L-14-061, Reply to Request for Additional Information for the Review of License Renewal Application (TAC No. ME4640) and License Renewal Application Amendment No. 47

Reply to Request for Additional Information for the Review of License Renewal Application (TAC No. ME4640) and License Renewal Application Amendment No. 47

ML14035A164
Person / Time
Site:	Davis Besse
Issue date:	01/31/2014
From:	Lieb R FirstEnergy Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-14-061, TAC ME4640
Download: ML14035A164 (44)

Text

FENOC-  %

5501 North State Route 2 Oak Harbor. Ohio 43449 FIrstEnergy Nuclear OperatingCompany Raymond A. Lieb 419-321-7676 Vice President,Nuclear Fax: 419-321-7582 January 31, 2014 L-14-061 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. 47 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 (Davis-Besse). By letter dated November 26, 2013 (ML13294A500), the Nuclear Regulatory Commission (NRC) requested additional information to complete its review of the License Renewal Application (LRA). The submittal date for this response was extended following discussion with Mr. Juan Uribe, NRC Project Manager, because additional time was needed for development of the responses due to the unavailability of personnel during the holidays and the inclement winter weather.

The Attachment provides the FENOC reply to the NRC request for additional information. The NRC request is shown in bold text followed by the FENOC response.

The Enclosure provides Amendment No. 47 to the Davis-Besse LRA.

Davis-Besse Nuclear Power Station, Unit No. 1 L-14-061 Page 2 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 January 31!f, 2014.

Sincerely, Raym eb**Lieb

Attachment:

Reply to Request for Additional Information for the Review of the Davis-Besse Nuclear Power Station, Unit No. 1 (Davis-Besse), License Renewal Application (LRA), Section 3.0

Enclosure:

Amendment No. 47 to the Davis-Besse 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-14-061 Reply to Requests for Additional Information for the Review of the Davis-Besse Nuclear Power Station, Unit No. 1 (Davis-Besse),

License Renewal Application (LRA),

Section 3.0 Page 1 of 9 Question RAI 3.0.3-3 Issue: Loss of coating integrity for Service Level III and Other coatings Industry operating experience (OE) indicates that degraded coatings have resulted in unanticipated or accelerated corrosion of the base metal and degraded performance of downstream equipment (e.g., reduction in flow, drop in pressure, reduction in heat transfer) due to flow blockage. Based on these industry OE examples, the staff has questions related to how the aging effect, loss of coating integrity due to blistering, cracking, flaking, peeling, or physical damage, would be managed for Service Level III and Other coatings.

For purposes of this request for additional information (RAI):

a. Service Level III coatings are those installed on the interior of in-scope piping, heat exchanges, and tanks which support functions identified under Title 10 of the Code of FederalRegulations (CFR) 54.4(a)(1) and (a)(2).

b. "Other coatings," include coatings installed on the interior of in-scope piping, heat exchangers, and tanks whose failure could prevent satisfactory accomplishment of any of the functions identified under 10 CFR 54.4(a)(3).

c. The term "coating" includes inorganic (e.g., zinc-based) or organic (e.g.,

elastomeric or polymeric) coatings, linings (e.g., rubber, cementitious), and concrete surfacers that are designed to adhere to a component to protect its surface.

d. The terms "paint" and "linings" should be considered as coatings.

The staff believes that to effectively manage loss of coating integrity due to blistering, cracking, flaking, peeling, or physical damage of Service Level III and Other coatings an aging management program should include:

a. Baseline visual inspections of coatings installed on the interior surfaces of in-scope components should be conducted in the 10-year period prior to the period of extended operation.

Attachment L-14-061 Page 2 of 9

b. Subsequent periodic inspections where the interval is based on the baseline inspection results. For example:

i. If no peeling, delamination, blisters, or rusting are observed, and any cracking and flaking have been found acceptable, subsequent inspections could be conducted after multiple refueling outage intervals (e.g., for example six years, or more if the same coatings are in redundant trains).

ii. If the inspection results do not meet the above; but, a coating specialist has determined that no remediation is required, subsequent inspections could be conducted every other refueling outage interval.

iii. If coating degradation is observed that required repair or replacement, or for newly installed coatings, subsequent inspections should occur over the next two refueling outage intervals to establish a performance trend on the coatings.

c. All accessible internal surfaces for tanks and heat exchangers should be inspected. A representative sample of internally coated piping components not less than 73 1-foot axial length circumferential segments of piping or 50 percent of the total length of each coating material and environment combination should be inspected.

d. Coatings specialists and inspectors should be qualified in accordance with an ASTM International standard endorsed in RG 1.54, "Service Level I, II, and III Protective Coatings Applied to Nuclear Power Plants," including staff guidance associated with a particular standard.

e. Monitoring and trending should include pre-inspection reviews of previous inspection results.

f. The acceptance criteria should include that indications of peeling and delamination are not acceptable. Blistering can be evaluated by a coating specialist; however, physical testing should be conducted to ensure that the blister is completely surrounded by sound coating bonded to the surface.

Request:

If coatings have been installed on the internal surfaces of in-scope components (i.e., piping, piping subcomponents, heat exchangers, and tanks), state how loss of coating integrity due to blistering, cracking, flaking, peeling, or physical damage will be managed, including:

a. for each installed coating application, whether installation records used to apply the coating included material manufacturer installation specifications

Attachment L-14-061 Page 3 of 9

b. the inspection method

c. the parameters to be inspected

d. when inspections will commence and the frequency of subsequent inspections

e. the extent of inspections and the basis for the extent of inspections if it is not consistent with item c above

f. the training and qualification of individuals involved in coating inspections

g. how trending of coating degradation will be conducted

h. acceptance criteria

i. corrective actions for coatings that do not meet acceptance criteria

j. the program(s) that will be augmented to include the above requirements If necessary, provide revisions to license renewal application Section 3 Table 2s, Appendix A, and Appendix B.

RESPONSE RAI 3.0.3-3 Service Level III coatings (including paint, linings and concrete surfacers) have been installed on the internal surfaces of certain components in Davis-Besse mechanical fluid systems within the scope of license renewal, as follows:

• The interior surfaces of the fire water storage tank have an epoxy coating. However, inspection of the interior coating and surfaces of the fire water storage tank will be performed in conjunction with the tank internal inspections required by the Fire Water Program under National Fire Protection Association (NFPA) 25, "Standard for the Inspection, Testing, and Maintenance of Water-Based Fire Protection Systems."

