Text

License Renewal Application (TAC No. ME4640) Amendment No. 48
	ML14055A067
Person / Time
Site:	Davis Besse
Issue date:	02/19/2014
From:	Lieb R; FirstEnergy Nuclear Operating Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	L-14-085, TAC ME4640
	Download: ML14055A067 (78)
	v • d • e

~

5501 North State Route 2 Oak Harbor. Ohio 43449 RrstEnergy Nuclear Operating Company Raymond A. Ueb 419-321-7676 Vice President, Nuclear Fax: 419-321-7582 February 19, 2014 L-14-085 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 Davis-Besse Nuclear Power Station. Unit No. 1. License Renewal Application (TAC No.

ME4640) Amendment No. 48 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 notice in the Federal Register on November 22, 2013 (78 FN 226), Nuclear Regulatory Commission (NRC) announced the availability of License Renewal Interim Staff Guidance (LR-ISG), LR-ISG-2012-02, "Aging Management of Internal Surfaces, Fire W~ter Systems, Atmospheric Storage Tanks, and Corrosion Under Insulation." This LR-ISG provides changes to NUREG-1801, "Generic Aging Lessons Learned (GALL) Report," and NUREG-1800, "Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants," (SRP-LR), including updated guidance on aging management for internal surfaces, fire water systems, atmospheric storage tanks, and corrosion under insulation.

FENOC staff performed a review of LR-ISG-2012-02, and identified necessary revisions to the Davis-Besse License Renewal Application (LRA) to align with the updated guidance in the LR-ISG. The Attachment provides a summary of the changes to the LRA. The Enclosure provides Amendment No. 48 to the Davis-Besse LRA.

Davis-Besse Nuclear Power Station, Unit No. 1 L-14-085 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 February J.:J!!:... 2014.

s4~a-tJ Raymond A. Lieb

Attachment:

Summary of Changes in Amendment 48 to the Davis-Besse Nuclear Power Station, Unit No. 1 (Davis-Besse), License Renewal Application (LRA)

Enclosure:

Amendment No. 48 to the Davis-Besse License Renewal Application cc: NRC DLR Project Manager NRC Region Ill Administrator cc: w/o Attachment or Enclosure NRC DLR Director NRR DORL Project Manager NRC Resident Inspector Utility Radiological Safety Board

Attachment L-14-085 Summary of Changes in Amendment 48 to the Davis-Besse Nuclear Power Station, Unit No. 1 (Davis-Besse),

License Renewal Application (LRA)

Page 1 of 6 The following paragraphs summarize the changes to the Davis-Besse LRA based on the updated guidance in Nuclear Regulatory Commission (NRC) License Renewal Interim Staff Guidance (LR-ISG), LR-ISG-2012-02, "Aging Management of Internal Surfaces, Fire Water Systems, Atmospheric Storage Tanks, and Corrosion Under Insulation."

Aging Management of Internal Surfaces Loss of Material due to Recurring Internal Corrosion Loss of material due to recurring internal corrosion has been identified in the Service Water (SW) System at Davis-Besse. Ultrasonic thickness measurements performed on SW piping identified segments that were below procedural limits. Reduced wall thickness of piping segments were evaluated utilizing the corrective action program.

Piping and associated components have been replaced as required.

Loss of material due to corrosion, erosion and pitting; and fouling and flow blockage of service water piping and piping components are monitored, inspected, and corrected.

Nondestructive examination methods are used to detect fouling and loss of material, prior to any loss of component intended functions. Nondestructive examination methods include visual inspections (VT) and ultrasonic testing (UT). Examination methods are chosen for any particular inspection activity based in part on the results of previous inspections. When visual inspections are used to detect loss of material, the inspection technique is capable of detecting surface irregularities that could indicate wall loss to below nominal pipe wall thickness due to corrosion and corrosion product deposition.

Where such irregularities are detected, follow-up volumetric wall thickness examinations are performed.

Service water piping corrosion and heat exchanger inspections and performance are monitored and trended with frequencies adjusted depending upon the trends observed.

Inspection procedures include acceptance criteria such as allowable wall thickness, maximum allowable tube blockage, and biofouling and silt deposit limits. Acceptance criteria are based on code requirements, design basis calculations, or analyses of system or component performance, or maintenance history. The Open-Cycle Cooling Water Program utilizes the corrective action program to document degradation and to evaluate corrosion rates so the piping and related components are cleaned or replaced prior to a loss of function.

Attachment L-14-085 Page 2 of 6 Davis-Besse has no in-scope components subject to recurring internal corrosion in the other auxiliary systems, the engineered safety features systems, and the steam and power conversion systems.

