Little in the way of quantitative inspection criteria are provided and at least one example of criteria provided does not meet ACI 349.3R requirements (i.e., crack widths < 0.0625 in. as acceptable whereas ACI lists crack widths < 0.015 in. as acceptable). It is unclear to the staff what quantitative acceptance criteria are used and that acceptance criteria utilized comply with design basis codes and standards such as ACI 349.3R.

The staff requests the following information:

1. Provide the quantitative acceptance criteria for the Structures Monitoring and the Water Control Structures Inspection Programs. If the concrete acceptance criteria deviate from those discussed in ACI 349.3R, provide technical justification for the differences.

Attachment B L-11-153 Page 25 of 28

2. If quantitative acceptance criteria will be added to the programs as an enhancement, provide plans and a schedule to conduct a baseline inspection with the quantitative acceptance criteria prior to the PEO.

RESPONSE RAI B.2.39-6

1. LRA Section B.2.39, "Structures Monitoring Program," Section B.2.40, "Water Control Structures Inspection," and Table A-1 are revised to include enhancements and new license renewal future commitments to add further clarification to the programs based on this RAI. Quantitative acceptance criteria for the Structures Monitoring Program and the Water Control Structures Inspection will follow the guidance in Chapter 5 of ACI 349.3R.

The Structures Monitoring Program procedure will be enhanced to include the recommendation from the NUREG-1801, Chapters XI.S6 and XI.S7 "Acceptance Criteria" element prior to entering the period of extended operation. The Structures Monitoring Program procedure will be enhanced to include additional acceptance criteria details developed from Chapter 5 of ACI 349.3R. The Structures Monitoring Program procedure will also be enhanced to reflect the "Periodic Evaluation" criteria defined in chapter 3.3 of ACI 349.3R. The Structures Monitoring Program procedure will include the "prioritization process" to develop a representative sample of areas to inspect in accordance with ACI 349.3R. As indicated in LRA Section B.2.40, the Water Control Structures Inspection is implemented as part of the Structures Monitoring Program, conducted for the Maintenance Rule.

2. FENOC will implement the required enhancements into the Structures Monitoring Program and Water Control Structures Inspection as indicated in LRA Table A-1 and will conduct a baseline inspection of the structures within the scope of license renewal prior to entering the period of extended operation.

See the Enclosure to this letter for the revision to the DBNPS LRA.

Question RAI B.2.39-7 During a field walkdown with the applicant's technical personnel on February 15, 2011, the NRC staff noted indications of spall repairs in two areas located on the NW side of the Shield Building near the upper right corner of the former reactor vessel head entry cut out.

This observation led to discussions relative to inspection procedures and criteria that were utilized for the Shield Building. It is unclear to the staff how inspections.

are performed to identify degradation such as the noted repair locations. It is also

Attachment B L-11-153 Page 26 of 28 unclear how inspections of the Shield Building will be performed during the PEO and how the inspections will be used to manageaging.

Explain how aging management will be accomplished for the shield building during the PEO. Explain which AMP will be credited for aging management and why it is appropriate for the Shield Building. If visual inspections are credited, explain how the concrete will be inspected (e.g., optical aids, scaling technologies, etc., for difficult to access areas such as upper exterior elevations).

RESPONSE RAI B.2.39-7 The Structures Monitoring Program is credited for aging management of the Shield Building during the period of extended operation, and aging management of the Shield Building will be accomplished by visual inspection. The Structures Monitoring Program is the appropriate program for inspection of the Shield Building because the program is an existing program that is currently used for visual inspection of the Shield Building, and, following enhancement, will be consistent with the XI.S6, "Structures Monitoring Program," recommended for structural inspections in NUREG-1801, "Generic Aging Lessons Learned (GALL) Report."

FENOC will enhance the Structures Monitoring Program to require optical aids, scaling technologies, mechanical lifts, ladders or scaffolding to allow visual inspections that meet the guidelines of Chapter 5 of ACI 349.3R. The areas to be inspected in accordance with the guidelines of Chapter 5 of ACI 349.3R will be selected to reflect the "Periodic Evaluation" criteria defined in Chapter 3.3 of ACI 349.3R. The selection methodology will include the "prioritization process" to develop a representative sample of areas to inspect in accordance with ACI 349.3R. LRA Table A-i, Commitment 20, is revised to include this Structures Monitoring Program enhancement as a new license renewal future commitment.

See the Enclosure to this letter for the revision to the DBNPS LRA.

Question RAI B.2.39-8 NRC staff review has determined that if ASTM A325, ASTM F1852, and/or ASTM A490 bolts are used, the preventative actions as discussed in Section 2 of the Research Council for Structural Connections, "Specification for Structural Joints Using ASTM A325 or A490 Bolts," should be followed. This recommendation is now captured in structural AMPs XI.S1, XI.S3, XI,S6, and XI.S7 of the GALL Report Revision 2.

Attachment B L-11-153 Page 27 of 28 The staff reviewed the structural AMPs in LRA Sections B.2.22, B.2.23, B.2.39, and B.2.40, as well as the associated support documents, and found no discussion of the preventative actions recommended in "Specification for Structural Joints Using ASTM A325 or A490 Bolts."

If ASTM A325, ASTM F1 852, and/or ASTM A490 bolts are used, explain how the preventative actions discussed in Section 2 of "Specification for Structural Joints Using ASTM A325 or A490 Bolts" are addressed, or why they are unnecessary.

The response should address all structural bolting within the scope of license renewal.

RESPONSE RAI B.2.39-8 ASTM A325 and ASTM A490 bolts are used at Davis-Besse.

In accordance with the plant's specifications for erecting structural steel, the materials and field operations conform to applicable codes, standards and specifications; including the Research Council for Structural Connections (RCSC) "Specification for Structural Joints Using ASTM A325 or A490 Bolts." Owing to its endorsement by the American Institute of Steel Construction (AISC), the RCSC specification is referred to in plant documents as an AISC specification rather than as an RCSC specification.

However, the 2004 "Specification for Structural Joints Using ASTM A325 or A490 Bolts" now referenced in NUREG-1801 is identified as an RSCS specification. Also, an earlier edition of the AISC specifications did not include the preventive actions now discussed in Section 2 of the RCSC specification. Therefore, LRA Table A-1 is revised to include a new license renewal future commitment to incorporate reference to and the preventive actions of the RCSC specification into the Davis-Besse specifications and implementing procedures that address structural bolting within the scope of license renewal.

See the Enclosure to this letter for the revision to the DBNPS LRA.

Question RAI B.2.40-1 A review of program basis documentation related to program element 10,

operating experience," noted that during Preventive Maintenance inspections in 2007 it was discovered that the north embankment of the safety-related portion of the intake canal had settled. This settlement reduced the slope of the embankment.

Attachment B L-11-153 Page 28 of 28 It is unclear to the staff that the degradation of the embankment has been adequately addressed and that the possible aging effects will be properly managed during the PEO.

Explain how the integrity of the embankment is being ensured and how related aging effects will be addressed during the PEO.

RESPONSE RAI B.2.40-1 The integrity of the embankment is currently being ensured by the evaluations and corrective actions initiated in accordance with the Corrective Action Program. The integrity of the embankment was initially addressed in 2007. A slope stability study was conducted by an independent geotechnical engineering firm as a corrective action.. The engineering evaluation of the slope stability study concluded that the affected area is localized to the areas identified and that the current condition is insignificant to the original design of the intake canal. Also, a preventive maintenance (PM) activity has been initiated to monitor the embankment for any changes. This PM was instituted based on engineering evaluation of the slope stability study. The PM includes inspection and measurement of the embankment both above and below the water surface.

Long-term plans have been developed for further evaluation of the embankment. To better understand and define the current degradation, further testing and monitoring is required. To ensure repairs meet the parameters described in the Davis-Besse Updated Safety Analysis Report, additional core borings in the failure surface are necessary.

Funds have been approved for completion of that work in 2011. Goals of the evaluation of the embankment condition include an attempt to better understand the mechanism of failure and to evaluate repair options. FENOC plans to address any related embankment aging effects that could occur during the period of extended operation based on completion of the evaluation, review of the evaluation by Davis-Besse site design engineering personnel and completion of any needed modification.

Enclosure Davis-Besse Nuclear Power Station, Unit No. 1 (DBNPS)

Letter L-11-153 Amendment No. 7 to the DBNPS License Renewal Application Page 1 of 206 License Renewal Application Sections Affected Section 2.4 Section 3.3.2.1.15 Table 3.3.2-7 Table 3.4.2-4 Appendix B Table 2.4-13 Section 3.3.2.1.16 Table 3.3.2-8 Table 3.4 Notes App. B Table of Cont.

Section 3.3.2.1.17 Table 3.3.2-12 Table B-1 Section 3.2 Section 3.3.2.1.19 Table 3.3.2-13 Section 3.5 Table B-2 Section 3.2.2.1.1 Section 3.3.2.1.21 Table 3.3.2-14 Section 3.5.2.1.13 Section B.2.2 Section 3.2.2.1.2 Section 3.3.2.1.23 Table 3.3.2-15 Table 3.5.2-13 Section B.2.4 Section 3.2.2.1.4 Section 3.3.2.1.28 Table 3.3.2-16 Table 3.5 Notes Section B.2.7 Section 3.2.2.2.3.4 Section 3.3.2.1.29 Table 3.3.2-17 Section B.2.8 Section 3.2.2.2.3.6 Section 3.3.2.1.30 Table 3.3.2-18 Appendix A Section B.2.10 Table 3.2.1 Section 3.3.2.1.31 Table 3.3.2-19 App. A Table of Cont. Section B.2.15 Table 3.2.2-1 Section 3.3.2.1.32 Table 3.3.2-21 Section A.1.2 Section B.2.18 Table 3.2.2-2 Section 3.3.2.2.3.3 Table 3.3.2-23 Section A.1.7 Section B.2.25 Table 3.2.2-4 Section 3.3.2.2.5.1 Table 3.3.2-24 Section A.1.8 Section B.2.27 Table 3.2.2-5 Section 3.3.2.2.5.2 Table 3.3.2-25 Section A.1.10 Section B.2.30 Table 3.2 Notes Section 3.3.2.2.7.3 Table 3.3.2-27 Section A.1.15 Section B.2.31 Section 3.3.2.2.10.3 Table 3.3.2-28 Section A.1.30 Section B.2.33 Section 3.3 Section 3.3.2.2.10.5 Table 3.3.2-29 Section A.1.31 Section B.2.36 Section 3.3.2.1.1 Section 3.3.2.2.10.6 Table 3.3.2-30 Section A.1.36 Section B.2.37 Section 3.3.2.1.2 Table 3.3.1 Table 3.3.2-31 Section A.1.37 Section B.2.39 Section 3.3.2.1.3 Table 3.3.2-1 Table 3.3.2-32 Section A.1.41 Section B.2.40 Section 3.3.2.1.6 Table 3.3.2-2 Table 3.3 Notes Section A.1.42 Section B.2.41 Section 3.3.2.1.8 Table 3.3.2-.3 Table A-1 Section 3.3.2.1.12 Table 3.3.2-4 Section 3.4 Section 3.3.2.1.13 Table 3.3.2-5 Section 3.4.2.1.4 Section 3.3.2.1.14 Table 3.3.2-6 Table 3.4.1 The Enclosure identifies the change to the License Renewal Application (LRA) by Affected 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 italics with deleted text Uned-ou and added text underlined.

Enclosure L-11-153 Page 2 of 206 Affected LRA Section LRA Page No. Affected Paralraph and Sentence Table 2.4-13 Page 2.4-51 New Row added A new row for cranes, monorails and hoists bolting is added to LRA Table 2.4-13, "Bulk Commodities Components Subject to Aging Management Review," based on the response to RAI B.2.10-2, and Table 2.4-13 is revised to read:

Table 2.4-13 Bulk Commodities Components Subject to Aging Management Review Component Type Intended Function (as defined in Table 2.0-1)

ThreadedFasteners Anchor Bolts SNS, SRE, SSR Anchor Bolts (ASME Class 1, 2, and 3 Supports Bolting) SRE, SSR Blowout Panel Release Fasteners PR, SSR Bolting SNS Expansion Anchors SNS, SRE, SSR

Enclosure L-11-153 Page 3 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence 3.2.2.1.1 Page 3.2-3 "Aging Management Programs" section In response to RAIs 3.3.2.2.5-1 and 3.3.2.71-2, the "Aging Management Programs" section of 3.2.2.1.1 is revised to read:

The following aging management programs manage the aging effects for subject mechanical components of the Containment Air Cooling and Recirculation System:

• Bolting Integrity Program

1. Boric Acid Corrosion Program

• External Surfaces Monitoring Program

• Inspection of Internal Surfaces in Miscellaneous Piping and Ductinq Program a One Timeinspc6tien

° Open-Cycle Cooling Water Program Affected LRA Section LRA Page No. Affected Paragraph and Sentence 3.2.2.1.2 Page 3.2-4 "Aging Management Programs" section In response to RAI 3.3.2.71-2, the "Aging Management Programs" section of 3.2.2.1.2 is revised to read:

The following aging management programs manage the aging effects for subject mechanical components of the Containment Spray System:

" Bolting Integrity Program

" Boric Acid Corrosion Program

" External Surfaces Monitoring Program

• Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Program

" One-Time Inspection

• PWR Water Chemistry Program

Enclosure L-11-153 Page 4 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence 3.2.2.1.4 Page 3.2-6 "Aging Management Programs" section In response to RAIs B.2.2-2 and B.2.2-3, the "Aging Management Programs" section of 3.2.2.1.4 is revised to read:

The following aging management programs manage the aging effects for subject mechanical components of the Decay Heat Removal and Low Pressure Injection System:

• Abovegqround Steel Tanks Inspection

" Bolting Integrity Program

" Boric Acid Corrosion Program

• Closed Cooling Water Chemistry Program

" External Surfaces Monitoring Program

" Lubricating Oil Analysis Program

• One-Time Inspection

• PWR Water Chemistry Program

• Selective Leaching Inspection Affected LRA Section LRA Page No. Affected ParaaraDh and Sentence 3.2.2.2.3.4 Page 3.2-9 Second sentence In response to RAI Sampling 1.0, the second sentence of Section 3.2.2.2.3.4 is revised to read:

At Davis-Besse, loss of materialfor stainless steel piping and components in the reactorcoolantpump oil collection system and the high Pressureiniection pump lube oil system, and for copper alloy heat exchangercomponents in the ESF Systems, that are exposed to lubricatingoil is managed by the Lubricating Oil Analysis Program.

Enclosure L-11-153 Page 5 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence 3.2.2.2.3.6 Page 3.2-9 Entire section In response to RAI 3.3.2.71-2, Section 3.2.2.2.3.6 is revised to read:

Loss of materialfrom pitting and crevice corrosioncould occur for stainless steel piping, piping components, piping elements, and tanks exposed to internal condensation. Moist air is enveloped by the NUREG-1801 ChapterIX definition of condensation.At Davis-Besse, loss of materialat air-waterinterfaces for stainless steel piping, piping components, piping elements, and tanks that are exposed internally to moist air will be detected and characterizedby the One-Time Inspection. Loss of material where contaminantsmay be concentratedby frequent wetting and drying for stainless steel piping, piping components, tubing, and valve bodies that are exposed internally to moist air,which is enveloped by the NUREG 1801 ChapterIX definition of condensation, will be managed by the plant-specific Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Program.

Enclosure L-11-153 Page 6 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Various Tables Various Various rows In response to RAI B.2.8-1, the rows identified below are deleted from the referenced Tables. To maintain table row numbering, for each row listed below the existing contents are deleted and a single entry of "Not Used" is inserted in the row.

Table Row Table Row Table Row Table Row 3.2.2-4 22 3.3.2-3 112 3.3.2-12 50 3.3.2-25 73 3.2.2-4 32 3.3.2-3 116 3.3.2-12 53 3.3.2-25 75 3.2.2-4 38 3.3.2-3 125 3.3.2-12 56 3.3.2-25 77 3.2.2-4 44 3.3.2-3 135 3.3.2-12 59 3.3.2-25 90 3.2.2-4 46 3.3.2-3 154 3.3.2-12 61 3.3.2-25 92 3.2.2-4 50 3.3.2-4 32 3.3.2-12 63 3.3.2-25 97 3.2.2-5 24 3.3.2-4 36 3.3.2-12 65 3.3.2-25 99 3.2.2-5 33 3.3.2-7 17 3.3.2-12 67 3.3.2-27 17 3.2.2-5 37 3.3.2-7 24 3.3.2-12 69 3.3.2-30 21 3.2.2-5 41 3.3.2-7 28 3.3.2-12 74 3.3.2-30 30 3.3.2-2 9 3.3.2-7 30 3.3.2-12 78 3.3.2-30 33 3.3.2-2 13 3.3.2-7 33 3.3.2-12 88 3.3.2-30 35 3.3.2-2 16 3.3.2-7 35 3.3.2-12 160 3.3.2-30 39 3.3.2-2 20 3.3.2-7 39 3.3.2-12 165 3.3.2-30 45 3.3.2-2 23 3.3.2-7 43 3.3.2-12 184 3.3.2-30 49 3.3.2-2 26 3.3.2-7 47 3.3.2-16 10 3.3.2-30 51 3.3.2-2 30 3.3.2-7 52 3.3.2-16 19 3.3.2-30 56 3.3.2-2 34 3.3.2-7 54 3.3.2-18 35 3.3.2-30 60 3.3.2-2 38 3.3.2-7 60 3.3.2-18 37 3.3.2-30 63 3.3.2-2 42 3.3.2-7 65 3.3.2-18 41 3.3.2-30 65 3.3.2-2 47 3.3.2-7 67 3.3.2-18 45 3.3.2-30 68 3.3.2-2 54 3.3.2-7 71 3.3.2-18 47 3.3.2 71 3.3.2-2 60 3.3.2-7 75 3.3.2-18 55 3.3.2-30 76 3.3.2-2 66 3.3.2-7 79 3.3.2-18 57 3.3.2-30 81 3.3.2-2 71 3.3.2-7 84 3.3.2-18 63 3.3.2-30 119 3.3.2-2 75 3.3.2-7 89 3.3.2-24 17 3.3.2-30 129 3.3.2-2 79 3.3.2-7 93 3.3.2-25 15 3.3.2-30 141 3.3.2-2 83 3.3.2-7 97 3.3.2-25 17 3.3.2-30 148 3.3.2-3 9 3.3.2-7 101 3.3.2-25 19 3.3.2-30 150 3.3.2-3 12 3.3.2-7 105 3.3.2-25 23 3.3.2-30 160 3.3.2-3 15 3.3.2-7 107 3.3.2-25 25 3.3.2-30 166 3.3.2-3 22 3.3.2-7 111 3.3.2-25 27 3.3.2-32 5 3.3.2-3 25 3.3.2-7 115 3.3.2-25 31 3.3.2-32 9 3.3.2-3 38 3.3.2-7 117 3.3.2-25 33 3.3.2-32 12 3.3.2-3 42 3.3.2-8 40 3.3.2-25 35 3.3.2-32 15 3.3.2-3 68 3.3.2-8 45 3.3.2-25 53 3.3.2-32 18 3.3.2-3 73 3.3.2-8 48 3.3.2-25 55 3.3.2-32 21 3.3.2-3 78 3.3.2-12 41 3.3.2-25 62 3.3.2-32 24 3.3.2-3 83 3.3.2-12 44 3.3.2-25 64 3.3.2-3 88 3.3.2-12 46 3.3.2-25 66

Enclosure L-11-153 Page 7 of 206 Affected LRA Section LRA Page No. Affected ParaaraDh and Sentence Table 3.2.1 Page 3.2-17 Row 3.2.1-08 Text in "Discussion" column is revised based on the response to RAI 3.3.2.71-2. LRA Table 3.2.1, "Summary of Aging Management Programs for Engineered Safety Systems Evaluated in Chapter VII of NUREG-1801," now reads:

Table 3.2.1 Summary of Aging Management Programs for Engineered Safety Features Systems Evaluated in Chapter V of NUREG-1 801 Item Aging Effect/ Aging Management Further Number Component/Commodity Mechanism Programs Evaluation Discussion Recommended 3.2.1-08 Stainless steel piping, piping Loss of material due A plant-specific aging Yes, plant- Consistent with NUREG-1801.

components, piping elements, to pitting and crevice management program is specific Loss of material due to pitting and tank internal surfaces corrosion to be evaluated. and crevice corrosion at air-water exposed to condensation interfaces in stainless steel (internal) piping, piping components, piping elements, and tanks that are exposed to moist air (internal) will be detected and characterized by the One-Time Inspection.

Loss of material where contaminants may be concentratedby frequent wetting and drying for stainless steel piping, piping components, tubing, and valve bodies that are exposed internally to moist air (internal)will be managed by the plant-specific InsPection of

Enclosure L-1 1-153 Page 8 of 206 Table 3.2.1 Summary of Aging Management Programs for Engineered Safety Features Systems Evaluated in Chapter V of NUREG-1801 Item T

Aging Effect/

I Aging Management T Euatiss Further Number Component/Commodity Mechanism Programs Evaluation Discussion Recommended Internal Surfaces in MiscellaneousPiping and Ductingq Program.

Further evaluation is documented in Section 3.2.2.2.3.6.

Enclosure L-11-153 Page 9 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table 3.2.1 Pages 3.2-25 "Discussion" column, various rows through 28 In response to RAI B.2.8-1, the following paragraphs are deleted from the "Discussion" column of the following rows of Table 3.2.1, "Summary of Aging Management Programs for Engineered Safety Features Systems Evaluated in Chapter V of NUREG-1 801 :"

Row 3.2.1-27 in additon, the One Time insepction will provide verficGation of the effectiveness of the Closed Coofing Watc Chemistr-y Program to manage loss of mqaterial.

Row 3.2.1-28 in additin, the One Time inspection wil1 provide verification of the effeetivcncss of the Closed Cooling Wate, Chcmisfty Program to m~anage loss of material.

Row 3.2.1-29 in addition, the One Time inspection wil provide veri~ficain of the effiectiveness of the Closed Cooling Water Chem*i*t Program to manage loss of material.

Row 3.2.1-30 in addition, the One Time Inspeetion twil provide verification of the effectiveness of the Closed Cooling Water Chemistry Program to manage redetio-n in heat transfer.

Enclosure L-11-153 Page 10 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table 3.2.2-1 Pages 3.2-45 Rows 13, 26, 28, 30 and 34 through 49 In response to RAI 3.3.2.71-2, rows of LRA Table 3.2.2-1, "Aging Management Review Results " Containment Air Cooling and Recirculation System," are revised as follows:

Table 3.2.2-1 Aging Management Review Results - Containment Air Cooling and Recirculation System dAging Effect NUREG-Row Component Intended Material Environment Requiring Aging Management 1801, Table I Notes No. Type Function(s) Management Program Volume Item 2 Item One Time inspectiOn Structural Stainless Condensation Loss of Inspection of Internal 331-13 Drain Pan Surfaces in VIIF1-1 E integrity Steel (Internal) material sce s in in.11 27 Miscellaneous Piping and Ductinq Heat Exchanger (cooling coil One Time inspe...On fins) - Inspection of Internal 26 Containment Heat transfer Copper Condensation Reduction in Surfaces in N/A N/A G air cooling Alloy (External) heat transfer Miscellaneous Piping coils (DB- and Ductinq E37-1, -2 &-

3)

Enclosure L-11-153 Page 11 of 206 Table 3.2.2-1 Aging Management Review Results - Containment Air Cooling and Recirculation System Aging ffectNUREG-Row Component Ro opnn neddAging Effect Aging Management NURE1 Tal1Noe Intended Material Environment Requiring 1801, Table Notes No. Type Function(s) Management Program Volume Item 2 Item Heat Exchanger (cooling coil One Time inspect.o.

tubes) - Inspection of Internal 28 Containment Heat transfer Copper Condensation Reduction in Surfaces in N/A N/A G air cooling Alloy (External) heat transfer Miscellaneous Pipinn coils (DB- and Ducting E37-1, -2 & -

3)

Heat Exchanger (cooling coil On,, Tim, IPe.tiO, tubes) - Pressure Copper Condensation Loss of Inspection of Internal 30 Containment Surfaces in VII.F1-16 3253.- E air cooling boundary Alloy (External) material Miscellaneous Piping 25 coils (DB- and Ducting E37-1, -2 & -

3)

One Time inspectiOn Pressure 34 ipngSteel Condensation (nrlSurfaces Loss of Inspectioninof Internal VII.F1-3 3.3 7 1-34 Piping boundary (Internal) material Miscellaneous Piping 72 and Ducting

Enclosure L-11-153 Page 12 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table 3.2.2-1 Page 3.2-50 New Rows In response to RAI 3.3.2.2.5-1, two new rows are added to LRA Table 3.2.2-1, "Aging Management Review Results - Containment Air Cooling and Recirculation System," as follows:

Table 3.2.2-1 Aging Management Review Results - Containment Air Cooling and Recirculation System NUREG-Row No.

Component Type Intended Function(s) Material Aging Effect Aging 1801, Table 1 Environment Requiring Management Volume 2 Item Notes Management Program Item Inspection of eAir-indoor Internal Flexible *Pressure Elastomer uncontrolled Hardening and Surfaces in VII.F1-7 3.3.1-11 E Connection boundary ucntrolle loss of strength Miscellaneous P(Internal) piing and Ducting Inspection of Air-indoor Internal Flexible Pressure Elastomer Andoor Hardeningand Surfaces in VIIFI-7 3.3.1-11 E Connection boundary (Externall loss of strength Miscellaneous Piping and Ducting

Enclosure L-11-153 Page 13 of 206 Affected LRA Section LRA Page No. Affected Paraararh and Sentence Table 3.2.2-2 Page 3.2-55 Row 35 In response to RAI 3.3.2.71-2, row 35 of LRA Table 3.2.2-2, "Aging Management Review Results - Containment Spray System," is revised as follows:

Table 3.2.2-2 Aging Management Review Results - Containment Spray System Aging Effect NUREG-Row Component Intended Material Environment Requiring Aging Management 1801, Table I Notes No. Type Function(s) Management Program Volume 2 Item Item One T-ime inspectiOn Structural LossmaeilSurfaces of Inspectioninof Internal N/A N/A G 00 35 Piping integrity Steel Air (Internal) material Miscellaneous Pipin 0203 and Ducting

Enclosure L-11-153 Page 14 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table 3.2.2-4 Page 3.2-82 Rows 81, 91,117,132, 152 through 92 In response to RAIs B.2.2-2 and B.2.2-3, rows 81, 91, 117, 132 and 152 of LRA Table 3.2.2-4, "Aging Management Review Results - Decay Heat Removal and Low Pressure Injection System," are revised as follows:

Row Row Table 3.2.2-4 Component Type Intended' Intends) Material I

Aging Management Review Results - Decay Heat Removal and Low Pressure Injection System Environment Aging Effect Requiring Aging Management NUREG-1801 Table1 Table 1 Notes No. Type Function(s) Management Program Volume 2 Item

, Item None 81 Piping Pressure Stainless Air-outdoor None External N/A N/A G boundary Steel (External) Cracking Surfaces

______Monitoring None 91 Piping Structural integrity Stainless Steel Air-outdoor (External) None Cracking External Surfaces N/A N/A G Monitoring Nene 117 Tank - BWST Pressure Stainless Air-outdoor None External N/A N/A G (DB-T10) boundary Steel (External) Cracking Surfaces Monitoring None Pressure Stainless Air-outdoor None External 132 Tubing boundary Steel (External) Cracking Surfaces N/A N/A G

________ __ ____ ____ ____

____ ___ ____ _ __ ____ ____ __ _ ____ ____ ___ Monitoring _ _ _ _ _ _ _ _ _

Enclosure L-11-153 Page 15 of 206

Enclosure L-11-153 Page 16 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table 3.2.2-4 Page 3.2-93 6 new rows In response to RAIs B.2.2-2 and B.2.2-3, six new rows are added to LRA Table 3.2.2-4, "Aging Management Review Results - Decay Heat Removal and Low Pressure Injection System," as follows:

Table 3.2.2-4 Aging Management Review Results - Decay Heat Removal and Low Pressure Injection System Row Component Intended Aging Effect Aging NUREG-Ro opnn nedd Material Environment Reurn aaeet 1801, Table I Notes No. Type Function(s) Requiring Management Volume 2 Item

• Management Program Item Pressure Stainless Air-outdoor External

-- Presunare Stainless A utdorn Loss of material Surfaces N/A N/A G bounda Steel (External) onitoring Structural Stainless Air-outdoor External

-- g Sterutu Steel integity teel (External) Loss of material Extenal)Monitoring_ Surfaces N/A N/A G Tank - BWST Pressure Stainless Air-outdoor Above ground G (DB-TI 0) boundary Steel (External) Loss of material Steel Tanks NA NA0212

-~ ~~~ _____

____ __ ____ npction 01 Tank - BWST Pressure Stainless Air-outdoor External Loss of material Surfaces N/A N/A G (DB-TIO) boundary Steel (External) Monitoring Pressure Stainless Air-outdoor External Tubing --

boundare bunday Steel Stel (ExteAral)

(xteral)MonitoringLoss of material Surfaces N/A N/A G Pressure* Stainless Air-outdoor External Valve body Pressure Stess Arotdr Loss of material Surfaces N/A N/A G boundary Steel (External) Monitoring

Enclosure L-11-153 Page 17 of 206 Affected LRA Section LRA Page No. Affected ParaaraDh and Sentence Table 3.2.2-5 Pages 3.2-104 Rows 48, 49, 50, 51, 56 and 57 through 105 In response to RAI Sampling 1.0, rows 48, 49, 50, 51, 56 and 57 of LRA Table 3.2.2-5, "Aging Management Review Results - High Pressure Injection System," are revised as follows:

Enclosure L-11-153 Page 18 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table 3.2.2-5 Page 3.2-106 Row 65 In response to RAI B.2.2-2, row 65 of LRA Table 3.2.2-5, "Aging Management Review Results - High Pressure Injection System," is revised as follows:

Enclosure L-11-153 Page 19 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table 3.2.2-5 Page 3.2-116 New row In response to RAI B.2.2-2, one new row is added to LRA Table 3.2.2-5, "Aging Management Review Results -

High Pressure Injection System," as follows:

Enclosure L-11-153 Page 20 of 206 Affected LRA Section LRA Page No. Affected Paraciraoh and Sentence Section 3.2 Page 3.2-118 Rows 0202, 0203 and 0211 Plant-Specific Notes In response to RAI 3.3.2.71-2, rows of Section 3.2 "Plant-Specific Notes" are revised as follows:

Plant-Specific Notes:

0202 The One-Time Inspection will confirm, for components subject to a "Moistair (Internal)" environment, the absence of aging effects or that aging is slow acting so as to not affect the subject component's intended function during the period of extended operation, which verifies the effectiveness of aging management programs credited above and below this interface.

0203 The One Time inspection will confirm, for .omponents subject to an "Air-(Inte.a. " environment, the absence of aging eff*cS eor tha aging is slow acting so as to not affect the subjet component's intended funtion during the period of extended operation.

The Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Pro-gram will manage loss of material, for components subiect to an "Air (Internal)" environment, where the compressed airis not reliably dry and free of contaminants. Moisture in the air may be sufficient to cause general corrosion of steel components.

0211 The One-Time Inspection will confirm, for components subject to a "Moist air (Internal)" environment at the air-waterinterface, the absence of aging effects or that aging is slow acting so as to not affect the subject component's intended function during the period of extended operation, which verifies the effectiveness of aging managementprogramscredited above and below this interface.

Enclosure L-11-153 Page 21 of 206 Affected LRA Section LRA Page No. Affected Paraciraph and Sentence Section 3.2 Page 3.2-118 Note 0207 Plant-Specific Notes In response to RAI B.2.8-1, Note 0207 in Section 3.2 "Plant-Specific Notes" is revised as follows:

Plant-Specific Notes:

0207 Not Used. The One Tirme Inspet..n wM9 provide ver.fit*.-,n f Clo.se-d Coaling Water-Chemistry Pro.gramof.*tiveno..

Affected LRA Section LRA Page No. Affected Paragraph and Sentence Section 3.2 Page 3.2-118 New Note 0212 Plant-Specific Notes In response to RAI B.2.2-2, new Note 0212 is added to Section 3.2 "Plant-Specific Notes" as follows:

Plant-Specific Notes:

0212 The Above-ground Steel Tanks Inspection focuses on the tank bottom and the interface between the tank and foundation. The External Surfaces Monitoring Program manages the external surfaces of the tank above the foundation.

Enclosure L-11-153 Page 22 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence 3.3.2.1.1 Page 3.3-5 "Aging Management Programs" section In response to RAls 3.3.2.2.5-1 and 3.3.2.71-2, the "Aging Management Programs" section of Section 3.3.2.1.1 is revised to read:

The following aging management programs manage the aging effects for subject mechanical components of the Auxiliary Building HVAC System:

• Bolting Integrity Program

• Boric Acid Corrosion Program

• Collection, Drainage, and Treatment Components Inspection Program

• External Surfaces Monitoring Program

" Inspection of Internal Surfaces in Miscellaneous Piping and Ductincq Program

• Lubricating Oil Analysis Program

" One-Time Inspection

" Open-Cycle Cooling Water Program

" Selective Leaching Inspection

Enclosure L-11-153 Page 23 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence 3.3.2.1.2 Page 3.3-6 "Aging Management Programs" section In response to RAI 3.3.2.71-2, the "Aging Management Programs" section of Section 3.3.2.1.2 is revised to read:

The following aging management programs manage the aging effects for subject mechanical components of the Auxiliary Building Chilled Water System:

• Bolting Integrity Program

• Boric Acid Corrosion Program

• Closed Cooling Water Chemistry n Program

• External Surfaces Monitoring Program

• Inspection of Internal Surfaces in Miscellaneous Piping and Ductinq Program

• One-Time Inspection

• Selective Leaching Inspection

Enclosure L-11-153 Page 24 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence 3.3.2.1.3 Page 3.3-8 "Aging Management Programs" section In response to RAI 3.3.2.71-2, the "Aging Management Programs" section of Section 3.3.2.1.3 is revised to read:

The following aging management programs manage the aging effects for subject mechanical components of the Auxiliary Steam and Station Heating System:

" Bolting Integrity Program

• Boric Acid Corrosion Program

• Closed Cooling Water Chemistry n Program

• External Surfaces Monitoring Program

• Flow-Accelerated Corrosion (FAC) Program

• Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Program

• One-Time Inspection

• PWR Water Chemistry Program

• Selective Leaching Inspection

Enclosure L-11-153 Page 25 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence 3.3.2.1.6 Page 3.3-11 "Aging Management Programs" section In response to RAI 3.3.2.2.5-1, the "Aging Management Programs" section of Section 3.3.2.1.6 is revised to read:

The following aging management programs manage the aging effects for subject mechanical components of the Circulating Water System:

" Bolting Integrity Program

" External Surfaces Monitoring Program

" Flow-Accelerated Corrosion (FAC) Program

" Inspection of Internal Surfaces in Miscellaneous Pipinq and Ductinq Program

" One Time Inspection

" Open-Cycle Cooling Water Program Affected LRA Section LRA Page No. Affected Paragraph and Sentence 3.3.2.1.8 Page 3.3-13 "Aging Management Programs" section In response to RAls B.2.8-1 and 3.3.2.71-2, the "Aging Management Programs" section of Section 3.3.2.1.8 is revised to read:

The following aging management programs manage the aging effects for subject mechanical components of the Containment Hydrogen Control System:

" Bolting Integrity Program

" Boric Acid Corrosion Program

" Closed Cooling Water Chemistry Program

" External Surfaces Monitoring Program

" Inspection of Internal Surfaces in Miscellaneous Pipinq and Ductinq Program

" One Timre Inspection

• Open-Cycle Cooling Water Program

Enclosure L-11-153 Page 26 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence 3.3.2.1.12 Page 3.3-17 "Aging Management Programs" section In response to RAIs 3.3.2.2.5-1 and 3.3.2.71-2, the "Aging Management Programs" section of Section 3.3.2.1.12 is revised to read:

The following aging management programs manage the aging effects for subject mechanical components of the Emergency Diesel Generators System:

• Bolting Integrity Program

" Buried Piping and Tanks Inspection Program

" Closed Cooling Water Chemistry Program

" External Surfaces Monitoring Program

• Fuel Oil Chemistry Program

" Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Pro-gram

• Lubricating Oil Analysis Program

• One-Time Inspection

" Selective Leaching Inspection Affected LRA Section LRA Page No. Affected Paragraph and Sentence 3.3.2.1.13 Page 3.3-18 "Aging Management Programs" section In response to RAI 3.3.2.2.5-1, the "Aging Management Programs" section of Section 3.3.2.1.13 is revised to read:

The following aging management programs manage the aging effects for subject mechanical components of the Emergency Ventilation System:

" Bolting Integrity Program

• Boric Acid Corrosion

• External Surfaces Monitoring Program

" Inspection of Intemal Surfaces in Miscellaneous Piping and Ducting Program

Enclosure L-11-153 Page 27 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence 3.3.2.1.14 Page 3.3-19 "Aging Management Programs" section In response to RAIs 3.3.2.2.5-1 and 3.3.2.71-2, the "Aging Management Programs" section of Section 3.3.2.1.14 is revised to read:

The following aging management programs manage the aging effects for subject mechanical components of the Fire Protection System:

" Aboveground Steel Tanks Inspection Program

" Bolting Integrity Program

" Boric Acid Corrosion Program

" Buried Piping and Tanks Inspection Program

" Collection, Drainage, and Treatment Components Inspection Program

" External Surfaces Monitoring Program

• Fire Water Program

• Fuel Oil Chemistry Program

" Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Program

" Lubricating Oil Analysis Program

" One-Time Inspection

" PWR Water Chemistry Program

• Selective Leaching Inspection

Enclosure L-11-153 Page 28 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence 3.3.2.1.15 Page 3.3-21 "Aging Management Programs" section In response to RAI 3.3.2.2.5-1, the "Aging Management Programs" section of Section 3.3.2.1.15 is revised to read:

The following aging management programs manage the aging effects for subject mechanical components of the Fuel Oil System:

• Aboveground Steel Tanks Inspection Program

• Bolting Integrity Program

• Buried Piping and Tanks Inspection Program

• External Surfaces Monitoring Program

• Fuel Oil Chemistry Program

" Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Program

" One-Time Inspection Affected LRA Section LRA Page No. Affected Paragraph and Sentence 3.3.2.1.16 Page 3.3-22 "Aging Management Programs" section In response to RAI B.2.8-1, the "Aging Management Programs" section of Section 3.3.2.1.16 is revised to read:

The following aging management programs manage the aging effects for subject mechanical components of the Gaseous Radwaste System:

" Bolting Integrity Program

• Boric Acid Corrosion Program

" Closed Cooling Water Chemistry Program

• Collection, Drainage, and Treatment Components Inspection Program

• External Surfaces Monitoring Program

" One Time Inspection

• Selective Leaching Inspection

Enclosure L-11-153 Page 29 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence 3.3.2.1.17 Page 3.3-23 "Aging Management Programs" section In response to RAI 3.3.2.71-2, the "Aging Management Programs" section of Section 3.3.2.1.17 is revised to read:

The following aging management programs manage the aging effects for subject mechanical components of the Instrument Air System:

" Bolting Integrity Program

• Boric Acid Corrosion Program

• External Surfaces Monitoring Program

" Inspection of Internal Surfaces in Miscellaneous Pipingand Ducting Program

" One Time Inspe-tion

• Selective Leaching Inspection Affected LRA Section LRA Page No. Affected Paragraph and Sentence 3.3.2.1.19 Page 3.3-25 "Materials" section In response to RAI Sampling 1.0, the "Materials" section of Section 3.3.2.1.19 is revised to read:

The materials of construction for subject mechanical components of the Makeup Water Treatment System are:

" Copper Alloy

• Copper Alloy > 15% Zn

• Gray Cast Iron

" Steel

Enclosure L-11-153 Page 30 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence 3.3.2.1.21 Page 3.3-27 "Aging Management Programs" section In response to RAI 3.3.2.2.5-1, the "Aging Management Programs" section of Section 3.3.2.1.21 is revised to read:

The following aging management programs manage the aging effects for subject mechanical components of the Miscellaneous Liquid Radwaste System:

" Bolting Integrity Program

• Boric Acid Corrosion Program

" Collection, Drainage, and Treatment Components Inspection Program

" External Surfaces Monitoring Program

" Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Pro-gram

" One Time Inspection

• Selective Leaching Inspection Affected LRA Section LRA Page No. Affected Paragraph and Sentence 3.3.2.1.23 Page 3.3-29 "Aging Management Programs" section In response to RAI 3.3.2.71-2, the "Aging Management Programs" section of Section 3.3.2.1.23 is revised to read:

The following aging management programs manage the aging effects for subject mechanical components of the Process and Area Radiation Monitoring System:

• Bolting Integrity Program

• Boric Acid Corrosion Program

• External Surfaces Monitoring Program

• Inspection of Internal Surfaces in Miscellaneous Piping and Ductinq Program Gne Time Inspection

Enclosure L-11-153 Page 31 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence 3.3.2.1.28 Page 3.3-34 "Aging Management Programs" section In response to RAI 3.3.2.2.5-1, the "Aging Management Programs" section of Section 3.3.2.1.28 is revised to read:

The following aging management programs manage the aging effects for subject mechanical components of the Spent Resin Transfer System:

• Bolting Integrity Program

• External Surfaces Monitoring Program

• Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Program

• One-Time Inspection Affected LRA Section LRA Page No. Affected Paragraph and Sentence 3.3.2.1.29 Page 3.3-35 "Materials" section In response to RAI Sampling 1.0, the "Materials" section of Section 3.3.2.1.29 is revised to read:

The materials of construction for subject mechanical components of the Station Air System are:

• CopperAlloy

• Copper Alloy > 15% Zn

• Polymer

" Steel

Enclosure L-11-153 Page 32 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence 3.3.2.1.29 Page 3.3-35 "Aging Effects Requiring Management" section In response to RAI Sampling 1.0, the "Aging Effects Requiring Management" section of Section 3.3.2.1.29 is revised to read:

The following aging effects require management for the subject mechanical components of the Station Air System

• Hardening and loss of strength 0 Loss of material

• Loss of preload Affected LRA Section LRA Page No. Affected Paragraph and Sentence 3.3.2.1.29 Page 3.3-35 "Aging Management Programs" section In response to RAI 3.3.2.71-2, the "Aging Management Programs" section of Section 3.3.2.1.29 is revised to read:

The following aging management programs manage the aging effects for subject mechanical components of the Station Air System:

" Bolting Integrity Program

" Boric Acid Corrosion Program

• External Surfaces Monitoring Program I

inspection of Internal Surfaces in Miscellaneous Piping and Ductinq Program One Tlime egInspection

• Selective Leaching Inspection

Enclosure L-11-153 Page 33 of 206.

Affected LRA Section LRA Page No. Affected Paragraph and Sentence 3.3.2.1.30 Page 3.3-37 "Aging Management Programs" section In response to RAIs 3.3.2.2.5-1 and 3.3.2.71-2, the "Aging Management Programs" section of Section 3.3.2.1.30 is revised to read:

The following aging management programs manage the aging effects for subject mechanical components of the Station Blackout Diesel Generator System:

" Bolting Integrity Program

" Closed Cooling Water Chemistry Program

" External Surfaces Monitoring Program

" Fuel Oil Chemistry Program

• Inspection of Internal Surfaces in Miscellaneous Piping and Ductinq Program

• Lubricating Oil Analysis Program

" One-Time Inspection

" Selective Leaching Inspection Affected LRA Section LRA Page No. Affected Paragraph and Sentence 3.3.2.1.31 Page 3.3-38 "Aging Management Programs" section In response to RAI 3.3.2.71-2, the "Aging Management Programs" section of Section 3.3.2.1.31 is revised to read:

The following aging management programs manage the aging effects for subject mechanical components, of the Station Plumbing, Drains, and Sumps System:

• Bolting Integrity Program

" Boric Acid Corrosion Program

" External Surfaces Monitoring Program

" Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Pro-gram

" One Time gInspection

" Selective Leaching Inspection

Enclosure L-11-153 Page 34 of 206 Affected LRA Section LRA Page No. Affected Paraaraph and Sentence 3.3.2.1.32 Page 3.3-39 "Aging Management Programs" section In response to RAI B.2.8-1, the "Aging Management Programs" section of Section 3.3.2.1.32 is revised to read:

The following aging management programs manage the aging effects for subject mechanical components of the Turbine Plant Cooling Water System:

• Bolting Integrity Program

• Closed Cooling Water Chemistry Program

• External Surfaces Monitoring Program

" One Time Inspection Affected LRA Section LRA Page No. Affected Paragraph and Sentence 3.3.2.2.3.3 Page 3.3-40 Entire section In response to RAI 3.3.2.71-2, Section 3.3.2.2.3.3 is revised to read:

Cracking due to stress corrosion cracking could occur in stainless steel diesel engine exhaust piping, piping components, and piping elements exposed to diesel exhaust. At Davis-Besse, the flexible connections and tubing of the diesel exhaust systems are stainless steel, while the diesel exhaust piping, and other piping components and piping elements are steel. Cracking due to stress corrosion cracking for stainless steel diesel engine exhaust piping components, though it is not expected to occur, will be detccted and ,haraGterizd4 managed by the plant-specific One Time Inspection Inspection of Internal Surfaces in Miscellaneous Pipingand Ducting Program.

Enclosure L-11-153 Page 35 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence 3.3.2.2.5.1 Page 3.3-41 Last sentence In response to RAI 3.3.2.2.5-1, the last sentence of Section 3.3.2.2.5.1 is revised to read:

At Davis-Besse, hardeningand loss of strength due to elastomer degradationin elastomer seals and components in the Auxiliary Systems that are exposed to air-indooruncontrolled (internaland external) are managed by the External Surfaces Monitoring Programsupplemented by the Inspection of Internal Surface in Miscellaneous Pioina and Ductinca Proaram.

Affected LRA Section LRA Page No. Affected Paragraph and Sentence 3.3.2.2.5.2 Page 3.3-41 Last sentence In response to RAI 3.3.2.2.5-1, the last sentence of Section 3.3.2.2.5.2 is revised to read:

Hardeningand loss of strength for these elastomer components will be deteoted and chaFGaterized managed by the One Time RnSPection Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Prowram.

Affected LRA Section LRA Page No. Affected Paragraph and Sentence 3.3.2.2.7.3 Page 3.3-43 Entire section In response to RAI 3.3.2.71-2, Section 3.3.2.2.7.3 is revised to read:

Loss of material due to general (steel only), pitting, and crevice corrosion could occur for steel and stainless steel diesel exhaust piping, piping components, and piping elements exposed to diesel exhaust. At Davis-Besse, loss of materialdue to general (steel only), pitting, and crevice corrosionfor steel and stainless steel diesel exhaust piping, piping components, and piping elements that are exposed to diesel exhaust will be detected and characterizedmanaged by theplant-specific One Time Inspecton* Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Program.

Enclosure L-11-153 Page 36 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence 3.3.2.2.10.3 Page 3.3-44 Entire section In response to RAI 3.3.2.71-2, Section 3.3.2.2.10.3 is revised to read:

Loss of material due to pitting and crevice corrosion could occur for copper alloy heating, ventilation, and air conditioning piping; piping components and piping elements exposed to condensation (external). At Davis-Besse, loss of material due to pitting and crevice corrosion for copper alloy piping,- piping components, and piping elements that are exposed to condensation (external) is managed by the External Surfaces Monitoring Program. Loss of material for copper alloy bolting that is exposed to a condensation (external) environment is managed by the Bolting Integrity Program. For copper alloy heat exchanger components that are exposed to a condensation (external)environment, the plant-specific One

-Time, nspetO.n Inspection of InternalSurfaces in Miscellaneous Piping and Ducting Programwill detect and characterizemanaqe loss of material.

Affected LRA Section LRA Page No. Affected Paragraph and Sentence 3.3.2.2.10.5 Page 3.3-45 Entire section In response to RAI 3.3.2.71-2, Section 3.3.2.2.10.5 is revised to read:

Loss of material due to pitting and crevice corrosion could occur for heating, ventilation, and air conditioning aluminum piping; piping components and piping elements, and stainless steel ducting and components exposed to condensation.

Loss of material due to pitting and crevice corrosion for stainless steel piping, piping components, and piping elements that are exposed to external condensation at Davis-Besse is managed by the External Surfaces Monitoring Program. The plant-specific One Time Inspectn* Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Program will detect and characterize manage loss of materialdue to pitting and crevice corrosionfor stainless steel heat exchangercomponents that are exposed to external condensation; and for stainless steel piping, piping components, piping elements, and tanks (including demisters, drain pans, and moisture separators)that are exposed to internal condensation. The Bolting Integrity Program will manage loss of material due to pitting and crevice corrosion for stainless steel bolting that is exposed to external condensation.

Enclosure L-11-153 Page 37 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence 3.3.2.2.10.6 Page 3.3-45 Entire section In response to RAI 3.3.2.71-2, Section 3.3.2.2.10.6 is revised to read:

Loss of material due to pitting and crevice corrosion could occur for copper alloy fire protection system piping, piping components, and piping elements exposed to internal condensation. The Davis-Besse Fire Protection System contains no piping, piping components, or piping elements exposed to internal condensation.

However, loss of materialdue to pitting and crevice corrosionfor other copper alloy piping, piping components, and piping elements exposed to internal condensation will be detected and characterizedmanaged by the plant-specific One Time inspection Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Program.

Enclosure L-11-153 Page 38 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table 3.3.1 Page 3.3-77 "Discussion" column, various rows through 83 In response to RAI B.2.8-1, the following paragraphs are deleted from the "Discussion" column of the below listed rows of Table 3.3.1:

Row 3.3.1-46 In addito, n, the One Time Inspection wil provide verficati;n of the effectivenes, of the Closed Cooling Water Chemisty Pfrogram to ma*nage cra*cng.

Row 3.3.1-47 In addition, the One Time Inspection w*il provide verification of the effecti,,nes, of the Closed Coling Water-Chemistry Program to manage loss of material.

Row 3.3.1-48 In addition, the One Time Inspection wil proVide verification of the effectiveness of the Closed Cooling Water Chemistry Program to manage loss of material.

Row 3.3.1-50 in additin, the One Time Inspection Mil provide verfication of the effectiveness of the Closed Cooling Water Chemistry P-rogram to m~anage loss of material.

Row 3.3.1-51 in addition, the One Time Inspection wil provide verification of the effectiveness of the Closed Cooln~g Wter-Chemistry P-rogram to manage loss of material.

Row 3.3.1-52 in addition, the One Time Inspection will provide verification of the effectiveness of the Clos-ed Coolhing Water-Chemistry Program to manage reduction in heat tvansfern

Enclosure L-11-153 Page 39 of 206 Affected LRA Section LRA Page No. Affected ParaaraDh and Sentence Table 3.3.1 Pages 3.3-50 Various Rows through 97 Text in "Discussion" column is revised based on the response to RAI 3.3.2.71-2. LRA Table 3.3.1, "Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of NUREG-1801," now reads:

Table 3.3.1 Summary of Aging Management Programs for Auxiliary. Systems Evaluated in Chapter VII of NUREG-1 801 Further Item Aging Effect/ Aging Management Number Component/Commodity Mechanism Programs Evaluation Discussion Recommended 3.3.1-06 Stainless steel diesel engine Cracking due to A plant specific aging Yes, plant Consistent with NUREG-1801.

exhaust piping, piping stresscorrosion management program is specific Cracking in stainless steel diesel components, and piping cracking to be evaluated.

elements exhaust exposed to diesel engine exhaust components, piping, and pipingpiping elements that are exposed to diesel exhaust, though it is not expected to occur, will be detected and Gharacterizedby the One Time !nSPoction managed by the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Program.

Further evaluation is documented in Section 3.3.2.2.3.3.

Enclosure L-11-153 Page 40 of 206 Table 3.3.1 Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of NUREG-1 801 Item Aging Effect/I Aging Management Further Number Numbr Component/Commodity Mechanism Mchaism Programs Evaluation rogamsRecommended Discussion 3.3.1-18 Stainless steel and steel diesel Loss of material/ A plant specific aging Yes, plant Consistent with NUREG-1801.

engine exhaust piping, piping general (steel only), management program is specific Loss of materialin stainless steel components, and piping pitting and crevice to be evaluated. and steel diesel engine exhaust elements exhaust exposed to diesel corrosion and piping piping, piping inenexhand components, and piping elements that are exposed to diesel exhaust will be deteGte4 and Gh-aracterizedby the One Time Inspection managed by the Inspection of Internal Surfaces in Miscellaneous Piping and Ductinq Program.

Further evaluation is documented in Section 3.3.2.2.7.3.

3.3.1-25 Copper alloy HVAC piping, Loss of material due A plant-specific aging Yes, plant Consistent with NUREG-1801.

piping components, piping to pitting and crevice management program is specific elements exposed to corrosion to be evaluated. Except as noted below, loss of condensation (external) material in copper alloy piping components, and piping, piping elements that are exposed to condensation (external) is managed by the External Surfaces Monitoring Program.

For copper alloy bolting that is exposed to condensation (external), the Bolting Integrity Program manages loss of material. For copperalloy heat exchanger components that are

Enclosure L-11-153 Page 41 of 206 Table 3.3.1 Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of NUREG-1 801 Item g Efft Ag Ma t Further Iter Component/Commodity Aging ec ging anagemens Evaluation Discussion Number Mechanism Programs Recommended exposed to condensation (external), the Qne-Time Inspetin 144ill detýct*,* ,;;,P1 GhaFa~teFqe-lnspection of Internal Surfaces in MiscellaneousPiping and Ducting Program will manage loss of material.

Further evaluation is documented in Section 3.3.2.2.10.3.

+

• 3.3.1-27 Stainless steel HVAC ducting Loss of material due A plant-specific aging Yes, plant Consistent with NUREG-1 801.

and aluminum HVAC piping, to pitting and crevice management program is specific piping components and piping Except as noted, loss of material corrosion to be evaluated.

in stainless steel piping, piping elements exposed to condensation components, and piping elements that are exposed to condensation (external) is managed by the External Surfaces Monitoring Program.

For stainless steel heat exchangercomponents that are exposed to external condensation, and for stainless steel piping, piping components, piping elements, and tanks (including demisters, drainpans, and moisture separators)that are exposed to internal

Enclosure L-11-153 Page 42 of 206 F Table 3.3.1 Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of NUREG-1 801 Aging Management Further Euatis T i Item Aging Effect/

Number Component/Commodity Mechanism Programs Econ Discussion Recommended condensation, the Qne-Time

!nspe'tiEnw41l detect and eharaGterze-lnspectionof Internal Surfaces in MiscellaneousPiping and Ducting Programwill manage loss of material.

Loss of material in stainless steel bolting that is exposed to external condensation is managed by the Bolting Integrity Program.

Further evaluation is documented in Section 3.3.2.2.10.5.

Enclosure L-1 1-153 Page 43 of 206 Table 3.3.1 Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of NUREG-1 801 Item CCAging Effect/ Aging Management Further Number Component/Commodity Mechanism Programs Evaluation Discussion Recommended 3.3.1-28 Copper alloy fire protection Loss of material due A plant-specific aging Yes, plant Consistent with NUREG-1 801.

piping, piping components, and to pitting and crevice management program is specific piping elements exposed to The Davis-Besse Fire Protection corrosion to be evaluated.

condensation (internal) System does not contain piping, piping components, or piping elements that are exposed to internal condensation and subject to aging management review. However, the mo- Time lnspectiOn wigl detOct andI aFate4e-lnspection of Internal Surfaces in Miscellaneous Piping and Ducting Program will manage loss of material due to pitting and crevice corrosion for other copper alloy piping, piping components, and piping elements that are exposed to internal condensation.

Further evaluation is documented in Section 3.3.2.2.10.6.

Enclosure L-11-153 Page 44 of 206 Table 3.3.1 Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of NUREG-1801 Further Euatis s Item Aging Effect/ Aging Management Number Component/Commodity Mechanism Programs Evaluation Discussion Recommended 3.3.1-53 Steel compressed air system Loss of material due Compressed Air No Consistent with NUREG 1801, piping, piping components, and to general and Monitoring but a differ-en A plant-specific piping elements exposed to pitting corrosion aging management program is condensation (internal) assigned.

Loss of materialin steel piping, piping components, and piping elements that are exposed to condensation (internal)is detected and Gharacterizedby the One Time InspectiGn managed by the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Program.

3.3.1-54 Stainless steel compressed air Loss of material due Compressed Air No Consistent with NUREG-1801, system piping, piping to pitting and crevice Monitoring but a different aging components, and piping corrosion management program is elements exposed to internal assigned.

condensation Loss of material in stainless steel piping, piping components, and piping elements that are exposed to condensation (internal) in the Waste Gas System will be detected and characterized by the Collection, Drainage, and Treatment Components Inspection. This item is also applied to the stainless steel waste gas surge tank that is

Enclosure L-11-153 Page 45 of 206 Table 3.3.1 Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of NUREG-1801 I Further Item Aging Effect/ Aging Management Euatiss Number Component/Commodity Mechanism Programs Evaluation Discussion Recommended exposed to condensation (internal).

Loss of material in stainless steel tubing in the InstrumentAir System that is exposed to condensation (internal)will be detected and characterizedby the One Time inSpection managed by the Inspection of Internal Surfaces in MiscellaneousPiping and Ducting Program.

For piping, piping components, and piping elements in the Auxiliary Steam and Station Heating System, where the condensation (internal) environment originates from the Main Steam System, loss of material is managed by the PWR Water Chemistry Program. The One-Time Inspection will provide verification of the effectiveness of the PWR Water Chemistry Program to manage loss of material. t

Enclosure L-11-153 Page 46 of 206 Table 3.3.1 Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of NUREG-1801 item Item Component/Commodity Aging Effect/ Aging Management T Further Euatis s Number i Mechanism Programs Evaluation Recommended Discussion 3.3.1-71 Steel piping, piping Loss of material due Inspection of Internal No Consistentwith NUREG 1801, components, and piping to general, pitting, Surfaces in but a different A plant-specific elements exposed to moist air and crevice Miscellaneous Piping aging management programis or condensation (Internal) corrosion and Ducting assigned.

Components Loss of materialin steel piping, piping components, piping elements, and tanks that are exposed to air (internal)and moist air(internal)will be dte te~ d anpd Gharactr-hrzedby the Ono Time Inspection managed by the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Pro-gram.

3.3.1-72 Steel HVAC ducting and Loss of material due Inspection of Internal No Consistent with NUREG-1 801, components internal surfaces to general, pitting, Surfaces in but a different aging exposed to condensation crevice, and (for drip Miscellaneous Piping management program is (Internal) pans and drain lines) and Ducting assigned.

microbiologically Components Although there is no steel ducting influenced corrosion that is exposed to condensation (internal), loss of material in steel piping; piping components, and piping elements that are exposed to condensation (internal) will be detected and Gharacterizedby the One Time inspection managed by the Inspection of Internal Surfaces in

Enclosure L-11-153 Page 47 of 206 Table 3.3.1 Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of NUREG-1 801 Item Aging Effect/ Aging Management Further Number Mechanism Programs Evaluation Discussion Recommended MiscellaneousPiping and Ducting Program, except as noted below.

For piping, piping components, and piping elements and tanks in the Auxiliary Steam and Station Heating System, where the condensation (internal) environment originates from the Main Steam System, loss of material is managed by the PWR Water Chemistry Program. The One-Time Inspection will provide verification of the effectiveness of the PWR Water Chemistry Program to manage loss of material.

Enclosure L-11-153 Page 48 of"206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Pages 3.3-53 Table 3.3.1 through 98 Various Rows Text in "Discussion" column is revised based on the response to RAI 3.3.2.2.5-1. LRA Table 3.3.1, "Summary of Aging Management Programs for Auxiliary System Evaluated in Chapter VII of NUREG-1801," is revised to read:

Table 3.3.1 Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of NUREG-1801 Item T Aging Aging Management Programs Further Evaluation Discussion Number Component/Commodity Effect/Mechanism Recommended 3.3.1-11 Elastomer seals and Hardening and loss A plant specific aging Yes, plant Consistent with NUREG-1801.

components exposed to air - of strength due to management program specific Hardeningand loss of strength in indoor uncontrolled elastomer is to be evaluated. elastomer seals and components (internal/external) degradation in the Auxiliary Systems that are exposed to air-indoor uncontrolled (internaland external) are managed by the External Surfaces Monitoring Programsupplemented by the Inspection of InternalSurfaces in MiscellaneousPiping and Ductinq Program.

Further evaluation is documented in Section 3.3.2.2.5.1.

Enclosure L-11-153 Page 49 of 206 Table 3.3.1 Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of NUREG-1801 Item Number ComponentCommodity Aging Effect/Mechanism i Aging Management Programs Further Evaluation Recommended Discussion 3.3.1-12 Elastomer lining exposed to Hardening and loss A plant specific aging Yes, plant Consistent with NUREG-1 801.

treated water or treated borated of strength due to management program specific There are no elastomer linings in water elastomer is to be evaluated.

the Spent Fuel Pool Cooling and degradation Cleanup System that are exposed to treated water or to treated borated water and subject to aging management review.

However, this item is applied to elastomer components (not linings) in the Spent Resin Transfer System that are exposed to the treated water >

60'C (> 140 0 F) environment that are susceptible to hardening and loss of strength. Hardeningand loss of strength in these elastomercomponents will be rdetected and Gharacterizedby the One Time Inspection managedby the Inspection of Internal Surfaces in MiscellaneousPiping and Ducting Program.

Further evaluation is documented in Section 3.3.2.2.5.2.

Enclosure L-11-153 Page 50 of 206 Table 3.3.1 Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of NUREG-1801 Item Aging Aging Management Further Number Effect/Mechanism Programs Evaluation Discussion Recommended 3.3.1-61 Elastomer fire barrier Increased Fire Protection No Consistent with NUREG-1 801, penetration. seals exposed to hardness, but a different aging air - outdoor or air - indoor shrinkage and loss management program is uncontrolled of strength due to assigned.

weathering Hardeningand loss of strength for elastomer flexible connections that are exposed to air-outdoorare managed by the External Surfaces Monitoring Programsupplemented by the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting ProQgram.