" A portion of the underground fire water main piping and fittings are cement-lined ductile iron pipe.

" The diesel oil storage tank interior walls and ceiling have an epoxy coating, and the bottom surface is coated with Sherwin Williams Magnaplate reinforced vinyl ester laminate.

" The main lubricating oil pump casings for the Emergency Diesel Generators and the Station Blackout Diesel Generator were received from the vendor with a coating.

Attachment L-14-061 Page 4 of 9

• The interior surface of Circulating Water System piping is coated with coal-tar enamel.

" Certain Service Water System butterfly valves are lined with rubber or elastomer.

Strainers in the system are coated internally with epoxy. Service water pumps and the dilution pump interior surfaces have an epoxy coating.

No heat exchangers in the scope of license renewal with internal Service Level III coatings were identified during the review.

Loss of coating integrity due to blistering, cracking, flaking, peeling, or physical damage will be managed as follows:

a. for each installed coating application, whether installation records used to apply the coating included material manufacturer installation specifications Installation records used to apply coatings to in-scope components do not include material manufacturer installation specifications.

b. the inspection method The inspection method is visual examination. Where accessibility permits a closer inspection of suspect, deficient, or degraded internal coatings, the Nuclear Coatings Specialist may supplement visual inspections with adhesion testing techniques in accordance with industry ASTM International (ASTM) standards.

c. the parameters to be inspected The parameters to be inspected include visual evidence of blistering, cracking, flaking, peeling, delamination, and physical damage. Visual evidence of underlying corrosion (e.g., rust spots) may also indicate a loss of coating integrity.

d. when inspections will commence and the frequency of subsequent inspections Visual inspections of internal coatings will be performed in accordance with the guidance in ASTM D7167-05, "Standard Guide for Establishing Procedures to Monitor the Performance of Safety-Related Coating Service Level III Lining Systems in an Operating Nuclear Power Plant." Baseline inspections will be performed during the 10-year period prior to the period of extended operation. Subsequent inspections will be based on an evaluation of the effect of a coating failure on the in-scope

Attachment L-14-061 Page 5 of 9 component's intended function, potential problems identified during prior inspections, and known service life history. Subsequent inspection intervals are established by a coating specialist qualified in accordance with an ASTM standard endorsed in Regulatory Guide 1.54. However, inspection intervals should not exceed those identified in Items 1-6, as follows:

1. If no peeling, delamination, blisters, or rusting are observed, and any cracking and flaking have been found acceptable, subsequent inspections will be conducted every three refueling outages (i.e., every 6 years).

2. If no cracking or spalling in cementitious linings, subsequent inspections will be conducted every three refueling outages (i.e., every 6 years).

3. For Items 1 and 2, if the following conditions are met, the inspection interval may be extended to 12 years:

a. The identical coating material was installed with the same installation requirements in redundant trains (e.g., piping segments) with the same operating conditions and at least one of the trains is inspected every 6 years.

b. The coating is not in a location subject to turbulence. Turbulent locations are those where fluid flow is such that the velocity at a given point varies erratically in magnitude and direction and mechanical damage to coatings can occur (e.g., piping downstream of certain control valves).

4. If the inspection results do not meet the criteria in Items 1 or 2, above, but a coating specialist has determined that no remediation is required, subsequent inspections will be conducted every other refueling outage (i.e., every 4 years).

These subsequent inspections will include locations that resulted in subsequent inspections being conducted as well as new locations.

a. Following two sequential subsequent inspections which demonstrate no change in coating condition, subsequent inspections may be conducted at six-year intervals as described in Items 1 or 2, above.

5. If coating degradation is observed that required repair or replacement or for newly installed coatings, subsequent inspections will be conducted over the next two refueling outage intervals to establish a performance trend on the coatings, after which the inspection interval may be increased by the coatings program owner as described in Item 1, Item 2 or Item 4, above.

6. The fire water storage tank inspection is exempt from the frequencies identified in Items 1-5, above. National Fire Protection Association (NFPA) 25, "Standard for the Inspection, Testing, and Maintenance of Water-Based Fire Protection

Attachment L-14-061 Page 6 of 9 Systems," Section 9.2.6, "Interior Inspection," governs the inspections and frequency (currently a five-year frequency) for fire water storage tanks.

The above recommendations for inspection of coatings in Items 1-5, above, may be omitted if the degradation of coatings cannot result in downstream effects such as reduction in flow, drop in pressure, or reduction in heat transfer for in-scope components. In this case, loss of coating integrity could result in unanticipated or accelerated corrosion rates of the base metal. If corrosion of the base material is the only issue related to coating degradation of the component, external wall thickness measurements can be performed in lieu of internal inspections to confirm the acceptability of the corrosion rate of the base metal.

e. the extent of inspections and the basis for the extent of inspections if it is not consistent with item c above In each inspection period, all accessible internal surfaces of in-scope tanks with installed coatings will be inspected. In addition, a representative sample of internally-coated piping components consisting of at least 73 1-foot axial length circumferential segments of piping, or 50 percent of the total length of each coating material and environment combination, will be inspected.

f. the training and qualification of individuals involved in coating inspections The coatings program owner will be qualified as a Nuclear Coatings Specialist in accordance with the requirements of ASTM D7108-12, "Standard Guide for Establishing Qualifications for a Nuclear Coatings Specialist." Coatings inspection personnel will be knowledgeable on coatings, and will be qualified in accordance with the requirements of ASTM D4537-12, "Standard Guide for Establishing Procedures to Qualify and Certify Personnel Performing Coating and Lining Work Inspection in Nuclear Facilities." The coatings program owner and coatings inspection personnel will also meet the guidance of Electric Power Research Institute (EPRI) 1019157, "Guideline on Nuclear Safety-Related Coatings, Revision 2."

g. how trending of coating degradation will be conducted The guidance from ASTM D7167-05, "Standard Guide for Establishing Procedures to Monitor the Performance of Safety-Related Coating Service Level III Lining Systems in an Operating Nuclear Power Plant," and EPRI 1019157 will be used to evaluate the performance of Service Level III coatings. Prior to performing inspections, a pre inspection review of at least the previous two inspection reports will be conducted to identify areas where degraded coatings exist and any subsequent repair activities. Inspection results will be reviewed by a qualified Nuclear Coatings Specialist. Identified degradation that does not meet the

Attachment L-14-061 Page 7 of 9 acceptance criteria is documented and evaluated in accordance with the FENOC Corrective Action Program.