The following sections of the LRA are revised to address loss of material due to recurring internal corrosion in response to the updated guidance provided in LR-ISG-2012-02:

Table 3.2.1, "Summary of Aging Management Programs for Engineered Safety Features Systems Evaluated in Chapter V of NUREG-1801"

Section 3.3.2.2.16, "Loss of Material due to Recurring Internal Corrosion"

[NEW SECTION]

Table 3.3.1, "Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of NUREG-1801"

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

Table 3.3.2 Plant-Specific Notes

Table 3.4.1, "Summary of Aging Management Programs for Steam and Power Conversion Systems Evaluated in Chapter VIII of NUREG-1801" Periodic Inspections of Internal Surfaces The Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Program is revised to include periodic inspections in addition to opportunistic inspections as follows:

At a minimum, in each 10-year period during the period of extended operation, a representative sample of 20 percent of the population (defined as components having the same material, environment, and aging effect combination) or a maximum of 25 components per population will be inspected. Where practical, the inspection will include a representative sample of the system population and will focus on the bounding or lead components most susceptible to aging because of time in service and severity of the operating conditions. This minimum sample size does not override the opportunistic basis of this AMP.

The following sections of the LRA are revised to address periodic inspections of internal surfaces in response to the updated guidance provided in LR-ISG-2012-02:

Section A.1.41, "Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Program"

Section 8.2.41, "Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Program"

Attachment L-14-085 Page 3 of 6 Fire Water System The Fire Water Program, including aging management review results of the Fire Protection System, are revised to include flow blockage as an aging effect requiring management for the components of the fire water supply and water-based suppression systems. In addition, the program enhancements are replaced in their entirety as follows:

The program will be enhanced to include inspections and testing conducted in accordance with Appendix D, Table 4a, "Fire Water System Inspection and Testing Recommendations," of License Renewal Interim Staff Guidance LR-ISG-2012-02.

The program will be enhanced to include augmented testing and inspections beyond those of Table 4a for portions of water-based fire protection system components that are (a) normally dry but periodically subjected to flow (e.g., dry-pipe or preaction sprinkler system components) and (b) cannot be drained or allow water to collect:

1. In each 5-year interval, beginning 5 years prior to the period of extended operation, a flow test or flush sufficient to detect potential flow blockage will be conducted, or a visual inspection of 100 percent of the internal surface of piping segments will be conducted.

2. In each 5-year interval of the period of extended operation, 20 percent of the length of piping segments that cannot be drained or piping segments that allow water to collect is subject to volumetric wall thickness inspections. Measurement points are obtained to the extent that each potential degraded condition can be identified (e.g., general corrosion, MIG). The 20 percent of piping that is inspected in each 5-year interval will be in different locations than previously inspected piping.

If the results of a 100-percent internal visual inspection are acceptable, and the segment is not subsequently wetted, no further augmented tests or inspections are necessary.

The program will be enhanced to perform representative sprinkler head sampling (laboratory field service testing) or replacement prior to 50 years in-service (installed), and at 10-year intervals thereafter, in accordance with the 2011 Edition of NFPA 25, or until there are no untested sprinkler heads that will see 50 years of service through the end of the period of extended operation.

Attachment L-14-085 Page 4 of 6 The following sections of the LRA are revised to address the Fire Water System in response to the updated guidance provided in LR-ISG-2012-02:

Section 3.3.2.1.14, "Fire Protection System"

Table 3.3.1, "Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of NUREG-1801"

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

Section A.1.18, "Fire Water Program"

Table A-1, "Davis-Besse License Renewal Commitments"

Section 8.2.18, "Fire Water Program" Atmospheric Storage Tanks For storage tanks supported on earthen or concrete foundations, corrosion may occur at inaccessible locations, such as the tank bottom. The Aboveground Steel Tanks Inspection Program manages the effects of loss of material and cracking on the outside and inside surfaces of aboveground tanks constructed on concrete or soil. Tanks included in the program are the steel diesel fuel oil storage tank (outdoor tank) and the stainless steel borated water storage tank (outdoor tank) and the steel condensate storage tanks (indoor tanks).

The Aboveground Steel Tanks Inspection Program including aging management review results for the borated water storage tank, diesel oil storage tank, and condensate storage tanks are revised to include loss of material as an aging effect requiring management for stainless steel or steel tank bottoms that are exposed to the environment of concrete. In addition, a new program enhancement is provided as follows:

The program will be enhanced to include tank inspections conducted in accordance with Table 4a, "Tank Inspection Recommendations," of License Renewal Interim Staff Guidance LR-/SG-2012-02.

