L-11-237, Reply to Request for Additional Information for the Review of the Davis-Besse Nuclear Power Station, Unit No. 1, License Renewal Application (TAC No. ME4640), & License Renewal Application Amendment No. 14

Reply to Request for Additional Information for the Review of the Davis-Besse Nuclear Power Station, Unit No. 1, License Renewal Application (TAC No. ME4640), & License Renewal Application Amendment No. 14

ML11242A166
Person / Time
Site:	Davis Besse
Issue date:	08/26/2011
From:	Byrd K FirstEnergy Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-11-237, TAC ME4640
Download: ML11242A166 (54)

Text

FENOC Davis-Besse Nuclear Power Station 5501 N. State Route 2 FirstEnergyNuclear Operating Company Oak Harbor.Ohio 43449 August 26, 2011 L-1 1-237 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 Request for Additional Information for the Review of the Davis-Besse Nuclear Power Station, Unit No. 1, License Renewal Application (TAC No. ME4640), and License Renewal Application Amendment No. 14 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, Unit No. 1 (DBNPS). By letters dated June 20, 2011 (ML11167A171), July 21, 2011 (ML11195A020), and July 27, 2011 (ML11203A080), the Nuclear Regulatory Commission (NRC) requested additional information to complete its review of the License Renewal Application (LRA).

The Attachment provides the FENOC reply to NRC requests for additional information (RAIs) as follows:

1 of 14 RAIs in NRC letter dated June 20, 2011 (ML11167A171)

- The response to Follow-up RAI B.2.1-2 from the June 20, 2011, letter had been delayed based on a discussion with Mr. Samuel Cuadrado de Jesus, NRC Project Manager, on July 19, 2011, during which it was agreed that the RAI response would be withheld pending further review by NRC. The NRC review is complete and the FENOC response is contained herein.

4 of 13 RAIs in NRC letter dated July 21, 2011 (ML11195A020)

- Includes RAIs B.2.22-6; B.2.39-11; B.2.39-12; and, 3.5.2.3.12-4 2 of 5 RAIs in NRC letter dated July 27, 2011 (ML1I1203A080)

- Includes RAIs 3.3.2-4 and 3.3.2.14-1 3 Supplemental RAI responses

- Includes supplemental responses for RAI 3.3.2.3.14-1; One-Time Inspection Program Examination Types; and, Makeup Pump Casing Inspections ,

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Davis-Besse Nuclear Power Station, Unit No. 1 L-1 1-237 Page 2 The NRC request is shown in bold text in the Attachment followed by the FENOC response. The Enclosure provides Amendment No. 14 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 August 2_6,, 2011.

Sincerely, Kendall W. By Director, Site Performance Improvement

Attachment:

Reply to Request for Additional Information for the Review of the Davis-Besse Nuclear Power Station, Unit No. 1 (DBNPS), License Renewal Application, Sections B.2.1, B.2.22, B.2.30, B.2.39, 3.3.2 and 3.5.2

Enclosure:

Amendment No. 14 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 L-11-237 Reply to Request for Additional Information for the Review of the Davis-Besse Nuclear Power Station, Unit No. 1 (DBNPS), License Renewal Application, Sections B.2.1, B.2.22, B.2.30, B.2.39, 3.3.2 and 3.5.2 Page 1 of 16 Question RAI Followup B.2.1-2

Background:

The applicant responded to the RAI B.2.1-1 by proposing to revise Subsection 2.1.2 of the Davis Besse Nuclear Power Station (DBNPS)

Surveillance Test Procedure DB-PF-03009, Revision 06, "Containment Vessel and Shielding Building Visual Inspection." Revised Subsection 2.1.2 shall state "Personnel who performed general visual examinations of the exterior surface of the Containment vessel and the interior and exterior surfaces of the Shielding Building shall meet the requirements for a general visual examiner in accordance with Nuclear Operating Procedure NOP-CC-5708, Written Practice for the Qualification and Certification of Nondestructive Examination Personnel."

Issue:

Element 5 "Detection of Aging Effects" in GALL AMP XI.S4 recommends the implementation of periodic in-service examinations for the containment structures by applying the requirements of subsections in ASME Section XI. The associated Subsection IWE-3510.1 of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code), Section X1 (1995),

requires that "The general Visual Examination shall be performed by, or under the direction of, a Registered Professional Engineer or other individual, knowledgeable in the requirements for design, in-service inspections, and testing of Class MC and metallic liners of Class CC components."

Request:

To comply with the ASME Code,Section XI requirement, the associated Subsection IWE-3510.1 of ASME Code,Section XI (1995) code requirement must be referenced in the new revision of the DBNPS's Nuclear Operating Procedure and/or Surveillance Test Procedure.

RESPONSE Followup RAI B.2.1-2 Davis-Besse is currently in the Third 10-year Inservice Inspection Interval (September 21, 2000, to September 20, 2012). The 1995 Edition through the 1996 Addenda of ASME Section XI is the Code Edition used for the Third 10-Year Inspection Interval. In response to license renewal future Commitment 27 provided in FENOC letter dated May 5, 2011 (ML11131A073), FENOC revised Davis-Besse procedure DB-PF-03009, "Containment Vessel and Shield Building Visual Inspection." To ensure

Attachment L-1 1-237 Page 2 of 16 the qualification requirements for examiners are clear, sections of the ASME Code are included in procedure NOP-CC-5708, "Written Practice for the Qualification and Certification of Nondestructive Examination Personnel." Procedure NOP-CC-5708 is a fleet procedure, applicable to three stations (Davis-Besse, Beaver Valley Nuclear Power Station, and Perry Nuclear Power Station), and the ASME Code Editions are different for the three stations.

The following items summarize how FENOC is meeting the Subsection IWE-3510.1 requirements of the ASME Section Xl Code (1995 Edition) for Davis-Besse:

1. Section 2.1.2 of procedure DB-PF-03009, "Containment Vessel and Shield Building Visual Inspection," requires that the General Visual examiner for Containment vessel and Shield Building examinations shall meet the requirements in NOP-CC-5708, as follows:

"Personnel who perform general visual examinations of the exterior surface of the Containment Vessel and the interior and exterior surfaces of the Shield Building shall meet the requirements for a general visual examiner in accordance with NOP-CC-5708. These individuals shall be knowledgeable of the types of conditions which may be expected to be identified during the examinations."

2. Section 1.3 of NOP-CC-5708 states that the procedure meets the requirements of ASME Section XI code through the 2001 Edition, 2003 Addenda. The procedure covers the Section XI code of record (as identified in each plant's Inservice Inspection program document) up to the most recent Edition applicable to the three sites using the procedure (Beaver Valley and Perry currently use the 2001 Edition of the ASME Code through the 2003 Addenda), which bounds the Code Edition currently in use by Davis-Besse. Based on the different Code Editions in use, separate requirements are included in the procedure for Davis-Besse, Beaver Valley and Perry.

3. Section 2.1 of NOP-CC-5708 specifically identifies that qualification and certification to perform Detailed and General Visual Examinations governed by Section Xl, Subsections IWE and IWL, are covered by the procedure.

4. Section 4.2.5 of NOP-CC-5708 provides the ASME Code requirements for the General Visual Examiner (IWE /IWL) for each station based on the plant's Code Edition.

Attachment L-1 1-237 Page 3 of 16 Question RAI B.2.22-6

Background:

By letter dated May 24, 2011, the applicant responded to a staff RAI B.2.22-2 regarding the examination of the inaccessible portion of the steel containment that may be exposed to borated water leakage from the reactor cavity pool leakage. The applicant added Commitment 39 to address the potential for borated water degradation of the steel containment vessel prior to entering the period of extended operation.

Issue:

In the RAI response, the applicant stated that 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 NDT 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. However, the applicant did not provide specific details, schedule, and location for accessing the inside surface of the embedded steel containment.

Request:

Please provide specific details, schedule, and location for accessing the inside surface of the embedded steel at the lowest point in the containment. In addition, the applicant is requested to provide details on how it will continue to inspect and monitor the inside surface (inaccessible area) of the steel containment until the borated water leakage from the reactor cavity is stopped.

RESPONSE RAI B.2.22-6 FENOC is planning to perform a core bore to access the inside surface of the embedded containment vessel. A core bore is planned for completion by the end of 2014. Based on the core bore inspection results and refueling canal leakage mitigation results, a second core bore may be necessary. If a second core bore is necessary, the second core bore will be planned for completion by the end of 2020. The inspection in 2014 will allow a visual inspection of the embedded surface of the containment vessel to determine if borated water is present. If water is found, FENOC plans to analyze the water for boron content, pH value, and iron content. Regardless of whether water is found, FENOC plans to collect samples of corrosion, boric acid residue, or other foreign material found at the surface of the containment vessel. FENOC plans to analyze the

Attachment L-1 1-237 Page 4 of 16 samples to the extent that there is enough material to allow analysis. Planned examination and chemical testing of removed concrete may provide evidence of current or past presence of an aging effect. If the concrete removal method provides large enough pieces of concrete, FENOC plans to perform a petrographic examination of those pieces. FENOC plans to use ultrasonic thickness (UT) measurements to determine the thickness of the containment vessel at the area accessed. FENOC also plans to examine and evaluate reinforcing bar if it is exposed. Upon completion of the inspection and testing, FENOC plans to fill the core bore hole with concrete or non-shrink grout. FENOC plans to enter the results of the inspection and testing into the FENOC Corrective Action Program to evaluate the conditions found to determine the need and scope of additional actions that need to be performed.

FENOC plans to locate the core bore below the reactor vessel where the Incore Tunnel opens through the primary shield wall into the area below the reactor vessel. That location is about eighteen feet from the containment vessel centerline. The lowest point of the containment vessel is about 30 inches lower than the elevation of the containment bottom head at the core bore location. The Incore Tunnel location was chosen because of the boron deposits that have been found in the Incore Tunnel.

FENOC plans to use the results of the 2014 core bore inspection and testing to determine the need and scope of additional actions that need to be performed.

If a second core bore is necessary, FENOC plans to perform similar actions for a future core bore as are planned for the 2014 core bore. FENOC plans to conduct future core bores and ultrasonic thickness (UT) measurements in the same manner if the refueling canal leakage continues or if the leakage resumes.

LRA Table A-I, "Davis-Besse License Renewal Commitments," license renewal future Commitment 39, is revised based on the information provided above.

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

Question RAI B.2.39-11

Background:

By letter dated May 24, 2011, the applicant responded to a staff RAI B.2.39-3 regarding operating experience with aggressive groundwater infiltration and possible degradation of inaccessible concrete. In the response the applicant stated that there is no evidence that aggressive groundwater has contributed to structural degradation. However, to address the possibility of degradation, the applicant committed to obtain and evaluate a concrete core from a representative, normally inaccessible location (Commitment 20).