3.3.1-75 Elastomer seals and Hardening and loss Open-Cycle Cooling No Consistent with NUREG-1801, components exposed to raw of strength due to Water System but a different aging water elastomer management program is degradation; loss assigned.

of material due to Hardeningand loss of strength for elastomer components that are exposed to raw water will be det**t*d and GharateFrizedby tho O-nt Time Ins* pction managed by the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Program.

Enclosure L-11-153 Page 51 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table 3.3.1 Page 3.3-75 Row 3.3.1-40, "Discussion" column Text in "Discussion" column is revised based on the response to RAI B.2.2-3. LRA Table 3.3.1, "Summary of Aging Management Programs for Auxiliary System Evaluated in Chapter VII of NUREG-1801," is revised to read:

Table 3.3.1 Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of NUREG-1801 Item i Aging Aging Management Further Number Component/Commodity Effect/Mechanism Programs Evaluation Discussion Recommended 3.3.1-40 Steel tanks in diesel fuel oil Loss of material due Aboveground Steel No Consistent with NUREG-1801, system exposed to air - outdoor to general, pitting, Tanks with exceptions.

(external) and crevice Loss of material in the steel fire corrosion water storage tank in Fire Protection System and the steel diesel oil storage tank in the Fuel Oil System that are exposed to air - outdoor (external) are managed by the Aboveground Steel Tanks Inspection Program.

Enclosure L-11-153 Page 52 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table 3.3.1 Page 3.3-76 Row 3.3.1-45, "Discussion" column Text in "Discussion" column is revised based on the response to RAI B.2.10-2. Bolting for cranes, monorails and hoists is now aligned to this row, and LRA Table 3.3.1, "Summary of Aging Management Programs for Auxiliary System Evaluated in Chapter VII of NUREG-1 801," now reads:

Table 3.3.1 Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of NUREG-1801 Item Component/Commodity Aging Aging Manams Further Evaluation Discussion Number Effect/Mechanism Programs Recommended 3.3.1-45 Steel closure bolting exposed to Loss of preload Bolting Integrity No Consistent with NUREG-1 801, air - indoor uncontrolled due to thermal with exceptions.

(external) effects, gasket creep, and Loss of preload in steel bolting self-loosening that is exposed to air-indoor uncontrolled (external) is managed by the Bolting Integrity Program.

Loss of preload in steel bolting for cranes, monorails and hoists that is exposed to air-indooris managed by the Cranesand Hoists Inspection Program.

Enclosure L-11-153 Page 53 of 206 Affected LRA Section LRA Page No. Affected ParaoraDh and Sentence Table 3.3.2-1 Pages 3.3-119 Various Rows through 140 In response to RAI 3.3.2.71-2, rows of LRA Table 3.3.2-1, "Aging Management Review Results - Auxiliary Building HVAC System," are revised as follows:

Table 3.3.2-1 Aging Management Review Results - Auxiliary Building HVAC Systems No. Type Function(s) Material TnAging Environment Effect Requiring Aging Management NUREG Voue1 Te Notes Row Cope Intended Management Program Volume 1 Item 2 Item One Time inspeGUeR Inspection of 23 Drain Pan Structural Steel Condensation Loss of Internal VII.F1- 3.3.1- E integrity (Internal) material Surfaces in 3 72 0306 Miscellaneous Piping and

__________Ductinci One-Time Heat Exchanger coil fins) Air-indoor Inspection of 76 -(cooling CREVS Copper uncontrolled Reduction in IntenalG cooling coils transfer Alloy (External) heat transfer Surfaces in Miscellaneous (DB-E106-1 &2) Piping and

____ ______ ___

________

___

____ ___ ____ _ __ ___ ____ __ _ ___ ____ ___ Ductina _ _ _ _ ____ _ _ _

Enclosure L-11-153 Page 54 of 206 Table 3.3.2-1 Aging Management Review Results - Auxiliary Building HVAC Systems Row Component IntendedAgnEfetgig-81 Aging Effect Aging NUREG Tal No. Type Function(s) Material Environment Requiring Management Volume TaIte Notes Management Program I Volume Item 2 Item One-Time Heat Exchanger PnPeehen (cooling coil fins) Heat Inspection of Condensation Reduction in Intemal 77 - ECCS Room Aluminum N/A N/A H coolers (DB-E42- transfer (External) -heat transfer Surfaces in Miscellaneous 1, 2, 4, & 5) Piping and Ducting One Time Heat Exchanger lnspeGtkn Inspection of 1=1 (cooling coil fins) Heat Condensation Loss of Intemal VII.Fl- 3.3.1- E 78 - ECCS Room Aluminum coolers (DB-E42- transfer (External) material Surfaces in 14 27 0306 Miscellaneous 0331 1, 2, 4, & 5) Piping and Ductinci OneTqme Heat Exchanger #nspeetien Inspection of (cooling coil fins) Heat Copper Condensation Reduction in Internal 79 - ECCS Room transfer Alloy (External) heat transfer Surfaces inH cooler Miscellaneous (DB-E42-3) Piping and Ducting QRe--Tme Heat Exchanger inSpeetieR Inspection (cooling coil fins) Heat Copper Condensation Loss of Internal of VII.Fl- 3.3.1- 1W E

C cooler transfer Alloy (External) material Surfaces in 16 25 0306 cooler Miscellaneous 0331 (DB-E42-3) Piping and

_______

______ ______

_______ _______

______ _______ ______ ______Ducting______________

Enclosure L-11-153 Page 55 of 206 Table 3.3.2-1 Aging Management Review Results - Auxiliary Building HVAC Systems Row No.

Component Type Intended Function(s)

MtgingEfc Material Environment TAging Effect Requiring Aging gn NUREG

-1801, Table Management Volume TaIte Notes Management Program Volume m Item 2 Item One Time Heat Exchanger (cooing oil ir-idoorInspection of 84 (cooling coil Heat Copper uncontrolled Reduction in Internal tubes) - CREVS transfer Alloy (External) heat transfer Surfaces in N/A N/A H cooling coils (Etra)Miscellaneous (DB-E106-1 & 2) Miscelland Ducting Gn T-ime Heat Exchanger ipeG6ie (cooling coil Inspection of 88 tubes) - ECCS Heat Stainless Condensation Reduction in Internal N/A N/A H Room coolers transfer Steel (External) heat transfer Surfaces in (DB-E42-1, 2, 4, Miscellaneous

& 5) Piping and Ducting One-Time Heat Exchanger npeeetien (cooling coil Inspection of 90 tubes) - ECCS Pressure Stainless Condensation Loss of Internal VIIF1- 3.3.1- E Room coolers boundary Steel (External) material Surfaces in 1 27 (DB-E42-1, 2, 4, Miscellaneous

& 5) Piping and Ducting Heat Exchanger inspeotien (cooling coil Inspection of 91 tubes) Heat Copper Condensation Reduction in Internal ECCS Room transfer Alloy (External) heat transfer Surfaces in N/A N/A H coolers Miscellaneous (DB-E42-3) Piping and

_____ ______________________________ ____________________ Duting

Enclosure L-11-153 Page 56 of 206 Table 3.3.2-1 Aging Management Review Results - Auxiliary Building HVAC Systems Row Component Intended Material Environment 1nAging Effect Requiring Aging Management NUREG Vo e Ttem Notes No. Type Function(s) M Program Volume 1 Item 2 Item Heat Exchanger lnspeotien (cooling coil Inspection of 94 tubes) Pressure Copper Condensation Loss of Internal VII.F1- 3.3.1- E ECCS Room boundary Alloy (External) material Surfaces in 16 25 cooler Miscellaneous (DB-E42-3) Piping and Ducting One Time lnspeotion Inspection of 114 Piping Structural Steel Condensation Loss of Internal VII.Fi- 3.3.1- E integrity (Internal) material Surfaces in 3 72 B Miscellaneous Piping and

_____

__ __

__ ___

___ ___

___ __ _ ___ ___ __ ___________ _ ___ ___ __ _ D ctng ___ __ ______ _____

Enclosure L-1 1-153 Page 57 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table 3.3.2-1 Page 3.3-137 Row 99 In response to RAI B.2.31-1, row 99 of LRA Table 3.3.2-1, "Aging Management Review Results - Auxiliary Building HVAC System," is revised as follows:

Table 3.3.2-1 Aging Management Review Results - Auxiliary Building HVAC System Row C t Intended Aging Effect Aging NUREG-Row Componen Funtend Material Environment Requiring L Management Management Program 1801, Item Table 1 Notes Heat Exchanger (tubes) - Copper epe Copper - Raw One-Tinme CREVS Pressure Alloy > Raw water Cracking OeiN/A N/A H water-cooled boundary 15%Aly (Internal) One-Time condensing Inspection unit (DB-S33-1

&2)

Enclosure L-11-153 Page 58 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table 3.3.2-1 Page 3.3-144 New Rows In response to RAI 3.3.2.2.5-1, four new rows are added to LRA Table 3.3.2-1, "Aging Management Review Results - Auxiliary Building HVAC System," as follows:

Table 3.3.2-1 Aging Management Review Results - Auxiliary Building HVAC System NUREG-Row Component Intended Aging Effect Aging 1801 Table 1 No. Type Function(s) Material Environment Requiring Management 1801, Table Notes Management Program Item Inspection of Internal Surfaces in Flexible Pressure Air-indoor Hardening and

- Connection boundary Elastomer uncontrolled loss of Scellnos VIIF1-7 3.3.1-11 E (Internal) strength Miscellaneous Piping and Ducting Inspection of Internal Surfaces in Flexible Pressure Air-indoor Hardening and oneton Elastomer bunayMiscellaneous uncontrolled loss of S n VI VII.-7I7 3311

- 3.3.1-11 E Connection bounda (External) strength Piping and Ducting Inspection of Internal Mechanical Pressure Elastomer uncontrolled loss of Surfaces in VII.F1-7 3.3.1-11 E Sealant boundary (Internal) strength Piping and Ducting

Enclosure L-11-153 Page 59 of 206 Table 3.3.2-1 Aging Management Review Results - Auxiliary Building HVAC System Row Row Component Type Intended Intended Material Environment AigEfc Aging Effect Requiring Aging gn Management

[NUREG-81 al 1801 Table I Notes No.Management Program Volume Item 2 Item Inspection of Internal Mechanical Pressure Elastome Air-indoor Hardening and Surfaces in VIIFI-7 3.3.1-11 E Sealant boundary unotrolle s of Miscellaneous (External) strength Piping and

_____

___ ____

___ ____

_________________ _____________ ____ ____ ____ Ductina ____q _ _ _ _

Enclosure L-11-153 Page 60 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table 3.3.2-2 Pages 3.3-148 Various Rows through 151 In response to RAI 3.3.2.71-2, rows of LRA Table 3.3.2-2, "Aging Management Review Results - Auxiliary Building Chilled Water System," are revised as follows:

Table 3.3.2-2 Aging Management Review Results - Auxiliary Building Chilled Water System Row Row Component Type Intended Intended Material Environment TAging Effect Requiring' Aging Management NUREG

-1801, Table Notes Management Program Volume 1 Item 2 Item Heat Exchanger inspeetien (tubing) - Inspection of 18 Access Control Structural Copper Condensation Loss of Internal VII.Fl- 3.3.1- E Area duct integrity Alloy (External) material Surfaces in 16 25 cooling coil (DB- Miscellaneous E47) Piping and Ducting QG-oTime Heat Exchanger lngpeetie Inspection of (tubing) -

21 Computer Room Structural Copper Condensation Loss of Internal VII.F1- 3.3.1- E A/C unit (DB- integrity Alloy (External) material Surfaces in 16 25 S77) Miscellaneous

$77) Piping and SDucting

Enclosure L-11-153 Page 61 of 206 Table 3.3.2-2 Aging Management Review Results - Auxiliary Building Chilled Water System Aging Effect Aging NUREG Row Component Intended -1801, Table No. Type Function(s) Material I Environment Requiring Management Management Program Volume 2 Item 1 Item Notes Re-Time Heat Exchanger lngpeGPOR (tubing) - Inspection of 24 Control Room air Structural Copper Condensation Loss of Internal VII.F1- 3.3.1- E handling cooling integrity Alloy (External) material Surfaces in 16 25 coil (DB-E44 & Miscellaneous

45) Piping and Ducting Heat Exchanger QneT4ime (tubing) - InSPetoo Electric Inspection of 28 Penetration Structural Copper Condensation Loss of Internal VII.F1- 3.3.1- E Room 402 integrity Alloy (External) material Surfaces in 16 25 cooling coil (DB- Miscellaneous E78) Piping and 578)_ing

Enclosure L-11-153 Page 62 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table 3.3.2-3 Pages 3.3-166 Various Rows, and 2 New Rows through 186 In response to RAI 3.3.2.71-2, rows of LRA Table 3.3.2-3, "Aging Management Review Results - Auxiliary Steam and Station Heating System," are revised as follows:

Table 3.3.2-3 Aging Management Review Results - Auxiliary Steam and Station Heating Systems Row No.

Component Type Intended Function(s) Material Environment TAging Ain Efc Effect Requiring Aging Aig-1801, NUREG Table Management V1ue1 Te Notes

_ _ _ Management Program Volume 1 Item 2 Item CondnN/AonN4A 27 Orifice Structural Stainless Treated water Cracking One-Time VIIIBI- 3.4.1- 4 integrity Steel >60C (>140F) Inspection 5 .4 A

____(Internal) 5 X_4 CondnsaionN/A N/A~I 28 Orifice integrity Steel >60C (>140FJ PWRcknWatemsry VIII.B1- 3.4.1- A

______(Internal)_

CondensationVU 3.-.-

29 Orifice Structural Stainless Treated water Loss of One-Time VII.E3 3.4 A integrity Steel >60C (>140F) material Inspection 15 3.3.1- A (Internal) 24 Condensation -VUD 4 ..

30 Orifice Structural Stainless Treated water Loss of PWR Water VII. E3- 3. A integrity Steel >60C (>140F) material Chemistry 15 3.3.1- A (Internal) 24 Condensation Flow- ,AJ/A G 43 Pn Structural Steel Treated water Loss of Accelerated V111 F- 3.4.1- A 4 iping integrity >60C (>140F) material Corrosion1 364.1- 0A (Internal) (FAC) 26 29

Enclosure L-11-153 Page 63 of 206 Table 3.3.2-3 Aging Management Review Results - Auxiliary Steam and Station Heating Systems Aging Effect Aging NUREG Row Component Intended Material Environment Requiring Management -1801, Table Notes Management Program Volume 1 Item 2 Item reAndsaeV4 -. F1 3.3.

Structural Treated water Loss of One-Time 3 72 E 44 Piping integrity Steel >60C (>140F) material Inspection V11.E4- 3.3.1- A (Internal) 17 177 G end- en s t de nV4 .F 4 3.34-Structural Treated water Loss of PWR Water 3 7-2 E 45 Piping integrity Steel >60C (>140F) material Chemistry V//.E4- 3.3.1- A (Internal) 17 17_

Pump Casing - GCodensateio Flow-10 psig Structural Treated water Loss of Accelerated N/A A/A G 51 condensate integrity Steel VIII. F- 3.4.1- A pump (DB-P118- >60C (>140F) material Corrosion 26 29 03 1 & 2) (Internal) (FAC)

Pump Casing - C33e1sato U Fi .-

10 psig Structural Treated water Loss of One-Time 3 7-2 E 52 condensate integrity Steel >60C (>140F) material Inspection VII. E4- 3.3.1- A pump (DB-P 18- (Internal) 17 17 1 & 2) _____ __

Pump Casing - r (ea at 0A43.3.1-10 psig Structural Treated water Loss of PWR Water 3 -72 E 53 condensate integrity Steel >60C (>140F) material Chemistry VII.E4- 3.3.1- A 1 & 2) (Internal) 17 17 Pump Casing - G3nde1satec U Degasifier Structural Gray Cast Treated water Loss of One-Time 3 72 E 56 package drain integrity Iron >60C (>140F) material Inspection VII.E4- 3.3.1- A pump (DB-P178- (Inera) m r 1-1 & 2) (Internal) 17 17

Enclosure L-11-153 Page 64 of 206 Row Table 3.3.2-3 Aging Management Review Results -Auxiliary Steam and Station Heating Systems Component Intended Material Environment Aging Effect Requiring Aging Management NUREG

-1801, Table I

Notes No. Ty.pe Function(s) Management Maaeet Program Porm 2VIteme Volume 2 Item 1Im 1 ItemI Pump Casing - eneP-at V3.3.1 Degasifier Structural Gray Cast Treated water Loss of PWR Water 3 -72 E pump (DB-P178- integrity Iron >60C (>140F) material Chemistry VII.E4- 3.3.1- A 1 & 2) (Internal) 17 17 Pump Casing - C'AAP A Degasifier S lsd water Selective 58 package drain Structural Gray Cast Treated water Loss of Leaching VII.F1- 3.3.1- A pump (DB-P178- integrity Iron >60C (>140F) material Inspection 18 85 0308 1 & 2) (Internal)

One Time Pump Casing - 18PeG6eee Evaporator Inspection of 61 package Structural Steel Air (Internal) Loss of Internal VII.H2- 3.3.1- E condensate integrity material Surfaces in 21 71 0312 drain pump (DB- Miscellaneous P275-1 & 2) Pipinq and Ducting Pump Casing -

Evaporator Gendensatioe V4 F - 3.3-.-

62 package Structural Steel Treated water Loss of One-Time 3 7-2 E condensate integrity >60C (>140F) material Inspection VII.E4- 3.3.1- A drain pump (DB- (Internal) 17 17 P275-1 & 2)

Pump Casing -

Evaporator GCodensation V41.F--- 3. 63 package Structural Steel Treated water Loss of PWR Water 3 72 E condensate integrity >60C (>140F) material Chemistry VII.E4- 3.3.1- A drain pump (DB- (Internal) 17 17 P275-1 & 2)

Enclosure L-11-153 Page 65 of 206 Table 3.3.2-3 Aging Management Review Results - Auxiliary Steam and Station Heating Systems No. Component w Type Intended Function(s) Material Environment TAging Effect Requiring Aging Management NUREG Volume TaIte Notes 90 (oy) Stuncturals) Management Program Volume 1 Item 2 Item 90 Strainer (body) Structural Gray Cast Treated water Loss of One-Time S 7-2 E integrity Iron >60C (>140F) material Inspection VII.E4- 3.3.1- A (Internal) 17 17 COndensation -V4 1. 344.-

91 Strainer (body) Structural Gray Cast Treated water Loss of PWR Water 3 7-2 E integrity Iron >60C (>140F) material Chemistry VII.E4- 3.3.1- A (Internal) 17 17 Structura R6atSelective Gra Cs 92 Strainer (body) Structural Gray Cast Treated water Loss of Leaching VII.F1- 3.3.1- A integrity Iron >60C (>140F) material Inspection18 85 30 (Internal)

Air indoor E-x-tenal33.

Tank - 10 psig Structural ... nre,,e, Loss of V-!15-8 C 95 condensate tank Steel Steam material A,,iteRg VIII.A- 3.4.1- 0309 (DB-T95)(Internal) PWR Water 16 Chemistry( 02 Tankd- 10 psig -VF4 10 Structural Codasnio Treated water Loss of One-Time 3 7-234- E 9DesTe integrity >60C (>140F) material Inspection. VII.E4- 3.3.1- A (DB-T95) (Internal) 17 17 Tank- 10 si Condensation VUF4- 3.-.--

cpsig 97 Structural Treated water Loss of PWR Water 3 7-2 =

(DB-T95) integrity >60C (>140F) material Chemistry VII.E4- 3.3.1- A (Internal) 17 17 Tank 0pg MeiLt-a i Less-eo V4eG 3.3m 4 E 98 r.. -aiPer-ytan cndensat, 98 StU't'Wal Steel n e.. terna mater-il 23-nspeGti0 74 034-3 Not used.

Enclosure L-11-153 Page 66 of 206 Table 3.3.2-3 Aging Management Review Results - Auxiliary Steam and Station Heating Systems Row No.

Component Type Intended AgnIEfc Aging Effect T Aging Aig-1801, NUREG Table Function(s) Material Environment Requiring Management Volume TaIte Notes Management Program Volume 1 Item 2 Item Tank - GendensatieR V4. F4 3.3--

101 Degasifier Structural Steel Treated water Loss of One-Time 372 -

package drain integrity >60C (>140F) material Inspection VII.E4- 3.3.1- A pump reservoir (Internal) 17 17 Tank - Gendensation VUF-i 3.-.-

102 Degasifier Structural Steel Treated water Loss of PWR Water 3 72 F package drain integrity >60C (>140F) material Chemistry VII.E4- 3.3.1- A pump reservoir (Internal) 17 17 Structural Gray Cast Steam Loss of Flow-Accelerated VIII.A- 3.4.1- A integrity Iron (Internal) material Corrosion (FAC)17 17 29 2_9 034

.3/

Structural Gray Cast Loss of One-Time 3 72 E 106 Trap Body integrity Iron Steam material Inspection VIII.A- 3.4.1- A (Internal) 16 02 Structural Gray Cast Loss of PWR Water 3 72 E 107 Trap Body integrity Iron Steam material Chemistry VIII.A- 3.4.1- A (Internal) 16 02 denesatieSeeciv A Structural Gray Cast Steam Loss of Selective VII.F1- 3.3.1- A 108 Trap Body integrity Iron (Internal) material Inspection 18 85 0308 (intrna) Inpecion0335 GeadensatieR VU F1 -l3.

Structural Treated water Loss of One-Time 3 72 F 117 Tubing integrity Steel >60C (>140F) material Inspection V1I.E4- 3.3.1- A (Internal) 17 17 VUF4 3.-_.-

Structural Treated water Loss of PWR Water 3 7-2 F S18 Tubing integrity Steel >60C (>140F) material Chemistry VII.E4- 3.3.1- A

- (Internal) 17 17

Enclosure L-11-153 Page 67 of 206 Table 3.3.2-3 Aging Management Review Results - Auxiliary Steam and Station Heating Systems Row Component Intended Agn fetAig-1801, Aging Aging Effect NUREG Table No. Type Function(s) Material Environment Requiring Management Voue1 Te Notes Management Program Volume 1 Item 2 Item Structural Copper oneate on One-Time G 128 Valve Body integrity Alloy > Cracking N/A N/A 0 15% Zn >60C (>140F) Inspection 0315 (Internal)

CnGdensation 129 Valve Body Structural Alloy > Treated water Cracking PWR Water N/A N/A G inte y 15%Zn >60C (>140F)

(Internal) Chemistry Cpr Copperrndeuttwa N/A A//A Structural Copper Treated water Loss of One-Time V1.E4- 3.3.1- G 130 Valve Body integrity 15% Zn >60C (>140F) material Inspection 7 31 A (Internal) 7 3_/_ A Stutrl Copper Galste Cndensa_;tion NA'A A//A 131 Valve Body Structural Clloppe Treated water Loss of PWR Water V11.E4 3.3.1- A integrity AlloZy >60C (>140F) material Chemistry 7 31 A (Internal)

CFlow- AVA AV/A 4G 137 Valve Body Structural Gray Cast Treated water Loss of Accelerated VIII.A- 3.4.1- A integrity Iron >60C (>140F) material Corrosion 17 29 (Internal) (FAC)

Condensation -V4 .F4 &3.3.

Structural Gray Cast Treated water Loss of One-Time 3 7-2. E 138 Valve Body integrity Iron >60C (>140F) material Inspection VIII.A- 3.4.1- A (Internal) 16 02 GCodensatien U F4- 3.-_-

Structural Gray Cast Treated water Loss of PWR Water 3 -72 9 139 Valve Body integrity Iron >60C (>140F) material Chemistry VIII.A- 3.4.1- A (Internal) 16 022

Enclosure L-1 1-153 Page 68 of 206 Table 3.3.2-3 Aging Management Review Results - Auxiliary Steam and Station Heating Systems Aging Effect Aging NUREG Row Component Intended Agn fet Aig-1801, Table No. Type Function(s) Material Environment Requiring Management Volume Table Notes Management Program Volume 1 Item 2 Item G

atewo nnSd e e le c t iv e 140 Valve Body Structural Gray Cast Treated water Loss of Leaching VII.F1- 3.3.1- A integrity Iron >60C (>140F)

(internal) material Inspection18 Iseto 85 0308 ondensatiGRA XA4 147 Valve Body Structural Stainless Treated water One-Time VIII.B- 3.4.1- 4 integrity Steel >60C (>140F) Cracking Inspection 5 14 A (Internal)

GeA.rnat AN/A A/A4 148 Valve Body Structural Stainless Treated water Cracking PWR Water VIII.BI- 3.4.1- 4 integrity Steel >60C (>140F) Chemistry 5 14 A (Internal) 1_44_ -

ondensatinVD4 3 .

149 Valve Body Structural Stainless Treated water Loss of One-Time VIII.B1- 34.

integrity Steel >60C (>140F) material Inspection 4 3.4.1- A (Internal) 416__66 GendensatiOR VD4 33 Valve Body Structural Stainless Treated water Loss of PWR Water I 5E 150 integrity Steel >60C (>140F) material Chemistry VIII.B1 3.4.1- A (Internal) , 16 C AMdensataOR Flow- VIII.F- 3.4.1- A Structural Steel Treated water Loss of Accelerated 155 Valve Body integrity >60C (>140F) material Corrosion (Internal) (FAC) 26 29 endensatiR VU F 3-_--

-4 Structural Treated water Loss of One-Time 3 7-2 E 156 Valve Body integrity Steel >60C (>140F) material Inspection VII.E4- 3.3.1- A (Internal) 1__17 177

Enclosure L-11-153 Page 69 of 206 Table 3.3.2-3 Aging Management Review Results - Auxiliary Steam and Station Heating Systems Aging Effect Aging NUREG No. Type Function(s) Material Environment Requiring Management Volum Management TaIte Notes Program Volu2 e I Item 2 Item GO~eRsatmen V4.F1 ..

Structural Treated water Loss of PWR Water 3 72 E 157 Valve Body integrity Steel >60C (>140FI material Chemistry VII.E4- 3.3. 1- A (Internal) 17 17 Tank - 10 psiq Structural Steel Steam Loss of One-Time VIII.A- 3.4.1- C

-- Condensate integrity (Internal) material Inspection 16 02 0315 Tank (DB-T95)

Valve Body Structural Copper Treated water Loss of Selective VIII. G- 3.4.1- A

-- integrity Alloy> >60C (>140F) material Leaching 23 35 15% Zn (Internal) Inspection

Enclosure L-11-153 Page 70 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table 3.3.2-4 Page 3.3-211 Rows 158 & 159 In response to RAI 3.3.2.71-2, rows of LRA Table 3.3.2-4, "Aging Management Review Results - Boron Recovery System," are revised as follows:

Table 3.3.2-4 Aging Management Review Results - Boron Recovery System Row Component Intended Aging Effect Aging NUREG Row Copnen Fnctiendd Material Environment Requiring Management -1801, Table Notes No. Type Function(s) Maaeet Porm Volume 1 Item Management Program 2 Item Tank - E Concentrates Structural Stainless Moist air Loss of One-Time V.D1- 3.2.1- 0312-storage tank integrity Steel (Internal) material Inspection 29 08 0313 (DB-T16) 0332 Tank -

Concentrates Structural Stainless Moist air One-Time H 159 storage tank integrity Steel (Internal) Cracking Inspection N/A N/A 0312 (DB-T16)

Enclosure L-11-153 Page 71 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table 3.3.2-5 Page 3.3-225 Rows 59 & 60 In response to RAI 3.3.2.71-2, rows of LRA Table 3.3.2-5, "Aging Management Review Results - Chemical Addition System," are revised as follows:

Table 3.3.2-5 Aging Management Review Results - Chemical Addition System Row Component Intended Aging Effect Aring T Magint Aging NUREG

-1801, Table No. Type Function(s) Material Environment Requiring Management Volume 1 Item Notes Management Program 2 Item Tank - Boric acid E Tankitioricacid Pressure Stainless Moist air Loss of One-Time V.D1- 3.2.1- 0312 59 addition tanks (DB-T7-1 & 2) boundary Steel. (Internal) material Inspection 29 08 0313 0332 60 Tank - Boric acid addition tanks Pressure Stainless Moist air One-Time N/A N/A H 60 (DB-T7-1 & 2) boundary Steel (Internal) Cracking Inspection 0313

Enclosure L-11-153 Page 72 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table 3.3.2-6 Page 3.3-231 Row 4 and 1 New Row In response to RAI 3.3.2.2.5-1, row 4 of LRA Table 3.3.2-6, "Aging Management Review Results - Circulating Water System," is revised and a new row is added as follows:

Enclosure L-11-153 Page 73 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table 3.3.2-8 Pages 3.3-254 Various Rows through 267 In response to RAI 3.3.2.71-2, rows of LRA Table 3.3.2-8, "Aging Management Review Results - Containment Hydrogen Control System," are revised as follows:

Table 3.3.2-8 Aging Management Review Results - Containment Hydrogen Control System Row Component Intended Aging Effect Aging NUREG Row Type Intended Material Environment Requiring Management -1801, Table Notes Management Program Volume 1 Item 2 Item One Tim~e Inspection of 25 Demister (DB- Pressure Stainless Condensation Loss of Internal VII.Fl- 3.3.1- E S432) boundary Steel (Internal) material Surfaces in 1 27 Miscellaneous Piping and Ducting 1nspeotieR Inspection of 28 Demister (DB- Water Stainless Condensation Loss of Internal VII.F1- 3.3.1- E S432) removal Steel (Internal) material Surfaces in 1 27 Miscellaneous Piping and

_____ __

______

___ ___

___ ___

__ ___ ___ __ ___ ___ ___ _ _ ___ ___ ___ _ D ctiQ _ __ __ __ __ _ __ __ _

Enclosure L-11-153 Page 74 of 206 Table 3.3.2-8 Aging Management Review Results - Containment Hydrogen Control System Row No.