The coatings program owner (or designee qualified as a Nuclear Coatings Specialist) will evaluate inspection results and prepare the inspection report to include: a list and location of all areas evidencing deterioration, a prioritization of the repair areas into areas that must be repaired before returning the system to service and areas where repair can be postponed to the next inspection, and where possible, photographic evidence indexed to inspection locations. When corrosion of the base material is the only issue related to coating degradation of the component and external wall thickness measurements are used in lieu of internal visual inspections of the coating, the corrosion rate of the base metal is trended.

h. acceptance criteria Acceptance criteria are established in accordance with ASTM D7167-05. Standard definitions of degradation mechanisms, in accordance with ASTM D4538-05, "Standard Terminology Relating to Protective Coating and Lining Work for Power Generation Facilities," and EPRI 1019157, are as follows:

• Blistering - formation of bubbles in a coating (paint) film

" Cracking - formation of breaks in a coating film that extend through to the underlying surface

• Flaking - detachment of pieces of the film itself either from its substrate or from coating (paint) previously applied

• Peeling - separation of one or more coats or layers of a coating from the substrate

" Delamination - separation of one coat or layer from another coat or layer or from the substrate

" Rusting - corrosion that occurs when the applied coating thickness is insufficient to completely or adequately cover steel surfaces

• Physical Damage - removal or reduction of thickness of coating by mechanical damage Acceptable coatings are free of peeling and delamination. Blistering will be evaluated by a Nuclear Coatings Specialist to determine acceptability; adhesion testing should be conducted to ensure that the blister is completely surrounded by sound coating bonded to the surface. Cracking, flaking, rusting and physical damage will also be evaluated by a Nuclear Coatings Specialist to determine acceptability.

Attachment L-14-061 Page 8 of 9 Where access to the interior of components is permitted, adhesion testing should be conducted for coated areas that are determined to be suspect, deficient, or degraded as directed by the coatings program owner. Degraded coatings are further categorized using industry guidance for evaluating the degree of blistering or rusting on coated surfaces.

Minor cracking and spalling of cementitious coatings is acceptable provided there is no evidence that the coating is debonding from the base material.

As applicable, wall thickness measurements meet design minimum wall requirements.

Adhesion testing results meet or exceed the degree of adhesion recommended in engineering documents specific to the coating and substrate.

i. corrective actions for coatings that do not meet acceptance criteria Coatings that do not meet the acceptance criteria will be documented and evaluated under the FENOC Corrective Action Program. Corrective actions may include determining the cause of the coating failure, leaving the degraded coatings in place until the next scheduled inspection, or replacing or repairing the coating to restore the area to an acceptable condition.

j. the program(s) that will be augmented to include the above requirements Loss of coating integrity will be managed by a new plant-specific aging management program, the Service Level III Coatings and Linings Monitoring Program. No existing program(s) need to be augmented to include the above requirements.

The following Sections of the LRA are revised to address aging management of Service Level III coatings:

" Section 3.3.2.1.6, "Circulating Water System"

• Section 3.3.2.1.12, "Emergency Diesel Generators System"

" Section 3.3.2.1.14, "Fire Protection System"

• Section 3.3.2.1.15, "Fuel Oil System"

" Section 3.3.2.1.26, "Service Water System"

" Section 3.3.2.1.30, "Station Blackout Diesel Generator System"

" Table 3.3.2-6, "Aging Management Review Results - Circulating Water System"

• Table 3.3.2-12, "Aging Management Review Results - Emergency Diesel Generators System"

Attachment L-14-061 Page 9 of 9

" Table 3.3.2-14, "Aging Management Review Results - Fire Protection System"

" Table 3.3.2-15, "Aging Management Review Results - Fuel Oil System"

" Table 3.3.2-26, "Aging Management Review Results - Service Water System"

• Table 3.3.2-30, "Aging Management Review Results - Station Blackout Diesel Generator System"

" Table 3.3.2 Plant-Specific Notes

• Section A.1.44, "Service Level III Coatings and Linings Monitoring Program"

• Section A.1.45, "References"

" Table A-i, "Davis-Besse License Renewal Commitments"

" Table B-i, "Correlation of NUREG-1 801 and Davis-Besse Aging Management Programs"

" Table B-2, "Consistency of Davis-Besse Aging Management Programs with NUREG-1801"

• Section B.2.44, "Service Level III Coatings and Linings Monitoring Program" See the Enclosure to this letter for the revision to the Davis-Besse LRA.

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

Letter L-14-061 Amendment No. 47 to the Davis-Besse License Renewal Application Page 1 of 33 License Renewal Application Sections Affected Section 3.3.2.1.6 Table 3.3.2-26 Section 3.3.2.1.12 Table 3.3.2-30 Section 3.3.2.1.14 Table 3.3.2 Section 3.3.2.1.15 Section A. 1.44 Section 3.3.2.1.26 Section A. 1.45 Section 3.3.2.1.30 Table A-1 Table 3.3.2-6 Table B-1 Table 3.3.2-12 Table B-2 Table 3.3.2-14 Section B.2.44 Table 3.3.2-15 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 lined-ou and added text underlined.