Attachment L-1 1-237 Page 5 of 16 Issue:

Although the applicant committed to taking core bores, the response did not provide details about when the cores would be taken, where they would be taken, what would be included in the evaluation of the cores, or the acceptance criteria that would be used to determine adequacy of effected concrete.

Request:

Provide more details about the concrete cores, including the timing, location, and tests to be completed on the cores. Also explain what criteria will be used to determine acceptable results. Provide technical justification for all of the responses.

RESPONSE RAI B.2.39-11 FENOC's current plan is as follows:

FENOC plans to investigate the effect of site groundwater on Davis-Besse reinforced concrete structures, using invasive testing and visual inspection to determine the extent, if any, of adverse effects of the site groundwater on the underground reinforced concrete structures.

FENOC plans to take core bores from two areas that are known to have had extended groundwater infiltration:

" The east wall of the Turbine Building condenser pit at approximately Elevation 573'.

• The Auxiliary Building Emergency Core Cooling System (ECCS) Pump Room No. 1 floor at approximately Elevation 545'.

FENOC plans to take the core bores from the inside of the building(s) and complete the evaluation prior to entering the period of extended operation.

FENOC plans to remove concrete as required at these locations to expose reinforcing steel for examination, and perform the following:

• Inspect reinforcing steel for corrosion,

" If corrosion exists on the rebar, collect corrosion samples for evaluation if there is sufficient material present,

• Measure reinforcing steel wastage if wastage is observed, and

" Measure corrosion buildup and evaluate cracking if a buildup of corrosion products has caused cracking of the concrete.

Attachment L-1 1-237 Page 6 of 16 FENOC plans to subject the core bore samples to petrographic examination to determine chemical effects on the concrete and conduct compressive strength tests for comparison with the original concrete design strength.

FENOC plans to document the results of the concrete testing and reinforcing steel visual examinations as Structures Monitoring Program inspection results and, if necessary, enter them into the FENOC Corrective Action Program to ensure tracking of follow on actions (if any).

FENOC plans to use American Concrete Institute (ACI) Report 349.3R-02 as a reference for acceptance criteria for specific inspection and testing results. The overall acceptance criterion will be that the structures that are in scope for license renewal, that are exposed to aggressive groundwater, will continue to perform their intended functions during the period of extended operation. FENOC plans to conduct additional inspections, if warranted, based on the inspection or testing results of the interaction between groundwater and concrete.

The technical justification for the above response is that visual inspection and the planned invasive testing and evaluation methods are recommended in ACI Report 349.3R-02.

LRA Table A-I, "Davis-Besse License Renewal Commitments," license renewal future Commitment 20, is revised based on the information provided above.

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

Question RAI B.2.39-12

Background:

By letter dated May 24, 2011, the applicant responded to a staff RAI B.2.39-7 regarding spalls observed on the shield building during a walkdown, and how the shield building would be inspected during the period of extended operation. In the response the applicant stated that the Structures Monitoring Program manages the shield building and will be enhanced to require optical aids, scaling technologies, mechanical lifts, ladders or scaffolding to allow visual inspections that meet the guidelines of ACI 349.3R (Commitment 20).

Issue:

Although the applicant committed to enhancing the Structures Monitoring Program prior to the period of extended operation, no information was provided on the spalls on the shield building.

Attachment L-1 1-237 Page 7 of 16 Request:

Provide more information about the spalls on the shield building, including how they were identified and found acceptable or repaired. If they were repaired explain how the repairs were determined to be acceptable.

RESPONSE RAI B.2.39-12 FENOC personnel reviewed condition reports in the FENOC Corrective Action Program and reviewed completed Maintenance Rule Evaluation Work Sheets (MREWS) for information on Shield Building spalls. The review determined that three spalls had been identified on the outside surface of the shield building at an elevation about 30 feet above finished grade. Based on the records reviewed, the spalls were first identified during a Maintenance Rule structural evaluation of the Shield Building in 1999. The spalls were also identified again by security and operations personnel during their normal activities in a 2001 CR and by a technical services employee in a 2007 CR as a result of a required external inspection of the Shield Building. All three spalls have been determined to be acceptable during Maintenance Rule structural evaluations, and they were documented for future evaluation. The sizes of the spalls were estimated in the CRs and varied based on the individual observations. The 2001 CR described the spalls as being approximately 5" by 11/2",while the 2007 CR noted that the areas of distressed concrete appeared to be approximately 6" by 10" and approximately 2" deep. As a result of evaluation of the spalls by the FENOC Corrective Action Program, there is a maintenance order for pending repair of Shield Building spalled concrete.

The basis for accepting the spalls was documented in the 1999 and 2005 MREWS. The 1999 MREWS noted that although some minor spalling was present no areas would create a structural concern. The 2005 MREWS described spalling as identified in the previous MREWS. Digital images of the spalls were attached to the 2005 MREWS to provide documentation for reference and future evaluations. The 2005 MREWS also noted that no areas identified would create a structural concern.

Section 15 of Specification 0-401Q; "Forming, Placing, Finishing, and Curing of Concrete," details the methods used to restore concrete. The method of repair is based on the actual size, depth and amount of rebar exposed in the area to be repaired.

Attachment L-1 1-237 Page 8 of 16 Question RAI 3.5.2.3.12-4

Background:

By letter dated June 3, 2011, the applicant responded to a staff RAI 3.5.2.3.12-2 asking how the Structures Monitoring Program would be used to manage loss of material for steel wave protection dikes in structural backfill and exposed to aggressive groundwater. The applicant stated the components are installed on both sides of a piping system that is subjected to the Buried Piping and Tank Inspections Program. Both this program and the Structures Monitoring Program have requirements for opportunistic inspections that would identify degradation of the components.

Issue:

Although the staff believes opportunistic inspections are appropriate for buried concrete when the groundwater is non-aggressive, the staff does not agree this approach is adequate for steel components in structural backfill with aggressive groundwater. In addition, the portion of Commitment 20 discussing opportunistic inspections does not discuss buried steel components.

Request:

1. Explain why opportunistic inspections are adequate to detect loss of material of steel components in structural backfill exposed to aggressive groundwater, or propose an appropriate aging management program to manage loss of material for the components. If the proposal involves focused inspections, justify the adequacy of the inspection technique and frequency.

Explain whether or not the opportunistic inspections apply to components other than concrete, and update the commitment as necessary.

RESPONSE RAI 3.5.2.3.12-4 FENOC's current plan is as follows:

FENOC plans to manage the steel components in structural backfill exposed to aggressive groundwater for loss of material by focused inspection (that will be included in the Structures Monitoring Program). FENOC plans to perform the inspection of the buried corrugated pipe prior to entering the period of extended operation.

Attachment L-1 1-237 Page 9 of 16 There are three types of steel components in the wave protection dike in structural backfill that are exposed to aggressive groundwater:

" H-piles (or soldier piles),

" corrugated galvanized steel pipe segments and

" protective enclosures made from carbon steel plates.

The corrugated galvanized steel pipe segments also have their ends closed with steel plates. FENOC has included the corrugated galvanized steel pipe segments and the protective enclosures made from carbon steel plates as components subject to inspection.

The H-piles were installed to support initial plant construction and were left in place to support construction of Units 2 and 3 (which never progressed past initial excavation activities). The excavation for Units 2 and 3 left a gap between the south wall of the Unit 1 Service Water (SW) Intake Structure and the wave protection dike to the south.

A temporary gabion wall was installed at the gap to provide wave protection. At the location of the gap, wave protection is required for postulated waves coming from the east. Two rows of H-piles were installed in the gap to the east of the gabion wall and to the east and west of buried piping that runs south from the SW Intake Structure. The H-piles were installed to stabilize the nearby soil. In 1988 the plant was modified by removing the gabion wall, filling in the excavated area and extending the southern wave protection dike to the south wall of the SW Intake Structure. The construction of the dike permanently stabilized the soil material near the rows of H-piles. Once the construction of the wave protection dike extension was completed, the H-piles no longer had a design function. Therefore, the H-piles have no license renewal intended function and they are removed from the scope of license renewal.

The buried corrugated pipe segments and enclosures exposed to aggressive groundwater protect piping that was buried during the construction of the wave protection dike extension. The piping is adjacent to or near the south wall of the SW Intake Structure. The buried corrugated pipe segments and protective enclosures are not pressure-retaining components rather, the corrugated pipe functions as a protective enclosure to the pressure retaining piping. For the focused visual inspection, FENOC plans to expose at least five linear feet of buried corrugated pipe and one protective enclosure by excavation for inspection. There are approximately 70 feet of corrugated galvanized steel pipe segments and two protective enclosures exposed to aggressive groundwater.

Five linear feet of buried corrugated protective pipe represents about 7 percent of the buried corrugated protective pipe, and one protective enclosure represents 50 percent of the protective enclosures. FENOC plans to select the excavation location(s) to ensure that all necessary plant design functions are maintained (e.g., wave control).

FENOC plans to inspect the external surfaces of the protective piping and enclosure to determine the presence and extent of corrosion, coatings deterioration, holes or

Attachment L-11-237 Page 10 of 16 perforation of pipe or steel plate, the condition of fasteners and other signs of distress (i.e. deflection or buckling), and to conducte the inspections prior to the period of extended operation.

FENOC plans to use the results of the inspections to determine the need or time frame for further inspections, with adverse conditions identified during this inspection entered into the FENOC Corrective Action Program for evaluation to determine required actions.

A visual inspection of the external surfaces of the protective piping and enclosure is adequate because evidence of the loss of material aging effect will be apparent due to visible presence of carbon steel corrosion products or visible disturbance of the coating.

Both the internal and external surfaces of these components are subject to the same aggressive groundwater environment. However, the external surfaces are also exposed to abrasive effects from the installation and presence of the backfill material. These protective structures are not pressure boundaries so there have been no aging effects caused by internal fluid flow. Therefore the condition of the internal surfaces can reasonably be expected to be better than the condition of the external surfaces. The elevation of the protective piping varies by only three feet and it protects a continuous length of SW piping, therefore the sample size can be expected to provide reasonable assurance that the condition of the inspected protective piping will be representative of the total length of the protective piping. The elevation of both protective enclosures is the same, therefore the condition of the inspected protective enclosure can be expected to provide reasonable assurance that the condition of the inspected protective enclosure will be representative of the condition of both protective enclosures.