Component Type Intended AgnIEfc Aging Effect I Aging Aig-1801, NUREG Table Function(s) Material Environment Requiring Management Voue1 Te Notes Management Program Volumem Item 2 Item One ie Heat Exchanger #ispe,Otn (tubes) - Air-indoor Inspection of 43 Containment gas Heat Stainless uncontrolled Reduction in Internal N/A N/A H analyzer heat transfer Steel (Internal) heat transfer Surfaces in exchangers (DB- Miscellaneous E197-1 & 2) Piping and Ductina Ot~e-Thme lnSpeetiOn Moisture Inspection of M oisture Pressure Stainless Condensation Loss of Internal VII.F1- 3.3.1- E 49 Separator (DB- boundary Steel (Internal) material Surfaces in 1 27 F131 & 132) Miscellaneous Piping and Ducting One Time Moisture Inspection of M oisture Water Stainless Condensation Loss of Internal VII.F1- 3.3.1- E 52 Separator (DB- removal Steel (Internal) material Surfaces in 1 27 F131 & 132) Miscellaneous Piping and Ducting Qne Time lnspeotien Moisture Inspection of 53 Separator (08- Pressure Steel Condensation Loss of Internal VII.F2- 3.3.1- E S404-1 & 2) boundary (Internal) material Surfaces in 3 72

&2) Miscellaneous Piping and

_________________________________________________________________Ducting ________

Enclosure L-1 1-153 Page 75 of 206 Table 3.3.2-8 Aging Management Review Results - Containment Hydrogen Control System Aging Effect Aging NUREG Row Component Intended Aging Magint -1801, Table No. Type Function(s) Material Environment Requiring Management Volume 1 Item Notes Management Program 2 Item ln~peetien Moisture Inspection of MoiStur Water Condensation Loss of Internal VII.F2- 3.3.1-56 Separator (DB- removal Steel (Itra)material Sufae En37 S404-1 & 2) rmvl(Internal) maeilSurfaces in 3 72 Miscellaneous Piping and Ducting One Time lnspeetion Inspection of 64 Piping Pressure Stainless Condensation Loss of Internal VII.F1- 3.3.1- E boundary Steel (Internal) material Surfaces in 1 27 Miscellaneous Piping and Ducting Qne Time 4inSpeGUen Inspection of Pressure boundary Steel Condensation (Internal) Loss of material Internal Surfaces in VII.F1-3 3.3.1-72 E Miscellaneous Piping and Ducting Qne 4ime Tank - inspeetien Containment Inspection of 85 radiation moisture monitor Pressure boundary Stainless Steel Condensation (Internal) Loss of material Internal Surfaces in VII.F1-1 3.3.1-27 E accumulation

• Miscellaneous tank (DB-T216) Piping and Ducting ________

Enclosure L-11-153 Page 76 of 206 Table 3.3.2-8 Aging Management Review Results - Containment Hydrogen Control System Aging Effect Aging NUREG No. Type Function(s) Material Environment Requiring Management Volume 1 Item Notes Management. Program 2 Item One-Time inspeetion Inspection of Pressure Stainless Condensation Loss of Internal VII.F1- 3.3.1-88 Trap Body boundary Steel (Internal) material Surfaces in 1 27 Miscellaneous Piping and Ducting ne Time lnSpeGfien Inspection of Pressure Stainless Condensation Loss of Internal VII.F1- 3.3.1-92 Tubing boundary Steel (Internal) material Surfaces in 1 27 Miscellaneous Piping and Ducting One Time Inspection of 103 Valve Body Pressure Stainless Condensation Loss of Internal VII.F1- 3.3.1- E boundary Steel (Internal) material Surfaces in 1 27 Miscellaneous Piping and Ducting One Time inspeofien Inspection of Pressure Condensation Loss of Internal VII.F1- 3.3.1-107 Valve Body boundary Steel (Internal) material Surfaces in 3 72 Miscellaneous Piping and Ducting

Enclosure L-11-153 Page 77 of 206 Affected LRA Section LRA Page No. Affected ParagraDh and Sentence Pages 3.3-281 Table 3.3.2-12 through 307 Various Rows In response to RAI 3.3.2.71-2, rows of LRA Table 3.3.2-12, "Aging Management Review Results - Emergency Diesel Generator System," are revised as follows:

Table 3.3.2-12 Aging Management Review Results - Emergency Diesel Generator System Row Component Intended Material Environment

{Aging Effect Requiring Aging Management NUREG

-1801, Table No. Type Function(s) ReuiItemnaemntNotes VolumeEnirnmnt Management Program Volume 1 Item 2 Item 4o-1Tme Compressor Inspection of 14 Casing -

Turbocharger Pressure boundary Steel Diesel exhaust Loss of Internal VII.H2- 3.3.1- E (Internal) material Surfaces in 2 18 (DB-C148-1 & 2) Miscellaneous Piping and Ductingq ne Time inspoe~gen Inspection of 31 Flexible Pressure Stainless Diesel exhaust Internal VII.H2- 3.3.1- E Connection boundary Steel (internal) Cracking Surfaces in 1 06 Miscellaneous Pipinq and

_____

_ __ ___

____

____ ____

_____ _____ ____ ___ ____ _____ ____ ____ ____ Ducting _ __ _ ____

Enclosure L-11-153 Page 78 of 206 Table 3.3.2-12 Aging Management Review Results - Emergency Diesel Generator System Aging Effect Aging NUREG Row Component Intended Aging Magint -1801, Table No. Type Function(s) Material Environment Requiring Management Volume 1 Item Notes Management Program 2 Item Inspection of Flexible Pressure Stainless Diesel exhaust Loss of Internal VII.H2- 3.3.1-Connection boundary Steel (Internal) material Surfaces in 2 18 Miscellaneous Piping and Ductinq One T4ime Hea t E x c h a n g e r .. .pe . . . .

Inspection of (tubes) - Heat Copper Air-outdoor Reduction in Internal E 196-1AA, 1 B, transfer 15% Zn (External) heat transfer Surfaces in N/A N/A H 2A, & 2B) Miscellaneous Piping and Ducting lnSpection Inspection of 89 Piping Pressure Condensation Loss of Internal VI1.D-2 3.3.1- E boundary Steel (Internal) material Surfaces in 53 Miscellaneous Piping and Ducting One Time nspeeGtOR Inspection of Pressure Diesel exhaust Loss of Internal VII.H2- 3.3.1-90 Piping boundary Steel (Internal) material Surfaces in 2 18 E Miscellaneous Piping and Ducting

Enclosure L-11-153 Page 79 of 206 Table 3.3.2-12 Aging Management Review Results - Emergency Diesel Generator System Row No.

Component Intended igingEfec Aging Effect T Aging Aig-1801, NUREG Table Type Function(s) Material Environment Requiring Management Volume TaIte Notes N Management Program Volume 1 Item 2 Item One Time l*speetion Inspection of E 91 Piping Pressure Steel Air (Internal) Loss of Intemal VII.H2- 3.3.1- 0312 boundary material Surfaces in 21 71 Miscellaneous Piping and Ducting ORe-Time inspegOtie Inspection of E 107 P Structural Steel Air (Internal) Loss of Internal VII.H2- 3.3.1- 0312 iping integrity material Surfaces in 21 71 Miscellaneous Piping and Ducting kspetieOn Inspection of 126 Silencer Pressure Steel Diesel exhaust Loss of Internal VII.H2- 3.3.1- E (exhaust) boundary (Internal) material Surfaces in 2 18 Miscellaneous Piping and Ducting One Tme inspeetiOn Inspection of E 134 Strainer (bdy Pressure Steel Air (internal) Loss of Internal VII.H2- 3.3.1- 0312 1oy) boundary material Surfaces in 21 71 Miscellaneous Piping and Ducting

Enclosure L-11-153 Page 80 of 206 Table 3.3.2-12 Aging Management Review Results - Emergency Diesel Generator System Row Component Intended Materiac Aging Effect F Aging agint NUREG

-1801, Table No. Type Function(s) Material Environment Requiring Management Volume 1 Item Notes Management j Program 2 Item One TimRe Tank - EDG Inspection of E 156 starting air Pressure Loss of Internal VII.H2- 3.3.1- 0 receiver (DB- boundary Steel Air (Internal) material Surfaces in 21 71 0312 T86-1, 2, 3, & 4) Miscellaneous Piping and Ducting in~spe~tion Inspection of 175 Tubing Structural Stainless Diesel exhaust Internal VII.H2- 3.3.1- E integrity Steel (Internal) Cracking Surfaces in 1 06 Miscellaneous Piping and Ducting Qne-Time lnpeGtien Inspection of 176 Tubing Structural Stainless Diesel exhaust Loss of Internal VII.H2- 3.3.1- E integrity Steel (Internal) material Surfaces in 2 18 Miscellaneous Piping and Ducting QneTime inseptien Inspection of 185 Valve Body Pressure boundary Condensation Loss of Internal VI1.2 3.3.1- E Steel (Internal) material Surfaces in 53 Miscellaneous Piping and Ducting

Enclosure L-11-153 Page 81 of 206 Row No.

Component Type Intended Function(s) Material Environment AingEEffect Requiring N Management 1ec Table 3.3.2-12 Aging Management Review Results - Emergency Diesel Generator System TAging Ang-1801, Aging Management Program NUREG Volume Volume 2 Item Table TaIte 1 Item Notes Qne Time Inspection of Pressure Diesel exhaust Loss of Internal VII.H2- 3.3.1-186 Valve Body boundary Steel (Internal) material Surfaces in 2 18 E Miscellaneous Piping and Ducting One Time lnspeGUGe Inspection of E Pressure boundary Steel Air (internal) Loss of Internal VII.H2- 3.3.1-material Surfaces in 21 71 0312 Miscellaneous Piping and Ductincq lnspeotio Inspection of E 197 Valve Body Structural Steel Air (Internal) Loss of Internal VII.H2- 3.3.1- 0312 integrity material Surfaces in 21 71 Miscellaneous Piping and Ducting

Enclosure L-11-153 Page 82 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table 3.3.2-12 Page 3.3-304 Row 174 In response to RAI B.2.2-2, row 174 of LRA Table 3.3.2-12, "Aging Management Review Results - Emergency Diesel Generator System," is revised as follows:

Enclosure L-11-153 Page 83 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table 3.3.2-12 Page 3.3-307 New Rows In response to RAIs 3.3.2.2.5-1 and B.2.2-2, new rows are added to LRA Table 3.3.2-12, "Aging Management Review Results - Emergency Diesel Generator System," as follows:

Table 3.3.2-12 Aging Management Review Results - Emergency Diesel Generator System Row Component Intended Aging Effect Aging NUREG-Row T bpe Intended Material Environment Requiring Management 1801 Table Notes No. Type Function(s) Management Program Volume 2 Item Item Structural Stainless Air-outdoor External iTubin ntegrity Steel (Internal) Loss of material Surfaces NIA NIA Q Inspection of Internal Flexible Pressure Air-outdoor Hardening and Surfaces in V11.G-2 3.3.1-61 E Connection boundary Elastomer loss of Miscellaneous V (etPiing and Ductini Inspection of Internal Flexible Pressure astome Air-indoor Hardening and Surfaces in VLF17 3.3.1-11 E Connection boundary uncontrolled loss of Miscellaneous (External) strength Piping and Ducting

Enclosure L-11-153 Page 84 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table 3.3.2-13 Page 3.3-312 4 New Rows In response to RAI 3.3.2.2.5-1, four new rows are added to LRA Table 3.3.2-13, "Aging Management Review Results - Emergency Ventilation System," as follows:

Table 3.3.2-13 Aging Management Review Results - Emergency Ventilation System NUREG-Row Component Intended Aging Effect Aging 1801, i Table 1 Notes No. Type Function(s) Material Environment Requiring Management Volume 2 Item Management Program Item Inspection of Internal Flexible Pressure Elastoe Air-indoor Hardeninqand Surfaces in VIF1-7 3.3.1-11 E Connection bounda uncontrolled loss of Miscellaneous Connection boundary (Internal) s h Piping and Ducting Inspection of Air-indoor Hardeningand Internal Flexible Pressure Elastomer uncontrolled loss of Surfaces in VII.FI-7 3.3.1-11 E Connection boundary (External) strenth Miscellaneous Piping and Ducting Inspection of Internal Mechanical Pressure Elastoe Sealattboudaryuncontrolled Air-indoor Hardening loss of and Surfaces in VIIF7 Miscellaneous1-11 3.3.1-11 E

_

Sealant bound (Internal) strength Miscellaneous Piping and

Enclosure L-11-153 Page 85 of 206 Table 3.3.2-13 Aging Management Review Results - Emergency Ventilation System Row Component Ro opnn Intended nedd Material IAging Environment Reurn Effect Mage Aging nt NUREG-1801, Table 1 Notes No. Type Function(s) equiring anagement Volume 2 Item Management

_ Program Item Inspection of Internal Mechanical Pressure Elastome Air-indoor Hardeningand Surfaces in VIIFI-7 3.3.1-11 E Sealant boundary (External) strensth Miscellaneous Piping and Ducting

Enclosure L-11-153 Page 86 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table 3.3.2-14 Pages 3.3-323 Rows 77, 85, 88, 100 and 131 through 330 In response to RAI B.2.18-1, rows 77, 85, 88, 100 and 131 of LRA Table 3.3.2-14, "Aging Management Review Results - Fire Protection System," are revised as follows:

Table 3.3.2-14 Aging Management Review Results - Fire Protection System

Enclosure L-11-153 Page 87 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table 3.3.2-14 Pages 3.3-327 Row 106 and Row 172 and 334 In response to RAIs 3.3.2.2.5-1, B.2.2-2 and B.2.2-3, rows 106 and 172 of LRA Table 3.3.2-14, "Aging Management Review Results - Fire Protection System," are revised as follows:

Enclosure L-11-153 Page 88 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table 3.3.2-14 Pages 3.3-333 Various Rows through 339 In response to RAI 3.3.2.71-2, rows of LRA Table 3.3.2-14, "Aging Management Review Results - Fire Protection System," are revised as follows:

Table 3.3.2-14 Aging Management Review Results - Fire Protection System Row No. Component Type Intended Function(s) Material TAging Environment Effect Requiring Aging NUREG Management Voue1 Te Notes ST Management Program Volume 2 Item 1 Item One-Time lnspe~hon Inspection of Compressor Pressure Steel Diesel exhaust Loss of Intemal VII.H2- 3.3.1- E Turbocharger boundary (Internal) material Surfaces in 2 18 Miscellaneous PipinQ and Ductingi One Time Inspection of 174 Flexible Pressure Stainless Diesel exhaust Internal VII.H2- 3.3.1- E Connection boundary Steel (Internal) Cracking Surfaces in 1 06 Miscellaneous PipinQ and Ductingq

Enclosure L-11-153 Page 89 of 206 Table 3.3.2-14 Aging Management Review Results - Fire Protection System Row Component Intended I giing AgingEffect Aging .

Mangint NUREG

-1801, Table No. Type Function(s) Material Environment Requiring Management 1 Item Notes Management Program 2VItem Q~e Time inspe~tien Inspection of 175 Flexible Pressure Stainless Diesel exhaust Loss of Internal VII.H2- 3.3.1- E Connection boundary Steel (Internal) material Surfaces in 2 18 Miscellaneous Piping and Ducting QneTqme lnspeetien Inspection of 201 Piping Pressure Steel Diesel exhaust Loss of Internal VII.H2- 3.3.1- E boundary (Internal) material Surfaces in 2 18 Miscellaneous Piping and Ducting OQe-Tqme inspeetion Inspection of 206 Silencer Pressure Steel Diesel exhaust Dislehut Loss offItra Ls Interal VII.H2-I.2 3.3.1-

..- E (exhaust) boundary (Internal) material Surfaces in 2 18 Miscellaneous Piping and Ducting

Enclosure L-11-153 Page 90 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table 3.3.2-14 Page 3.3-342 3 New Rows In response to RAIs B.2.2-2 and 3.3.2.2.5-1, three new rows are added to LRA Table 3.3.2-14, "Aging Management Review Results - Fire Protection System," as follows:

Table 3.3.2-14 Aging Management Review Results - Fire Protection System Row Component Intended Aging Effect Aging NUREG-Ro opnn nedd Material Environment Reurn Mage nt 1801, Table I Notes No. Type Function(s) equiring Managemen Volume 2 Item N SManagement Program Item Tank - Fire Pressure Air-outdoor External

-- Storage

_Water Steel Loss of material Surfaces VII.L-9 3.3.1-58 A Tank (DB-T81) boundary (Extemal)Monitoring Inspection of Internal Surfaces in Pressure Flexible FlxblErssrlastomer s Air-indoor Hardeningand uncontrolled loss of, Sraein VILI.F-7 3. 3.1-11 E Connection boundary (Internal) strensth Miscellaneous sPiping and Ducting Inspection of Internal Flexible Pressure Elastom Air-indoor Hardeningand Surfaces in VILF17 3.3.1-11 E Connection boundary Euncontrolled loss of Miscellaneous (External) strength Piping and

______

____ ________ __ _______ ___ ___________Ducting _ _ _ _ _ _ _ _ _ _ _ _

Enclosure L-11-153 Page 91 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table 3.3.2-15 Page 3.3-346 Row 28 In response to RAls B.2.2-2 and B.2.2-3, row 28 of LRA Table 3.3.2-15, "Aging Management Review Results -

Fuel Oil System," is revised as follows:

Enclosure L-11-153 Page 92 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table 3.3.2-15 Page 3.3-349 1 New Row In response to RAI 3.3.2.2.5-1, a new row is added to LRA Table 3.3.2-15, "Aging Management Review Results -

Fuel Oil System," as follows:

Table 3.3.2-15 Aging Management Review Results - Fuel Oil System Row Component Intended AigEfc Aging Effect Aging gn NUREG-81 al Row Cmponen Fnteondd Material Environment Requiring Management 1801, Table 1 Notes No.Management Program Volum 2 item Inspection of Internal Flexible FeilPrsuePressure EAir-indoor Hardening and I.n Suraces Elastomer uncontrolled loss of Sraein VILI.F-7 3.3.1-11 E Connection boundary (External) strength Miscellaneous Piping and

_______ _ ___

_ ___ ____

____ ___

_ ________ __ ___ ___ ___ ___ ___ ___ ___ Ducting _ _ _ _ _ _ _ _ _

Enclosure L-11-153 Page 93 of 206 Affected LRA Section LRA Pane No. Affected Paraqraph and Sentence Table 3.3.2-17 Pages 3.3-361 Various Rows and 363 In response to RAI 3.3.2.71-2, rows of LRA Table 3.3.2-17, "Aging Management Review Results - Instrument Air System," are revised as follows:

Table 3.3.2-17 Aging Management Review Results - Instrument Air System Row Component Intended 1Aging Aring Effect Aging Mangint NUREG

-1801, TableT No. Type Function(s) Material Environment Requiring Management Volume 1 Item Notes SManagement Program 2 Item lnSpeetien Inspection of 0 Drain Trap Bod Structural Gray Cast Condensation Loss of Intemal 3.3.1- 0319 y Integrity Iron (Internal) material Surfaces in VII.D-2 53 Miscellaneous Piping and Ducting Gne-T-ime 4n*ee~et Inspection of E 14 Moisture Structural Gray Cast Condensation Loss of Internal VI.D-2 3.3.1- 0319 Separator Body Integrity Iron (Internal) material Surfaces in 53 Miscellaneous Piping and Ductinq

Enclosure L-11-153 Page 94 of 206 Table 3.3.2-17 Aging Management Review Results - Instrument Air System Row Component Intended Aging Effect Aging NUREG No. Type Function(s) Material Environment Requiring Management Voue1 Te Notes Management Program Volume 1 Item 2 Item OneTime inspeetion Inspection of E 29 Tubing Structural Stainless Condensation Loss of Internal VHDA 3.3.1- 0319 integrity Steel (Internal) material Surfaces in 54 Miscellaneous Piping and Ducting

Enclosure L-11-153 Page 95 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table 3.3.2-19 Page 3.3-401 3 New Rows In response to RAI Sampling 1.0, three new rows are added to LRA Table 3.3.2-19, "Aging Management Review Results - Makeup Water Treatment System," are revised as follows:

Table 3.3.2-19 Aging Management Review Results - Makeup Water Treatment System Row Component Intended Aging Effect Aging NUREG-Ro opnn nedd Material Environment Reurn Management 1801, Table I Notes No. Type Function(s) Maequiring Program Volume 2 Item Management PItem Collection, Structural Gray Cast Raw water Drainage,and

-- Valve Body . Iron (Internal) Loss of material Treatment VII.CI-19 3.3.1-76 E Components Inspection Gray Cast Raw water Selective

-- Valve Body iStructural Iron (Internal) Loss of material Leaching VII. Cl-11 3.3.1-85 A Inspection Structural Gray Cast Air-indoor External Body inteCrtuValve Iron uncontrolled Loss of material Surfaces VII.I-8 3.3.1-58 A

-- __ValveBody__ (External) Monitoring

Enclosure L-11-153 Page 96 of 206 Affected LRA Section LRA Page No. Affected Paraqraph and Sentence Table 3.3.2-21 Pages 3.3-405 Row 16 and New Row and 417 In response to RAI 3.3.2.2.5-1, row 16 of LRA Table 3.3.2-21, "Aging Management Review Results -

Miscellaneous Liquid Radwaste System," is revised and a new row is added as follows:

Table 3.3.2-21 Aging Management Review Results - Miscellaneous Liquid Radwaste System Aging Effect Aging NUREG- T Row Component Intended Material Environment Requiring Management 1801, Table I Notes No. Type Function(s) Management Program Volume 2 Item Item Inspection of 16 Flexible Structural Elastomer Raw water Hardening and Inteoal VII.C1-1 3.3.1-75 E Connection integrity (Internal) loss of strength Surfaces in Miscellaneous Piping and Ductinq Inspection of Internal Flexible Structural Elastomer Air-indoor Hardening and Surfaces in VIIFI-7 3.3.1-11 E Connection integrity (Exteroall loss of strength Miscellaneous Piping and

___ __

__ ___ ________ __

__ _________ __ ___ ___ __ __ ___ __ ___ ___ Du tig _ ___ __ _ _ ___ __

Enclosure L-11-153 Page 97 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table 3.3.2-23 Page 3.3-427 Row 27 In response to RAI 3.3.2.71-2, row 27 of LRA Table 3.3.2-23, "Aging Management Review Results - Process and Area Radiation Monitoring System," is revised as follows:

Table 3.3.2-23 Aging Management Review Results - Process and Area Radiation Monitoring System Row Component Intended Agn fet Aging Effect Aging Aig1801, NUREG- Table No. Type Function(s) Material Environment Requiring Management Volum TaIte Notes Management Program Volume 1 Item 2 Item inspeatiOR Inspection of 27 Trap Body Pressure Stainless Condensation Loss of Internal VII El1 3.3.1- E boundary Steel (Internal) material Surfaces in 27 Miscellaneous Piping and DuctinA

Enclosure L-11-153 Page 98 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table 3.3.2-27 Page 3.3-488 Row 38

.In response to RAI 3.3.2.71-2, row 38 of LRA Table 3.3.2-27, "Aging Management Review Results - Spent Fuel Pool Cooling and Cleanup System," is revised as follows:

Table 3.3.2-27 Aging Management Review Results - Spent Fuel Pool Cooling and Cleanup System Row Component Intended Aging Effect Aging NUREG-Row Type Intended Material Environment Requiring Management 1801, Table 1 Notes No.Management Program Volume 2 Item' Item 3PiigStructural Stainless Moist air Loso aeil One-Time N/ /, G 38 Piping integrity Steel (External) lnspetion N/A N/A 0313

Enclosure L-11-153 Page 99 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table 3.3.2-28 Pages 3.3-494 Row 5 and New Row and 502 In response to RAI 3.3.2.2.5-1, row 5 of LRA Table 3.3.2-28, "Aging Management Review Results - Spent Resin Transfer System," is revised and a new row is added as follows:

Table 3.3.2-28 Aging Management Review Results - Spent Resin Transfer System Row Component Intended Aging Effect Aging N8UREG-Row Typonet Fnctnded Material Environment Requiring Management 1801, Table No. Type Function(s) Management Notes Program Volume 2 Item Item

> 6 0 0 Ha d e ni g a d I n er nll

• v l lAil Treated water Inspection of Flexible Structural Elastomer >1 60 0C Hardening and Internal VIIA4-1 3.3.1-12 E Connection integrity (> 1400F) loss of strength Surfaces in 0311 (Internal) Miscellaneous Piping and Ductinq Inspection of Air-indoor Internal Flexible Structural Elastomer Andoor Hardeninqand Surfaces in VIIFI-7 3.3.1-11 E Connection integrit (External) loss of strength Miscellaneous Ex a Piping and

___ ___

__ __

__ ___

___ __ __

___ ___ ___ __ ___ __ ___ ___ _ ___ __ ___ __ ucing__ ___ ___ __ ___ __ ____A

Enclosure L-11-153 Page 100 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table 3.3.2-29 Pages 3.3-503 Rows 7, 8, 9, 20, 21, 22, 23, 27, 28, 29 and 30 through 506 In response to RAI Sampling 1.0, rows 7, 8, 9, 20, 21, 22, 23, 27, 28, 29 and 30 of LRA Table 3.3.2-29, "Aging Management Review Results - Station Air System," are revised as follows:

Table 3.3.2-29 Aging Management Review Results - Station Air System Row No.

Component Ro opnnt Type Intended Itne Function(s)

Material IAging Environment Reurn Effect aequiring Aging Magent anagemen

]TNUREG-1801, Volume 2 Table I item Notes Management Program eo tItem Iteume2 Ie Structural stee/ Condensation~vv Loss ,,,*,,,of n *"t Qne Time -V4/4-- 3.. 5 Filter Housing integrity Polymer (Internal) None NIA

___eGtie NIA 03i None F Bo4G-AGd 8 Filter Housing Structural Stee Air with borated LoA f Mait e Ger"osioeV414l . A integrity Polyme water leakage Hardening and External N/A N/A F (External) loss of strength Surfaces Monitoring Housing Structural Steel Air-indoor Los;' of r*ateral External . A 9 Filter Housing' integrity Polyt e uncontrolled Hardeninq and Surfaces NIA N F (External) loss of strength Monitoring N/A N/A F 20 ... rA..74 -VWH..., 24",,3.. E Not Used. i r Steel A#-(#eant l) Loss of material 24 3.. 03-1-2 TubinStutua Air- with boratd AG 21 ot Ud .f-eakage ........ Loss of rnaterja V41.1 1,-,8 Not Used. # y G

..........

Enclosure L-11-153 Page 101 of 206

Enclosure L-11-153 Page 102 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table 3.3.2-29 Pages 3.3-504 Various Rows through 506 In response to RAI 3.3.2.71-2, rows of LRA Table 3.3.2-29, "Aging Management Review Results - Station Air System," are revised as follows:

Table 3.3.2-29 Aging Management Review Results - Station Air System Row Component Intended TAgi Aging ng Effect Aging Mangint NUREG

-1801, Table No. Type Function(s) Material Environment Requiring Management Volume 1 Item Notes Management Program 2 Item One Time J#see~et Inspection of E 10 Piping Pressure Steel Air (Internal) Loss of Internal VII.H2- 3.3.1- 0312 boundary material Surfaces in 21 71 Miscellaneous Piping and Ducting OneTime Inspection of E 13 Piping Structural Steel Air (Internal) Loss of Internal VII.H2- 3.3.1- 0312 integrity material Surfaces in 21 71 Miscellaneous Piping and Ducting

Enclosure L-11-153 Page 103 of 206 Table 3.3.2-29 Aging Management Review Results - Station Air System Row No. Component Intended Agn Effect Aging fetAig-1801, Aging TNUREG Table Type Function(s) Material Environment Requiring Management Voue1 Te Notes Management Program Volume 1 Item 2 Item inspe~teo Copper Inspection of E 16 T Structural Alloy> Condensation Loss of Intemal VI/G-9 3.3.1- 0319 ubing integrity 15% Zn (Internal) material Surfaces in 28 Miscellaneous Piping and Ducting Qne Time inspeG60P Inspection of E 24 Valve Body Pressure Loss of Internal VII.H2- 3.3.1- 0312 boundary Steel Air (Internal) material Surfaces in 21 71 Miscellaneous Piping and

____ _ ___

_____________

___ ___ ___ ____ _ ___________ ____________ Ducting _ _ _ _ ____ ____

Enclosure L-11-153 Page 104 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table 3.3.2-30 Pages 3.3-507 Various Rows through 529 In response to RAI 3.3.2.71-2, rows of LRA Table 3.3.2-30, "Aging Management Review Results - Station Blackout Diesel Generator System," are revised as follows:

Table 3.3.2-30 Aging Management Review Results - Station Blackout Diesel Generator System Row Component Intended TAging Effect Aging NUREG

-1801,EfectTable No. Type IFunction(s) Material Environment Requiring Management -1801 j Table Notes N Management Program Volume m Item 2 Item One Tim-e

/nspection of Compressor Pressure Diesel exhaust Loss of Internal VII.H2- 3.3.1-8rcasing - Steel (Internal) material Surfaces in 2 18 E Turbocharger bMiscellaneous Piping and Ducting One Time lnspeetGgf Inspection of 22 Flexible Pressure Stainless Diesel exhaust Internal VII.H2- 3.3.1- E Connection boundary Steel (.Internal) Cracking Surfaces in 1 06 Miscellaneous Piping and SDuctin_

Enclosure L-1 1-153 Page 105 of 206 Table 3.3.2-30 Aging Management Review Results - Station Blackout Diesel Generator System NUREG Row Component Intended Aging Effect Aging -1801, Table No. Type Function(s) Material Environment Requiring Management Volume 1 Item Notes Management Program 2VItem inspeotieR Inspection of 23 Flexible Pressure Stainless Diesel exhaust Loss of Internal VII.H2- 3.3.1- E Connection boundary Steel (Internal) material Surfaces in 2 18 Miscellaneous Piing and Ductinag t"ne Tirme inspe~tio Heat Exchanger Inspection of 31 (tubes)- Heat Copper Air-outdoor Reduction in Internal Aftercooler (DB- transfer 15% Zn (External) heat transfer Surfaces in N/A N/A H E215-1 & 2) Miscellaneous Piping and Ducting Qne Time lnspeetion Inspection of 82 Piping Pressure boundary Steel Condensation (Internal) Loss of material Internal 3.3.1-Surfaces in VII.D-2 53 E Miscellaneous Piping and Ducting Inspection of Pressure Diesel exhaust Loss of Internal VII.H2- 3.3.1-83 Piping boundary Steel (Internal) material Surfaces in 2 18 E Miscellaneous Pining and Ducting

Enclosure L-11-153 Page 106 of 206 Table 3.3.2-30 Aging Management Review Results - Station Blackout Diesel Generator System Row No.