Enclosure A L-14-061 Page 2 of 33 Affected LRA Section LRA Page No. Affected Paragraph and Sentence 3.3.2.1.6 3.3-10 & -11 New "Materials" bullet; New "Aging Effects Requiring Management" bullet; New "Aging Management Programs" bullet In response to NRC request for additional information (RAI) 3.0.3-3, new bullets are added under the "Materials," "Aging Effects Requiring Management," and "Aging Management Programs" headings of LRA Section 3.3.2.1.6, "Circulating Water System," which is revised to read as follows:

Materials The materials of construction for subject mechanical components of the Circulating Water System are:

" Elastomer

" Steel

• Steel (Coated)

Aging Effects Requiring Management The following aging effects require management for the subject mechanical components of the Circulating Water System:

" Cracking

• Hardening and loss of strength

• Loss of coating integrity

" Loss of material

" Loss of preload Aging Management Programs 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

Enclosure A L-14-061 Page 3 of 33

" One-Time Inspection

• Open-Cycle Cooling Water Program

• Service Level Ill Coatings and Linings Monitorinq Program

Enclosure A L-14-061 Page 4 of 33 Affected LRA Section LRA Page No. Affected Paragraph and Sentence 3.3.2.1.12 3.3-16 & -17 New "Materials" bullet; New "Aging Effects Requiring Management" bullet; New "Aging Management Programs" bullet In response to RAI 3.0.3-3, new bullets are added under the "Materials," "Aging Effects Requiring Management," and "Aging Management Programs" headings of LRA Section 3.3.2.1.12, "Emergency Diesel Generators System," which is revised to read as follows:

Materials The materials of construction for subject mechanical components of the Emergency Diesel Generators System are:

" Aluminum

" Copper alloy > 15% Zn

" Elastomer

• Glass

• Stainless steel

• Steel

" Steel (Coated)

Aging Effects Requiring Management The following aging effects require management for the subject mechanical components of the Emergency Diesel Generators System:

" Cracking

" Hardening and loss of strength

" Loss of coating integrity

" Loss of material

• Loss of preload

• Reduction in heat transfer

Enclosure A L-14-061 Page 5 of 33 Aging Management Programs 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 Program

" Lubricating Oil Analysis Program

" One-Time Inspection

" Selective Leaching Inspection

• Service Level Ill Coatings and Linings Monitoring Program

Enclosure A L-14-061 Page 6 of 33 Affected LRA Section LRA Page No. Affected Paragraph and Sentence 3.3.2.11.14 3.3-18 & -19 New "Materials" bullet; New "Aging Effects Requiring Management" bullet; New "Aging Management Programs" bullet In response to to RAI 3.0.3-3, new bullets are added under the "Materials,"

"Aging Effects Requiring Management," and "Aging Management Programs" headings of LRA Section 3.3.2.1.14, "Fire Protection System," which is revised to read as follows:

Materials The materials of construction for subject mechanical components of the Fire Protection System are:

• Aluminum

" Copper alloy

" Copper alloy > 15% Zn

" Elastomer

• Gray cast iron

• Stainless steel

• Steel

" Steel (Coated)

Aging Effects Requiring Management The following aging effects require management for the subject mechanical components of the Fire Protection System:

" Cracking

" Hardening and loss of strength

• Loss of coating integrity

" Loss of material

" Loss of preload

• Reduction in heat transfer

Enclosure A L-14-061 Page 7 of 33 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

" Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Program

" Lubricating Oil Analysis Program

" One-Time Inspection

" PWR Water Chemistry Program

" Selective Leaching Inspection

" Service Level Ill Coatinqs and Lininc/s Monitorinc Prociram

Enclosure A L-14-061 Page 8 of 33 Affected LRA Section LRA Page No. Affected Paragraph and Sentence 3.3.2.1.15 3.3-20 & -21 New "Materials" bullet; New "Aging Effects Requiring Management" bullet; New "Aging Management Programs" bullet In response to RAI 3.0.3-3, new bullets are added under the "Materials," "Aging Effects Requiring Management," and "Aging Management Programs" headings of LRA Section 3.3.2.1.15, "Fuel Oil System," previously revised in FENOC Letter dated May 24, 2011 (ML11151AO90). LRA Section 3.3.2.1.15 is revised as follows:

Materials The materials of construction for subject mechanical components of the Fuel Oil System are:

• Copper alloy

" Copper alloy > 15% Zn

" Elastomer

" Gray cast iron

" Stainless steel

• Steel

• Steel (Coated)

Aging Effects Requiring Management The following aging effects require management for the subject mechanical components of the Fuel Oil System:

" Cracking

• Hardening and loss of strength

• Loss of coating integrity

• Loss of material

• Loss of preload

Enclosure A L-14-061 Page 9 of 33 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

• Buried Piping and Tanks Inspection

" External Surfaces Monitoring Program

" Fuel Oil Chemistry Program

" Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Program

" One-Time Inspection

" Service Level Ill Coatings and Linings Monitoring Program

Enclosure A L-14-061 Page 10 of 33 Affected LRA Section LRA Page No. Affected Paragraph and Sentence 3.3.2.1.26 3.3-31 & -32 New "Materials" bullet; New "Aging Effects Requiring Management" bullet; New "Aging Management Programs" bullet In response to RAI 3.0.3-3, new bullets are added under the "Materials," "Aging Effects Requiring Management," and "Aging Management Programs" headings of LRA Section 3.3.2.1.26, "Service Water System," which is revised to read as follows:

Materials The materials of construction for subject mechanical components of the Service Water System are:

• Copper alloy

" Copper alloy > 15% Zn

" Gray cast iron

" Gray cast iron (Coated)

• Stainless steel

" Steel

" Steel (Coated)

Aging Effects Requiring Management The following aging effects require management for the subject mechanical components of the Service Water System:

• Cracking

" Loss of coating integrity

• Loss of material

• Loss of preload

Enclosure A L-14-061 Page 11 of 33 Aging Management Programs The following aging management programs manage the aging effects for subject mechanical components of the Service Water System:

" Bolting Integrity Program

• Boric Acid Corrosion Program

• Buried Piping and Tanks Inspection Program

• External Surfaces Monitoring Program

• Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Program

• Open-Cycle Cooling Water Program

• Selective Leaching Inspection

" Service Level Ill Coatings and Linings Monitorinq Program

Enclosure A L-14-061 Page 12 of 33 Affected LRA Section LRA Page No. Affected Paragraph and Sentence 3.3.2.1.30 3.3-36 & -37 New "Materials" bullet; New "Aging Effects Requiring Management" bullet; New "Aging Management Programs" bullet In response to RAI 3.0.3-3, new bullets are added under the "Materials," "Aging Effects Requiring Management," and "Aging Management Programs" headings of LRA Section 3.3.2.1.30, "Station Blackout Diesel Generator System," which is revised to read as follows:

Materials The materials of construction for subject mechanical components of the Station Blackout Diesel Generator System are:

" Aluminum

• Copper alloy

• Copper alloy > 15% Zn

• Elastomer

" Glass

" Stainless steel

• Steel

• Steel (Coated)