The frequency of the inspections is expected to be adequate based on the timing of the first inspections and the evaluation of the need for further inspections being based on the results of the first inspections. Because these protective structures were installed in 1988, they will have been in service for less than 30 years when the initial inspections are conducted. The number and frequency of future inspections are expected to be adequate because FENOC plans to base the need for future inspections on the results of the conditions identified during the first inspections. Since the inspected structures will have been in service for almost 30 years when they are inspected, the first inspections can reasonably be expected to identify potential aging effects.

The opportunistic inspections also apply to structural components other than concrete.

LRA Section B.2.39, "Structures Monitoring Program," enhancement for the "Parameters Monitored or Inspected" element, and LRA Table A-I, "Davis-Besse License Renewal Commitments," license renewal future Commitment 20, are revised accordingly.

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

Attachment L-1 1-237 Page 11 of 16 Question RAI 3.3.2-4

Background:

In its response to RAI 3.3.2-2 dated June 3, 2011, the applicant stated that the copper alloy and copper alloy with greater than 15 percent zinc components (spray nozzles and valve bodies) exposed internally to outdoor air in the fire protection system (LRA Table 3.3.2-14) are sprinkler system components which are normally drained but vented to the outdoor atmosphere. The applicant further stated that these components are not susceptible to loss of material, cracking, or selective leaching because the environment to which they are exposed is not wetted and therefore the components have no aging effects requiring management.

The staff noted that while the sprinkler system internal components are not directly exposed to a wetted environment, they are open to the atmosphere, which contains moisture that can potentially become trapped in the system and cause condensation to accumulate. Normal daily temperature variations can promote the exchange of air from within the system to the atmosphere and vice versa, allowing moisture and contaminants to enter the system.

The GALL Report, Revision 2, Item VII.I.AP-159, states that copper alloy components exposed externally to outdoor air are susceptible to loss of material and recommends GALL AMP XI.M36, "External Surfaces Monitoring," to manage the aging effect. The staff noted that there are no GALL Report recommendations for copper alloy components exposed to condensation, but that a condensation environment can be bounded by a raw water environment. The GALL Report, Revision 2, Item VII.G.AP-1 59, states that copper alloy fire protection components exposed to raw water are susceptible to loss of material and recommends GALL AMP XI.M27, "Fire Water System," to manage the aging effect. GALL AMP XI.M27 includes flow testing and inspection recommendations for sprinkler system components, including sprinkler heads.

The GALL Report,Section IX.C states that copper alloy with greater than 15 percent zinc components are susceptible to selective leaching and cracking in addition to the aging effects for copper alloy components.

Issue:

It is not clear to the staff why the sprinkler system components exposed to outdoor air are not susceptible to loss of material, cracking, and selective leaching.

Request:

State why the copper alloy components exposed to outdoor air are not susceptible to loss of material and the copper alloy with greater than 15% zinc components are not also susceptible to cracking and selective leaching; or provide an appropriate program to manage the aging effects.

Attachment L-1 1-237 Page 12 of 16 RESPONSE RAI 3.3.2-4 The sprinkler system internal surfaces are not directly exposed to a wetted environment, however they are open to the atmosphere, which contains moisture that can potentially become trapped in the system and cause the internal surfaces to be subjected to prolonged wetting. Therefore, the subject sprinkler system components exposed to air-outdoor (internal) are susceptible to loss of material and cracking.

The Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Program will manage loss of material for the subject copper alloy components of the FP System that are exposed to the "Air-outdoor (Internal)" environment.

The Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Program will manage cracking and loss of material, other than due to selective leaching, for the subject copper alloy with greater than 15 percent zinc components of the Fire Protection System that are exposed to the "Air-outdoor (Internal)" environment.

The Selective Leaching Inspection will detect and characterize loss of material due to selective leaching for the subject copper alloy with greater than 15 percent zinc components of the FP System that are exposed to the "Air-outdoor (Internal)" environment.

LRA Table 3.3.2-14, "Aging Management Review Results - Fire Protection System," is revised to include the appropriate rows based on the information provided above.

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

Question RAI 3.3.2.14-1

Background:

The GALL Report states that stainless steel components exposed to steam are susceptible to loss of material and stress corrosion cracking. In LRA Table 3.3.2-14, the fire water storage tank heat exchanger contains stainless steel tubes exposed to steam that are being managed for reduction in heat transfer.

However, the applicant has not identified loss of material or stress corrosion cracking as applicable aging effects, as discussed in the GALL Report.

Issue:

Even though the heat exchanger tubes license renewal function is heat transfer, both loss of material and stress corrosion cracking could affect the intended function. It is unclear to the staff why the applicant has not included both loss of material and stress corrosion cracking as applicable aging effects.

Attachment L-1 1-237 Page 13 of 16 Request:

Justify why loss of material and stress corrosion cracking are not applicable aging effects for the fire water storage tank heat exchanger tubes exposed to steam. If it is determined that both loss of material and stress corrosion cracking are applicable, provide information on how these aging effects will be managed.

RESPONSE RAI 3.3.2.14-1 As discussed in NUREG-1 801 (the GALL Report), the only aging mechanism that is identified as causing the aging effect of reduction of heat transfer is the aging mechanism of fouling. Loss of material and cracking (due to the aging mechanism of stress corrosion cracking) are potential aging effects for the fire water storage tank heat exchanger tubes exposed to steam, and could ultimately affect the pressure boundary function of the tubes, but would not affect the license renewal function of heat transfer for this heat exchanger.

The fire water storage tank heat exchanger tubes are not credited with a license renewal pressure boundary function. Should the heat exchanger tubes leak, fire water would not leak from the tubes; rather, the higher pressure (i.e., approximately 50 psig) steam from the Auxiliary Steam System on the external surfaces of the tubes would pass through the tubes and mix with fire water (approximately 25 psig), thereby continuing to add heat to the water. Fire water storage tank level would increase due to water entering the system, but level in the tank could be controlled (i.e., feed-and-bleed) to prevent the tank from overflowing onto the ground. A breach of the heat exchanger tubes would result in continued heat transfer to fire water, and would not prevent the Fire Water System from performing its functions. Therefore, loss of material and stress corrosion cracking are not applicable license renewal aging effects for the fire water storage tank heat exchanger tubes exposed to steam.

Attachment L-1 1-237 Page 14 of 16 Supplemental Question 3.3.2.3.14-1 The NRC initiated a telephone conference call with FENOC on August 2, 2011, to discuss the FENOC response to RAI 3.3.2.3.14-1, submitted under FENOC letter dated June 3, 2011 (ML11159A132). The NRC staff stated that they do not agree with the FENOC response to this RAI and that aging mechanisms do exist and loss of preload could occur. FENOC agreed to supplement the response and add a row for loss of pre-load, and include the response with the next RAI response letter. The NRC staff agreed to this action and noted that some additional detail should be provided on how the LOP will be managed for the subject submerged bolting (e.g., opportunistic inspection or pump performance).

Original Question RAI 3.3.2.3.14-1 reads as follows:

In LRA Table 3.3.2-14, the applicant identified loss of material and cracking as aging effects for steel bolting exposed to an external environment of raw water.

As identified in EPRI NP-5769 and NUREG-1833, loss of pre-load for bolting can occur in any environment.

In LRA Table 3.3.2-14, the applicant did not identify loss of pre-load for steel bolting exposed to an external environment of raw water.

Justify why loss of pre-load is not identified as an aging effect for steel bolting in an environment of raw water.

SUPPLEMENTAL RESPONSE 3.3.2.3.14-1 FENOC replaces the previous response to RAI 3.3.2.3.14-1 submitted under FENOC letter dated June 3, 2011 (MLI 1159A1 32) in its entirety, as follows.

LRA Table 3.3.2-14, "Aging Management Review Results - Fire Protection System," is revised to add loss of pre-load as an aging effect for steel bolting exposed to an external environment of raw water. Loss of pre-load for steel bolting exposed to an external environment of raw water will be managed by the Bolting Integrity Program.

The bolting in the Fire Protection System that is exposed to an external environment of raw water is associated with the diesel fire pump column that is submerged in raw water supplied by Lake Erie. In addition to the Bolting Integrity Program there are other opportunities to identify loss of pre-load in the diesel fire pump column bolting. For example, loss of pre-load could also be identified during pump flow testing conducted in accordance with the Fire Protection Program or during inspection of the diesel fire pump column bolting that is done in accordance with the Collection, Drainage, and Treatment Component Inspection Program.

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

Attachment L-1 1-237 Page 15 of 16 Supplemental Question One-Time Inspection Examination Types - Revision The NRC initiated a telephone conference call with FENOC on August 22, 2011, to discuss the FENOC Supplemental Response - Methods for One-Time Inspections, submitted in FENOC letter L-11-238 dated August 17, 2011. NRC stated that there were two inconsistencies in the response provided. The Supplemental question and FENOC response provided in letter L-11-238 dated August 17, 2011, is replaced in its entirety by the following:

The NRC initiated a telephone conference call with FENOC on August 2, 2011, to discuss FENOC's response to RAI 3.3.2.2.4.3-1 and corresponding LRA Section B.2.30 amendment in letter dated June 3, 2011 (ML11159A132). The amendment to LRA Section B.2.30 states that the "scope" program element is to include visual and volumetric inspections of the stainless steel makeup pump casings for cracking due to cyclic loading, but it does not state what type of visual examinations will be used to detect cracking. The GALL [NUREG-1801] AMP Xl.M32, "One-Time Inspection" states in the "detection of aging effects" program element that the program manages cracking due to cyclic loading using enhanced visual (EVT-1 or equivalent), surface, or volumetric examinations.

However, some types of visual examination may not be sufficient to identify cracking, and it is unclear what visual examinations will be performed to meet this need. The NRC requests the type of visual examination that will be used to identify cracking as part of the One Time Inspection Program.

SUPPLEMENTAL RESPONSE One-Time Inspection Examination Types - Revision LRA Section B.2.30, "One-Time Inspection," subsection "Detection of Aging Effects," is revised to include a table that identifies the types of inspections that will be used for detection of aging effects.

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

Attachment L-11-237 Page 16 of 16 Supplemental Question - Makeup Pump Casing Inspections During the NRC Region III Inspection Procedure (IP) 71002, "License Renewal Inspection," held the week of August 22, 2011, NRC Inspectors identified that there are inconsistencies between LRA Table A-1, "Davis-Besse License Renewal Commitments," license renewal future Commitment 13, related to inspection for cracking due to cyclic loading of the stainless steel high-pressure makeup pumps (i.e., DB-P37-1 and 2) in the Makeup and Purification System, and LRA Section B.2.30, "One-Time Inspection," subsections "Enhancements," and "Aging Management Program Elements - Detection of Aging Effects." Commitment 13 and the affected B.2.30 subsections should consistently identify the inspection methods to be used to detect cracking. Open Item OIN-376 was created to track the issue.