Component Type Intended Function(s) Material Environment Aging Effect Requiring Management Aging Management

{i-1801, NUREG Volume 1 Table Item Notes Program Vl2 Item I2 Item Inspection of E 84 Piping Pressure Loss of Internal VII.H2- 3.3.1- 0312 boundary Steel Air (Internal) material Surfaces in 21 71 Miscellaneous Piping and Ducting One-Time lnspeGUen Inspection of 106 Silencer Pressure Diesel exhaust Loss of Internal VII.H2- 3.3.1- Ete (exhaust) boundary (Internal) material Surfaces in 2 18 Miscellaneous Piping and Ductinqg Qne Time lnspe~tion Inspection of E 108 Strainer (body) Pressure Loss of Internal VII.1H2- 3.3.1- 0312 boundary Steel Air (Internal) material Surfaces in 21 71 Miscellaneous Piping and Ducting Q~e-Thme inspeGfien Tank-Air Inspection of E 115 receivertank (DB-T209-1 &2) Pressure boundary Steel Air(internal) Loss of Internal VII.H2- 3.3.1- E material Surfaces in Miscellaneous 21 71 Piping and Ducting

Enclosure L-11-153 Page 107 of 206 Table 3.3.2-30 Aging Management Review Results - Station Blackout Diesel Generator System Row Component Intended Aging Effect Aging NUREG Material Environment Requiring Management -1801, Itaem No. Type Function(s) Maaeet Porm Volume 1 Item Noe Management Program 2 Item lnspeetieR Inspection of Pressure Diesel exhaust Loss of Internal VII.H2- 3.3.1-130 Tubing boundary Steel (Internal) material Surfaces in 2 18 E Miscellaneous Piping and Ducting Qne Time inspeGUen Inspection of E 131 Tubing Pressure Loss of Internal VILH2- 3.3.1- 0312 boundary Steel Air (Internal) material Surfaces in 21 71 Miscellaneous Piping and DuctinUg Qne-Time inspe~tin Inspection of 167 Valve Body Pressure Condensation Loss of Internal 3.3.1- E boundary Steel (Internal) material Surfaces in VII.D-2 53 Miscellaneous Piping and Ducting Qne-Tome ins pee4R Inspection of Pressure Diesel exhaust Loss of Internal VII.H2- 3.3.1-168 Valve Body boundary Steel (Internal) material Surfaces in 2 18 E Miscellaneous Piping and Ducting

Enclosure L-11-153 Page 108 of 206 Table 3.3.2-30 Aging Management Review Results - Station Blackout Diesel Generator System Row Component Intended Aging Effect Aging NUREG Row Type Intended Material Environment Requiring Management -1801, Table Notes No. Type Function(s) Maaeet Management Porm Program Volume 2VIteme I1Im 2 Item Item QneTime lnspeetieR Inspection of E 169 Valve Body Pressure Steel Air (Internal) Loss of Intemal VII.H2- 3.3.1- 0312 boundary material Surfaces in 21 71 Miscellaneous Piping and

____ ____

___ ___

____ ____ _____ ____ ___ _ __ ____ ___ __ _ ___ ____ ___ Ducting _ _ _ _ ____ ____

Enclosure L-11-153 Page 109 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table 3.3.2-30 Page 3.3-530 2 New Rows In response to RAI 3.3.2.2.5-1, two new rows are added to LRA Table 3.3.2-30, "Aging Management Review Results - Station Blackout Diesel Generator System," as follows:

Table 3.3.2-30 Aging Management Review Results - Station Blackout Diesel Generator System Row Component Intended Aging Effect Aging NUREG-Row Type Intended Material Environment Requiring Management 1801, Table I Notes No. Type Function(s) Management Maaeet Program Porm 2VIteme Volume tm Item 2 Item Inspection of Flexible Pressure Air-outdoor Hardeningand Internal Sufcsi Cnecion boure Elastomer loss of Surfaces in VII.G-2 3.3.1-61 E Connection boundary (Internal) strength Miscellaneous Piping and Ducting Inspection of Internal Flexible Pressure Fat Air-indoor Hardeningand Surfaces in VLF17 3.3.1-11 E Connection boundary Euncontrolled loss of Miscellaneous S(External) strength Piping and DuctinA

Enclosure L-1 1-153 Page 110 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table 3.3.2-31 Pages 3.3-533 Various Rows through 540 In response to RAI 3.3.2.71-2, rows of LRA Table 3.3.2-31, "Aging Management Review Results - Station Plumbing, Drains, and Sumps System," are revised as follows:

Table 3.3.2-31 Aging Management Review Results - Station Plumbing, Drains, and Sumps System Row Component Intended Material Environment IAging Effect Requiring Aging Management NUREG-1801, Tablees No. Type Function(s) Management Program Volume I Item 2 Item 20 Piping Pressure boundary Stainless Steel Moist air (Internal) Loss of material Srnfcetoin MiscellaneousofInerna Pipin 3.2.1-08 03E2 0334 and Ducting Pressure Moist air Loss of Inspection of Internal 3.3.1- E 25 Piping ur boundary Steel (Internal) material Surfaces in Miscellaneous Piping VIIG-23 71 03-/-2 0334 and Ducting One Time Inspet*,i. E Structural Gray Cast Moist air Loss of Inspection of Internal 3.3.1 31 Piping integrity Iron (Internal) material Surfaces in VIIG-23 71 0332 Miscellaneous Piping 0334 and Ducting 0Ono Tim.ne InSpectien.

Structural Stainless Moist air Loss of Inspection of Interal 3.2.1- O3--2 37 Piping integrity Steel (Internal) material Surfaces in V.D1-29 08 0332 Miscellaneous Piping 0334 and Ducting

Enclosure L-11-153 Page 111 of 206 Table 3.3.2-31 Aging Management Review Results - Station Plumbing, Drains, and Sumps System Aging Effect NUREG-Row Component Intended Aging Management 1801, Table No. Type Function(s) Material Environment Requiring Program Volume 1 Item P 2Management Item Stne Tifes inVpIt7on 44 Ppn Structural te Moist air Loss of Inspectioninof Intemal Surfaces VII.G-23 3.3.1- E 03i*

Piping integrity (Internal) material Miscellaneous Piping 71 0334 and Ducting One -Tim IenPeGtion E Structural Stainless Moist air Loss of Inspection of Internal 3.2.1- 0342 52 Tubing integrity Steel (Internal) material Surfaces in VD1-29 08 0332 Miscellaneous Pipinq 0334 and Ducting One Time Inspectin Pressure Stainless Moist air Loss of Inspection of Internal 3.2.1-57 Valve Body boundary Steel (Internal) material Surfaces in V.D1-29 08 0332 Miscellaneous Piping 0334 and Ducting O~ne- Time inspectiOn Pressure Moist air Loss of Inspection of Internal 3.3.1- E 61 Valve Body boundary Steel (Internal) material Surfaces in VII.G-23 71 Miscellaneous Piping 0334 and Ducting One- Tim~e InSpection Structural Stainless Moist air Loss of Inspection 65 Valve Body integrity Steel (Internal) material Surfaces inof Internal V.D1-29 3.2.1-08 0342 0332 Miscellaneous Piping 0334 and Ducting _

One Time Insctin Structural Moist air Loss of Inspection of Internal 3.3.1- E 70 Valve Body integrity Steel (Internal) material Surfaces in VIinG-23 71 0342 Miscellaneous c ipinn 0334

_______________

__________ ________ __ _____ ____andDucting_____ ____ _ _ _ _ _ _

Enclosure L-11-153 Page 112 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Section 3.3 Pages 3.3-548 Notes 0312, 0313, 0319, and new Notes 0334 and 0335 Plant-Specific Notes through 550 In response to RAI 3.3.2.71-2, three Notes in Section 3.3 "Plant-Specific Notes" are revised, and two new Notes are added, as follows:

Plant-Specific Notes:

0312 The One Time inispedin wigl Gonfi~mthe absen~of aging effects or-that aging is slow acting so as to not affect thc subjoct comp oncnt's innd*d function during the peried of Wetnded perfation.

The Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Programwill manacge loss of material for steel air system components where the compressed air is not reliably dry and free of contaminants. Moisture in the airmay be sufficient to cause generalcorrosion of steel components.

0313 The One-Time Inspection will detect and characterizeloss of material confirm, for components subject to a moist air environment at the air-waterinterface, the absence of aging effects or that aging is slow acting so as not to affect the subiect components' intended functions during the period of extended operation. The aging effects above and below the air-waterinterface are managed, as necessary, by their respective programs.

0317 Not used. Flew acce..Fated corrosion was deter ined to be an applicable aging effect in accordancewith the flow accelerated corrosio. . s septiblity study.

0319 The One Time Inspection Will confirm, for Station air and instrument air drFainage components, the absence of aging effeGts or that peio*dýG expo*sur to condensation does not affect the subject GomPonen" f intended function during the pened of extended operation.

The Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Programwill manage loss of materialfor station air and instrument air drainagecomponents exposed to condensation.

0334 The Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Program will manage loss of materialfor station plumbing, drains, and sumps system components that are open to ambient outdoor or indoor airand subject to frequent wetting and drying, referred to as a "Moist air (Internal)"environment.

Enclosure L-11-153 Page 113 of 206 Plant-Specific Notes:

0335 For the purposes of NUREG-1801 comparison, "Steam"is equivalent to the "Treatedwater" NUREG-1801 environment for this materialand aging effect.

Affected LRA Section LRA Page No. Affected Paragraph and Sentence Section 3.3 Page 3.3-548 Note 0314 Plant-Specific Notes In response to RAI B.2.8-1, Note 0314 in Section 3.3 "Plant-Specific Notes" is revised as follows:

Plant-Specific Notes:

0314 Not Used. The QOn Time lnpo.tin*

.... .id willp ... rif of Closed Cooling tr Che,,-O-Y P*r.gram. .

-ff,-,ivnes..

Enclosure L-11-153 Page 114 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence 3.4.2.1.4 Page 3.4-5 "Environments" section In response to RAIs 3.3.2.71-2 and B.2.8-1, the "Environments" section of Section 3.4.2.1.4 is revised to read:

Subject mechanical components of the Main Steam System are exposed to the following normal operating environments:

" Air-indoor uncontrolled

" Air with borated water leakage

• Air with steam or water leakage

• Dried air

• Lubricating oil

• Steam

• Treated water

• Treated water > 60 0 C (> 140 0 F)

Enclosure L-11-153 Page 115 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table 3.4.1 Page 3.4-32 Row 3.4.1-30 Based on the response to RAI 3.3.2.71-2, LRA Table 3.4.1, "Summary of Aging Management Programs for Steam and Power Conversion Systems Evaluated in Chapter VII of NUREG-1 801 ," is revised to read:

Table 3.4.1 Summary of Aging Management Programs for Steam and Power Conversion Systems Evaluated in Chapter VIII of NUREG-1 801 Item Further Component/Commodity Aging Effect/ Aging Management Evaluation Discussion Number Mechanism Programs Recommended 3.4.1-30 Steel piping, piping components, Loss of material due Inspection of Internal No Consistent -it NUREG !90!,

and piping elements exposed to to general, pitting, Surfaces in jut a d, .. ,

air outdoor (internal) or and crevice Miscellaneous Piping ,anagment pro.gam ,.

condensation (internal) corrosion and Ducting 3ss~gn.

Components .... o matei.l due .......

The Steam and Power Con version Systems do not ontain steel piping, piping components, or piping elements that are exposed to air outdoor internal) or condensation Te and subect to aging

_anagement review.

Enclosure L-11-153 Page 116 of 206 Affected LRA Section LRA Page No. Affected Paralraph and Sentence Table 3.4.2-4 Page 3.4-93 Rows 50, 63,143 and 156 through 109 In response to RAI 3.3.2.71-2, four rows of LRA Table 3.4.2-4, "Aging Management Review Results - Main Steam System," are revised as follows:

Table 3.4.2-4 Aging Management Review Results - Main Steam System Aging Effect Aging NUREG-Row Component Intended 1801, Table I Notes No. Type Function(s) Material Environment Requiring ManagementItem Management Program Item 50 Not Used P-Fessure be4..da. Condcnsatn (k#emal) Less-ef material One-Time n*.peetion 63 poping .... 4 trw G..n.nsptip L-ess-ef One--Time Not Used integrty nerna material .nspe.i.n 143 Vave Be Not Used P-iessuFe boundaj..

,'Inema, Cee Lsat

-ess-ef material One-Time 411.

.nspeo..n 34.4-3 E 156 -Valve-Bey Str-'ctua C-aGAP dPati- R L-es-se One-Time 9 344 3 E Not Used integry ntema mateF/a/ inspetie..

Enclosure L-11-153 Page 117 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Section 3.4 Page 3.4-111 Note 0404 Plant-Specific Notes In response to RAI 3.3.2.71-2, Note 0404 of Section 3.4 "Plant-Specific Notes" is revised as follows:

Plant-Specific Notes:

0404 Thc air-wat..r iterfaGe is evaluated as a mo.ist a'r e. Ronment.

The One-Time Inspection will confirm, for components subject to a moist air environment at the air-waterinterface, the absence of aging effects or that aging is slow acting so as not to affect the subiect components' intended functions during the period of extended operation. The aging effects above and below the air-waterinterface are managed, as necessary, by their respective programs.

Enclosure L-11-153 Page 118 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Section 3.5.2.1.13 Page 3.5-18 New "Aging Effects Requiring Management and "Aging Management Programs" items A new aging effect requiring management and an additional aging management program are added based on the response to RAI B.2.10-2. LRA Section 3.5.2.1.13, "Bulk Commodities," is revised to read:

Aging Effects Requiring Management The following. aging effects associated with structural components of evaluated bulk commodities require management:

• Change in material properties

• Cracking

• Delamination

" Loss of material

" Loss of preload

• Separation Aging Management Programs The following programs are credited for managing the effects of aging on bulk commodities:

" Bolting Integrity Program

" Boric Acid Corrosion Program

" Cranes and Hoists Inspection Program

• Fire Protection Program

" Structures Monitoring Program

• PWR Water Chemistry Program

• Inservice Inspection (ISI) Program - IWF

Enclosure L-11-153 Page 119 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table 3.5.2-13 Page 3.5-157 2 New Rows Two new rows for cranes, monorails and hoists bolting are added to LRA Table 3.5.2-13, "Aging Management Review Results - Bulk Commodities," subsection "Threaded Fasteners," based on the response to RAI B.2.10-2, and Table 3.5.2-13 is revised to read:

Table 3.5.2-13 Aging Management Review Results - Bulk Commodities Component / Intended Aging Effect Aging NUREG-Copnn nedd Material Environment Rqing Magent 1801, Table 1 Notes Commodity Function 1 Mequiring anagemen Volume 2 Item Management Program Item Threaded Fasteners Carbon Loss of Cranes and Boltin. SNS Steel Air-indoor orelof Hoists VII. 1-5 3.3. 1-45 E Steel preload Inspection -

Loss of Cranes and Cae n Carbon Boltinc SNS Steel Air-outdoor preload Hoists N/A N/A H Inspection_

Enclosure L-11-153 Page 120 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table 3.5.2-13 Pages 3.5-153 Rows 138, 140, 146, 149, 158, and 160 through 156 In response to RAI B.2.4-1, new plant specific note 0550 is added to rows 138, 140, 146, 149, 158 and 162 of LRA Table 3.5.2-13, "Aging Management Review Results - Bulk Commodities," as follows:

Table 3.5.2-13 Aging Management Review Results - Bulk Commodities Aging Effect Aging NUREG-Row Component / Intended Aging Magint 1801, Table 1 No. Commodity Function1 Material Environment Requiring Management Volume 2 Item Notes Management Program Item C

SNS, SRE, Carbon Bolting 3.5.1- 0537 138 Anchor Bolts SSR Steel Air-indoor Cracking Integrity 51.B1.1-3 0544 0550 C

140 Anchor Bolts SNS, SRE, Stainless Air-indoor Cracking Bolting 3.5.1- 0537 SSR Steel Integrity 51 0544 0550 C

146 Anchor Bolts SNS, SRE, SSR Stainless A td Cki Bolting 3.5.1- 0537 Steel rouoor racing Integrity 51.B1.1-3 0544 0550

Enclosure L-11-153 Page 121 of 206 Table 3.5.2-13 Aging Management Review Results - Bulk Commodities Aging Effect Aging NUREG-Row Component I Intended Material Environment Requiring Management 1801, Table 1 Notes No. Commodity Function1 Mea Ein teng Managem Volume 2 Item Management Program Item Anchor Bolts (ASME 149 Class 1, 2, SRE, SSR Carbon Ai-d Cki Bolting B113 3.5.1- A and 3 Steel Arinoor racing Integrity 51 0550 Supports Bolting)

C 0544 Expansion SNS, SRE, Carbon Bolting 3.5.1-158 Anchors SSR Steel Air-indoor Cracking Integrity 111.B1.1-3 51 0550 C

162 Expansion EpAnchors SNS, SRE, SSR Stainless Steel Air-indoor Cracking Bolting Integrity III.B1.1-3 3.5.1-51 0544 0550

Enclosure L-11-153 Page 122 of 206 Affected LRA Section LRA Page No. Affected Paraaranh and Sentence Section 3.5 Page 3.5-172 New Note Plant-Specific Notes In response to RAI B.2.4-1, new Note 0550 is added to Section 3.5 "Plant-Specific Notes" as follows:

Plant-Specific Notes:

0550 The Bolting Integrity Program includes the Inservice Inspection (ISI) Program- IWE, Inservice Inspection (ISI)

Program - IWF, and Structures Monitoring Programfor the management of structuralbolting. Structural bolting is monitored for loss of materialand cracking, and other conditions indicative of degradationsuch as loose bolts, missing or loose nuts.

Enclosure L-11-153 Page 123 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence A.1.2 Page A-10 Entire section Based on the responses to RAIs B.2.2-1, B.2.2-2 and/or B.2.2-3, LRA Section A.1.2 is revised to read:

The Aboveground Steel Tanks Inspection Programmanages the effects of corrosion on the external surfaces and inaccessible locations of the steel fire water storage tank, steel and diesel oil storage tank and the stainless steel boratedwater storage tank. The Aboveground Steel Tanks Inspection Programis a condition monitoring program that consists of periodic visual inspections of tank external surfaces and volumetric examinations of tank bottoms at least once for each tank within five years after enterinq the period of extended operation.

Additional opportunistic tank bottom inspections will be performed whenever the tanks are drained.

Enclosure L-11-153 Page 124 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence A.1.7 Page A-1I Entire section In response to RAI B.2.7-1, the section A.1.7 is replaced in its entirety to read:

The Buried Piping and Tanks Inspection Program manages the loss of material from the external surfaces of piping and tanks exposed to a buried environment.

The program also manages the aging of the external surfaces of underground piping. The program includes protective coatings for buried steel piping and tanks, backfill quality, and cathodic protection as preventive measures to mit4gate corrosion.

The program also includes visual inspections of the pipe or tank from the exterioras permitted by opportunisticor directed excavations. If damage to the protective coatings is found and the piping surface is exposed, the pipe is inspected for loss of materialdue to general,pitting, crevice, or microbiologicallyinfluenced corrosion. If corrosionhas occurred, the wall thickness will be determined.

The program includes verification of the effectiveness of the cathodic protection system, and monitoring the iockey fire pump operationor equivalent parameter.

The program also manages buried fire protection system bolting through opportunisticinspections.

Preventive measures are in accordance with standardindustry practice for maintaining external coatings and wrappings and cathodic protection.

The minimum number of buried in-scope piping inspections during the 30-40, 40-50, and 50-60 year operatingperiod is one safety-related steel piping segment and one steel piping segment containing hazmat. Each inspection will have a minimum of 10 feet of piping inspected.

A visual and volumetric inspection of the undergroundpiping within the borated water piping trench will be performed during each lO-Vear period beginning no soonerthan 10 years prior to the entry into the period of extended operation.

Degradationor leakage found during inspections is entered into the Corrective Action Program to ensure evaluations are performed and appropriatecorrective actions are taken. If adverse indicationsare detected, additionalburied in-scope piping inspections will be performed in orderto provide reasonableassuranceof the integrity of buried piping. The selection of components to be examined will be based on previous examination results, trending, risk ranking, and areas of cathodic protection failures or gaps, if applicable.Additional sampling continues until reasonableassuranceof the integrity of buried piping is provided.

Enclosure L-11-153 Page 125 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence A.1.8 Page A-11 Second paragraph In response to RAI B.2.8-1, the second paragraph of Section A.1.8 is revised to read:

The Closed Cooling Water-Chemistry' Rogram includes corrosion rate measurement at selected locations in the closed cooling wa9ter systms andi supplemented by the One Time inspection, which providles verification of the effectiveness of the proegram in managing the effects of aging.

Also, the Closed Cooling Water Chemistry Programincludes corrosion rate measurement at selected locations in the closed cooling water systems. In addition, periodicinspections of opportunity will be conducted when components are opened for maintenance, repair,or surveillance, to ensure that the existing environmental conditions are not causing materialdegradationthat could result in a loss of component intended function during the period of extended operation.

A representative sample of piping and components will be inspected on a 10-year interval, with the first inspection taking place prior to entering the period of extended operation.

Enclosure L-11-153 Page 126 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence A.1.10 Page A-12 Both paragraphs New requirements for visual inspections of bolting and an. evaluation of loads to be lifted by cranes, monorails and hoists are added to LRA Section A. 1.10, "Cranes and Hoists Inspection Program," based on the responses to RAIs B.2.10-1 and B.2.10-2, and LRA Section A.1.10 is revised to read:

A.1.10 CRANES AND HOISTS INSPECTION PROGRAM The Cranes and Hoists Inspection Program manages loss of material for structural components and loss of preloadfor bolted connections of cranes (including bridge, trolley, rails, and girders), monorails, and hoists within the scope of license renewal through periodic visual inspection of structural members for signs of corrosion and wear and bolted connections for loose bolts and missing or loose nuts. The cranes, monorails and hoists within the scope of license renewal are those defined by NUREG-0612, "Control of Heavy Loads at Nuclear Power Plants," and light load handling systems related to refueling.

The Cranes and Hoists Inspection Program is based on guidance contained in ANSI B30.2 [Reference A.1-5] for overhead and gantry cranes, ANSI B30.11

[Reference A.1-6] for monorail systems and underhung cranes, and ANSI B30.16

[Reference A. 1-7] for overhead hoists. The program includes a review of the number and maanitude of lifts made bv a crane, monorailor hoist.

Enclosure L-11-153 Page 127 of 206.

Affected LRA Section LRA Page No. Affected Paragraph and Sentence A.1.15 Page A-14 First and third paragraphs In response to RAI B.2.2-2, the first paragraph of section of A. 1.15 is revised to read:

The External Surfaces Monitoring Programis a condition monitoringprogram that consists of periodic visual inspections and surveillance activities of in-scope mechanical component external surfaces to manage cracking and loss of material, including cracking and loss of materialfor internalsurfaces where the environment is the same as the external environment.

In response to RAI 3.3.2.2.5-1, the third paragraph of section of A. 1.15 is revised to read:

Also, the External Surfaces Monitoring Program,supplemented by the One-T4me inspeotiOn Inspection of Internal Surfaces of Miscellaneous Piping and Ductincq Program, includes inspection and surveillance of elastomers and polymers that are exposed to air-indooruncontrolledand air-outdoorenvironments, but are not replaced on a set frequency or interval (i.e., are long-lived), for evidence of cracking and change in materialproperties(hardeningand loss of strength).

Enclosure L-1 1-153 Page 128 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence A.1.30 Page A-20 Entire section In response to RAIs 3.3.2.2.5-1, 3.3.2.71-2, B.2.8-1 and B.2.18-1, LRA Section A.1.30, "One-Time Inspection," is revised to read:

A. 1.30 One-Time INSPECTION One-Time Inspection performs inspections to verify the effectiveness of &e C.oscdl Coohing Water-Chemisty *o gram, the Fuel Oil Chemistry Program, the Lubricating Oil Analysis Program, and the PWR Water Chemistry Program, or confirms the absence of aging effects. One-time inspections address situations where: 1) an aging effect is not expected to occur, but it cannot be ruled out with reasonable assurance, or2) an aging effect is expected to progress very slowly in the specified environment, but the local environment may be more adverse._,-er

3) the characteriSticS of the aging effect include a long incubation period.

One-Time Inspection also provides assurance that aging which has not yet manifested itself is indeed not occurring, or that the age-relateddegradationis so insignificant that an aging management program is not warranted. Inspection at air-waterinterfacesprovides further confirmation that degradationis not occurring at locations where a potential exists for contaminants to concentrate due to altemate wetting and drying.

The elements of One-Time Inspection include:

• Determination of a representative sample size based on an assessment of materials of fabrication, environment, plausible aging effects, and operating experience;

• Identification of the inspection locations in the system or component based on the aging effect, or based on the areas susceptible to concentration of contaminants that promote certain aging effects;

• Determination of the examination technique, including acceptance criteria that is effective in managing the aging effect for which the component is examined; and 0 Evaluation of the need for follow-up examinations to monitor the progression of any age-related degradation.

The One-Time Inspection includes visual and volumetric inspections to detect and characterize cracking of copper alloy >15% zinc exposed to raw water. The

Enclosure L-11-153 Page 129 of 206 one-time inspections provides direct evidence as to whether, and to what extent, cracking has occurred. Crackinq of copper alloy >15% zinc exposed to raw water is not addressedby anotheraging management program.

When evidence of an aging effect is revealed by a one-time inspection, the routine evaluation of the inspection results triggers additionaI corrective actions to assure the intended function of affected components will be maintained through the period of extended operation.

Affected LRA Section LRA Page No. Affected Paragraph and Sentence A.1.31 Page A-20 Entire section In response to RAI B.2.31-1, Section A.1.31 is revised as follows:

The Open-Cycle Cooling Water Programmanages loss of materialdue to crevice, galvanic, general,pitting and microbiologically-influencedcorrosion;and erosion for in-scope components in the Service Water System and components connected to or cooled by the Service Water System (including the cooling tower makeup water relative to the Circulating Water System), along ith, cracking Of SUS..ptible ma erial.*- The program manages fouling due to particulates (e.g.,

corrosion products) and biological material (micro- and macro-organisms) resulting in reduction in heat transfer for heat exchangers (including condensers, coolers, cooling coils, and evaporators) within the scope of the program.

The Open-Cycle Cooling Water Programconsists of inspections, surveillances, and testing to detect and evaluate-oraekk*,- fouling, and loss of material, combined with chemical treatments and cleaning activities to minimize Graoking, fouling, and loss of material.The program is a combination condition and performance monitoring, and mitigation program that implements the recommendations of NRC Generic Letter 89-13, "Service Water System Problems Affecting Safety-Related Equipment" [Reference A. 1-17] for safety-related equipment in the scope of the program and manages loss of material for in-scope nonsafety-related components that contain service water or cooling tower makeup water.

Enclosure L-11-153 Page 130 of 206 Affected LRA Section LRA Page No. Affected Paraqraph and Sentence A.1.36 Page A-23 New sentence added to end of section.

In response to RAI B.2.36-1, addressing GALL Rev. 1 versus Rev. 2, the timing of the inspections was clarified in the Program description for LRA Appendix A, "Updated Safety Analysis Report Supplement." The following new sentence is added to the end of Section A.1.36, "Selective Leaching Inspection:"

The inspection activities will be conducted within the last five years priorto enterina the /eriod of extended oneration.

Enclosure L-11-153 Page 131 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence A.1.37 Page A-24 Entire section In response to RAIs B.2.37-1, B.2.37-2 and B.2.37-3, Section A.1.37 is replaced in its entirety to read:

The Small Bore Class 1 Piping Inspection is a one-time inspection that is desiqned to detect crackinq of small bore ASME Code Class 1 piping less than 4 inches nominal pipe size (less than NPS 4) and greaterthan or equal to NPS 1, which includes pipe, fittings, and branch connections, and all full and partial penetration (socket) welds.

The Davis-Besse Small Bore Class I PipingInspection consists of volumetric examination of a statisticallysiqnificant sample of small bore piping locations (full penetration welds and socket welds) that are susceptible to cracking. Location selection is based on susceptibility,inspectability, dose considerations,operating experience, and limiting locations of the total population of ASME Code Class I small bore piping (1 to < 4 inches NPS).

Volumetric examinations are performed using demonstrated techniques that are capable of detecting the aging effects in the examination volume of interest. For partialpenetration (socket) welds, the inspection will be either a volumetric or opportunisticdestructive examination. If a qualified volumetric examination procedure for socket welds endorsed by the industry and the NRC is available and incorporatedinto the ASME Code Section X1 at the time of the small-bore socket weld inspections, then this is used for the volumetric examinations.

Otherwise, the socket weld volumetric examinations shall follow guidelines set forth in ASME Code Section V, Article 4 consistent with the guidelines for examination volume of 1/2" beyond the toe of the weld as establishedin EPRI Report 1011955, "MaterialsReliability Program:Management of Thermal Fatique in Normally Stagnant Non-Isolable ReactorCoolant System Branch Lines (MRP-146)." Volumetric examinations are performed by qualified personnel following proceduresthat are consistent with Section X1 of the ASME Code and 10 CFR 50, Appendix B.

Davis-Besse with over 30 years of operatingexperience has experienced two instances of cracking of small bore Class I piping and in both cases; design changes were implemented to effectively mitiqate the cracking. Therefore, the one-time inspection is applicable to Davis-Besse. Should evidence of cracking be revealed by the one-time inspection, periodic inspection will be implemented using a plant-specific aging management program.

Enclosure L-11-153 Page 132 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence A.1.41 & A.1.42 Page A-16 New section / Title Revision Appendix A Table of Page A-4 A.1.41 & A.1.42 Contents In response to RAIs 3.3.2.2.5-1 and 3.3.2.71-2, a new LRA section is created to include a new plant-specific aging management program. LRA Section A.1.41 is renamed from "References" to "Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Program." The "References" section is renumbered as Section A.1.42, "References." Although not shown below, LRA Appendix A, "Updated Safety Analysis Report Supplement," "Table of Contents" on LRA Page A-4 is revised accordingly to include the renumbered sections.

New LRA Section A.1.41 reads:

A. 1.41 INSPECTION OF INTERNAL SURFACES IN MISCELLANEOUS PIPING AND DUCTING PROGRAM The Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Program manages loss of material,cracking, and reduction in heat transferof aluminum, copper alloy (includinq copper alloy > 15% Zn), stainless steel, and steel (includinggray cast iron) components that are exposed to air, condensation, diesel exhaust, or moist air. The program also manages hardening and loss of strength of non-metallic, flexible (elastomeric)components.

The Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Program is a new plant-specific Davis-Besse program that will be implemented via baseline inspection followed by opportunistic inspections when components are opened for periodic maintenance, repair,or surveillance activities and surfaces are made available for inspection. These inspections ensure that the existing environmental conditions are not causing materialdegradationthat could result in a loss of component intended function during the period of extended operation.

At least one inspection of each materialand environment combination will be conducted within the 10-year period prior to entering the period of extended operation.

Enclosure L-11-153 Page 133 of 206 Affected LRA Section LRA Page No. Affected Paraqraph and Sentence Table A-1 Page A-55 Commitment No. 1 Based on the response provided to RAI B.2.2-1, row 1 of LRA Table A-i, "Davis-Besse License Renewal Commitments," is revised to read:

Table A-1 Davis-Besse License Renewal Commitments Item Implementation Related LRA Number Commitment Schedule Source Section No./

Comments Enhance the Aboveground Steel Tanks Inspection Program to: Priorto LRA A.1.2

• Include a volumetric examination of t4e tank bottoms to detect April 22, 2017 and B.2.2 evidence of loss of materialdue to crevice, general, or pitting FENOC Response to corrosion, or to confirm a lack thereof. Establish the examination Letter NRC RAI technique, the inspection locations, and the acceptance criteria L-1 1-153 B.2.2-1 from for the examination of the tank bottoms. Require that NRC Letter unacceptable inspection results be entered into the FENOC dated Corrective Action Program. The volumetric examination of the April 20, 2011 tank bottoms will be performed within five years after entering the period of extended operation.Additional opportunistictank bottom inspections will be performed whenever the tanks are drained.