Aging Effects Requiring Management The following aging effects require management for the subject mechanical components of the Station Blackout Diesel Generator System:

" Cracking

" Hardening and loss of strength

• Loss of coating integrity

• Loss of material

• Loss of preload

" Reduction in heat transfer

Enclosure A L-14-061 Page 13 of 33 Aging Management Programs 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 Ducting Program

" Lubricating Oil Analysis Program

" One-Time Inspection

" Selective Leaching Inspection

" Service Level /// Coatings and Linings Monitoring Program

Enclosure A L-14-061 Page 14 of 33 Affected LRA Section LRA Page No. Affected Paraqraph and Sentence Table 3.3.2-6 3.3-232 One new row In response to RAI 3.0.3-3, a new row is added to LRA Table 3.3.2-6, "Aging Management Review Results -

Circulating Water System," which is revised to read as follows:

Table 3.3.2-6 Aging Management Review Results - Circulating Water System Row Component Intended Aging Effect Aging NUREG-Row Typoent I Material Environment Requiring Management 1801, Table I Notes No.Management Program Volume 2 Item Item Structural Steel Raw water Loss

__Service Loss of T Level Ill Coatingsand NA NA H integrit (Coated) (Internal) integrit Linings 0343

___Monitoring

Enclosure A L-14-061 Page 15 of 33 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table 3.3.2-12 3.3-297 One new row In response to RAI 3.0.3-3, a new row is added to LRA Table 3.3.2-12, "Aging Management Review Results -

Emergency Diesel Generators System," which is revised to read as follows:

Table 3.3.2-12 Aging Management Review Results - Emergency Diesel Generators System Aging Effect Aging NUREG-Row Component Intended Material Environment Requiring Management 1801, Table I Notes No. Type Function(s) Management Maaeet Program Porm Iteume22 Volume Im Item Item Pump Casing - Service Level Ill Engine-driven Pressure Steel ofat Lubricating oiLosscoating CoatingsanN H

-- main pumplube (DB-oil boundary (Coated) N/A_-

(Internal) cine Lining pum 10 & 2)

- 0343 P150-1 &2) rit Monitoring

Enclosure A L-14-061 Page 16 of 33 Affected LRA Section LRA Page No. Affected Paraqraph and Sentence Table 3.3.2-14 3.3-342 Two new rows In response to RAI 3.0.3-3, two new rows are added to LRA Table 3.3.2-14, "Aging Management Review Results -

Fire Protection System," which is revised to read as follows:

Table 3.3.2-14 Aging Management Review Results - Fire Protection System Row Component Intended TAging Aging Effect Aging Magint NUREG-1801, Table I Notes No. Type Function(s) Material Environment Requiring Management Volume 2 Item Management j Program Item Lsf Service Level Ill Pressure Steel Raw water Loss Coatingsand H

-- P boundary (Coated) (Internal) integrit N/A N/A 0343 Monitorinq Tank - Fire Loss of Service Level II

-- water storage Pressure Steel Raw water catin Coatings and N/A N/A H tank (DB-T81) boundary (Coated) (Internal) integrit Lining 0343 IMonitorinqg

Enclosure A L-14-061 Page 17 of 33 Affected LRA Section LRA Page No. Affected Paraqraph and Sentence Table 3.3.2-15 3.3-343 One new row In response to RAI 3.0.3-3, a new row is added to LRA Table 3.3.2-15, "Aging Management Review Results - Fuel Oil System," which is revised to read as follows:

Table 3.3.2-15 Aging Management Review Results - Fuel Oil System Component Intended Aging Effect Aging NUREG-Row Row Copnet Fnctiondd Material Environment Requiring Management 1801, Table 1 Notes No. Type Function(s) Management Program Volume 2 Item

__ _ __ _ __ _ __ _ _ _ _ _ _ _ _ _ _ _ _ _ _ Item_ _

Structural Steel Raw water SLoss of coating Service Level Ill Coatings and NA NA H

-- integrit (Coated) (Internal) integrit Linings 0343 inte___rity_ Monitoring

Enclosure A L-14-061 Page 18 of 33 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table 3.3.2-26 3.3-482 Five new rows In response to RAI 3.0.3-3, five new rows are added to LRA Table 3.3.2-26, "Aging Management Review Results -

Service Water System," which is revised to read as follows:

Table 3.3.2-26 Aging Management Review Results - Service Water System Aging Effect Aging NUREG-Row Component Intended Aging Magint 1801, Table I Notes No. Type Function(s) Material Environment Requiring Management Management Program Volme2ete Volume 2 Item Item Ser'ice Level Ill Pump Casing - Gray Raw water Loss of Coatine andeH Pressure Cast Iron coating Coatings an NA NA -

-- Dilution Pump (DB-P180)

__DB-P180) boundary

________ (Coated) (Internal) integritV (Coated____________Monitoring Linings - 0343 Pump Casing - Loss of Service Level Ill Putin - Pressure Steel Raw water coatin Coatings and NA H

- DiiPum boundary (Coated) (Internal) integrit Lininqs 0343 (DB-P1 80) *Monitoring Pump Casing - Loss of Service Level Ill Service Water Pressure Steel Raw water ______ Coatings and NA NA H

- Pump (DB-P3- boundary (Coated) (Internal) integrit Linings 0343 1_2, and 3) Monitoring Loss of Service Level Ill Strainer(body) Pressure Steel Raw water coatin Coatings anf NA H Sboundary (Coated) (Internal) integrit Liningsa NA - 343 Monitoring Loss of Service Level Ill Valve Bod Pressure Steel Raw water coating Coatings and NA NA H boundary (Coated) (Internal) integrit Lininqs NA 0343

__Monitoring

Enclosure A L-14-061 Page 19 of 33 Affected LRA Section LRA Page No. Affected Paraqraph and Sentence Table 3.3.2-30 3.3-521 One new row In response to RAI 3.0.3-3, a new row is added to LRA Table 3.3.2-30, "Aging Management Review Results -

Station Blackout Diesel Generator System," which is revised to read as follows:

Table 3.3.2-30 Aging Management Review Results - Station Blackout Diesel Generator System Row Component Intended AigEfc Aging Effect Aging gn NUREG-81 al Row Copnet Fnctiondd Material Environment Requiring Management 1801, Table 1 Notes No. Type Function(s) Maaeet Management Porm Program Volume Item 2 Item Pump Casing -