SUPPLEMENTAL RESPONSE - Makeup Pump Casing Inspections LRA Table A-1, "Davis-Besse License Renewal Commitments," license renewal future Commitment 13, and LRA Section B.2.30 are revised to state that the inspection for cracking due to cyclic loading of the stainless steel high-pressure makeup pumps (DB-P37-1 and 2) in the Makeup and Purification System will consist of enhanced visual (VT-I or equivalent) and/or volumetric (RT or UT) inspections to align with the revised FENOC response to Supplemental Response - One-Time Inspections contained in this letter.

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

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

Letter L-11-237 Amendment No. 14 to the DBNPS License Renewal Application Page 1 of 36 License Renewal Application Sections Affected Table 2.4-12 Section 3.3.2.1.14 Table 3.3.2-14 Table 3.3.2 Plant-Specific Notes Table 3.5.2-12 Table 3.5.2 Plant-Specific Notes Table A-1 Section B.2.30 Section B.2.39 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 hined-ou and added text underlined.

Enclosure L-1 1-237 Page 2 of 36 Affected LRA Section LRA Page No. Affected Paracrarh and Sentence Table 2.4-12 Pages 2.4-47 Wave Protection Dike Corrugated and 2.4-48 Pipe Casings Row; and, Wave Protection Dike Piles Row In response to RAI 3.5.2.3.12-4, the Wave Protection Dike Corrugated Pipe Casings and Wave Protection Dike Piles rows of Table 2.4-12, "Yard Structures, Components Subject to Aging Management Review," are revised as follows:

Component Type Intended Function Component__Type_(as defined in Table 2.0-1)

Wave Protection Dike Corrugated Pipe Casings EN, S.S, SSR, SRE Wa-e ProtectienDike Pi*es SNS

Enclosure L-1 1-237 Page 3 of 36 Affected LRA Section LRA Page No. Affected Paragraph and Sentence 3.3.2.1.14 Page 3.3-19 Detection of Aging Effects In response to RAI 3.3.2-4, the Aging Management Program subsection of Section 3.3.2.1.14 is revised as follows:

Aging Management Programs 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

" Internal Surfaces in Miscellaneous Pipinqand Ducting Program

• Lubricating Oil Analysis Program

• One-Time Inspection

" PWR Water Chemistry Program

• Selective Leaching Inspection

Enclosure L-1 1-237 Page 4 of 36 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table 3.3.2-14 Page 3.3-313 Entire Table In response to RAI 3.3.2-4 and the Supplemental Response to RAI 3.3.2.3.14-1,, LRA Table 3.3.2-14, "Aging Management Review Results - Fire Protection System" is replaced in its entirety with the following:

Table 3.3.2-14 Aqing Manaqement Review Results - Fire ProtectionSystem Row Component Intended AiigEfctl*10.

Aging Effec Aging NUREG- al Row Topoe Intended Material Environment Requirin Management 1801 Table 1 Notes

o. -Tpe FunctionPs) r a Volume Item A hement Pro-gram 2 Item Air with I Bolting Pressure Stainless borated water 1 olting boundary Steel leakage None None VII J-16 3.3.1-99 C (External)

Air with steam 2 Bolting Pressure Stainless or water Crackin Bolting Integrit N/A N/A F boundary Steel leakage Cty (External)

Air with steam Pressure Stainless or water Loss of 3Bolting boundary Steel leakage material Bolting Integrity N/A N/A F (External)

Pressure Stainless Air-indoor Loss of 4ting boundar Steel uncontrolled reloa Bolting Integrity N/A N/A F (External)

Air with 5 Pressure borated water Loss of Boric Acid VII.1-2 3.3.1-89 A Bolting boundary Steel leakage material Corrosion I (External)

Enclosure L-1 1-237 Page 5 of 36 Table 3.3.2-14 Aqing Management Review Results - Fire ProtectionSystem Row Component Intended Matria Environment SA-ging Effect Aqi~ng NUREG-R g Management 1801, Table 1 Notes No. Type Function(s) Material Environe Reuirin Maaeet Manaement a Pro-gram 2 Item Air with steam 6 Boltinq Pressure Steel lewater Cracking Bolting Integrity VII.1-3 3.3.1-41 B boundarv te leakan-(External)

Air with steam Pressure or water Loss of 7 Bolting boundary Steel leakage material Bolting Integrity VII.I-6 3.3.1-42 B (External)

Pressure Air-indoor 8 Bolting boundary Steel uncontrolled mrel Bolting Integrity VII.1-4 3.3.1-43 B Pressure Ai-nor (External) Loss of Pressure Air-oudoor Loss of 1 Bolting boundary Steel uncontrolled (Externall rlaea Boltin Integrity VII.1-5 3.3.1-45 B 1_0 Bolingboundary Pressure Sel (External)

Air-outdoor material Loss of BligItgiy VII .314 11oltnaPressure Sel Air-outdoor Loss of Bligltg~ I I 11 Bolting boundary Steel (External) preload Bolting Integrity N/A N/A H Collection, Pressure Raw water Drainage,and G 12 Bolting boundar Steel (External) Cracking Treatment N/A N/A 0324 Components Inspection Collection, Pressure Raw water Loss of Drainage,and E 13 Bolting bounda Steel (External) material Treatment VI1.CI-19 3.3.1-76 0324 Components Inspection

Enclosure L-1 1-237 Page 6 of 36 Table 3.3.2-14 Aging Management Review Results - Fire ProtectionSystem A-gingEffect Ag"in NUREG-Row No. Component TVl~e Intended Function(s) Material Environment Refuitin euiin Management 1801. Table VolumeEviomet 1 ItemmntNoeNotes R Management Pro-gram Volume Item 2 Item 14 Bolting Pressure boundary Raw water Loss of Steel (External) preload Bolting Integrity NA NA H 15 15 Boltin Boltingboundary Pressure Steel Soil (Exteral) Loss of Buried Piping and material Tanks Inspection VII.G-25 3.3.1-19 C Air with steam 1.6 Boltin.tu Steel lewater Cracking Bolting Integrity VII.1-3 3.3.1-41 B 16oltnginte~grity leakage (External)

Air with steam 17 Bolting.WStructural Steel or water Loss of Bolting Integriy VII.1-6 3.3.1-42 B inte1grit leakage material (External) 18 Bolting Structural integrit Steel Air-indoor uncontrolled Loss of material Bolting Integrity VII.I-4 3.3.1-43 B (External) material Structural Air-indoor Loss of 19 Boltin integrit Steel uncontrolled preloa Bolting Integrity VII.1-5 3.3.1-45 B (External)

Heat Exchanger (channel)-Air-indoor Fire Water Pressure Steel Andoor Loss of External Surfaces V1I. G-5 3.3.1-59 A 20 Storage Tank boundary uncontrolled material Monitoring V Heat (External)

Exchanger (DB-E52)

Enclosure L-1 1-237 Page 7 of 36 Table 3.3.2-14 Aging Management Review Results - FireProtectionSystem Acina Effect Aging NUREG-Row Component Intended i 1801 Table 1 Type Function(s) Material Environment Reguinna Management Volume Item Notes No.

Management Program 2 Item Heat Exchanger (channel) -

Fire Water Pressure Raw water Loss of 21 Storage Tank boundary Steel (Internal) material Fire Water VII.G-24 3.3.1-68 C Heat Exchanger (DB-E52)

Heat Exchanger (shell) - Fire 22 Water Pressure Steel Steam Loss of One-Time VIII.B1-8 3.4.1-37 E

-

Storage Tank boundary (Internal) material Inspection 0315 Heat Exchanger (DB-E52)

Heat Exchanger (shell) - Fire Water Pressure Steel Steam Loss of PWR Water 23 Storage Tank boundary (Internal) material Chemistry VIII.B1-8 3.4.1-37 C Heat Exchanger (DB-E52) I

Enclosure L-1 1-237 Page 8 of 36 Table 3.3.2-14 Aging Management Review Results - Fire Protection System Agin Effct &i~ngNUREG-Row Component Intended Mea iAin Effect A 1801, Table 1 No. Type Function(s) Material Environment Reouirinn Management Volume Item Notes Management Program 2 Item Heat Exchanger (shell) - Fire Air-indoor Water Pressure Steel Andoor Loss of External Surfaces V. G-5 3.3.1-59 A 24 Storage Tank boundary uncontrolled material Monitoring Heat (External)

Exchanger (DB-E52)

Heat Exchanger Collectio (tubes) - Fire Drain ,

Water Stainless Raw water Reduction in Drainage, and 255 Storage Tank Heat transfer Steel (Internal) heat transfer Treatment VII.G-7 3.3.1-83 E Heat Comnponents Exchanger Inspection (DB-E52)

Heat Exchanger (tubes) - Fire 26 Water Stainless Steam Reduction in PWR Water N/A N/A G Storage Tank Heat transfer Steel (External) heat transfer Chemistry N/

Heat Exchanger (DB-E52)

Enclosure L-1 1-237 Page 9 of 36 Table 3.3.2-14 Aging Management Review Results - Fire ProtectionSystem Aoin Effct AiagNUREG-Row No. Component Tvne Intended Function(s) Material Maeil Environmet Environment Aging Effect Reauirnnl Ainage n Management 1801, Vlm Table Itm 1 Notes R Management Program Volume Item 2 Item Heat Exchanger (tubes) - Fire 27 Water Heat transfer Stainless Steam Reduction in One-Time NIA NIA G 27 Storage Tank Steel (External) heat transfer Inspection 0315 Heat Exchanger (DB-E52)

Heat Exchanger (tubesheet) -

Fire Water Pressure Raw water Loss of 28 Storage Tank boundary Steel (Internal) material Fire Water VII.G-24 3.3.1-68 C Heat Exchanger (DB-E52)

Heat Exchanger (tubesheet) -

Fire Water Pressure Steam Loss of One-Time VIII.B1-8 3.4.1-37 E 29 Storage Tank boundary Steel (External) material Inspection 0315 Heat Exchanger (DB-E52)

Enclosure L-1 1-237 Page 10 of 36 Row Row Component Tmoe Table 3.3.2-14 Intended Intended Material Environment IAoina Acinq Management Review Results - Fire ProtectionSystem AqnqEfc Effect Aqi~ngq on NUREG-81 al Requiring Management 1801 Table 1 Notes No. Type Function(s) Management Pro-gram Volume Item 2 Item Heat Exchanger (tubesheet) -