Enclosure L-11-153 Page 134 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table A-1 Page A-55 Commitment No. 3 In response to RAI B.2.7-1, row 3 of LRA Table A-i, "Davis-Besse License Renewal Commitments," is revised to read:

Table A-1 Davis-Besse License Renewal Commitments Item. Commitment e Implementation IRelated Source Section LRA No./

Number Schedule Comments 3 Enhance the Buried Piping and Tanks Inspection Program to: Priorto LRA A.1.7 0 Add 1) bolting for buried Fire Protection System piping and 2) April 22, 2017 and B.2.7 the emergency diesel fuel oil storage tanks (DB-T1 53-1, DB- FENOC and T1 53-2) to the scope of the program. Letter Reque

' .. that. an eet.on

. . of ated and w.apped buried pip.. ""L-11-153 NRC RAI or tank be peFnrlrnedw*ithn the 10 year-perid prir to entefring B.2.7-1 from the period of extended operation i.e., between year-30 and yea! R Lte 40%p eifythat if an ioppo.~unistio#nepetion has not oeeGUro-ddae betwen yar 30 and year-38.,then an ex.avation of a se.UOn o dapril20e,2 coated and wrapped buried piping for-the purpose of insection 50ý-, ~

wi be peori med before year- ~~40. inpVi*pIýSPt

~ ~ ~9G ~ tha if an ~

Sp.if ~ ~ ~ . Ipetnsi

• Require that an additinal insection Of coated and wrapped buried piping or tank be pedor~med within 10 years after enteriny the period of extended operation Cýe., between 0adya yeah

Enclosure L-11-153 Page 135 of 206 Table A-1 Davis-Besse License Renewal Commitments ItemCommitment Related LRA Implementation Source Section No./

Number Schedule Comments betwenyer4 and year-48, then an eXcaVation of a se'tion Of Goated and wraPpped buricd piping for-te pu~rpose ofn h~petoen Mil be performed before year 50.

• Require that an kn~pccien Of uncoa ted Gast keon buried pipiny be performed within the 410 year-period prior to cnterng the p9id of extended operation 0.e., betw~een yecar- 30 and yea; 40.Specify that if an opp odunistic insection haS not oceurr-e betweenIRya 30 and year 38, then an exGavation of a section-or Uncoated caSt i-ro buried piping for the purpose of insection will be performed before year-40.

nRequie that an additional ispoectiovn of unoatedcast ione buried piping be md in 1r0 years after- enterg the erodcivene

-of ded ce.,operation i between year 40 and year eff ectifenethat if an oppros unistio4n.Tetion has not OGcurred end yoear-40 and year-4, then an excavation of a setion oa uncoated cast keon buricd piping for the purpose of insection w.'l be performed before year-50.

Con duet annual ground potential surveys of the eathodic Protection system using the acceptance eriteria listed in NACE RP0285 2002 and NA CE SP0 169-2007. Monitor eat hodie protection voltage and current monthly to determine the effectiveness of cathodic Protection systems and, thereby, the effectiveness of corrosion mitigation. Trend voltage, current, and ground potential readings and evaluate for adverse changes.

Enclosure L-11-153 Page 136 of 206 Table A-1 Davis-Besse License Renewal Commitments Item Implementation Related LRA Number Commitment Schedule Source Section No./

Comments Require that the activity of the jockey fire pump or equivalent parameterbe monitored on at least a monthly interval. Conduct a flow test by the end of the next refuelina outaae when unexplained changes in jockey pump activity are observed.

Reauire that the directed buried nine insoection locations be selected based on risk.

Require that the minimum number of buried in-scope piping inspections durina the 30-40. 40-50. and 50-60 year oneratina period is one steel safety-related pipinq segment and one steel pinina seament containinahazardousmaterial.Perform the directed buried steel nine and tank inspections each ten year interval based upon the followinq table. Each inspection will have a minimum of 10 feet of pipinq inspected.

Preventive # of inspections of safety # of Hazmat inspections Actions related piping or tanks or % of pipe length A 1 (Note 2) 1 (Note 2)

B 1 2%

C 4 5%

D 8 10%

Note 1: Preventive actions are cateqorized as follows:

A. - Cathodicprotection, in accordance with NACE SP0169-2007 or NACE RP0285-2002, was installed for at least 5 years priorto enterinq the period of extended operation and was operationalfor 90% of the time durina

Enclosure L-11-153 Page 137 of 206 Table A-1 Davis-Besse License Renewal Commitments Item Implementation Related LRA Number Commitment Schedule Source Section No./

Comments that 5 years or cathodic protection was operationalfor 90%

of the time since the last inspection conducted under this program.

B. - Cathodic protection, in accordancewith NACE SP0169-2007or NACE RP0285-2002, was installed for less than 5 years priorto entering the period of extended operation or was operationalfor less than 90% of the time during that 5 years or cathodic inspection was operational for less than 90% of the time since the last inspection conducted under this program C. - Protective coatings are in place and no mechanical coating damage due to the backfill, but cathodicprotection is not provided or not in accordance with criteriaA or B and the period of extended operation has not been entered.

D. - Criteria of A, B, and C not met.

Note 2: Only one inspection is required for piping which is both safety-related and contains hazardous material.

Require that the EDG Fuel Oil Storage Tanks (DB-T153-1 and DB-T153-2) be inspected priorto entering the period of extended operation. The inspection will be either a visual inspection of at least 25% of each tank and include at least some portion of the tank top and bottom or, an internal inspection consistina of UT measurements with at least one

________________ -I measurement Der sauare foot of the surface of the tanks. These L _______________________ +/- _____________ [ ___________________

Enclosure L-11-153 Page 138 of 206 Table A-1 Davis-Besse License Renewal Commitments Item Iter Commitment Implementation Sheme IRelated Source LRA Section No./

Number ScheduleComments inspections are not required if it is demonstratedthat the tanks are cathodicallyprotected in accordance with NACE SP0169-2007 or NACE RP0285-2002.

Require that a visual and volumetric inspection of the undergroundpiping within the borated water piping trench will be performed during each 10-year period beginning no sooner than 10 years priorto the entry into the period of extended operation.

Require that if adverse indicationsare detected, additional buried in-scope piping inspections be performed in order to provide reasonableassurance of the integrity of buried piping.

Base the selection of components to be examined on previous examination results, trending, risk ranking, and areas of cathodic protection failures or gaps, if applicable. Continue additionalsampling until reasonableassurance of the integrity of buried piping is provided.

Require that an inspection of buried Fire Protection System bolting will be performed when the bolting becomes accessible during opportunistic or focused inspections.

Require that the inspections of buried piping be conducted using visual (VT-3 or equivalent) inspection methods. Excavation shall be a minimum of approximately 10 linearfeet of piping, with all surfaces of the pipe exposed.

Enclosure L-11-153 Page 139 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table A-1 Page A-58 .Commitment No. 8 Based on the response provided to RAIs 3.3.2.2.5-1 and B.2.2-2, row 8 of LRA Table A-i, "Davis-Besse License Renewal Commitments," is revised to read:

Table A-1 Davis-Besse License Renewal Commitments Item Implementation Related LRA Iter Commitment Sheme Source Section No./

Number Schedule Comments Cmet 8 Enhance the External Surfaces Monitoring Program to: Priorto LRA A.1.15 Add systems which credit the program for license renewal but April 22, 2017 and B.2.15 do not have Maintenance Rule intended functions to the scope FENOC Response to of the program. Letter NRC RAI

• Perform opportunistic inspections of surfaces that are L-11-153 B.2.2-2 from inaccessible or not readily visible during normal plant operations NRC Letter or refueling outages, such as surfaces that are insulated, dated Perform, in conjunction with the ,nc Tige, npeG.fi*n Inspection April 20, 2011 of Internal Surfaces in Miscellaneous Piping and Ductinq Program,inspection and surveillance of elastomers and polymers exposed to air-indooruncontrolled or air-outdoor environments, but not replaced on a set frequency or interval (i.e., are long-lived), for evidence of cracking and change in materialproperties (hardeningand loss of strength). Specify

Enclosure L-11-153 Page 140 of 206 Table A-1 Davis-Besse License Renewal Commitments T Related LRA Item iImplementationRead A Number Number Commitment ImScede Schedule Source Section No./

Comments acceptance criteria of no unacceptable visual indications of cracks or discoloration that would lead to loss of function prior to the next inspection.

Perform inspection of the control room emergency ventilation system air-cooled condensing unit cooling coil tubes and fins and the station blackout diesel generator radiator tubes and fins for visible evidence of external surface conditions that could result in a reduction in heat transfer. Specify acceptance criteria of no unacceptable visual indications of fouling (build up of dirt or other foreign material) that would lead to loss of function prior to the next scheduled inspection.

• Manage cracking of stainless steel components exposed to an outdoor airenvironment through plant sVstem inspections and walkdowns for evidence of leakage. Specify acceptance criteria of no unacceptable visual indicationsof cracks that would lead to loss of function priorto the next scheduled inspection.

Enclosure L-11-153 Page 141 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table A-1 Page A-62 Commitment No. 12 A new license renewal future commitment is added to existing Commitment 12, Masonry Wall Inspection Enhancements, a new 4th bullet, based on the response to RAI B.2.39-5. LRA Table A-1, "Davis-Besse License Renewal Commitments," Commitment 12, is revised as follows:

Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Commitment Implementation Source Section No./

Number Schedule Comments 12 Specify that for the masonry walls within the scope of license Priorto LRA A.1.27 renewal, inspections will be conducted at least once every five April 22, 2017 B.2.27 years, with provisions for more frequent inspectionsin areas Response to where significant loss of materialor cracking is observed to FENOC NRC RAI ensure there is no loss of intended function between Letter inspections. L-11-153 B.2 NRC3e-5er Letter dated April 5, 2011

Enclosure L-11-153 Page 142 of 206 Affected LRA Section LRA Page No. Affected ParaqraDh and Sentence Table A-1 Page A-63 Commitment No. 13 License renewal future Commitment 13 regarding the One-Time Inspection is changed based on the responses to RAIs 3.3.2.2.5-1, 3.3.2.71-2 and B.2.18-1. LRA Table A-i, "Davis Besse License Renewal Commitments," is revised to read:

Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Implementation Number Commitment Schedule Source Section No./

Comments 13 Implement the One-Time Inspection as described in LRA Section Priorto LRA A. 1.30 B.2.30. Enhance the One-Time Inspection to: April 22, 2017 B.2.30 S*,nlud, visual in . sp tions to dt`,tand`hara .t.re.z th FENOC Response to qatera'l od,-n of a4,'m÷nu*M, copper-aloy ,opin..ud.ng pc, Letter NRC RAIs alley gro.t.. the 15%. zinc., stai..ss.stee.. and steel including L-11-153 gray Gast ir9n) Gompo..... axp...d to.ond.nsati.n or-dia,. 3.3.2.71-2 and haust

.. top .id. ,dire, t v;dn, as to whether-, and to what 3.3.2.2.5-1 tn*ca.king.

t, loss of mat.ria., or-reducion in heat transfeF from NRC has ..... 4 ' Letter dated

_____,_,___,_.._________,____..__...._..._.,,__ April 20, 2011 0 InclUde visual and physial examination, such as manipulation and prdding, of alast*o* rs (flaxibia cannactions)to supplement the External Sudfacas Monitoring Program and provide di'et videnca as to whetheor-, and to what extent,

"

had*nin,* and le'ss' of strength due to thormal expeoorn ultraviolet

. xpur*,s÷ and ionizing rad;iation of alastemars has GGee~re4o

Enclosure L-1 1-153 Page 143 of 206 Table A-1 Davis-Besse License Renewal Commitments Related LRA Item ImplementationRead A Iter Number. Commitment Sheme Schedule.Cmet Source Section No./

Comments

• Include visual and volumetric inspections to detect and characterizecracking of copperalloy > 15% zinc exposed to raw water. The one-time inspections will provide direct evidence as to whether, and to what extent, crackinghas occurred. Cracking of copper alloy > 15% zinc exposed to raw water is not addressedby anotheraging management program.

Enclosure L-11-153 Page 144 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table A-1 Page A-64 Commitment No. 19 Based on the response to RAI B.2.37-2, license renewal future Commitment 19 in LRA Table A-1, "Davis-Besse License Renewal Commitments," is revised as follows:

Table A-1 Davis-Besse License Renewal Commitments Related LRA Item ImplementationRead A Iter Commitment Sheme Source Section No./

Number Schedule Cmet Comments 19 Implement the Small Bore Class 1 Piping Inspection as described in Completed within LRA A.1.37 LRA Section B.2.37. the six year B.2.37 period priorto April 22, 2017 FENOC Response to Letter B.2.37-2 from L-11-153 NRC Letter dated April 20, 2011

Enclosure L-11-153 Page 145 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table A-1 Page A-66 Commitment No. 20 A new license renewal future commitment is added to the table to replace existing Commitment 20, Structures Monitoring Program Enhancements, 6th bullet (1st bullet on page A-66), based on the response to RAI B.2.39-3.

LRA Table A-1, "Davis-Besse License Renewal Commitments," Commitment 20, 6th bullet is replaced in its entirety, and now reads:

Table A-1 Davis-Besse License Renewal Commitments Item m

Commitment TiImplementation Source Related LRA Section No./

Number Schedule Cmet Comments 20 Include a special provision to m.onitor below grade inaccessible Priorto LRA A.1.39

[continued] concrete components before and during the peFid of extendd April 22, 2017 B.2.39 operation. .. Pe. or. a below grade examination Of concrete Resp below elevain

............. 570 .. (goundwater elevation) of

___.................__ . a.......

i__ e FENOC Resonse NRC RAl to Structure prior to the period of extended operation Letter B 2.39-3 from inspection will include onccrete examination using acceptance L-11-153 criteria

........ from ..NUREG ... 1801

... Xl.S6

___ Program.

......... .... element 6. The

............... N dated Lter examination..of.concrete.below..ele.ation.570.feet ma be Aprill5, 2011 found that exceeds the acceptance criteria will be trended and processed through the FENOC Corrective ActionProgramn.

Obtain and evaluate for degradation a concrete core bore from a representative inaccessible concrete component of an in-scope structure subjected to aggressive groundwaterprior to entering the period of extended operation. Based on the results of the initial core bore sample, evaluate the need for collection

Enclosure L-11-153 Page 146 of-206 Table A-1 Davis-Besse License Renewal Commitments Related LRA Iter Nuber Commitment Implementation Source Section No./

ScheduleComments and evaluation of representative concrete core bore samples at additionallocations that may be identified during the period of extended operation as having aggressive groundwater infiltration. Select additionalcore bore sample locations based on the duration of observed aggressive groundwaterinfiltration.

Require the use of the FENOC Corrective Action Programfor identified concrete or rebardegradation.

[continuedl

Enclosure L-11-153 Page 147 of 206 Affected LRA Section LRA Page No. Affected Paraqraph and Sentence Table A-1 Page A-67 Commitment No. 20 A new license renewal future commitment is added to existing Commitment 20, Structures Monitoring Program Enhancements, based on the response to RAI B.2.39-4. LRA Table A-i, "Davis-Besse License Renewal Commitments," Commitment 20, is revised as follows:

Table A-I Davis-Besse License Renewal Commitments Item Implementation Related LRA Number Commitment Schedule Source Section No./

Comments 20 Require that personnel performinq the structuralinspections Priorto LRA A. 1.39

[continued] meet qualifications that are commensurate with ACI 349.3R, April 22, 2017 B.2.39 "Evaluationof Existinq Nuclear Safety-Related Concrete Response to Structures," Chapter 7, "Qualificationsof Evaluation Team." FENOC NRC RAI Letter B. 2.39-4 from L-11-153 NRC Letter dated April 5, 2011

Enclosure L-11-153 Page 148 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table A-1 Page A-67 Commitment No. 20 A new license renewal future commitment is added to existing Commitment 20, Structures Monitoring Program Enhancements, based on the response to RAI B.2.39-5. LRA Table A-1, "Davis-Besse License Renewal Commitments," Commitment 20, is revised as follows:

Table A-1 Davis-Besse License Renewal Commitments Item CImplementation Related LRA Number Number Commitment Iledlen Schedule n Source Section Cmet No.!

Comments 20 The program procedure will be enhanced by specifying that, for Priorto LRA A.1.39

[continued] the structureswithin the scope of license renewal, inspections April 22, 2017 B.2.39 will be conducted at least once every five years.

FENOC Response to NRC RAI L-11-e53 B. 2.39-5 from NRC Letter dated April 5, 2011

Enclosure L-11-153 Page 149 of 206 Affected LRA Section LRA Page No. Affected Paraqraph and Sentence Table A-1 Page A-67 Commitment No. 20 A new license renewal future commitment is added to existing Commitment 20, Structures Monitoring Program Enhancements, based on the response to RAI B.2.39-6. LRA Table A-i, "Davis-Besse License Renewal Commitments," Commitment 20, is revised as follows:

Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Implementation Iter Number Commitment Schedule Shdl Source Section No./

Comments 20 Conduct a baseline inspection of the structures within the scope Priorto LRA A. 1.39

[continued] of license eraon renewal priorto entering the period of extended April 22, 2017 B.2.39 oFeration. Response to Letter NRC RAI Letter B.-2.39-6 from NRC Letter dated April 5, 2011

Enclosure L-11-153 Page 150 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table A-1 Page A-66 Commitment No. 20, New Bullet A new license renewal future commitment is added to LRA Table A-I, "Davis-Besse License Renewal Commitments," Commitment 20, as a new Structures Monitoring Program Enhancement based on the response to RAI B.2.39-7. LRA Table A-1, is revised to read:

Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Commitment Implementation Rected No.

Number ComitmntSource Schedule Section No./

Comments 20 Require optical aids, scaling technologies, mechanicallifts, Priorto LRA A.1.39

[continued] ladders or scaffolding of structures for tallinspections to allow visual structures or difficult that meet to thereach areas guidelines April 22, 2017 B.2.39 to

Response

of Chapter5 of ACI 349.3R. Select the areasto be inspected in FENOC NRC RAI accordance with the guidelines of Chapter 5 of ACI 349.3R to Letter B 2.39-7 from reflect the "PeriodicEvaluation"criteriadefined in Chapter3.3 of L-11-153 ACI 349.3R. Include the "prioritizationprocess'"in the selection dated methodology to develop a representativesample of areas to April 5, 2011 inspect in accordancewith A CI 349.3R.

Enclosure L-1 1-153 Page 151 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table A-1 Page A-67 Commitment No. 20 Based on the response to RAI B.2.39-6, the 10th bullet of Commitment 20, Structures Monitoring Program Enhancements, of LRA Table A-1, "Davis-Besse License Renewal Commitments," is revised as follows:

Table A-1 Davis-Besse License Renewal Commitments ItemRelated LRA Number Commitment Implementation Source Section No./

Comments 20 Revise to add sufficient acceptance criteriaand critical Priorto LRA A.1.39

[continued] parametersto tricgeran increasedlevel of inspection and April 22, 2017 B.2.39 initiationof corrective action. Indicate that A Cl 349.3R--96 provides acceptable guidelines which will be consideredin FENOC Response NRC RAI to developing acceptance criteriafor concrete structuralelements, Letter B 2.39-6 from steel liners,joints, coatings, and waterproofingmembranes. L-11-153 Plant specific quantitative degradationlimits, similar to the three- dated tierhierarchyacceptance criteria from Chapter 5 of ACI 349.3R, April 5, 2011 will be developed and added to the inspection procedure. The Sýtructures Monitoring Programprocedure will also be enhanced to reflect the "PeriodicEvaluation"criteriadefined in chapter 3.3 of ACI 349.3R. The Structures Monitoring Programprocedure will include the "prioritizationprocess"to develop a representativesample of areas to inspect in accordance with ACI 349.3R.

Enclosure L-11-153 Page 152 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table A-1 Page A-68 Commitment No. 21 A new license renewal future commitment is added to existing Commitment 21, Water Control Structures Inspection Enhancements, a new 6th bullet, based on the response to RAI B.2.39-6. LRA Table A-i, "Davis-Besse License Renewal Commitments," Commitment 21, is revised as follows:

Table A-1 Davis-Besse License Renewal Commitments Item Implementation Related LRA Number CommitmentSchedule Source Section No./

Comments 21

• Conduct a baseline inspection of the structures within the scope Priorto LRA A. 1.40 of license renewal priorto entering the period of extended April 22, 2017 B.2.40 operation. FENOC Response to Letter NRC RAI L-11-153 B. 2.39-6 from NRC Letter dated April 5, 2011

Enclosure L-11-153 Page 153 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table A-1 Page A-68 Commitment No. 21 Based on the response to RAI B.2.39-6, the 5th bullet of Commitment 21, Water Control Structures Inspection Enhancements, of LRA Table A-i, "Davis-Besse License Renewal Commitments," is revised as follows:

Table A-1 Davis-Besse License Renewal Commitments Item Implementation Related LRA Commitment Source Section No./

Number Schedule Comments 21 List ACI 349.3R 96as af*. . and indiato that it w;l be Priorto LRA A.1.40

.. n,,decrcd in developing

,-.- .r...a ptance a for-4W...i of April 22, 2017 B.2.40 wator control str'-ctu'rcs. Revise to add sufficient acceptance Response to criteriaand criticalparametersto triggeran increasedlevel of FENOC NRC RAI inspection and initiation of corrective action. Indicate that ACI Letter 349.3R provides acceptable guidelines which will be considered L-11-153 B.NRC 2 Letter e9-er in developing acceptance criteria for water control structures. dated Plantspecific quantitative degradationlimits, similar to the three- April 5, 2011 tier hierarchyacceptance criteria from Chapter5 of ACI 349.3R, will be developed and added to the inspection procedure. The Structures Monitoring Program procedure will also,be enhanced to reflect the "PeriodicEvaluation"criteria defined in chapter3.3 of ACI 349.3R. The Structures Monitoring Programprocedure will include the "prioritizationprocess"to develop a representative sample of areasto inspect in accordancewith ACI 349.3R.

Enclosure L-11-153 Page 154 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table A-1 Page A-55 New Row A new license renewal future commitment is added based on the Cranes and Hoists Inspection Program enhancement provided in the response to RAI B.2.10-2. LRA Table A-1, "Davis-Besse License Renewal Commitments," is revised to read:

Table A-1 Davis-Besse License Renewal Commitments Item Implett Related LRA Iter Number Commitment plemenaion Schedule. Source Section No.d Comments 29 Enhance the Cranes and Hoists Inspection Pro-gram to: Priorto FENOC Response to Include visual inspections for loose bolts and missing or loose April 22, 2017 Letter NRC RAI nuts in crane, monorail and hoist inspection procedures at the L-11-153 B. 2.10-2 from same frequency as inspections of rails and structural dated components. April 20, 2011

Enclosure L-11-153 Page 155 of 206 Affected LRA Section LRA Page No. Affected Paralraph and Sentence Table A-1 Page A-55 New Row A new license renewal future commitment is added to the table based on the Leak Chase Monitoring Program enhancement provided in the response to RAI B.2.25-5. LRA Table A-1, "Davis-Besse License Renewal Commitments," is revised to read:

Table A-I Davis-Besse License Renewal Commitments I I I ____________________

Item Commitment Number 30 Enhance the Leak Chase Monitoring Pro-gram acceptance criteria Priorto Response to such that measurementof leakage from any monitoring line April 22, 2017 NRC RAI exceeding 15 milliliters per minute must be documented in the B. 2.25-5 from CorrectiveAction Programfor evaluation and potential NRC Letter corrective actions. dated April 5, 2011

Enclosure L-11-153 Page 156 of 206 Affected LRA Section LRA Page No. Affected Paraaraoh and Sentence Table A-1 Page A-55 New Row A new license renewal future commitment is added based on the response to RAI B.2.39-8. LRA Table A-i, "Davis-Besse License Renewal Commitments," is revised to read:

Table A-1 Davis-Besse License Renewal Commitments Item CImplementation Related LRA e

Number CommitmentSee Schedule Source Section CmetNo./

Comments 31 FENOC will incorporatereference to and the preventative Priorto FENOC Response to actions of the Research Council for Structural Connections April 22, 2017 Letter NRC RAI "Specificationfor StructuralJoints Usinq ASTM A325 or A490 L B.2.39-8 from Bolts" into the Davis-Besse specifications and implementing 153 NRC Letter proceduresthat address Davis-Besse structuralbolting within dated the scope of license renewal. April 5, 2011

Enclosure L-11-153 Page 157 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table A-1 Page A-55 New Row A new license renewal future commitment is added based on the response to RAI B.2.8-1. LRA Table A-i, "Davis-Besse License Renewal Commitments," is revised to read:

Table A-1 Davis-Besse License Renewal Commitments Related LRA Item ImplementationRead A Iter Nurnber Commitment Shede Schedule Source Section No./

Comments 32 Enhance the Closed Cooling Water Chemistry program to: Priorto FENOC Response to Document the results of periodic inspections of April 22, 2017 Letter NRC RAI opportunity,performed when components are opened for L B. 2.8-1 from 153 NRC Letter maintenance, repair,or surveillance. dated

• Ensure that a representative sample of piping and April 20, 2011 components will be inspected on a 10-year interval, with the first inspection taking place prior to entering the period of extended operation.

Enclosure L-11-153 Page 158 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table A-A Page A-55 New Row A new license renewal future commitment is added based on the response to RAI B.2.39-1. LRA Table A-i, "Davis-Besse License Renewal Commitments," is revised to read:

Table A-1 Davis-Besse License Renewal Commitments Item Implementation Related LRA Number Commitment Schedule Source Section No./

Comments 33 FENOC will continue to reduce or mitgate the refueling na 33wll ENO ontnu toreuceor itgat th rfuein canal Prior to FENOC Response to leaks inside containment priorto entering the period of April 22, 2017 Letter NRC RAI extended operation. L-11-153 B.2.39-1 from NRC Letter dated April 5, 2011

Enclosure L-11-153 Page 159 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table A-1 Page A-55 New Row A new license renewal future commitment is added based on the response to RAI B.2.4-3. LRA Table A-i, "Davis-Besse License Renewal Commitments," is revised to read:

Table A-1 Davis-Besse License Renewal Commitments TC Implementation Related LRA Item Number Schedule Source Section No./

Comments 34 Enhance the Bolting Integrity Programto: Priorto FENOC Response to

• Select an alternate stable lubricantthat is compatible with April 22, 2017 Letter NRC RAI the fastenermaterial and the environment. A specific L B. 2.4-3 from precautionagainst the use of compounds containing sulfur 153 NRC Letter dated (sulfide), including molybdenum disulfide (MoS 2), as a April 20, 2011 lubricant will be included in the program.

Enclosure L-11-153 Page 160 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table A-1 Page A-55 2 new Row Two new license renewal future commitments are added based on the response to RAI B.2.22-1. LRA Table A-i, "Davis-Besse License Renewal Commitments," is revised to read:

Table A-I Davis-Besse License Renewal Commitments Item Implementation Related LRA Number Commitment Schedule Source Section No./

Comments 35 Perform nondestructive testing (NDT) of the steel containmentin Priorto FENOC Response to the sand pocket region at a minimum of three representative April 22, 2017 Letter NRC RAI locations, including the areas above and below the grout at each L-11-153 B.2.22-1 from location, and evaluate the NDT results. NRC Letter Based on the nondestructive testing (NDT) results, use the dated Corrective Action Program to evaluate the need for and frequency April 5, 2011 of future ND T to monitor the extent of aging of the steel containment in the sand pocket region for areaswhere water seepage is identified.

36 Inspect the annulus sand pocket area during each plant refueling On-going FENOC Response to outage when the annulus is accessible. Address issues of degraded Letter NRC RAI accessible grout, moisture barrieror sealant identified during the L-11-153 B.2.22-1 from inspections using the FENOC Corrective Action Program. NRC Letter dated April 5, 2011

Enclosure L-11-153 Page 161 of 206 Affected LRA Section LRA Page No. Affected ParaqraDh and Sentence Table A-1 Page A-55 2 new Row Two new license renewal future commitments are added based on the response to RAI B.2.39-2. LRA Table A-i, "Davis-Besse License Renewal Commitments," is revised to read:

Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Implementation Number Commitment Schedule Source Section Comments No./

37 FENOC will perform and evaluate core bores of the ECCS Pump Priorto FENOC Response to Room No. 1 wall and the Room 109 ceiling priorto entering the April 22, 2017 Letter NRC RAI period of extended operation. L-11-153 B.2.39-2 from NRC Letter dated April 5, 2011 38 FENOC will further evaluate the concrete cracking observed on the Priorto FENOC Response to underside of the spent fuel pool. If necessary, based on the April 22, 2017 Letter NRC RAI evaluation, FENOC will repairthe crack priorto entering the period L-11-153 .B.2.39-2 from of extended operation. NRC Letter dated April 5, 2011

Enclosure L-11-153 Page 162 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table A-1 Page A-55 New Row A new license renewal future commitment is added based on the response to RAI B.2.22-2. LRA Table A-i, "Davis-Besse License Renewal Commitments," is revised to read:

Table A-1 Davis-Besse License Renewal Commitments IImplementation Related LRA Item Iter Number Commitment ISheme Schedule Source jCmet Section No./

Comments 39 Address the potentialfor borated water degradation of the steel Priorto FENOC Response to containment vessel through the following actions: April 22, 2017 Letter NRC RAI Access the inside surface of the embedded steel containment. L-11-153 B. 2.22-2 from If there is evidence of the presence of borated water in contact NRC Letter with the steel containment vessel, conduct non-destructive dated testing (NDT) to determine what effect, if any, the borated April 5, 2011 water has had on the steel containment vessel. Based on the results of NDT, perform a study to determine the effect through the period of extended operation of any identified loss of thickness in the steel containment due to exposure to borated water.

Enclosure L-1 1-153 Page 163 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table A-1 Page A-55 New Row A new license renewal future commitment is added based on the response to RAI 3.3.2.71-2. LRA Table A-i, "Davis-Besse License Renewal Commitments," is revised to read:

Table A-1 Davis-Besse License Renewal Commitments Item Implementation Related LRA Number Commitment Schedule Source Section No./

Comments 40 Implement the Inspection of Internal Surfaces in Miscellaneous Priorto FENOC A. 1.41 Piping and DuctinqProgramas describedin LRA Section B. 2.41. April 22, 2017 Letter L-11-153 Response to NRC RAIs from NRC Letters dated April 5, 2011 and April 20, 2011

Enclosure L-11-153 Page 164 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table B-1 Page B-13 Rows XI.M24 and XI.M38 In response to RAIs 3.3.2.71-2 and 3.3.2.2.5-1, the "Corresponding Davis-Besse AMP" column of rows XI.M24 and XI.M38 of Table B-1 are revised to read:

Table B-1 Correlation of NUREG-1801 and Davis-Besse Aging Management Programs (continued)

Number NUREG-1801 Program Corresponding Davis-Besse AMP XI.M24 Compressed Air Monitoring Not credited for aging management. Operating experience shows that the air and gas is dry except in certain locations for which the One Time I.spet.n* -plant-specific Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Program (See Section B.2.30-B. 2.41) is credited.

In addition, the plant-specific Air Quality Monitoring Program (See Section B.2.3) ensures that compressed air in the Instrument Air System is dry and free of contaminants.