Engine-driven Pressure Steel Lubricatingoi Loss of Coatings and NA/

-- main lube oil boundary (Coated) (Internal) gr' coatin NiA NnA 0343 pump (DQB- Monitoring P286A)

Enclosure A L-14-061 Page 20 of 33 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table 3.3.2 3.3-549 One new note / row Plant-Specific Notes In response to RAI 3.0.3-3, a new note / row is added to LRA Table 3.3.2 Plant-Specific Notes, which is revised to read as follows:

Enclosure A L-14-061 Page 21 of 33 Affected LRA Section LRA Page No. Affected Paragraph and Sentence A.1.44 & A.1.45 A-25 & -26 New section / title revision Appendix A Table of A-4 New & revised listing Contents Based on the response to RAI 3.0.3-3, a new LRA section is created to describe a new plant-specific aging management program. LRA Section A. 1.44 is renamed from "References" to "Service Level III Coatings and Linings Monitoring Program."

The "References" section is renumbered as Section A. 1.45, "References."

Although not shown below, LRA Appendix A, "Updated Safety Analysis Report Supplement," "Table of Contents" is revised accordingly to include the new and renumbered sections. New LRA Section A.1.44 reads as follows:

A. 1.44 SERVICE LEVEL /// COA TINGS AND LININGS MONITORING PROGRAM The Service Level Ill Coatings and Linings Monitoring Program manages loss of coating integrity due to blistering, cracking, flaking, peeling, delamination or physical damage of all Service Level Ill coatings and linings on the internal surfaces of mechanical fluid systems within the scope of license renewal. This program ensures that degraded coatings do not result in loss of intended function due to unanticipated or accelerated corrosion or flow blockage of mechanical components within the scope of license renewal.

The program is a condition monitoring program which consists of visual inspections of the in-scope Service Level Ill coatings and linings. The program follows the guidelines of ASTM D7167-05, "Standard Guide for Establishing Procedures to Monitor the Performance of Safety-Related Coating Service Level Ill Lining Systems in an Operating Nuclear Power Plant," and EPRI 1019157, "Guideline on Nuclear Safety Related Coatings Revision 2," for monitoring the performance of in-scope coatings and linings, including training and qualification guidance for coatings inspectors. The Service Level Ill Coatings and Linings Monitoring Program will be implemented via baseline inspections prior to the period of extended operation, followed by subsequent periodic inspections on an interval based on baseline inspection results.

Enclosure A L-14-061 Page 22 of 33 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table A-1 A-69 New Commitment No. 51 Based on the response to RAI 3.0.3-3, LRA Table A-1, "Davis-Besse License Renewal Commitments," is revised to include a new license renewal future commitment, to read as follows:

Table A-1 Davis-Besse License Renewal Commitments Item Iter Commitment Impl-meRelated Implementation Source LRA Section No./

N urnber Schedule ,Cmet Comments 51 Implement the Service Level Ill Coatings and Linings Monitoring Priorto LRA A. 1.44 Program. October 22, 2016 B. 2.44 and and FENOC Response to Letter NRC RAI L-14-061 3.0.3-3 from NRC Letter dated November 26, 2013

Enclosure A L-14-061 Page 23 of 33 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table B-I B-17 New row In response to RAI 3.0.3-3, LRA Table B-i, "Correlation of NUREG-1801 and Davis-Besse Aging Management Programs," is revised to include a new row for the plant-specific program, "Service Level III Coatings and Linings Monitoring Program," as follows:

Table B-1 Correlation of NUREG-1801 and Davis-Besse Aging Management Programs (continued)

Number NUREG-1801 Program Corresponding Davis-Besse AMP NA Plant-specific Program Service Level III Coatings and Linings Monitoring Program See Section B. 2.44.

Enclosure A L-14-061 Page 24 of 33 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table B-2 B-22 New row In response to RAI 3.0.3-3, LRA Table B-2, "Consistency of Davis-Besse Aging Management Programs with NUREG-1 801," is revised to include a new row for the plant-specific program, "Service Level III Coatings and Linings Monitoring Program," as follows:

Consistent Consistent wt New / with NUEG Plant- Enhancement Existing NUREG- 1801 with Specific Required 1801 181wt Exceptions Service Level Ill Coatings and Linings New - -- Yes --

Monitoring Program - -

Section B. 2.44

Enclosure A L-14-061 Page 25 of 33 Affected LRA Section LRA Page No. Affected Paragraph and Sentence B.2.44 B-167 New Aging Management Program Appendix B Table of B-4 New listing Contents In response to RAI 3.0.3-3, a new LRA Section B.2.44, "Service Level III Coatings and Linings Monitoring Program," is created to describe a new plant-specific aging management program. Although not shown below, LRA Appendix B, "Aging Management Programs," "Table of Contents" is revised accordingly to include the new section. New LRA Section B.2.44 reads as follows:

B.2.44 SERVICE LEVELY/ COATINGS AND LININGS MONITORING PROGRAM ProgramDescription The Service Level Ill Coatings and Linings Monitoring Program is a new plant-specific condition monitorinq program for Davis-Besse. The program consists of periodic visual inspections of all Service Level Ill coatings and linings on the intemal surfaces of piping, piping components, and tanks in mechanical fluid systems that are within the scope of license renewal The program includes organic (e.g., elastomeric or polymeric) and inorganic (e.g., zinc-based) coatings and linings (e.g., rubber,cementitious).

The program will manage loss of coating integrity due to blistering, cracking.

flaking, peeling, delamination, or physical damage of coatings and linings to ensure that degradation does not result in loss of intended function due to unanticipated or accelerated corrosion or flow blockage of in-scope mechanical components. The program will follow the guidelines of ASTM International (ASTM) D7167-05, "Standard Guide for Establishing Procedures to Monitor the Performance of Safety-Related Coating Service Level Ill Lining Systems in an Operating Nuclear Power Plant," for monitoring the performance of in-scope coatings and linings, including training and qualification guidance for coatings inspectors. The program will also follow the guidance of EPRI 1019157, "Guideline on Nuclear Safety Related Coatings Revision 2," for managing coatings and linings. Baseline inspections will be performed during the 10-year period priorto the period of extended operation, followed by subsequent periodic inspections on an interval based on the results of the baseline inspections.