30 Fire Water Pressure Steam Loss of PWR Water VI.BI-8 3.4.1-37 C Storage Tank boundary Steel (External) material Chemistry I Heat Exchanger (DB-E52) 31 Hydrant Pressure Gray Raw water Loss of Fire Water VII.G-24 3.3.1-68 A 31 boundary Cast Iron (Internal) material 32 Hydrant Pressure Gray Raw water Loss of material Selective Leaching Inspection VI. G-14 3.3.1-85 A boundary Cast Iron (Internal) 33 Hydran Pressure Gray Air-outdoor Loss of External Surfaces VII.I-9 3.3.1-58 A

__ boundary Cast Iron (External) material Monitoring 34 Hydran Pressure Gray Soil (External) Loss of Buried Piping and VIG-25 3.3.1-19 A

__ Hydrant boundary Cast Iron material Tanks Inspection 35 Hydran Pressure Gray Loss of Selective Leachin VII.G-15 3.3.1-85 A boundar Cast Iron material Inspection 366 Orifice Pressure boundary Steel Raw water (Internal) Loss of material Fire Water VII. G-24 3.3.1-68 A Pressure Air-indoor Loss of External Surfaces 37 Orifice boundar Steel (External) uncontrolled material Monitoring3.3.1-58 A

Enclosure L-1 1-237 Page 11 of 36 Table 3.3.2-14 Aginq ManagementReview Results - Fire Protection System Row Component Intended AiaEfc Acing Effect Aging on NNUREG-81 al Row Tmoe Intended Material Environment Reauiring Manaement 1801 Table I otes Management Proram Volume ItemI R -gram2 Item 38 Orifice Throttling Steel Raw water Loss of Fire Water VII.G-24 3.3.1-68 A (Internal) material Pressure Copper Raw water Loss of 3.99 Piin boundary Alloy (Internal) material Fire Water VII.G-12 3.3.1-70 A Air with 40 Eking Pressure Conper borated water None None VIIJ-5 3.3.1-99 A 4_ Pin boundary Alloy leakaae

_(External)

Pressure Conner Air-indoor 41 Piking 41boundary Coy Alloy uncontrolled (External) None None VIII.1-2 3.4.1-41 A 42 Piking Pressure Gray Raw water Loss of Fire Water VIIG-24 3.3.1-68 A boundary Cast Iron (Internal) material 43 __Pressure Gray Raw water Loss of Selective Leaching V11.G-14 3.3.1-85 A 43 Pn boundary Cast Iron (Internal) material Inspection V 44 Eking Pressure Gray Air-outdoor Loss of External Surfaces VII.l-9 3.3.1-58 A 4_ i boundary Cast Iron (External) material Monitoring 45 Eking Pressure Gray Soil (External) Loss of Buried Piping and VII.G-25 3.3.1-19 A 4_ Pin boundary Cast Iron material Tanks Inspection 46 Piing Pressure Gray Soil (External) Loss of Selective Leaching VII.G-15 3.3.1-85 A boundary Cast Iron material Inspection

Enclosure L-1 1-237 Page 12 of 36 Table 3.3.2-14 Aging Management Review Results - FireProtectionSystem Agin Effct Ai~ngNUREG-Row Component Intended Material Aginm Effect

_oe_ agint 1801, Table No. Type Function(s) Maeil _

Environment Reguirnng Managqement Vlm Itm Notes S -Management Pro-gram Volume Item 2 Item Pressure Stainless Air-indoor C 47 Pipin Steel uncontrolled None None VII. J- 15 3.3.1-94 0-301 4-/

• boundary Steel (Internal)

Air with 48 Piping borated None None VIIJ-16 3.3.1-99 A Pressure boundary Stainless Steel leakaqge water

_(External)

Pressure Stainless Air-indoor 49 Pipin uncontrolled None None VII.J-15 3.3.1-94 A boundary 4._99

• Steel (External)

Air with 50 Pipin Pressure borated water Loss of Boric Acid VI0l10 3.3.1-89 A boundary Steel leakage material Corrosion V (External)

Pressure Air-indoor Loss of External Surfaces C 51 Pipin boundar Steel uncontrolled material Monitoring VII. 1-8 3.3.1-58 0301 (Internal)

Piping Pressure Steel Air-outdoor Loss of External Surfaces VII.1-9 3.3.1-58 52 boundary (Internal) material Monitoring 0301 Pressure Raw water Crakin ____ N/A N/A H 0339 5.3 Pn boundary Steel (Internal) Cracking TLAA Pressure Raw water Loss of 5.4 Pipig boundary Steel (Internal) material Fire Water VII. G-24 3.3.1-68 A Pressure Air-indoor Loss of External Surfaces f_5_ boundary Steel (External) uncontrolled material Monitoring3.3.1-58 A

Enclosure L-1 1-237 Page 13 of 36 Table 3.3.2-14 Aging Management Review Results - Fire ProtectionSystem Ac NUREG-Row Component Intended Aging Effect Aging 1801, Table N TVle Function(s) Material Environment Reguiring Management Volume Item Notes No.

Pe rManagement Prolramm 2 Item 56Pressure Steel Air-outdoor Loss of External Surfaces VI1.I-9 3.3.1-58 A boundary (External) material Monitoring V Pressure Concrete 57 Pipin boundary Steel (External) None None VII.J-21 3.3.1-96 A Pressure Raw water Loss of A 58 Piping bur Steel (External) material Fire Water VII. G-24 3.3.1 boundary (External materia 0323 Pressure Steel Soil (External) Loss of Buried Piping and VIG-25 3.3.1-19 A 5.*9 n boundary material Tanks Inspection Air-indoor Structural Comper Airido 60 PiCinoy uncontrolled None None VIII.1-2 3.4.1-41 A

• 0-.

• integqrity Alloy (Internal) 0301 Structural Copper Air-indoor 6r1 Piintgr 6.1intert Coy uncontrolled None None VIII. 1-2 3.4.1-41 A Alloy (External)

Air-indoor 6._2 Et* Structural integqritv Stelinconr uncontrolled Steel Loss of maeilM External Surfaces ntrnV11.1-8 3.3.1-58 A 0-301 (Internal) material Monitoring 63 Piping Structural inte.grit Steel Raw water (Internal) Loss of material Fire F Water V11.G-24 3.3.1-68 A Structural Air-indoor Loss of External Surfaces 6.4

__ inte_qrit Steel (External) uncontrolled material matrilIonoin Monitorin3.1-58 A

Enclosure L-1 1-237 Page 14 of 36 Table 3.3.2-14 Aging Management Review Results - Fire ProtectionSystem Comonent Intended Aging Effect Aoingo NUREG-Ro.w Row Funtended Material Environment Reuiringl Management 1801, Table I Notes o Management Program Volume Item 2 Item Pump Casing Air-indoor 65 - Diesel Fire Pressure Gray uncontrolled Loss of Exteal Surfaces VII.I-8 3.3.1-58 0301 Pump (DB- boundary Cast Iron ucntroll material Monitoring 030 P5-2) (Internal)

Pump Casing 66 - Diesel Fire Pressure Gray Moist air Loss of Selective Leaching N/A N/A H Pump (DB- boundary Cast Iron (Internal) material Inspection 0321 P5-2)

Pump Casing 67 - Diesel Fire Pressure Gray Moist air Loss of One-Time VII.G-23 3.3.1-71 E Pump (DB- boundary Cast Iron (Internal) material Inspection 0313

___P5-2)

Pump Casing 68 - Diesel Fire Pressure Gray Raw water Loss of Fire Water VII.G-24 3.3.1-68 A Pump (DB- boundary Cast Iron (Internal) material P5-2)

Pump Casing 69 - Diesel Fire Pressure Gray Raw water Loss of Selective Leaching VII. G- 14 3.3.1-85 A Pump (DB- boundary Cast Iron (Internal) material Inspection P5-2) ______

Pump Casing Air-indoor

- Diesel Fire Pressure Gray uncontrolled Loss of Exteal Surfaces VII.I-8 3.3.1-58 A 70 Pump P5-2) (DB- boundary Cast Iron unotroll (External) material Monitoring Pump Casing Pressure Gray Moist air Loss of Selective Leaching N/A N/A G

- Diesel Fire Pump (DB- boundary Cast Iron (External) material Inspection 0321 SP5-2)

Enclosure L-1 1-237 Page 15 of 36 Row Row Component Type Table 3.3.2-1.4 Intended Intended Material Environment I

Aqing Management Review Results - Fire ProtectionSystem A-ging Effect AgnEfet____.Tbl Reguiring Agi~ng Management NUREG-1801 Table 1 Notes Te Function(sI Management Volume Item

_____ _ Pro gram 2 Item Pump Casing E 72 - Diesel Fire Pressure Gray Moist air Loss of One-Time V11.G-23 3.3.1-71 0313, Pump (DB- boundary CastIron (External) material Inspection 0322 P5-2)

Pump Casing

- Diesel Fire Pressure Gray Raw water Loss of Fire Water V11. G-24 3.3.1-68 A Pump (DB- boundary CastIron (External) material P5-21 Pump Casing

- Diesel Fire Pressure Gray Raw water Loss of Selective Leaching VII.G-14 3.3.1-85 A Pump (DB- boundary CastIron (External) material Inspection P5-2)

Pump Casing

- Electric Fire Pressure Gray Raw water Loss of Pump (DB- boundary Cast Iron (Internal) material Fire Water VII. G-24 3.3.1-68 A P5-1)

Pump Casing 76 - Electric Fire Pressure Gray Raw water Loss of Selective Leaching VII.G-14 3.3.1-85 A Pump (DB- boundary Cast Iron (Internal) material Inspection P5-1)

Puma Casing Pump asingAir-indoor

- Electric Fire Pressure Gray Andoor Loss of External Surfaces VII.1-8 3.3.1-58 A Pump (DB- boundary Cast Iron (External) material Monitorin P5-11) _External_

Pump Casing

- Fire Water Storage Tank Pressure Gray Raw water Loss of Fire Water V11.G-24 3.3.1-68 A 78 Recirculation boundary Cast Iron (Internal) material Pump (DB-P1141

Enclosure L-1 1-237 Page 16 of 36 Table 3.3.2-14 Aging Management Review Results - FireProtection System Acing Effect Aoing NUREG-Row Component Intended AnEfet__80_,Tbl_

Row Copoet Fnctiondd Material Environment Requirina Management 1801V Table Notes No.Management Programo Volume Item PumpCasng ray Rawressre ate L~sof2 Item Pump Casing

- Fire Water VII.G-14 3.3.1-85 A L9 80 Storage Tank Recirculation Pressure boundary Gray Cast Iron Raw water (Internal) Loss of material InspectionLeaceisg Selective Pump (DB-Pi14)