XI.M38 Inspection of Internal N*t ,-,ted for÷aging manag..m. nt. The Exte.nal Surfaces in Miscellaneous Sufac.. Monitoring Proga-,. (See Sec.n 9.-2.41ý) i Piping and Ducting ,--d4te;insteadfor-,0 agin ngcmnt of i.tc..a Components sufaces whe.o the interna, an- xlter.n.al en.v.....

are the same (eg., air indoor.Unn*terG,*. Confirmation that oarging "' intternal s-,fa~cs that are not the same as the extern4l e.nirmnment (., ipnetrnal envkronments of air Outdoor- Or Gendensation) is provided by,the One Time !nspection (Se~e SectionG_ B6.2.30).

Plant-specificaging management program is credited for aging management; Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Program. (See Section B.2.41 .

Enclosure L-11-153 Page 165 of 206 Affected LRA Section LRA Page No. Affected Paracraph and Sentence Table B-1 Page B-17 New Row In response to RAts 3.3.2.2.5-1 and 3.3.2.71-2, a new row is added to the "Davis-Besse Plant-Specific Programs" section of Table B-1 as follows:

Table B-1 Correlation of NUREG-1801 and Davis-Besse Aging Management Programs (continued)

NumberI NUREG-1801 Program I Corresponding Davis-Besse AMP Davis-Besse Plant-Specific Programs Plant-SpecificProgram Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Program See Section B. 2.41.

Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table B-2 Page B-18 "Aboveground Steel Tanks" row In response to RAI B.2.2-3, the "Aboveground Steel Tanks" row of Table B-2 is revised to read:

Consistent Consistent wt New / with NUEG Plant- Enhancement Existing NUREG- 1801 with Specific Required 1801 181wt Exceptions Aboveground Steel Tanks Inspection Existing -Yes -Yes Yes Program Section B.2.2

Enclosure L-11-153 Page 166 of 206 Affected LRA Section I LRA Page No. Affected Paraqraph and Sentence Table B-2 Page B-18 "Bolting Integrity Program" Row In response to RAI B.2.4-3, the "Bolting Integrity Program" row of Table B-2 is revised to read:

Consistent Consistent wt New / with NUEG Plant- Enhancement Existing NUREG- 1801 with Specific Required 1801 181wt Exceptions Bolting Integrity Program Existing - Yes Yes Section B.2.4 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table B-2 Page B-18 New row In response to RAIs 3.3.2.2.5-1 and 3.3.2.71-2, a new Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Program row is added. Table B-2 is revised to read:

Consistent Consistent wt New I with NUREGh Plant- Enhancement Existing NUREG- 1801 with Specific Required 1801 181wt Exceptions Inspection of Internal Surfaces in Miscellaneous Piping New .... Yes --

and Ducting Program Section B.2.41

Enclosure L-11-153 Page 167 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence B.2.2 Page B-25 "Program Description" section In response to RAIs B.2.2-1, B.2.2-2 and B.2.2-3, the "Program Description" section of B.2.2 is revised to read:

The Aboveground Steel Tanks Inspection Programmanages the effects of corrosionon the external surfaces and inaccessible locations of the steel fire water storage tank, steel aind diesel oil storage tank and the stainless steel borated water storage tank (BWST). The Aboveground Steel Tanks Inspection Program is a condition monitoringprogram that consists of periodic visual inspections for less of material, effects of corrosion, and volumetric examination of the tank bottoms. This program includes an assessment of the condition of tank surfaces protected by a coating, although the paint is not credited to perform a preventive function. This program also includes an assessment of the condition of sealantinstalled at the external interface between the tank and the foundation.

Performinginspection of the tank bottoms ensures that degradationor significant loss of material will not occur in inaccessiblelocations. The f.equenGyof ta*,

bottom volumetric inspetion ýwil be based on the findings of an inspection Of each tank performed p.rir to the period of extended*operation volumetric examination of each tank bottom will be performed within five years after entering the period of extended operation.Additional opportunistic tank bottom...

inspections will be performed whenever the tanks are drained.

Affected LRA Section LRA Page No. Affected Paragraph and Sentence B.2.2 Page B-25 "NUREG-1801 Consistency" section In response to RAI B.2.2-3, the "NUREG-1 801 Consistency" section of B.2.2 is revised to read:

The Aboveground Steel Tanks Inspection Programis an existing Davis-Besse program that, with enhancement, will be consistent with the 10 elements of an effective aging management program as describedin NUREG-1801, Section Xl. M29, "AbovegroundSteel Tanks-," with the following exception:

Enclosure L-11-153 Page 168 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence B.2.2 Page B-25 "Exceptions to NUREG-1801:"

section In response to RAI B.2.2-3, the "Exceptions to NUREG-1801:" section of B.2.2 is revised to read:

None Preventive Actions The fire water storage tank does not have sealant or caulking at the interface edge between the tank and the foundation. Instead, the tank rests on an oiled sand pad on top of granularfill, which slopes down from the tank center to the outside edge. The bottom surface of the tank is raised 6 inches from the finished grade. This desiqn precludes water accumulation around the tank bottom. Therefore, no sealant or caulking inspection is requiredfor the fire water storage tank.

Enclosure L-11-153 Page 169 of 206 Affected LRA Section LRA Page No. Affected ParaaraDh and Sentence B.2.2 Page B-25 "Enhancements" section In response to RAI B.2.2-1, the "Enhancements" section of B.2.2 is revised to read:

Enhancements The following enhancements will be implemented in the identified program elements prior to entering the period of extended operation.

Scope, Parameters Monitored or Inspected, Detection of Aging Effects, Monitoring and Trending, Acceptance Criteria The program will be enhanced to include a volumetric examination of tank bottoms to detect evidence of loss of materialdue to crevice, general, or pitting corrosion, or to confirm a lack thereof The enhancement will include establishingthe examination technique, the inspection locations, and the acceptance criteriafor the examination of the tank bottoms.

Unacceptableinspection results will be entered into the Corrective Action Program. The volumetric examination of the tank bottoms will be performed-pior- to within five years after entering the period of extended operation.Additional opportunistic tank bottom inspections will be performed whenever the tanks are drained.

Affected LRA Section LRA Page No. Affected Paraciraih and Sentence B.2.2 Page B-26 "Operating Experience" section In response to RAI B.2.2-2, the following sentence is added to the end of the "Operating Experience" section of B.2.2:

A review did not identify any plant-specific operatingexperience related to the effects of corrosionand the Borated Water Storage Tank.

Enclosure L-11-153 Page 170 of 206 Affected LRA Section LRA Page No. Affected Paraqraph and Sentence B.2.2 Page B-26 "Conclusion" section, first sentence In response to RAIs B.2.2-2 and B.2.2-3, the first sentence of the "Conclusion" section of B.2.2 is revised to read:

The Aboveground Steel Tanks Inspection Programhas been demonstratedto be capable of managing loss of materialfor the accessible external surfaces of the boratedwater storage tank, the fire water storage tank and the diesel oil storage tank.

Affected LRA Section LRA Page No. Affected Paragraph and Sentence B.2.4 Page B-30 "NUREG-1801 Consistency" section In response to RAI B.2.4-3, the "NUREG-1801 Consistency" section is revised as follows:

The Bolting Integrity Programis an existing Davis-Besse program that is, with Enhancement, will be consistent with the 10 elements of an effective aging management program as describedin NUREG- 1801 Section XI.M18, "Bolting Integrity," with the following exceptions.

Enclosure L-11-153 Page 171 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence B.2.4 Page B-31 "Enhancements" section In response to RAI B.2.4-3, the "Enhancements" section is revised as follows:

Enhancements N*ne The following enhancement will be implemented in the identified program elements prior to entering the period of extended operation.

Preventive Actions The Bolting Integrity Program will be enhanced to select an alternate stable lubricant that is compatible with the fastener materialand the environment. A specific precaution againstthe use of compounds containingsulfur (sulfide), including molybdenum disulfide (MoS 2 ), asa lubricantwill be included in the program.

Affected LRA Section LRA Page No. Affected Paragraph and Sentence B.2.7 Page B-40 "Program Description" section In response to RAI B.2.7-1, the "Program Description" section of B.2.7 is replaced in its entirety to read:

ProgramDescription The Buried Pipingand Tanks Inspection Programmanages the loss of material from the external surfaces of piping and tanks exposed to a buried environment.

The program also manages the aging of the external surfaces of underground piping. The program includes protective coatings for buried steel piping and tanks, backfill quality, and cathodic protection as preventive measures to mitigate corrosion.

The program also includes visual inspections of the pipe or tank from the exterior as permitted by opportunistic or directed excavations. If damage to the protective coatings is found and the piping surface is exposed, the pipe is inspected for loss of materialdue to general, pitting, crevice, or microbiologicallyinfluenced corrosion. If corrosionhas occurred, the wall thickness will be determined.

Enclosure L-11-153 Page 172 of 206 The program includes verification of the effectiveness of the cathodicprotection system, and monitoring the iockey fire pump operation or equivalent parameter.

The program also manages buried fire protection system bolting through opportunistic inspections.

Preventive measures are in accordance with standardindustry practice for maintainingexternal coatings and wrappings and cathodic protection.

The minimum number of buriedin-scope piping inspections during the 30-40, 40-50, and 50-60 year operatingperiod is one safety-related steel piping segment and one steel piping segment containinghazmat. Each inspection will have a minimum of 10 feet of piping inspected.

A visual and volumetric inspection of the undergroundpiping within the borated water piping trench will be performed during each 10-year period beginning no sooner than 10 years prior to the entry into the period of extended operation.

Degradationor leakage found during inspections is entered into the Corrective Action Programto ensure evaluations are performed and appropriatecorrective actions are taken. If adverse indicationsare detected, additionalburiedin-scope piping inspections will be performed in order to provide reasonableassurance of the integrity of buriedpiping. The selection of components to be examined will be based on previous examination results, trending, risk ranking, and areas of cathodic protection failures or gaps, if applicable.Additional sampling continues until reasonableassurance of the integrity of buriedpiping is provided.

The Buried Pipingand Tanks Inspection Programensures that the intended function of the subject components will be maintained consistent with the current licensing basis during the period of extended operation.

The buried piping and piping components within the scope of this program are in the following plant systems:

• Emergency Diesel Generators(EDG) System - fuel oil subsystem

• Fire ProtectionSystem 0 Service Water System The buried tanks within the scope of the program are the EDG Fuel Oil Storaqe Tanks (DB- T153-1 and DB- T153-2).

The buried bolting within the scope of the program is associatedwith Fire Protection System piping.

Enclosure L-1 1-153 Page 173 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence B.2.7 Page B-41 "Enhancements" section In response to RAI B.2.7-1, the "Enhancements" section of B.2.7 is replaced in its entirety to read:

Enhancements The followinq enhancements will be implemented in the identified program elements priorto entering the period of extended operation.

• Scope Add the emergency diesel fuel oil storage tanks (DB-T153-1, DB-T153-2) to the scope of the program. The existing program scope includes only buried piping.

Add bolting for buried Fire Protection System piping to the scope of the program.

• ParametersMonitored or Inspected Annual ground potential surveys of the cathodic protection system will be conducted and the acceptancecriteria are listed in NACE RP0285 2002 and SP0169-2007 Cathodicprotection voltage and current, will be monitored monthly to determine the effectiveness of cathodicprotection systems and, thereby, the effectiveness of corrosion mitigation. Voltage, current, and ground potential readings will be trended and evaluated for adverse changes.

• Detection of Aging Effects Add a requirement that the activity of the jockey fire pump or equivalent parameterbe monitored on at least a monthly interval. When unexplained changes in jockey pump activity are observed, a flow test will be conducted by the end of the next refueling outage.

Add a requirement that the directed buriedpipe inspection locations be selected based on risk.

Add a requirement that the minimum number of buried in-scope piping inspections during the 30-40, 40-50, and 50-60 year operating period is one steel safety-related piping segment and one steel piping segment containing hazmat. The directed buried steel pipe and tank inspections

Enclosure L-11-153 Page 174 of 206 are performed each ten year interval based upon the following table.

Each inspection will have a minimum of 10 feet of piping inspected.

Preventive Actions # of inspections ofsafetv # of Hazmat inspectionsor related piping or tanks  % of pipe length A 1 (Note 2) 1 (Note 2)

B 1 2%

C 4 5%

D 8 10%

Note 1 Preventive actions are categorizedas follows.

A. - Cathodic protection, in accordancewith NACE SP0169-2007 or NACE RP0285-2002, was installed for at least 5 years priorto the period of extended operation and was operationalfor 90% of the time during that 5 years or cathodic protection was operationalfor 90% of the time since the last inspection conducted under this program.

B. - Cathodic protection, in accordancewith NACE SP0169-2007 or NACE RP0285-2002, was installed for less than 5 years priorto the period of extended operation or was operationalfor less than 90% of the time during that 5 years or cathodic inspection was operationalfor less than 90% of the time since the last inspection conducted under this program C. - Protective coatings are in place and no mechanical coating damage due to the backfill, but cathodic protection is not provided or not in accordancewith criteriaA or B and the period of extended operation has not been entered.

D. - Criteria of A, B, and C not met.

Note 2 Only one inspection is requiredfor piping which is both safety related and contains hazmat.

Add a requirement that the EDG Fuel Oil Storage Tanks (DB-T153-1 and DB-T153-2) will be inspected prior to the period of extended operation.

The inspection will be eithera visual inspection of at least 25% of each tank and include at least some portion of the tank top and bottom or, an internalinspection consisting of UT measurements with at least one measurementper square foot of the surface of the tanks. These inspections are not requiredif it is demonstratedthat the tanks are cathodicallyprotectedin accordance with NACE SP0 169-2007 or NACE RP0285-2002.

Enclosure L-11-153 Page 175 of 206 Add a requirement that a visual and volumetric inspection of the undergroundpiping within the borated waterpiping trench will be performed during each 10-year period beginning no sooner than 10 years prior to the entry into the periodof extended operation.

Add a requirement that if adverse indications are detected, additional buried in-scope piping inspections will be performed in order to provide reasonableassurance of the integrity of buriedpiping. The selection of components to be examined will be based on previous examination results, trending, risk ranking, and areas of cathodic protection failures or gaps, if applicable. Additional sampling continues until reasonable assuranceof the integrity of buriedpiping is provided.

Add a requirement that an inspection of buried Fire Protection System bolting will be performed when the bolting becomes accessible during opportunistic or focused inspections.

Add a requirementthat the inspections of buried piping be conducted using visual (VT-3 or equivalent) inspection methods. Also, to ensure that a sufficient inspection area of the buried component is exposed, the excavation shall be a minimum of 10 linearfeet of piping, with all surfaces of the pipe exposed.

Acceptance Criteria The principalacceptance criteriaassociatedwith the inspections contained with this AMP follow:

a. Criteriafor soil-to-pipe potential are listed in NACE RP0285 2002 and SP0169-2007.

b. Forcoated piping or tanks, there should be eitherno evidence of coating degradationor the type and extent of coating degradation should be insignificantas evaluated by an individualpossessing a NACE operatorqualification or otherwise meeting the qualifications to evaluate coatings as contained in 49 CFR 192 and 195.

c. If metallic piping or tanks show evidence of corrosion, the remaining wall thickness in the affected area is determined to ensure that the minimum wall thickness is maintained.

d. Changesin iockey pump activity or equivalent parameterthat cannot be attributedto causes other than leakage from buried Dipinc are not occurrina.

Enclosure L-1 1-153 Page 176 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence B.2.7 Page B-42 "Operating Experience" section In response to RAI B.2.7-1, the "Operating Experience" section of B.2.7 is replaced in its entirety to read:

A search of Davis-Besse operating experience identified a fuel oil piping leak in 1995 associatedwith the steel piping from the above ground Diesel Oil Storage Tank. The cause was determined to be stray currentcorrosion. The protective coating on the top side of the pipe had small breaks in it, possibly due to the welder standing on the pipes during installation. The corrosion was confined to the top surface of the pipes. The loss of cathodic protection in the area allowed the corrosion to continue, leading to leakage from the pipe. The damaged pipe was replaced and the cathodicprotection repaired.

In 2002 an External Corrosion Direct Assessment (ECDA) and cathodic protection study was performed for the two emergency diesel fuel oil lines that are parallel steel pipes of approximately 420 feet length. The ECDA assessment indicates the pipelines had been receiving approximately 55 to 65% cathodic protection since installation. Following the indirect inspection, three excavation locations were selected for direct assessment. The mainline coating was found in sound condition. The tape wrap was poor at all three excavation locations and a coating holiday was found at one location. No significantexternal corrosion damage was found. The holiday was on the top of the pipe apparently damaged when the pipe was installed..

In 2008 an ECDA was performed on the same two emergency diesel fuel oil lines. One site was selected for excavation and direct examination and one validationdig was performed. Underfilm corrosion was identified at one location as a result of moisture ingress beneath disbonded coating. Remediation included cleaning the pipe surface and the applicationof two coats of mastic.

This was supplemented by the application of a cold applied adhesive-backed polyethylene tape.. Two areas of coating damage were thought to be the result of probe strikes in an earliereffort to locate the buried piping. A UT examination was performed on the areas where pitting was identified. The wall thickness was found to be greaterthan the nominal thickness for the pipe and was determined acceptable. The defects were considered to be minor and the overall condition of the pipe was noted to be very good.

The Corrective Action Program documents (October 2008) a leak in buried carbon steel piping associatedwith a three-inch condensate demineralizer backwash line. The 3 inch pipe is not within the scope of license renewal. The original function of the 3 inch pipe was to allow transferof non-radioactive resin slurry from the Backwash Receivina Tank to the Settlina Basin. The current

Enclosure L-11-153 Page 177 of 206 function is discharge from the Condenser Pit Sump pumps and Flood pumps.

The cause of failure was external corrosiondue to coating failure combined with an absence of cathodic protection. Numerous excavations in the area may have initiatedthe coating failure. A corrective action was the establishment of a buried piping integrity program for Davis-Besse. The degraded section of piping was replaced with high density polyethylene (HDPE)plastic piping.

The industry has issued EPRI TR- 10 16456, "Recommendationsfor an Effective Programto Control the Degradationof Buried Pipe," which includes a six step process to have an effective buriedpiping program. FENOC has implemented the program, which has identified all systems and components potentially susceptible to the buriedpiping conditions and their risk of degradationthrough a Systems Susceptibility Risk Ranking Criteria. The criteria include radiological process fluid, EPA concern, safety related, Limiting Condition for Operation risk, and others.

Davis-Besse operatingexperience demonstrates that the coating of buried steel piping and tanks is now effective in managing the effects of aging. Plant design considerationsaddressedthe potential for degradation of buried steel piping and tanks through the application of protective coatings. Review of site operating experience demonstrates that the uncoated cast iron piping is resistantto corrosionin the buried environment by virtue of no identified instances of noted degradationor failures. Industry operatingexperience has been addressedin the implementation of the EPRI buried piping program, and will continue to be addressedas industry operating experience is gained.

Enclosure L-11-153 Page 178 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence B.2.8 Page B-44 "Program Description" section, second paragraph In response to RAI B.2.8-1, the second paragraph of the "Program Description" section of B.2.8 is revised to read:

Also, the The Closed Cooling Water Chemistry Program also includes corrosion rate measurement at selected locations in the closed cooling water systems. In addition, the Closed Cooling W.ater Chem.istry

.. Progra m i . . .upmentedby thc One Time InspectionR, which provides verificat*io of the effectiveness of the program i. managing the effects of aqin* periodic inspections of opportunity will be conducted when components are opened for maintenance, repair, or surveillance, to ensure that the existing environmental conditions are not causing material degradation that could result in a loss of component intended function during the period of extended operation. A representative sample of piping and components will be inspected on a 10-year interval, with the first inspection taking place prior to entering the period of extended operation.

Affected LRA Section LRA Page No. Affected Paragraph and Sentence B.2.8 Page B-44 "Exceptions to NUREG-1801" section, second paragraph In response to RAI B.2.8-1, the second paragraph of the Parameters Monitored or Inspected, Detection of Aging Effects, Monitoring and Trending, and Acceptance Criteria subsection of the Program Elements Affected section of the Exceptions to NUREG-1801 section of B.2.8 is deleted as follows:

in addition, tO cOnfir adequate conditio monitoring and mgitigation of less of material andf Gracking in low flow and stagnant areas and adequate mitigation et reduction in heat transfer-, the prga isspplemgented by the One Timg InspectiOn, which includes cloGSeid:cooling water- system locations and ha eXchanger-s ser-vcd by closed cooling water-Systems.,

Enclosure L-11-153 Page 179 of 206 Affected LRA Section LRA Page No. Affected Paraqraph and Sentence B.2.8 Page B-45 "Enhancements" section In response to RAI B.2.8-1, the "Enhancements" section of B.2.8 is revised to read:

None

1. The Closed Coolinq Water Chemistry program will be enhanced to document the results of periodic inspections of opportunity, performed when components are opened for maintenance, repair,or surveillance.

2. The Closed Cooling Water Chemistry program will be enhanced to ensure that a representative sample of piping and components will be inspected on a 10-year interval, with the first inspection taking place prior to entering the period of extended operation.

Affected LRA Section LRA Page No. Affected Paragraph and Sentence B.2.8 Page B-45 "Conclusion" section, last sentence In response to RAI B.2.8-1, the last sentence of the "Conclusion" section of B.2.8 is revised to read:

The Closed Cooling Water Chemistry Program,as supplemented by the periodic inspections of opportunity One Time inspectO , provides reasonableassurance that the aging effects will be managed such that components within the scope of this program will continue to perform their intended functions consistent with the currentlicensing basis for the period of extended operation.

Enclosure L-11-153 Page 180 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence B.2.10 Page B-52 "Program Description" and "Enhancements" subsections New requirements for visual inspections of bolting and an evaluation of loads to be lifted by cranes, monorails and hoists are added to LRA Section B.2.10, "Cranes and Hoists Inspection Program," based on the responses to RAIs B.2.10-1 and B.2.10-2. Also the Cranes and Hoists Inspection Program is enhanced to add the visual inspections of bolting to station procedures. LRA Section B.2.10 is revised to read:

B.2.10 CRANES AND HOISTS INSPECTION PROGRAM Program Description The Cranes and Hoists Inspection Program is credited with managing loss of material for the structural components of cranes (including bridge, trolley, rails, and girders), monorails, and hoists within the scope of license renewal. The program also is credited with managing loss of preload for bolted connections associated with the cranes, monorails and hoists components within the scope of license renewal. The cranes, monorails and hoists within the scope of license renewal are those defined by NUREG-0612, "Control of Heavy Loads at Nuclear Power Plants," and light load handling systems related to refueling.

The Cranes and Hoists Inspection Program is a condition monitoring program that is based on guidance contained in American National Standards Institute (ANSI) B30.2 for overhead and gantry cranes, ANSI B30.11 for monorail systems and underhung cranes, and ANSI B30.16 for overhead hoists. The inspections monitor structural members for signs of corrosion and wear and bolted connections for loose bolts and missinq or loose nuts. The inspections are performed periodically for installed cranes and hoists. The program includes a review of the number and maqnitude of lifts made by a crane, monorail or hoist.

Enhancements Noene.

The following enhancements will be implemented in the identified prowram

Enclosure L-11-153 Page, 181 of 206 elements prior to entering the period of extended operation:

Scope, Parameters Monitored or Inspected, Detection of Aging Effects, and Acceptance Criteria Include visual inspections for loose bolts and missing or loose nuts in crane, monorailand hoist inspection procedures at the same frequency as mnsnections of rails and structuralcomponents.

insnections of rails and structuralcomnonents Affected LRA Section LRA Page No. Affected Paragraph and Sentence B.2.15 Page B-72 "Program Description" section, second paragraph In response to RAI B.2.2-2, the second paragraph of the "Program Description" section of B.2.15 is revised to read:

The External Surfaces Monitoring Programis a condition monitoring program that consists of periodic visual inspections and surveillance activities of component external surfaces to manage cracking and loss of material. The program includes components located in plant systems within the scope of license renewal that are constructed of copper alloy (copper, brass, bronze, and copper-nickel), stainless steel (including cast austenitic stainless steel), and steel (carbon and low-alloy steel and cast iron) materials. Cracking and loss Less of materialfrom the external surfaces of these metals will be evidenced by surface irregularities, leakage, or localized discolorationand be detectable priorto loss of intended function.

Affected LRA Section LRA Page No. Affected Paragraph and Sentence B.2.15 Page B-72 "Program Description" section, third paragraph In response to RAI 3.3.2.2.5-1, the third paragraph of the "Program Description" section of B.2.15 is revised to read:

The External Surfaces Monitoring Program,supplemented by the Qne Time JnspeGtion Inspection of Internal Surfaces in Miscellaneous Piping and Ducting

Enclosure L-11-153 Page 182 of 206 Program, includes inspection and surveillance of elastomers and polymers that are exposed to air-indooruncontrolled and air-outdoorenvironments, but are not replaced on a set frequency or interval (i.e., are long-lived), for evidence of cracking and change in materialproperties (hardeningand loss of strength).

Affected LRA Section LRA Page No. Affected Paragraph and Sentence B.2.15 Page B-73 "Enhancements" section, "Scope, Parameters Monitored/inspected, Detection of Aging Effects, Acceptance Criteria" first paragraph, first sentence In response to RAI 3.3.2.2.5-1, the first sentence of the first paragraph of the "Scope, Parameters Monitored/Inspected, Detection of Aging Effects, Acceptance Criteria" subsection of the "Enhancements" section, is revised as follows:

The External Surfaces Monitoring Program,supplemented by the One-Tim lnspeetien Internal Surfaces in Miscellaneous Piping and Ducting Program, will perform inspection and surveillance of elastomers and polymers exposed to air-indoor uncontrolled or air-outdoorenvironments, but not replaced on a set frequency or interval (i.e., are long-lived), for evidence of cracking and change in materialproperties (hardeningand loss of strength).

Affected LRA Section LRA Page No. Affected Paragraph and Sentence B.2.15 Page B-73 "Enhancements" section, new paragraph In response to RAI B.2.2-2, the following paragraph is added to the end of the "Enhancements" section of B.2.15:

The External Surfaces Monitoring Programwill also manage cracking of stainless steel components exposed to an outdoor air environment through plant system inspections and walkdowns for evidence of leakage. Acceptance criteriafor stainless,steel surfaces consist of no unacceptable visual indications of cracks that would lead to loss of function orior to the next scheduled insDection.

Enclosure L-11-153 Page 183 of 206 Affected LRA Section LRA Page No. Affected Paraqraph and Sentence B.2.15 Page B-74 "Conclusion" section, first sentence In response to RAI B.2.2-2, the first sentence of the "Conclusion" section of B.2.15 is revised to read:

The External Surfaces Monitoring Programhas been demonstratedto be capable of detecting and managing cracking and loss of material for metallic components.

Affected LRA Section LRA Page No. Affected Paragraph and Sentence B.2.18 Page B-81 "Program Description" section, second paragraph, first sentence In response to RAI B.2.18-1, the first sentence of the second paragraph of the "Program Description" section of B.2.18 is revised to read:

The program is credited with managing loss of material, as well as Gracking of sus.eptible materials,*for fire water supply and water-based fire suppression components in the scope of license renewal.

Enclosure L-11-153 Page 184 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence B.2.25 Page B-107 "Enhancements" section in response to RAI B.2.25-5, the "Enhancements" section of B.2.25, "Leak Chase Monitoring Program," is revised to read:

None The Leak Chase Monitoring Programacceptance criteria will be enhanced such that measurementof leakage from any monitoring line exceeding 15 milliliters per minute must be documented in the Corrective Action Programfor evaluation and potential corrective actions.

Affected LRA Section LRA Page No. Affected Paragraph and Sentence B.2.27 Page B-110 "Enhancements," section In response to RAI B.2.39-5, a "Detection of Aging Effects" enhancement is added before the Monitoring and Trending bullet as follows:

• Detection of Aging Effects The Masonry Wall Inspection, implemented by the Structures Monitoring Programprocedure, will be enhanced by specifying that, for the masonry walls within the scope of license renewal, inspections will be conducted at least once every five years, with provisions for more frequent inspections in areaswhere significant loss of materialor cracking is observed to ensure there is no loss of intended function between inspections.

Enclosure L-11-153 Page 185 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence B.2.30 Page B-120 All In response to RAIs 3.3.2.2.5-1, 3.3.2.71-2, B.2.8-1 and B.2.18-1, LRA Section B.2.30, "One-Time Inspection," is replaced in its entirety, and now reads:

B.2.30 ONE-TIME INSPECTION ProgramDescription One-Time Inspection is a new activity that will be implemented prior to entering the period of extended operation.

The activity will require one-time inspections to verify the effectiveness of the Fuel Oil Chemistry Program, the Lubricating Oil Analysis Program, and the PWR Water Chemistry Program. One-time inspections are used to address situations where: 1) an aging effect is not expected to occur, but there is insufficient data to completely rule it out, or 2) an aging effect is expected to progress very slowly in the specified environment, and the local environment may be more adverse.

One-Time Inspection will provide assurance that aging which has not yet manifested itself is indeed not occurring, or that the age-related degradationis so insignificant that an aging management program is not warranted. Inspection at air-water interfaces provides further confirmation that degradation is not occurring at locations where a potential exists for contaminants to concentrate due to alternate wetting and drying.

If evidence of age-related degradation is revealed by a one-time inspection, the routine evaluation of the inspection results will triggercorrective actions to ensure the intended function of the affected components is maintained through the period of extended operation.

The elements of the one-time inspections will include:

" Determination of a representativesample size based on an assessment of materials of fabrication, environment, plausible aging effects, and operating experience;

" Identification of the inspection locations in the system or component based on the aging effect, or based on the areas susceptible to concentration of contaminants that Dromote certain aainaeffects:

Enclosure L-11-153 Page 186 of 206 0 Determination of the examination technique, including acceptance criteria that would be effective in identifying the aging effects for which the component is examined; and

• Evaluation of the need for follow-up examinations -to monitor the progressionof identified age-relateddegradation.

NUREG-1801 Consistency One-Time Inspection is a new Davis-Besse activity that will be consistent with the 10 elements of an effective aging management program as described in NUREG- 1801 Section XI. M32, "One-Time Inspection."

Enhancements The followinq enhancements, which are plant-specific and in addition to the NUREG-1801,Section XI.M32 elements, will be implemented in the identified program elements prior to entering the period of extended operation.

• Scope The One-Time Inspection will also include visual and volumetric inspections to detect and characterize cracking of copper alloy >15% zinc exposed to raw water. The one-time inspections will provide direct evidence as to whether, and to what extent, cracking has occurred.

Cracking of copper alloy >15% zinc exposed to raw water is not addressedby anotheraging management program.

Aging Management ProgramElements The results of an evaluation of each program element are provided below.

Scope One-Time Inspection will require one-time inspections to verify the effectiveness of mitigation aging management programs; to confirm that age-related degradation is not occurring, is insignificant, or is occurring slowly such that component intended function will be maintained through the period of extended operation.

One-time inspections are required to verify the effectiveness of the Fuel Oil Chemistry Program, Lubricating Oil Analysis Program, and the PWR Water Chemistry Program for managing loss of material, cracking, or reduction in heat transferin the treated water, fuel oil. and lubricatinaoil environments.

The one-time inspections will also provide assurancethat:

Enclosure L-11-153 Page 187 of 206

" Aging effects are not occurring for susceptible materials in environments where degradation is not expected but cannot be ruled out based on available data.