Enclosure A L-14-061 Page 26 of 33 NUREG-1801 Consistency The Service Level Ill Coatings and Linings Monitoring Program is a new plant-specific program for Davis-Besse. The Service Level Ill Coatings and Linings Monitoring Program is evaluated against the ten elements described in Appendix A. 1, Section A. 1.2.3 of NUREG-1800, the Standard Review Plan for License Renewal (SRP LR).

Aging Management ProgramElements The results of an evaluation of each program element are provided below.

Scope The scope of the Service Level Ill Coatings and Linings Monitoring Program is Service Level Ill coatings and linings installed inside of components within the scope of license renewal exposed to raw water, fuel oil and lubricatingoil, as follows:

" the fire water storage tank, and a portion of the underground fire water main (pipingand fittings) in the Fire Protection System;

• the diesel oil storage tank in the Fuel Oil System;

• the main lubricating oil pump casings in the Emergency Diesel Generators and the Station Blackout Diesel Generator:

" piping in the Circulating Water System; and,

• valves, strainersand pumps in the Service Water System.

• Preventive Actions The Service Level Ill Coatings and Linings Monitoring Program is a condition monitoring program that does not include preventive actions. No actions are taken as part of the Service Level Ill Coatings and Linings Monitorinq Program to prevent aging effects or mitigate age-related degradation.

" ParametersMonitored or Inspected The Service Level Ill Coatings and Linings Monitoring Program uses visual inspections to monitor Service Level Ill coatings and linings in accordance with ASTM D7167-05, "Standard Guide for Establishing Procedures to Monitor the Performance of Safety-Related Coating Service Level Ill Linin, Systems in an OperatingNuclear Power Plant."

Enclosure A L-14-061 Page 27 of 33 Parameters monitored or inspected by the Service Level Ill Coatings and Linings Monitoring Program include any visible defects, such as blistering, cracking, flaking, peeling, delamination, and physical damage of coatings.

Loss of coating integrity as evident through rusting of the underlying bare metal will also be monitored by the program.

Detection of Aging Effects Visual inspections of intemal coatings are performed in accordance with the guidance in ASTM D7167-05. Baseline inspections will be performed during the 10-year period prior to the period of extended operation. Subsequent inspections are based on an evaluation of the effect of a coating failure on the in-scope component's intended function, potential problems identified during prior inspections, and known service life history. Subsequent inspection intervals are established by a coating specialist qualified in accordance with an ASTM Intemational standard endorsed in RG 1.54. However, inspection intervals should not exceed those identified in Items 1-6, as follows:

1. If no peeling, delamination, blisters, or rusting are observed, and any cracking and flaking have been found acceptable, subsequent inspections will be conducted every three refueling outages (i.e., every 6 years).

2. If no crackinq or spalling in cementitious coatings, subsequent inspections will be conducted every three refueling outages (i.e., every 6 years).

3. For Items I and 2, if the following conditions are met, the inspection interval may be extended to 12 years:

a. The identical coating material was installed with the same installation requirements in redundant trains (e.g., piping segments) with the same operating conditions and at least one of the trains is inspected every 6 years.

b. The coating is not in a location subiect to turbulence. Turbulent locations are those where fluid flow is such that the velocity at a given point varies erratically in magnitude and direction and mechanical damage to coatings can occur (e.g., piping downstream of certain control valves).

4. If the inspection results do not meet the criteria in Items I or 2, above, but a coating specialist has determined that no remediation is required, subsequent inspections will be conducted every other refueling outage (i.e.. every 4 years). These subseauent inspections will include locations

Enclosure A L-14-061 Page 28 of 33 that resulted in subsequent inspections beinq conducted as well as new locations.

a. Following two sequential subsequent inspections which demonstrate no change in coating condition, subsequent inspections may be conducted at six-year intervals as describedin Items 1 or 2, above.

5. If coating degradation is observed that required repair or replacement or for newly installed coatings, subsequent inspections will be conducted over the next two refueling outage intervals to establish a performance trend on the coatings, after which the inspection interval may be increased by the coatings program owner as described in Item 1, Item 2 or Item 4, above.

6. The fire water storage tank inspection is exempt from the frequencies identified in Items 1-5, above. National Fire ProtectionAssociation (NFPA) 25, "Standard for the Inspection, Testing, and Maintenance of Water-Based Fire Protection Systems," Section 9.2.6, "Interior Inspection,"

govems the inspections and frequency (currentlya five-year frequency) for fire water storage tanks.

In each inspection period, all accessible intemal surfaces of in-scope tanks with installed coatings will be inspected. In addition, a representative sample of internally coated piping components consisting of at least 73 1-foot axial length circumferentialsegments of piping or 50 percent of the total length of each coating material and environment combination will be inspected.

The above recommendations for inspection of coatings in Items 1-5, above, may be omitted if the degradation of coatings cannot result in downstream effects such as reduction in flow, drop in pressure, or reduction in heat transfer for in-scope components. In this case, loss of coating integrity could result in unanticipated or accelerated corrosion rates of the base metal. If corrosion of the base materialis the only issue related to coating degradation of the component, external wall thickness measurements can be performed in lieu of intemal inspections to confirm the acceptability of the corrosion rate of the base metal.

Coatings Surveillance Personnel shall be knowledgeable on coatings, meeting the requirements of ASTM D4537-12. The coatings program owner shall be a Nuclear Coatings Specialist meeting the requirements of ASTM D7108-12. The coatings program owner and coating surveillance personnel will meet the guidance of EPRI 1019157.

Enclosure A L-14-061 Page 29 of 33

" Monitoring and Trending The Service Level Ill Coatings and Linings Monitoring Program incorporates guidance from ASTM D7167-05 and EPRI 1019157. Prior to performing inspections, a pre inspection review of at least the previous two inspection reports will be conducted to identify areas where degraded coatings exist and any subsequent repair activities. Inspection results are reviewed by a qualified Nuclear Coatings Specialist. Identified degradation that does not meet the acceptance criteriais documented and evaluated in accordance with the FENOC Corrective Action Program.