Pump Casing

- Fire Water Storage Tano Pressure Gray uncontrolled Non None VIII.1-8 3.3.1-58 A Recirculation Pump (DB- boundary Cast Iron (ternal)

(xenl material Monitoring Pressure Copper Air-indoor A 81 Spray Nozzle boundary Alloy> uncontrolled None None V111.1-2 3.4.1-41 0301 15% Zn PDnternalI of Inspection 83 Spray Nozzle Pressure CoAner Air-outdoor Loss of Internal Surfaces in N/A N/A G boundary Alloy> (Internal) material Miscellaneous N 15% Zn S Piping and Ducting

ýCOD~erInspection of Pressure CoAoer Air-outdoor Loss of Internal Surfaces in N/A NA G

_3 Speboundary Alloy> (Internal) 15% ZnPiping material Miscellaneous and Ducting 84 pryPNzz e sboundre AIogy_ Air-outdoor Loss of Selective Leaching 84 Sra Nozzle boundary ZNA material Inspection NIA G Pressure Copper Raw water Loss of 8_5 Spray Nozzle boundar Alloy>

15% Zn (Internal) material Fire Water VIIG-12 3.3.1-70 A

Enclosure L-1 1-237 Page 17 of 36 Table 3.3.2-14 Aqing Management Review Results - FireProtectionSystem Component Intended Aging Effect Aqing NUREG-Row Row Co oen Fnctiond Material Environment Reauiring Management 1801, Table 1 Notes

o. Type Functions) Mana iemenProgram2 Volume Item Item 86 Noe Pressure boundar Copper Alloy> Raw water (Internal) Loss material of InspectionLeaching Selective VII.G-13 3.3.1-84 3 A 15% Zn Cotmer Air with Pressure Aop> borated water Loss of Boric Acid 87 Spra Nozzle boundary Alloy> leaka-ae material Corrosion V10-12 3.3.1-88 A 15% Zn

_ _ (External)

Pressure Comner Air-indoor 88 Sprav Nozzle boundar Alloy> uncontrolled None None VIII.I-2 3.4.1-41 A 15% Zn (External)

Pressure Copper Air-outdoor External Surfaces 89 Spra Nozzle boundary Alloy> (External) Crackin Monitoring NA NIA G 15% Zn 9_0 Spray Nozzle Pressure boundar Copper Alloy> Air-outdoor (External) Loss material of External MonitoringSurfaces NA NIA G 15% Zn 9_1 Spray Nozzle Pressure boundary Conner Alloy> Air-outdoor (External) Loss material of InspectionLeaching Selective NIA NIA G 15% Zn Copper Air-indoor A 92 Spray Nozzle Spray Alloy> uncontrolled None None VIII.1-2 3.4.1-41 0301 15% Zn (Internal)

Inspection of in N/A N/A G Co9eer Air-outdoor Cracking InternalSurfaces 9.3 Spray Nozzle Snray Alloy> (ItrnlraknqMselaeos NA_/

15% Zn (Internal) Miscellaneousci

______

_____~~~~~~~~~~~ ____ ______ ______ Pining and DuctLing I______ _____ ____ _ _ _ _

Enclosure L-1 1-237 Page 18 of 36 Table 3.3.2-14 Aging Management Review Results - Fire ProtectionSystem A-gig Efect gingNUREG-Row No.

Component Intended Type SManagqement Function(s)

Material Environment AiguEffect Reauinn

[

j Agint Proaqram ManaMnement 1801, Vo2lItme Volume Table I Im Item Notes 2 Item Inspection of Coyper Air-outdoor Loss of Internal Surfaces in Zn (Internal) material Miscellaneous N/A N/A G 9._4_Spray Nozzle _Sray15%

Piping and Ducting Copper Air-outdoor Loss of Selective Leaching N/A N/A G 9_5 Spray Nozzle Spra Alloy > (Internal) material Inspection 15% Zn Conper Raw water Loss of 96 SprayNozzle Spra AlloyZ> (Internal) material Fire Water VII. G-12 3.3.1-70 A 15% Zn Copper Raw water Loss of Selective Leaching 97 Spray Nozzle Sprav Alloy> (Internal) material Inspection VII. G- 13 3.3.1-84 A 15% Zn Comner Air with 98 Spray Nozzle Sprav Alloy>

15% Zn borated leakage water Loss of material Boric Acid Corrosion VII.1-12 3.3.1-88 A (External)

Copper Air-indoor 99 Spray Nozzle Spray Alloy> uncontrolled None None VIII.I-2 3.4.1-41 A 15% Zn (External)

Comper Air-outdoor External Surfaces 100 Spray Nozzle Spray Alloy> (External) Cracking Monitoring NA NIA G 15% Zn Conner Air-outdoor Loss of External Surfaces 101 Spray Nozzle Sra% AlloyZ> (External) material Monitoring NA NIA G 15% Zn Copper Air-outdoor Loss of Selective Leaching N/A N/A G 10_2 Spray Nozzle Spray Alloy> (External) material Inspection 15% Zn

Enclosure L-11-237 Page 19 of 36 Table 3.3.2-14 Agincj Management Review Results - Fire ProtectionSystem Row Component Intended Material Environment

{A-gingEffect Refuftr Aging Manae NUREG-1801e Volume Table 1 Item Notes No. Type Function(s) Mona M ement Management Program 1 2 Item Structural Copper Air-indoor VIII.1-2 3.4.1-41 A 103 Spra Nozzle Alloy > uncontrolled None None ineriy 15% Zn (Internal) 0301 104 Spray Structural Cooper Alloy> Raw water (Internal) Loss of material Fire Water V11.G-12 3.3.1-70 A 104 Spray Nozzle i y 15% Zn 1105 S Sray

_________ o Nozzle Structural in y Copper Alloy>

15% Zn Raw water (Internal) Loss of material InspectionLeaching Selective " VIG-13 3.3.1-84 A Structural Comner Air-indoor 106 Srv Nozzle Alloy> uncontrolled None None VIII.I-2 3.4.1-41 A intSra z egt 15% Zn (External) 107 Strainer Pressure Gray Raw water Loss of Fire Water V11.G-24 3.3.1-68 A (body) boundary Cast Iron (Internal) material 108 Strainer Pressure Gray Raw water Loss of Selective Leaching VII.G-14 3.3.1-85 A (body) boundary Cast Iron (Internal) material Inspection Air with 109 Strainer Pressure Gray borated water Loss of Boric Acid VlI.I- 10 3.3.1-89 A (body) boundary Cast Iron leakage material Corrosion

_(External)

Strainer Pressure Gray Air-indoor 110 (bd)bure Cas uncontrolled Loss of External Surfaces3.3.1-58 A boundar Cast Iron (External) material Monitoring Strainer Pressure Raw water Loss of (body)Steel Fire Water VII. G-24 3.3.1-68 A

Enclosure L-1 1-237 Page 20 of 36 Table 3.3.2-14 Aqing Management Review Results - Fire Protection System I Aging

_

Effect Aing NUREG-Row Component Intended . Aatiniq Effect 1801, Table 1 Io. Type Function(s) Material Environment Reguinn Management Management

_roraVluete Volume Item Notes

-rgram 2 Item Air with 112 Strainer (body) Pressure boundary borated leakage water Loss of material Boric Acid V/0I10 3.3.1-89 A Corrosion (External)

Strainer Pressure Air-indoor Loss of External Surfaces 113 _ _ Steel uncontrolled material Monitorin-8 3.3.1-58 A (body) boundary (External) maeilMntrn Strainer Copner Raw water Loss of 114 (screen) Filtration Alloy> (External) material Fire Water VII.G-12 3.3.1-70 A 15% Zn Strainer Filtration CoAoe> Raw water Loss of Selective Leaching 115 (screeno Alloy (External) material Inspection V11. G- 13 3.3.1-84 A (screen)15% Zn Strainer . .Stainless Raw water Loss of 116 Screen)

(sre)Steel Filtration Steel (Exter (External) materialFire material Water VII. G- 19 3.3.1-69 A Tank - Fire 117 Water Pressure Steel Air-outdoor Loss of External Surfaces VII.1-9 3.3.1-58 C Storage Tank boundary (Internal) material Monitoring 0301 (DB-T81) _____

Tank - Fire 118 Water Pressure Steel Moist air Loss of One-Time V11.G-23 3.3.1-71 E Storage Tan boundar (Internal) material Inspection 0313 (DB-T81)

Tank - Fire Water Pressure Raw water Loss of 119 Storage Tank boundary Steel (Internal) material Fire Water VII.G-24 3.3.1-68 C (DB-T81)

Enclosure L-11-237 Page 21 of 36 Table 3.3.2-14 Aging Management Review Results - Fire ProtectionSystem Aging Effect Agi~ng NUREG-Row Component Intended Material Environment Requiri Management 1801. Table 1 Notes No. Tye Function(s) Proram Volume Item 2 Item Tank - Fire 120 Water Pressure Steel Air-outdoor Loss of Above-ground Steel VII.HI-11 3.3.1-40 B Storage Tank boundary (External) material Tanks Inspection 0333 (DB-T81)

Tank - Fire 121 Water Pressure Air-outdoor Loss of External Surfaces VII.1-9 3.3.1-58 A Storage Tank boundary Steel (External) material Monitoring V (DB-T81)

Tank - Pressure Comner Air-indoor 122 Retard boundary Alloy> uncontrolled None None VIII.I-2 3.4.1-41 0-301 Chamber 15% Zn (Internal)

Tank - Copper Air with Pressure borated water Loss of Boric Acid 123 Retard boundary Alloy> leakage material Corrosion VII.I-12 3.3.1-88 C Chamber 15% Zn (External)

Tank - Pressure Comper Air-indoor 124 Retard boundary Alloy > uncontrolled None None VIII.I-2 3.4.1-41 C Chamber 15% Zn (External) 125 Tank -

Retard Pressure Prsue Gra ry Air-indoor uncontrolled Loss of LsofEtraSuacs External Surfaces VII.l-8 3.3.1-58 C C

Char boundary CastIron (Introlle material Monitoring 0301 Chamber (Internal)

Tank - Air with 126 Retard Pressure Gray borated water Loss of Boric Acid VII.I-10 3.3.1-89 A Chamber boundary Cast Iron leakage material Corrosion (External)

Tank - Pressure Gray Air-indoor Loss of External Surfaces VII.I-8 3.3.1-58 A Chamber boundary Cast Iron (External) material Monitoring