" Aging effects are not occurring, or are progressing very slowly in a specified environment, as well as where the local environment may be more adverse than the bulk environment.

In addition, one-time inspections will characterize the material condition of susceptible materials exposed to the "Raw Water" environment, which is not addressed by other aging management programs, to verify that cracking is not occurring or to trigger additional actions that will assure the intended function of affected components will be maintained through the period of extended operation.

Furthermore, the one-time inspections will include UT exams of the internal bottom surfaces of a sample of fuel oil tanks to ensure that siqnificant degradationis not occurring.

• Preventive Actions One-Time Inspection is a condition monitoring activity that will consist of inspections independent of methods to mitigate or prevent degradation. The activity does not include any preventive actions.

" ParametersMonitored or Inspected One-Time Inspection will require inspections to be performed by qualified personnel following procedures consistent with the requirements of the ASME Code and 10 CFR 50, Appendix B. Inspections will be performed using a variety of nondestructive examination methods, including visual, volumetric, and surface inspection techniques.

The activity will inspect parameters directly related to degradation of the metallic components under review such as wall thickness, visual evidence of corrosion, or evidence of fouling.

• Detection of Aging Effects A representative sample of the system and component population will be inspected using a variety of nondestructive examination methods, includin, visual inspection, volumetric inspection, and surface inspection techniques.

The sample population will be determined by engineering evaluation, and where practical, will be focused on the (bounding or lead) components considered most susceptible to aging degradationdue to time in service, the severity of the operatingconditions, and the lowest design margin.

The inspections will be completed with sufficient time to ensure that the aging effects which may imDact comnonent intended functions early in the period of

Enclosure L-1 1-153 Page 188 of 206 extended operation will be appropriately managed. At the same time, the inspections will be timed to allow the components to attain sufficient age to ensure that aging effects with long incubationperiods can be identified.

"Monitoring and Trending The inspection sample size will be determined based on an assessment of materials of fabrication, environment, plausible aging effects, and operating experience. Inspection findings will be evaluated by assiqned engineering personnel Inspection findings not meeting the acceptance criteria will be evaluated and tracked through the FENOC Corrective Action Program. The Corrective Action Program will be used to identify the corrective actions including additionalinspections or expansion of the inspection sample size.

" Acceptance Criteria Indications or relevant conditions of degradationdetected during the one-time inspections will be compared to pre-determined acceptance criteria, such as design minimum wall thickness for piping. Inspection findings will be evaluated by assigned engineering personnel If the acceptance criteria are not met, then the indications or conditions will be evaluated under the Corrective Action Program to determine whether they could result in a loss of component intended function during the period of extended operation.

Determination of acceptance criteria will include evaluation of design standards and industry codes or standards, as applicable. Unacceptable inspection findings will include evidence of cracking, loss of material, or reduction in heat transfer (fouling) that could lead to loss of intended function during the period of extended operation.

• Corrective Actions This element is common to Davis-Besse programs and activities that are credited with aging management during the period of extended operation and is discussed in Section B. 1.3.

" Confirmation Process This element is common to Davis-Besse programs and activities that are credited with aging management during the period of extended operation and is discussed in Section B. 1.3.

" Administrative Controls This element is common to Davis-Besse programs and activities that are credited with aging management during the period of extended operation and is discussed in Section B. 1.3.

Enclosure L-11-153 Page 189 of 206 OperatingExperience Operating experience for select components and environments within the scope of One-Time Inspection was evaluated to ensure use of a one-time inspection was appropriate. Review of Davis-Besse operating experience did not identify any instances of deqradation that were caused by an ineffective chemistry program. As such, One-Time Inspection is credited to verify the effectiveness. Review of Davis-Besse operating experience did not identify any aging effects that were attributed to air-water interfaces (water-line attack). As such, One-Time Inspection is credited to verify that aging is not occurring or is occurring very slowly at air-water interfaces and component function is maintainedthrough the period of extended operation.

The elements that comprise the one-time inspections are consistent with industry practice. Industry and plant-specific operating experience will be considered in the development and implementation of this activity. As additional operating experience is obtained, lessons learned will be incorporated,as appropriate.

Conclusion Implementation of One-Time Inspection will provide reasonable assurance that the aging effects will be managed so that components within the scope of this inspection will continue to perform their intended functions consistent with the current licensing basis for the period of extended operation.

Enclosure L-11-153 Page 190 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence B.2.31 Page B-126 "Program Description" section In response to RAI B.2.31-1, the "Program Description" section of Section B.2.31 is revised as follows:

The Open-Cycle Cooling Water Program manages loss of material due to crevice, galvanic, general, pitting, and microbiologically-influenced corrosion (MIC), and also due to erosion for components located in the Service Water System, and for components connected to or cooled by the Service Water System, and also in the Circulating Water System. The program manages fouling due to particulates (e.g., corrosion products) and biological material (micro- and macro-organisms) resulting in reduction in heat transfer for heat exchangers within the scope of the program. In addition, the program manageS acking fo,-

cop per alley greater-than 15% z'n omnents that arc coolcd byf the ScR.'ic WatFSystem-.

The Open-Cycle Cooling Water Programconsists of inspections, surveillances, and testing to detect and evaluate fouling; and loss of material,and-oraoking-combined with chemical treatments and cleaning activities to minimize fouling, and loss of materia/-and Graeking. The existing program is a combination condition and performance monitoring and mitigation program that implements the recommendations of Generic Letter 89-13, "Service Water System Problems Affecting Safety-Related Equipment."

Affected LRA Section LRA Page No. Affected Paragraph and Sentence B.2.31 Page B-128 "Conclusion" section In response to RAI B.2.31-1, the "Conclusion" section of Section B.2.31 is revised as follows:

The Open-Cycle Cooling Water Programhas been demonstratedto be capable of detecting and managing loss of material-c raoking, and reduction in heat transfer for susceptible components in raw water environments. The Open-Cycle Cooling Water Program provides reasonable assurance that the aging effects will be managed such that 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.

Enclosure L-11-153 Page 191 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence B.2.33 Page B-134 Program Description, first paragraph, second sentence Based on the response to RAI B.2.33-1, the second sentence of the first paragraph of the Program Description of Section B.2.33, "PWR Water Chemistry Program," is revised to read:

The program manages the relevant conditions that could lead to the onset and propagationof a loss of material, cracking, or reduction in heat transferthrough propermonitoringand control consistent with EPRI TR-10 14986 Revision 6, "PressurizedWater Reactor PrimaryWater Chemistry Guidelines"and EPRI TR 10234 1016555 Revision k7, "PressurizedWater ReactorSecondary Water Chemistry Guidelines."

Affected LRA Section LRA Page No. Affected Paragraph and Sentence B.2.36 Page B-144 "Detection of Aging Effects" Section, second paragraph In reponse to RAI B.2.36-2, the second paragraph of the "Detection of Aging Effects" section is replaced as follows:

The aging management activties include (a) determination of the sample size based on an assessment of matefrials of fabrication, environmcntcondXitonS, time in er'ieand operating experience, (b) identificationofthenspect6on location in the ....... sy;tem or-c (0; determination of the examination

.ponen-technique, inclUding acceptance criteria; and (d) evaluation of the need for-folo up examinations to moenitor the progression of aging if age related degradationi found that could jeopardize an intended fun eten before the end of the period of extended operation.

The inspection includes a representative sample of the system population and focuses on the bounding or lead components most susceptible to aging due t time in service, severity of operating conditions, and lowest design margin.

Twenty percent of the population with a maximum sample of 25 constitutes a representative sample size.

Enclosure L-11-153 Page 192 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence B.2.37 Page B-146 Entire section In response to RAIs B.2.37-1, B.2.37-2 and B.2.37-3, Section B.2.37 is replaced in its entirety to read:

B.2.37 SMALL BORE CLASS 1 PIPING INSPECTION ProgramDescription The Small Bore Class 1 Piping Inspection is a one-time inspection that will be designed to detect cracking of small bore ASME Code Class I piping less than 4 inches nominal pipe size (less than NPS 4) and greaterthan or equal to NPS 1, which includes pipe, fittings, and branch connections, and all full and partial penetration (socket) welds.

The Davis-Besse Small Bore Class I Piping Inspection will consist of volumetric examination of a statisticallysignificant sample of small bore piping locations (full penetration welds and socket welds) that are susceptible to cracking. Location selection will be based on susceptibility, inspectability, dose considerations, operating experience, and limiting locations of the total population of ASME Code Class I small bore piping (less than NPS 4 and greaterthan or equal to NPS 1).

Volumetric examinations will be performed using demonstratedtechniques that are capable of detectinq the aging effects in the examination volume of interest.

Forpartialpenetration (socket) welds, the inspection will be eithera volumetric or opportunistic destructive examination. If a qualified volumetric examination procedure for socket welds endorsed by the industry and the NRC is available and incorporatedinto the ASME Code Section X1 at the time of the small-bore socket weld inspections, then this will be used for the volumetric examinations.

Otherwise, the socket weld volumetric examinations will follow guidelines set forth in ASME Code Section V, Article 4 consistent with the guidelines for examination volume of 1/2" beyond the toe of the weld as established in EPRI Report 1011955, "MaterialsReliability Program:Management of Thermal Fatique in Normally Stagnant Non-Isolable Reactor Coolant System Branch Lines (MRP-146)." Volumetric examinations will be performed by qualified personnel following procedures that are consistent with Section XA of the ASME Code and 10 CFR 50, Appendix B.

Davis-Besse with over 30 years of operating experience has experienced two instances of cracking of small bore Class 1 piping and in both cases, design changes were implemented to effectively mitigate the cracking. Therefore, the one-time inspection is applicable to Davis-Besse. Should evidence of cracking be

Enclosure L-11-153 Page 193 of 206 revealed by the one-time inspection, periodicinspection will be implemented using a plant-specific aging management program.

The Small Bore Class I Piping Inspection is a new one-time inspection that will be completed within the six year period prior to entering the period of extended operation.

NUREG-1801 Consistency The Small Bore Class I Piping Inspection is a new one-time inspection for Davis-Besse that will be consistent with the 10 elements of an effective aging management program as describedin NUREG-1801,Section XI. M35, "One-time Inspection of ASME Code Class 1 Small-Bore Piping."

Exceptions to NUREG-1801:

None.

Enhancements:

None.

Aging Management ProgramElements The results of an evaluation of each program element are provided below.

Scope The Small Bore Class 1 Piping Inspection is a one-time inspection of a sample of ASME Code Class I piping less than NPS 4 and greaterthan or equal to NPS 1. The inspection will include measures to verify that unacceptable degradationis not occurring in Class 1 small bore piping, thereby confirming that an aging management program is not needed for the period of extended operation. The Small Bore Class I Piping Inspection will consist of small bore piping locations that are susceptible to cracking.

" Preventive Actions The Small Bore Class 1 Piping Inspection will consist of evaluation and inspection activities with no actions to prevent or mitigate aging effects.

" ParametersMonitored or Inspected The Small Bore Class I Piping Inspection is a one-time inspection that will include volumetric examinations performed by gualified personnel, using

Enclosure L-11-153 Page 194 of 206 qualified volumetric examination techniques and following procedures consistent with Section Xl of the ASME Code and 10 CFR 50, Appendix B.

• Detection of Aging Effects The Davis-Besse Small Bore Class I Piping Inspection will consist of volumetric examination of a statisticallysignificant sample of small bore piping locations (full penetration welds and socket welds) that are susceptible to cracking. Location selection will be based on susceptibility, inspectability, dose considerations,operating experience, and limiting locations of the total population of ASME Code Class 1 small bore piping (less than NPS 4 and greaterthan or equal to NPS 1). A statisticallysignificant sample size will consist of 10% of the weld population or a maximum of 25 welds of each weld type (e.g., full penetration or socket weld) using a methodoloqy to select the most susceptible and risk-siqnificantwelds. Forsocket welds, opportunistic destructive examination may be performed in lieu of volumetric examination.

Because more information can be obtainedfrom a destructive examination than from nondestructive examination, each destructive examination will be considered equivalent to having volumetrically examined two welds. The ASME Code Class 1 piping weld population (less than NPS 4 and greater than or equal to NPS 1) for Davis-Besse consist of approximately 179 full penetration welds and 437 partialpenetration (socket) welds.

Volumetric examinations will be performed using demonstratedtechniques that are capable of detecting the aging effects in the examination volume of interest. Forpartialpenetration (socket) welds, the inspection will be either a volumetric or opportunistic destructive examination. If a qualified volumetric examination procedure for socket welds endorsed by the industry and the NRC is available and incorporatedinto the ASME Code Section XA at the time of the small-bore socket weld inspections, then this will be used for the volumetric examinations. Otherwise, the socket weld volumetric examinations will follow guidelines set forth in ASME Code Section V, Article 4 consistent with the guidelines for examination volume of 1/2" beyond the toe of the weld as establishedin EPRI Report 1011955, "MaterialsReliability Program:

Management of Thermal Fatigue in Normally Stagnant Non-Isolable Reactor Coolant System Branch Lines (MRP-146)."

This one-time inspection will be completed within the six year period priorto entering the period of extended operation.

Davis-Besse with over 30 years of operating experience has experienced two instances of cracking of small bore Class I piping and in both cases, design changes were implemented to effectively mitigate the cracking. Therefore, the one-time inspection is applicable to Davis-Besse. Should evidence of

Enclosure L-11-153 Page 195 of 206 cracking be revealed by the one-time inspection, periodic inspection will be implemented using a plant-specific aging management program.

" Monitoringand Trending The Small Bore Class I Piping Inspection is a one-time inspection to determine whether cracking in ASME Code Class I small-bore piping resulting from stress corrosion, cyclical (including thermal, mechanical, and vibration fatique) loading, or thermal stratificationand thermal turbulence

[EPRI reports 1011955, "MaterialsReliability Program:Management of Thermal Fatiquein Normally Stagnant Non-Isolable Reactor Coolant System Branch Lines (MRP-146)" and 1018330, "MaterialsReliability Program:

Management of Thermal Fatique in Normally Stagnant Non-Isolable Reactor Coolant System Branch Lines - Supplemental Guidance (MRP-146S)'7 is an issue.

Should evidence of cracking be revealed by the one-time inspection, periodic inspection will be implemented using a plant-specific aging management program.

" Acceptance Criteria Unacceptableinspection findings will be evaluated by the Corrective Action Program using criteriain accordancewith the ASME Code.

• Corrective Actions This element is common to Davis-Besse programs and activities that are credited with aging management during the period of extended operationand is discussed in Section B. 1.3.

" Confirmation Process This element is common to Davis-Besse programs and activities that are credited with aging management during the period of extended operationand is discussed in Section B. 1.3.

• Administrative Controls This element is common to Davis-Besse programsand activities that are credited with aging management during the period of extended operation and is discussed in Section B. 1.3.

Enclosure L-11-153 Page 196 of 206 Operating Experience Davis-Besse with over 30 years of operatingexperience has experienced two instances of cracking of small bore Class 1 piping and in both cases, design changes were implemented to effectively mitiqate the cracking.

The first instance of cracking due to stress corrosion cracking was found in the reactorvessel closure gasket leakage monitoring line. It was determined that the stress corrosioncracking was promoted by chlorides left after water evaporatedin the line. The issue was evaluated usinq the Corrective Action Programand it was determined that these lines are not indicative of other small bore piping. The affected piping was replaced and the procedure was changed to require draining of the line after use.

The second instance of cracking was an axial indication found on the RCS Loop I cold leg drain line 1-1 nozzle-to-elbow weld durinq the Cycle 14 refueling outage. The probable cause is extensive localized weld repairduring initialconstruction. This repaireither resulted in a latent flaw or a crack initiation site. The residual stresses from the construction weld repair, combined with the environment in the reactorcoolant system and the susceptibility of Alloy 600 material, establishedthe presence of the three key elements for the development of primary water stress corrosion cracking in spite of the low susceptibilityin cold leq drain lines. This cracking was due to an event (local weld repair)and is not indicative of general aging in small bore lines. Corrective action during the Cycle 14 refueling outage included a full structuralweld overlay repairof the subiect dissimilarmetal weld (Alloy 82/182 weld). During the Cycle 16 refueling outage, full structuralweld overlays were installedfor the other equivalent dissimilarmetal welds in RCS Cold Leg Drain lines 1-2, 2-1 and 2-2 to preemptively mitigate primary water stress corrosioncracking (PWSCC).

Conclusion The Small Bore Class 1 Piping Inspection will verify that cracking due to stress corrosion, cyclical (including thermal, mechanical,and vibration fatigue) loading, or thermal stratificationand thermal turbulence is not occurringor is insignificant, such that an aging management program is not requiredduring the period of extended operation. The Small Bore Class 1 Piping Inspection will provide reasonableassurancethat the aging effects are not occurringsuch that components within the scope of this inspection will continue to perform their.

intended functions consistent with the current licensing basis for the period of extended operation.

Enclosure L-11-153 Page 197 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence B.2.39 Page B-156 "Enhancements" section In response to RAI B.2.39-4, the following additional "Detection of Aging Effects" paragraph is added to the "Enhancements" section of B.2.39:

Detection of Aqing Effects The Structures Monitorinq Program will be enhanced to require that personnel performing the structuralinspections meet qualificationsthat are commensurate with ACI 349.3R, "Evaluationof Existing Nuclear Safety-Related Concrete Structures," Chapter 7, "Qualificationsof Evaluation Team."

Affected LRA Section LRA Page No. Affected Paragraph and Sentence B.2.39 Page B-156 "Enhancements," section In response to RAI B.2.39-5, a "Detection of Aging Effects" enhancement is added before the Monitoring and Trending bullet as follows:

• Detection of Aqin-q Effects The program procedure will be enhanced by specifying that, for the structures within the scope of license renewal, inspections will be conducted at least once every five years.

Enclosure L-11-153 Page 198 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence B.2.39 Page B-156 "Enhancements," section Table A-1 Pages A-65, 67 Commitments 20 & 21

& 68 B.2.40 Page B-163 "Enhancements" section In response to RAI B.2.39-7, a "Detection of Aging Effects" enhancement is added before the Monitoring and Trending bullet.

Additionally, the LRA is revised (eight locations in the following sections: LRA Table A-i, Commitments 20 and 21; Section B.2.39; and Section B.2.40) to delete the published year (i.e., -96) when referring to ACI 349.3R.

LRA Section B.2.39, "Structures Monitoring Program," subsection "Enhancements," is revised to read:

• Detection of Aging Effects The Structures Monitoring Programprocedure will be enhanced to require optical aids, scaling technologies, mechanical lifts, ladders or scaffolding for tall structures or difficult to reach areas of structures to allow visual inspections that meet the guidelines of Chapter5 of ACI 349.3R. Select the areasto be inspected in accordance with the guidelines of Chapter5 of ACI 349.3R to reflect the "PeriodicEvaluation"criteriadefined in Chapter3.3 of ACI 349.3R. Include the "prioritizationprocess"in the selection methodology to develop a representativesample of areasto inspect in accordance with ACI 349.3R.

Enclosure L-11-153 Page 199 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence B.2.39 Page B-156 "Acceptance Criteria," section In response to RAI B.2.39-6, the "Acceptance Criteria" enhancement is revised as follows:

Acceptance Criteria The program procedure will be enhanced by adding sufficient acceptance criteriaand criticalparametersto triggeran increased level of inspection and initiationof corrective action. Indicate that A Cl 349.3R-96, "Evaluationof Existing Nuclear Safety-Related Concrete Structures," provides acceptable guidelines which will be considered in developing acceptance criteria for concrete structuralelements, steel liners,joints, coatings, and waterproofing membranes. Plant specific quantitative degradationlimits, similar to the three-tier hierarchyacceptance criteriafrom Chapter5 of ACI 349.3R, will be developed and added to the inspection procedure. The Structures Monitoring Programprocedure will also be enhanced to reflect the "PeriodicEvaluation" criteriadefined in chapter 3.3 of ACI 349.3R. The Structures Monitoring Program procedure will include the "prioritizationprocess"to develop a representative sample of areas to inspect in accordance with ACI 349.3R.

Conduct a baseline inspection of the structures within the scope of license renewal prior to entering the period of extended operation.

Enclosure L-11-153 Page 200 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence B.2.40 Page B-163 "Acceptance Criteria," section In response to RAI B.2.39-6, the "Acceptance Criteria" enhancement is revised as follows:

Acceptance Criteria The Water ControlStructures Inspection, included in the existing Structures Monitoring Program, will lit A G-1 3-249.3R 96, "Evaluationof Ex-iting Nulea, Safet Related ConGrete StrUctures, " as1 a reference and wil indicate that-it

.wil be considered in developing acceptance criteria for-inspection of w-ater control structures, add sufficient acceptancecriteria and criticalparametersto triggeran increasedlevel of inspection and initiation of corrective action.

Indicate that ACI 349.3R provides acceptable guidelines which will be considered in developing acceptance criteriafor water control structures.

Plant specific quantitative degradationlimits, similar to the three-tierhierarchy acceptance criteria from Chapter5 of ACI 349.3R, will be developed and added to the inspection procedure. The Structures Monitoring Program procedure will also be enhanced to reflect the "PeriodicEvaluation"criteria defined in chapter 3.3 of ACI 349.3R. The Structures Monitoring Program procedure will include the "prioritizationprocess"to develop a representative sample of areasto inspect in accordancewith ACI 349.3R.

Conduct a baseline inspection of the structures within the scope of license renewal priorto enterina the period of extended operation.

Enclosure L-11-153 Page 201 of 206 Affected LRA Section LRA Page No. Affected Paragraph and Sentence B.2.41 Page B-166 New section Appendix B Table of Page B-4 New listing - B.2.41 Contents In response to RAIs 3.3.2.2.5-1 and 3.3.2.71-2, LRA Section B.2.41, "Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Program," is created to include a new plant-specific aging management program. Although not shown below, LRA Appendix B, "Aging Management Programs," "Table of Contents" on LRA Page B-4 is revised accordingly to include the new section.

New LRA Section B.2.41 reads:

B.2.41 INSPECTION OF INTERNAL SURFACES IN MISCELLANEOUS PIPING AND DUCTING PROGRAM ProgramDescription The Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Program is a new plant-specific program for Davis-Besse. The program will consist of inspections of the internal surfaces of aluminum, copper alloy (includingcopper alloy > 15% Zn), stainless steel, and steel (including gray cast iron) components exposed to air,condensation, diesel exhaust, or moist air, and external coolinq coil surfaces. The Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Programwill also consist of accessible inspections of the internal surfaces of non-metallic, flexible (elastomeric)components that are not included in other aging management programsand the external surfaces of non-metallic, flexible (elastomeric) components as a supplement to the External Surfaces Monitoring Program.

The program will manage loss of material, cracking of susceptible stainless steel components, hardeningand loss of strength of non-metallic, flexible (elastomeric) components, and reduction in heat transferof cooling coil tubes and fins.

The Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Program will include opportunisticinspections, when components are opened for maintenance, repair,or surveillance to ensure that the existing environmental conditions are not causing materialdegradationthat could result in a loss of component intended function during the period of extended operation.

Enclosure L-11-153 Page 202 of 206 Implementation of this program will ensure that the intended functions of susceptible components are maintaineddurinq the period of extended operation.

The Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Program is a new condition-monitoringprogram. At least one inspection of each material and environment combination will be conducted within the 10-year period prior to entering the period of extended operation.

NUREG-1801 Consistency The Inspection of Internal Surfaces in Miscellaneous Piping and Ductinq Program is a new plant-specific program for Davis-Besse. While NUREG-1801-includes an Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program (XI. M38), because the Davis-Besse Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Programis plant-specific, it is evaluated against the ten elements described in Appendix A. 1, Section A. 1.2.3 of NUREG-1800, "StandardReview Plan for Review of License Renewal Applications for Nuclear PowerPlants." The results of an evaluation for each element are provided below.

Aging Management ProgramElements The results of an evaluation of each program element are provided below.

Scope The scope of the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Programincludes the external surfaces of cooling coils and the internalsurfaces of aluminum, copper alloy (including copper alloy > 15% Zn),

stainless steel, and steel (includinggray cast iron) components exposed to air,condensation, diesel exhaust, or moist air,and the internaland external surfaces of non-metallic, flexible (elastomeric)components that are not included in other aging management programs.

The program will include baseline inspections followed by opportunistic inspections, when components are opened for maintenance, repair,or surveillance to ensure that the existing environmental conditions are not causing materialdegradationthat could result in a loss of component intended function during the period of extended operation. This program includes indication of boric acid wastage on internalsurfaces.

The program will include visual and physical (manipulation or prodding) examination of subject non-metallic, flexible (elastomeric)components in various environments for evidence of hardening or loss of strength due to

Enclosure L-11-153 Page 203 of 206 thermal exposure, ultraviolet exposure, or ionizing radiationas a supplement to the External Surfaces Monitoring Program.

Preventive Actions The Inspection of Intemal Surfaces in Miscellaneous Piping and Ducting Programis a condition monitoringprogram that consists of inspection activities independent of methods to mitigate or prevent degradation. This program does not include any preventive actions.

ParametersMonitored or Inspected The program will inspect parametersdirectly related to degradationof the metallic components under review including visual evidence of corrosionor fouling, and wall thickness measurements where applicable. Also, since visual inspection may not detect cracking prior to a loss of function, enhanced visual inspection will be used, as applicable.

The parametersto be inspected for non-metallic (elastomeric)components include visual evidence of surface degradation,such as cracking or discoloration,as well as hardening and loss of strength identified through manipulation or prodding.

Detection of Aging Effects The Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Program provides for detection of aging effects prior to the loss of component intended function. Baseline inspections for each materialand environment combination within the scope of the program will be conducted priorto entering the period of extended operation at locations with conditions likely to exhibit the aging effects of concern in the identified environments.

Subsequently, opportunistic visual inspections will be conducted when components are opened for any reason, including maintenance, repair,or surveillance, and surfaces are available for inspection. Visual inspections will be performed by qualified personnel and will be supplemented by other establishednondestructive examination (NDE) techniques, as appropriate.

For non-metallic (elastomeric)components, establishedvisual examination techniques, as well as physical manipulation or prodding, will be performed by qualified personnel on a sample population of subiect components to identify evidence of hardening and loss of strength (change in materialproperties).

The sample population for physical manipulation is 10 percent of available surface area, including known suspect locations. These tactile inspections

Enclosure L-11-153 Page 204 of 206 are also performed on an opportunisticbasis, whenever components are opened for maintenance, repair,or surveillance.

At least one inspection of each materialand environment combination will be conducted within the 10-year period priorto entering the period of extended operation. Any evidence of degradationwill be documented and evaluated through the Corrective Action Program.

Monitoring and Trending The Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Program will include baseline inspections prior to entering the period of extended operation, followed by opportunisticinspections when components are opened for any reason, including maintenance, repair,or surveillance, and surfaces are available for inspection. Visual inspections will be performed by qualified personnel and will be supplemented by other establishedNDE techniques, as appropriate. Inspection findings will be documented and evaluated by assiqned engineeringpersonnel such that the results can be trended. Inspection findings that do not meet acceptance criteriawill be evaluated and tracked using the Corrective Action Program with subsequent adjustments to the program, as necessary, to ensure timely corrective or mitigative actions.

Additionally, the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Program will include a periodic review of maintenance and surveillance history to ensure that opportunitiesfor inspection of each materialand environment combination have occurred during the period or to initiate appropriateaction through the Corrective Action Program. The interval between these reviews will be establishedbased on the results of the baseline inspections for each materialand environment combination in the scope of the program.

Acceptance Criteria Indications of relevant conditions of degradationdetected durinq the inspections will be evaluated and compared to pre-determinedacceptance criteria. Any abnormalsurface condition may be an indication of an aging effect for metals and non-metallic (elastomeric)components. Forstainless steel surfaces, a clean, shiny surface is expected. Visual indicationsof cracks, discoloration,or tube or fin fouling (buildup of dirt or other foreign material)may indicate an aging effect for metallic components, and for elastomeric components. The acceptance criteriaare defined to ensure that the need for corrective actions is identified before loss of component intended function. If the acceptance criteriaare not met, then the indicationsor conditions will be evaluated under the Corrective Action Program.

Enclosure L-11-153 Page 205 of 206 Engineerinqevaluation by qualified personnel will be used for determination of acceptancecriteria for the aging effects of concern for materialand environment combinations in the scope of the program. Unacceptable inspection findings include evidence of cracking, loss of material, heat exchanger tube or fin fouling, and hardening and loss of strength that could lead to loss of intended function during the period of extended operation.

• Corrective Actions This element is common to Davis-Besse programsand activities that are credited with aging management durinq the period of extended operation and is discussed in Section B. 1.3.

" Confirmation Process This element is common to Davis-Besse programsand activities that are credited with aging management during the period of extended operation and is discussed in Section B. 1.3.

• Administrative Controls This element is common to Davis-Besse programs and activities that are credited with aging management during the period of extended operation and is discussed in Section B. 1.3.

• Operating Experience Review of Davis-Besse operating experience identified select instances of degradationin materialand environment combinations in the scope of the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Program that were eithercorrected via modification or the corrective actions did not include establishing actions to prevent recurrence and no subsequent degradationwas identified. However, not all materialenvironment combinations within the scope of the program are represented.

In 2003, because of chronic rust and particulateaccumulation in the diesel air start compressorand filter components, a modification was implemented for the emergency diesel generator(EDG) airstart system. The modification replaced carbon steel piping and components with stainless steel and added air filters, air dryers, and moisture separators,etc. to mitigate rust particulates and moisture effects in the EDG airstart subsystem. A similarmodification was implemented for the station blackout diesel generator(SBODG) air start system. Review of Davis-Besse operating experience subsequent to these modifications did not identify any aging effects that were attributedto

Enclosure L-11-153 Page 206 of 206 excessive moisture in the compressed airdownstream of EDG dryers or SBODG dryer-filters.

Some corrosion caused by moisture accumulation in Station Air components with a moisture removal function (e.g., aftercoolerseparatordrain trap) has been documented. Corrective action included removing the moisture and rust, and confirming propertrap (automatic drain) operation, but did not result in component replacementor establishment of actions to prevent recurrence.

In 2004, industry operatingexperience regardingcorrosion of refrigeration lines due to condensation forming on cold carbon steel piping surfaces was evaluated for applicability at Davis-Besse. Units were evaluated, includinq some that are in the scope of this program, and it was determined that copper piping and tubing was not subiect to the identified corrosion. Expected surface rust was also identified on many components in Davis-Besse refrigerationsystems through walkdown. It was concluded that the concern raisedby the operating experience is not an issue for Davis-Besse.

The elements that comprise the Inspection of Internal Surfaces in Miscellaneous Pipingand Ducting Programinspections will be consistent with industry practice. Industry and plant-specific operating experience will be consideredin the development and implementation of this program. As additionaloperatingexperience is obtained,lessons learned will be incorporated,as appropriate.

Enhancements:

None.

Conclusion Implementation of the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Program will provide reasonableassurancethat the existing environmental conditions are not causing materialdegradation that could result in a loss of component intended function, aging effects will be managed such that the component intended functions will be maintainedconsistent with the current licensing basis during the period of extended operation, and spatialinteractions (e.g., leakage) will not result in loss of safety-related component intended functions during the period of extended operation.