The coatings program owner (or designee qualified as a Nuclear Coatings Specialist)will evaluate inspection results and prepare the inspection report to include: a list and location of all areasevidencing deterioration,a prioritization of the repair areas into areas that must be repaired before returning the system to service and areas where repair can be postponed to the next inspection, and where possible, photographicevidence indexed to inspection locations. When corrosion of the base material is the only issue related to coating degradation of the component and external wall thickness measurements are used in lieu of intemal visual inspections of the coating, the corrosion rate of the base metal is trended.

" Acceptance Criteria The Service Level Ill Coatings and Linings Monitoring Program assesses the condition of coatings to identify defects characterizedby blistering, cracking, flaking, peeling, delamination, rusting, and physical damage in accordance with ASTM D7167-05.

The coatings surveillance personnel will inspect the coatings according to the following degradationdefinitions:

" Blistering - formation of bubbles in a coating (paint)film.

• Cracking - formation of breaks in a coating film that extend through to the underlying surface.

• Flaking - detachment of pieces of the film itself either from its substrate or from coating (paint)previously applied.

" Peeling - Separation of one or more coats or layers of a coating from the substrate.

• Delamination - separation of one coat or layer from another coat or layer or from the substrate.

Enclosure A L-14-061 Page 30 of 33

" Rusting - corrosion that occurs when the applied coating thickness is insufficient to completely or adequately cover steel surfaces.

" Physical Damage - removal or reduction of thickness of coating by mechanical damage.

Acceptable coatings are free of peeling or delamination. Blistering will be evaluated by a Nuclear Coatings Specialist to determine acceptability; adhesion testinq should be conducted to ensure that the blister is completely surroundedby sound coating bonded to the surface. Cracking, flaking, rusting and physical damage will also be evaluated by a Nuclear Coatings Specialist to determine acceptability.

Where access to the interior of components is permitted, adhesion testing should be conducted for coated areas that are determined to be suspect, deficient, or degraded as directed by the coatings program owner. Degraded coatings are further categorized using industry guidance for evaluating the degree of blistering or rusting on coated surfaces.

Minor cracking and spalling of cementitious coatings is acceptable provided there is no evidence that the coating is debonding from the base material As applicable, wall thickness measurements meet desiqn minimum wall requirements.

Adhesion testing results meet or exceed the degree of adhesion recommended in engineering documents specific to the coating and substrate.

Coatings that do not meet the acceptance criteria will be documented and evaluated under the FENOC Corrective Action Program. Corrective actions may include determining the cause of the coating failure, leaving the degradedcoatings in place until the next scheduled inspection, or replacingor repairing the coating to restore the area to an acceptablestatus.

fCorrective 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.

Enclosure A L-14-061 Page 31 of 33

" 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 durinq the period of extended operation and is discussed in Section B. 1.3.

• Operating Experience Industry operatingexperience regardingissues related to coating degradation is documented in NRC Information Notice (IN) 85-24, "Failuresof Protective Coatings in Pipes and Heat Exchangers." The IN provides several examples of coating failures and the issues that resulted in the failure of the coatings.

Also, IN 2013-06, "Corrosionin Fire Protection Piping Due to Air and Water Interaction," describes examples of coated (i.e., zinc galvanized) fire protection piping that corroded due to an air water interaction.

There are a number of recent industry events that occurred due to coating degradationand failure, describedas follows:

" In 2012, a licensee noted foreiqn materialduring a planned replacement of the high-pressure coolant iniection turbine oil sump drain valve. The attached drain piping was noted to be about 2/3 full of foreign material the whole length of the pipe (about a 5 ft section of 1" piping). Chemical analysis showed the material to be a two-part epoxy.

" In 2012, a licensee found foreiqn material at the inlet tubesheet of 2 Component Cooling Water (CCW) heat exchangers. The foreiqn material was pieces of rubberliner from butterfly valves in the Intake Cooling Water system.

• In 2012, a licensee found a through-wall leak due to localized internal corrosion from degraded ceramic coating that was applied to the Service Water Pump Discharge Piping (elbows and spool pieces) on multiple trains of Service Water.

" In 2012, as part of the NRC GL 89-13 pipe inspection program for service water, a licensee identified through-wall leak and degradation of the cement lining on Service Water dischargepiping.

Enclosure A L-14-061 Page 32 of 33

" In 2012, a licensee identified three separate through wall leaks on a circulating water pipe spool piece for the condenser due to internal piping coating failures or lack of coating priorto spool installation.

" In 2013, a licensee identified that the internal coating of the PrimaryPlant Demineralized Water Storage Tank was degraded, leaving several areas of corrosion,paint blistering and exposed plate.

" In 2013, a licensee identified multiple un-isolable through-wall leaks and/or thin wall areas on Service Water headerdrain lines. An internalvisual-only inspection for cement liner degradation and/or corrosion on the 4" diametercarbon steel drain lines was not adequate.

A review was performed of Davis-Besse operating experience related to Service Level Ill coatings. Fire water storage tank operating experience is documented in the Fire Water Program. The remaining operating experience related to coatings is limited to the four Service Water System strainers.The four strainers (including three main strainersand the back-up Service Water System strainer)are periodically replaced, cleaned and refurbished. These strainers are susceptible to significant corrosion pitting due to system desiqn and the strainer service application. Epoxy liner degradation and significant corrosion pitting have been identified for the removed SW Strainers in the past, and that operating experience provides the basis for the existing strainer replacement schedule. No downstream affects from the degraded coating or strainer internals was identified. Coating degradation on the strainers was documented in the Corrective Action Program.

The elements that comprise the Service Level Ill Coatings and Linings Monitoring Program inspections will be consistent with industry practice.

Industry and plant-specific operating experience will be considered in the implementation of this program. As additional operating experience is obtained, lessons learned will be incorporated,as appropriate.

Enhancements None.

Conclusion The Service Level Ill Coatings and Linings Monitoring Program monitors the condition of Service Level Ill coatings and linings within mechanical components to ensure degraded coatings do not lead to flow blockage or unanticipated or acceleratedcorrosion that would result in a loss of component intended function during the period of extended operation. Implementation of the Service Level Ill

Enclosure A L-14-061 Page 33 of 33 Coatings and Linings Monitoring Program provides reasonable assurance that the effects of aging will be managed such that the Service Level Ill coatings will be maintained consistent with the current licensing basis for the period of extended operation.