Enclosure L-11-237 Page 22 of 36 Table 3.3.2-14 Aging Management Review Results - Fire ProtectionSystem Row Component Intended Material Environment SAging Effect Requiring A-gin Management NUREG-1801, Table 1 Notes No. Type SManaaqement Function(s) ManalevenmnPeurnVolumePro gram 2oum Itemj Item iram 2 Item Pressure Copper Raw water Loss of Fire Water VIIG-12 3.3.1-70 A 128 Tubing boundary Alloy (Internal) material Air with Pressure Copper borated water 129 Tubing boundary Alloy leakage None None VIIJ-5 3.3.1-99 A (External)

Pressure C~o~er Air-indoor 130 TubinCoy 30 nboundary Alloy uncontrolled (External) None None VIII. 1-2 3.4.1-41 A 13__1 Tubin Pressure boundar Steel Air-indoor uncontrolled Loss of material External Surfaces Monitorin-8 3.3.1-58 C 0301 (Internal)

Pressure Raw water Loss of 132 Tubing boundary Steel (Internal) material Fire Water VII. G-24 3.3.1-68 A Air with 133 Tubin Pressure boundary Steel borated leakage water Loss of material Boric Acid Corrosion VI0-10 3.3.1-89 A (External) 134 Tubin Pressure boundar Steel Air-indoor uncontrolled Loss of material External Surfaces Monitorin3.3.1-58 A (External) mtrl Mnoi 135 Tubin Structural interit Steel Air-indoor uncontrolled Loss of material External Surfaces Monitorin-8 3.3.1-58 C 0301 S(Internal) mtrl Mnoi 136 Tubing Structural Steel Raw water Loss of Fire Water V11.G-24 3.3.1-68 A inte3grit (Internal) material

Enclosure L-11-237 Page 23 of 36 Table 3.3.2-14 Acing Management Review Results - Fire ProtectionSystem Agin Effct Ai~ggNUREG-Row Component Intended _ Agin Effect A 1801, Table _

No. Type Function(s) Material Environment Reauirin Management Volume Item Notes I Management Pro-gram 2 Item Structural Air-indoor Loss of External Surfaces 137 TubinWg integrity Steel uncontrolled material Monitoring VII.l-8 3.3.1-58 A (External) 138 Valve Body Pressure Presundary Copper Aoy Air-indoor uncontrolled None None VIII.1-2 3.4.1-41 0301 1d boundary Alloy (Internal)

Inspection of 139 Valve Body Pressure Copper Air-outdoor Loss of Internal Surfaces in N/A N/A G boundary Alloy (Internal) material Miscellaneous Piping and Ductinq Pressure Comper Raw water Loss of Fire Water VII.G-12 3.3.1-70 A 140 Valve Body boundary Alloy (Internal) material Air with 141 Valve Bodv Pressure Copper borated leakagge water None None VIIJ-5 3.3.1-99 A boundary Alloy (External)

Pressure Copper Air-indoor 142 Valve Body uncontrolled (External) None None VIII.1-2 3.4.1-41 A boundary 14y Alloy 143 Valve Bodv Pressure Copper Air-outdoor Loss of External Surfaces N/A N N/A G boundary Alloy (External) material Monitoring Pressure Copper Air-indoor 144 Valve Body boundary Alloy> uncontrolled None None VIII.1-2 3.4.1-41 A 15% Zn (Internal)

Enclosure L-1 1-237 Page 24 of 36 Table 3.3.2-14 Aging Management Review Results - Fire Protection System A-ging Effect Agin NUREG-A 1801, Table Row Component TypeMaterial Intended Environment Aaina Effect Reauirin Management Volume Item 1 Notes Management Program 2 Item Inspection of Pressure Coy er Air-outdoor Internal Surfaces in 145 Valve Body boundary Alloy> (Internal) Cracking Miscellaneous N/A N/A G 15% Zn S Pining and Ducting Inspection of Pressure boundary CoAoer Alloy> Air-outdoor (Internal) Loss of material Internal Surfaces in Miscellaneous N/A N N/A G r15% Zn Piping and Ducting Pressure Copper Air-outdoor Loss of Selective Leaching 147 Valve Body boundary Alloy > (Internal) material Inspection N/A N/A G 15% Zn 148 Valve Body Pressure boundary Copper Alloy> Raw water (Internal) Loss of material Fire Water VIIG-12 3.3.1-70 A 15% Zn Pressure Copner Raw water Loss of Selective Leaching 149 Valve Body boundary Alloy> (Internal) material Insection VII.G-13 3.3.1-84 A 15% Zn (tnmtiIpi Pressure Copper Air-indoor 150 Valve Body boundary Alloy> uncontrolled None None VIII.1-2 3.4.1-41 A 15% Zn (External)

Pressure Copper Air-outdoor External Surfaces 151 Valve Body bd Alloy> (External) Cracking Monitoring N/A N/A G

________ 15% Zn 152 Valve Body Pressure boundary Copper Alloy> Air-outdoor (External) Loss of material External MonitoringSurfaces NIA NIA G 15% Zn Pressure Copper Air-outdoor Loss of Selective Leaching 153 15Valve Body boundary Alloy >

15% Zn (External) material Inspection " NA NIA G

Enclosure L-1 1-237 Page 25 of 36 Table 3.3.2-14 Aging Management Review Results - Fire ProtectionSystem Row Component Intended Ai__Efc__i~

Aging Effect Aging NUREG-

10. Tal Row Tmoe Intended Material Environment Reguiring Managiement 1801 Table 1 Notes

o. Tye Function(s) Proram Volume Item 2 Item 154eVaverBoyGra_ Pressure Gray uncontrolled Air-indoor Loss of External Surfaces VII.I-8 3.3.1-58 030 C

154 Valve Body boundary Cast Iron uintrolle material Monitoring 0301

________ (nternal) 155 Valve Bodv Pressure Gray Air-outdoor Loss of External Surfaces VC0-9 3.3.1-58 boundary Cast Iron (Internal) material Monitoring 0301 Pressure Gray Raw water Loss of Fire Water V11.G-24 3.3.1-68 A 156 Valve Body boundary Cast Iron (Internal) material 157 Valve Bodv Pressure Gray Raw water Loss of Selective Leaching V11.G-14 3.3.1-85 A boundary Cast Iron (Internal) material Inspection Air with Pressure Gray borated water Loss of Boric Acid VI0-10 3.3.1-89 A 158 Valve Body boundary Cast Iron leaka-e material Corrosion (External)

__uncontrolled Pressure Gray Air-indoor material8Mnitoring8 Loss of External Surfaces 159 Valve Body boundary Cast Iron (External)ial MonitorinV1- 3.158 160 Valve Body Pressure boundary Gray Cast Iron Air-outdoor (External) Loss of material External Surfaces Monitoring VII.I-9 3.3.1-58 A 161 Valve Body Pressure boundary Gray Cast Iron S (External)

Soil Loss of material Buried Piping and Tanks Inspection VII. G-25 3.3.1-19 A 162 Valve Body Pressure Gray Soil (External) Loss of Selective Leaching VII.G-15 3.3.1-85 A boundary Cast Iron material Inspection

Enclosure L-1 1-237 Page 26 of 36 Table 3.3.2-14 Aging Management Review Results - Fire ProtectionSystem Row Component Intended Material EEte IAging Effect c M Aqi~nA NUREG-1801, Table 1 No. Type Function(s) nvironmen Reauinn Management Volume Item Notes No.Management Pro ram 2 Item Pressure Air-indoor LOSS Of External Surfaces C 163 Valve Body boundary Steel uncontrolled material Monitorin VII.I-8 3.3.1-58 0301 6_aeBd budr (Internal)

Pressure Raw water H 164 Valve Body boundary Steel (Internal) Cracking TLAA N/A N/A 0339 Pressure Raw water Loss of 165 Valve Body boundary Steel (Internal) material Fire Water VII.G-24 3.3.1-68 A Air with 166 Valve Body Pressure borated water Loss of Boric Acid VI.-10 3.3.1-89 A boundary Steel leakage material Corrosion V (External) _

Pressure Air-indoor Loss of External Surfaces 167 Valve Body boundary Steel uncontrolled material Monitorin VII.1-8 3.3.1-58 A (External) materialIonitorin Structural CODDer Air-indoor A 168 Valve Body uncontrolled None None VIII.1-2 3.4.1-41 -

inteqrity Alloy (Internal) 0301 Structural Copper Raw water Loss of 169 Valve Body inte.grity Alloy (Internal) material Fire Water VII.G-12 3.3.1-70 A Structural Conner Air-indoor 170 Valve Body 70 Va y integrit Alloy uncontrolled None None VIII.1-2 3.4.1-41 A (External)

__uncontrolled Structural Gray Air-indoor Loss of External Surfaces VI.- .. -5 A A

171 Valve Body integrity Cast Iron (Introlle material Monitoring 0301 1 1 Vav Bod ___ _ (Internal) I______ ________ _________ ____

Enclosure L-11-237 Page 27 of 36 Table 3.3.2-14 Aging Management Review Results - Fire ProtectionSystem A-gin EffctAi~ngNUREG-Row Component Intended Material EnvironAging Effect agent 1801, Table Itm 1 No. Tvne Function(s) MaeilEvrnment j Reguirnna Management Management Program Vlm Volume 2 Item Item Notes Structural Gray Raw water Loss of material Fire Water VIIG-24 3.3.1-68 A 172 Valve Body integrit Cast Iron (Internal) 173 Valve Body Structural Gray Raw water Loss of Selective Leaching VIG-14 3.3.1-85 A 7 inteVBrit Cast Iron (Internal) material Inspection V 174rValvealodGray.

Structural Gray uncontrolled Air-indoor Loss of External Surfaces VII.I-8 3.3.1-58 A 174 Valve Body integrit Cast Iron (Extrolle material Monitoring V

_______ (xternal)

Affected LRA Section LRA Page No. Affected Paragraph and Sentence Plant Specific Notes Page 3.3-549 Plans Specific Note 0321 In response to RAI B.2.22-6, Plant Specific Note 0321 is revised as follows:

Plant-Specific Notes:

0321 The Selective Leaching Inspection will detect and characterizeloss of materialdue to selective leaching at the air-waterinterface on the diesel fire prctectien pump.

Enclosure L-1 1-237 Page 28 of 36 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table 3.5.2-12 Page 3.5-114 Rows 20 and 21 In response to RAI 3.5.2.3.12-4, rows 20 and 21 of LRA Table 35.2-12, "Aging Management Review Results -

Yard Structures" are revised as follows:

Table 3.5.2-12 Aging Management Review Results - Yard Structures Ac NUREG-Row Component Intended MAing Effect Agi*ng 1801N Table 1 No. Type Function(s) Mari Reuirin Management Volume Item Notes Management Program 2 Item Wave Protection EN, SNS, Galvinized Structural Loss of Structures N/A N/A H 20 Dike SSR, SRE Steel backfill material Monitoring 0532 Corrugated Pipe Casings 21 P-t9G, SNS Gar-/* seiIAn AA N/A DNteP8 St-ee/ matera/ ____.._i_ _ 053 Not used.

Enclosure L-1 1-237 Page 29 of 36 Affected LRA Section LRA Page No. Affected ParaaraDh and Sentence Plant Specific Notes Page 3.5-170 Plans Specific Note 0532 In response to RAI 3.5.2.3.12-4, Plant Specific Note 0532 is revised as follows:

Plant-Specific Notes:

0532 The Wave Protection Dike corrugatedpipe casings and Wave Protection Dike pile-s buried in the wave protection dikes can be exposed to groundwatersince some of the corrugatedpipe casings are located below site groundwaterelevation. Since these buried steel components can be in direct contact with groundwater,a raw water environment is conservatively used for aging evaluation.

P

Enclosure L-1 1-237 Page 30 of 36 Affected LRA Section LRA Page No. Affected ParaaraDh and Sentence Table A-1 Page A-63 Commitment No. 13 Based on the response to Supplemental Question - Makeup Pump Casing Inspections, license renewal future Commitment 13 in LRA Table A-1, "Davis-Besse License Renewal Commitments," is revised as follows:

Table A-1 Davis-Besse License Renewal Commitments IRelated LRA Item Iter Number Commitment Implementation SchedulejCmet Source Section No./

Comments 13 Implement the One-Time Inspection as described in LRA Section Prior to LRA A.1.30 B.2.30. Enhance the One-Time Inspection to: April 22, 2017 B.2.30 FENOC 0 Include enhanced visual (VT-I or equivalent) and/or Letter Response to volumetric (RT or UT) vi4sua inspections to detect and L-11-166 NRC RAI characterizecrackingdue to cyclic loading of the stainless and 3.3.2.2.4.3-1 steel makeup pump casings (DB-P37-1 and 2) of the Makeup L-11-237 from and PurificationSystem. The one-time inspections will provide NRC Letter verification of the absence of cracking due to cyclic loading. dated May 2, 2011 and Supplemental Question -

Makeup Pump Casing Inspections

Enclosure L-1 1-237 Page 31 of 36 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table A-1 Page A-65 Commitment No. 20, sixth and seventh bullets Based on the responses to RAI B.2.39-11 and RAI 3.5.2.3.12-4, the sixth and seventh bulleted items in license renewal future Commitment 20 in LRA Table A-I, "Davis-Besse License Renewal Commitments," are revised as follows:

Table A-1 Davis-Besse License Renewal Commitments Item Implementation Related LRA Iter Number Commitment Sheme Schedule Source Section CmetNo./

Comments 20 Obtain and evaluate for degradationa concrete core bore Prior to LRA A. 1.39 from two representativeinaccessible concrete components April 22, 2017 and B.2.39 of an in-scope structure subjected to aggressive FENOC groundwaterpriorto entering the period of extended Letter Responses to operation. Based on the results of the initial core bore L-11-153 NRC RAls sample, evaluate the need for collection and evaluation of and B.2.39-3, representative concrete core bore samples at additional L-11-237 B.2.39-4, locations that may be identified during the period of B.2.39-5, extended operation as having aggressive groundwater B.2.39-6 infiltration. Select additional core bore sample locations and based on the duration of observed aggressive groundwater B.2.39-7 infiltration. Perform an inspection for loss of material for from carbon steel structuralcomponents subiect to aggressive NRC Letter groundwater.Require the use of the FENOC Corrective dated Action Programfor identified concrete or Feb steel April 5, 2011 degradation. and B.2.39-11 and Specify that, upon notification that a below-gradestructural 3.5.2.3.12-4 wall or other in-scope concrete or metal structural

Enclosure L-1 1-237 Page 32 of 36 Table A-1 Davis-Besse License Renewal Commitments Commitment Implementation Source Related LRA Item Number Commitment Schedule conts Comments component will become accessible through excavation, a from follow-up action is initiatedto the responsible engineer to NRC Letter inspect the exposed surfaces for age-relateddegradation. dated Such inspections will include concrete examination using July 21, 2011 acceptance criteria from NUREG-1801 XI.S6 Program element 6. Degradation found that exceeds the acceptance criteria will be trended and processed through the FENOC Corrective Action Program.

Enclosure L-11-237 Page 33 of 36 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table A-1 Page A-69 Commitment No. 39 Based on the response to RAI B.2.22-6, license renewal future Commitment 39 in LRA Table A-i, "Davis-Besse License Renewal Commitments," is revised as follows:

Table A-1 Davis-Besse License Renewal Commitments e IRelated LRA Item Number jSchedule Commitment Implementation Source Section No./

Cmet Comments 39 Address the potential for borated water degradation of the steel P*49F t FENOC Response to containment vessel through the following actions: Apr-#,2,2** 47 Letter NRC RAI B.2.22-2 from L-1 1-153 Letter Access the inside surface of the embedded steel Phase I prior to December 31, and dated containment.A core bore will be completed by the end of 2014 FENOC April 5, 2011, 2014 (Phase 1). If necessary, a second core bore will be and Letter and completed by the end of 2020 (Phase 2). Ifthere is evidence L-11-237 RAI B.22-6 of the presence of borated water in contact with the steel Phase 2 prior to fRom containment vessel, conduct non-destructive testing (NDT)

December 31, NRC Letter to determine what effect, if any, the borated water has had 2020 dated on the steel containment vessel. Based on the results of NDT, perform a study to determine the effect through the Julyd27 2011 loss of period of extended operation of any identified thickness in the steel containment due to exposure to borated water.

Enclosure L-11-237 Page 34 of 36 Affected LRA Section LRA Page No. Affected Paragraph and Sentence B.2.30 Page B-121 "Scope" subsection of the "Enhancements" section, last paragraph Based on the response to Supplemental Question - Makeup Pump Casing Inspections, the last paragraph of the "Scope" subsection of the "Enhancements" section of Section B.2.30 is revised as follows:

The One-Time Inspection will also include enhanced visual (VT-1 or equivalent) and/or volumetric (RT or UT) viaua! and v-!'mtric inspections to detect and characterizecracking due to cyclic loading of the stainless steel makeup pump casings (DB-P37-1 and 2) of the Makeup and Purification System. The one-time inspections will provide verification of the absence of cracking due to cyclic loading.

Enclosure L-1 1-237 Page 35 of 36 Affected LRA Section LRA Page No. Affected Paragraph and Sentence B.2.30 Page B-123 Aging Management Program Element: "Detection of Aging Effects" - new third (last) paragraph (Table)

The NRC initiated a telephone conference call with FENOC on August 22, 2011, to discuss the FENOC Supplemental Response - Methods for One-Time Inspections, submitted in FENOC letter L-1 1-238 dated August 17, 2011. NRC stated that there were two inconsistencies in the response provided. The FENOC response provided in letter L-1 1-238 dated August 17, 2011, is replaced in its entirety. LRA Section B.2.30, "One-Time Inspection," Aging Management Program Element "Detection of Aging Effects," is revised to include a new third (last) paragraph that consists of a table identifying the types of inspections that are planned to be performed, as follows:

B.2.30 ONE-TIME INSPECTION Aging Management Program Elements 0 Detection of Aging Effects ParametersMonitored or Inspected And Aging Effect for Specific Corponent Agoing Aging Parameter Inspection Effect Mechanism Monitored Method "I Loss of Material Crevice Surface Condition, Visual (VT-1 or equivalent) and/or Corrosion Wall Thickness Volumetric (RT or UT)

Loss of Material Galvanic Surface Condition, Visual (VT-3 or equivalent) and/or Corrosion Wall Thickness Volumetric (RT or UT)

Loss of Material General Surface Condition, Visual (VT-3 or equivalent) and/or Corrosion Wall Thickness Volumetric (RT or UT)

Loss of Material MIC Surface Condition, Visual (VT-3 or equivalent) and/or Wall Thickness Volumetric (RT or UT)

Loss of Material Pitting Corrosion Surface Condition, Visual (VT-1 or equivalent) and/or Wall Thickness Volumetric (RT or UT)

Loss of Material Erosion Surface Condition, Visual (VT-3 or equivalent)and/or Wall Thickness Volumetric (RT or UT)

Reduction of Foulinq Tube Foulinq Visual (VT-3 or equivalent)or Heat Transfer Enhanced VT-1 for CASS Crackinq SCC or Cyclic Surface Condition, Enhanced Visual (EVT- 1 or equivalent) or Loading Cracks Surface Examination (magnetic particle, liquid penetrant,or Volumetric (RT or UT)

(1)

Examinations of code comoonents will follow orocedures consistent with the reauirements of the ASME Code and 10 CFR 50 Appendix B. Non-code examinations will be performed in accordance with site procedures.

Enclosure L-1 1-237 Page 36 of 36 Affected LRA Section LRA Page No. Affected Paragraph and Sentence B.2.39 Page B-155 Parameters Monitored or Inspected subsection of the Enhancements section In response to RAI 3.5.2.3.12-4, the Parameters Monitored or Inspected subsection of the Enhancements section of Section B.2.39, "Structures Monitoring Program" is revised as follows:

• Parameters Monitored or Inspected Davis-Besse's area groundwater is aggressive and operating experience has shown that structural elements have experienced degradation. Although there is no evidence that the aggressive groundwater has contributed to structural degradation, a special provision in the program will be implemented to monitor below-grade inaccessible concrete components before and during the period of extended operation. FENOC will perform a below-grade examination of concrete below elevation 570 feet (groundwater elevation) of an in-scope structure prior to the period of extended operation. That inspection will include concrete examination using acceptance criteria from NUREG-1801 XI.S6 Program element 6. The below-grade examination of concrete below elevation 570 feet may be conducted during maintenance activities. FENOC will perform an inspection for loss of materialfor carbon steel structural components subject to aggressive groundwater.Degradation found that exceeds the acceptance criteria will be trended and processed through the Corrective Action Program.

The program procedure will be enhanced by specifying that, upon notification that a below-grade structuralwall or other in-scope concrete or metal structuralcomponent will become accessible through excavation, a follow-up action is initiated to the responsible engineer to inspect the exposed surfaces for age-relateddegradation.Such inspections will include concrete examination using acceptance criteria from NUREG-1801 XI.S6 Program element 6. Degradation found that exceeds the acceptance criteria will be trended and processed through the Corrective Action Program.