The following sections of the LRA are revised to address atmospheric storage tanks in response to the updated guidance provided in LR-ISG-2012-02:

Section 3.2.2.1.4, "Decay Heat Removal and Low Pressure Injection System"

Section 3.2.2.2.3.6, "Stainless Steel Piping, Piping Components, Piping Elements, and Tanks- Internal Condensation"

Table 3.2.1, "Summary of Aging Management Programs for Engineered Safety Features Systems Evaluated in Chapter V of NUREG-1801"

Attachment L-14-085 Page 5 of 6

Table 3.2.2-4, "Aging Management Review Results- Decay Heat Removal and Low Pressure Injection System"

Table 3.2.2 Plant-Specific Notes

Section 3.3.2.1.14, "Fire Protection System"

Section 3.3.2.1.15, "Fuel Oil System"

Table 3.3.1, "Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of NUREG-1801"

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 Plant-Specific Notes

Section 3.4.2.1.2, "Condensate Storage System"

Section 3.4.2.2.2.1, "Steel Piping, Piping Components, Piping Elements, Tanks, and Heat Exchangers-Treated Water and Steam"

Table 3.4.1, "Summary of Aging Management Programs for Steam and Power Conversion Systems Evaluated in Chapter VIII of NUREG-1801"

Table 3.4.2-2, "Aging Management Review Results- Condensate Storage System"

Table 3.4.2 Plant-Specific Notes

Section A.1.2, "Aboveground Steel Tanks Inspection Program"

Table A-1, "Davis-Besse License Renewal Commitments"

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

Section 8.2.2, "Aboveground Steel Tanks Inspection Program" Corrosion Under Insulation The External Surfaces Monitoring Program is revised to address corrosion under insulation. A new program enhancement is provided as follows:

Outdoor insulated components, and indoor insulated components exposed to condensation (because the in-scope component is operated below the dew point), have portions of the insulation inspected or removed to determine whether the exterior surface of the component is degrading or has the potential to degrade.

Attachment L-14-085 Page 6 of 6 Notes are added to the aging management review results tables to identify that, for outdoor insulated components and indoor insulated components exposed to condensation (because the in-scope component is operated below the dew point), the aging effect of corrosion under insulation is managed by the External Surfaces Monitoring Program.

Systems with outdoor insulated components are the Decay Heat Removal and Low Pressure Injection System (borated water storage tank) and the Auxiliary Building HVAC System.

Systems with indoor insulated components exposed to condensation (because the in-scope component is operated below the dew point) are the SW System, the Auxiliary Building HVAC (control room HVAC ducting and associated bolting) and the Auxiliary Building Chilled Water System.

The following sections of the LRA are revised to address corrosion under insulation in response to the updated guidance provided in LR-ISG-2012-02:

Table 3.2.2-4,"Aging Management Review Results- Decay Heat Removal and Low Pressure Injection System"

Table 3.2.2 Plant-Specific Notes

Table 3.3.2-1 "Aging Management Review Results- Auxiliary Building HVAC System"

Table 3.3.2-2, "Aging Management Review Results- Auxiliary Building Chilled Water System"

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

Table 3.3.2 Plant-Specific Notes

Section A.1.15, "External Surfaces Monitoring Program"

Table A-1, "Davis-Besse License Renewal Commitments"

Section B.2.15, "External Surfaces Monitoring Program" See the Enclosure to this letter for the revision to the Davis-Besse LRA.

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

Letter L-14-085 Amendment No. 48 to the Davis-Besse License Renewal Application Page 1 of 70 License Renewal Application Sections Affected Section 3.2.2.1.4 Table 3.3.2-2 Section A.1.2 Section 3.2.2.2.3.6 Table 3.3.2-14 Section A.1 .15 Table 3.2.1 Table 3.3.2-15 Section A.1 .18 Table 3.2.2-4 Table 3.3.2-26 Section A.1 .41 Table 3.2.2 Plant-Specific Notes Table 3.3.2 Plant-Specific Notes Table A-1 Section 3.3.2.1.14 Section 3.4.2.1.2 Table 8-2 Section 3.3.2.1.15 Section 3.4.2.2.2.1 Section 8.2.2 Section 3.3.2.2.16 Table 3.4.1 Section 8.2.15 Table 3.3.1 Table 3.4.2-2 Section 8.2.18 Table 3.3.2-1 Table 3.4.2 Plant**Specific Notes Section 8.2.41 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, ete. 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 fined out and added text underlined.

Enclosure L-14-085 Page 2 of 70 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Section 3.2.2.1.4 3.2-5 New "Environments" bullet In response to the updated guidance regarding the issue of atmospheric storage tanks described in Nuclear Regulatory Commission (NRC) License Renewal Interim Staff Guidance (LR-ISG), LR-ISG-2012-02, "Aging Management of Internal Surfaces, Fire Water Systems, Atmospheric Storage Tanks, and Corrosion Under Insulation," the "Environments" subsection of LRA Section 3.2.2.1.4, "Decay Heat Removal and Low Pressure Injection System," is revised to include a new bullet to read as follows:

Environments Subject mechanical components of the Decay Heat Removal and Low Pressure Injection System are exposed to the following normal operating environments:

Air-indoor uncontrolled

Air-outdoor

Air with borated water leakage

Air with steam or water leakage

Closed cycle cooling water

Concrete

Lubricating oil

Moist air

Steam

Treated borated water

Treated borated water > 60C (> 140F)

Enclosure L-14-085 Page 3 of 70 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Section 3.2.2.2.3.6 3.2-9 Last sentence In response to the updated guidance regarding the issue of atmospheric storage tanks described in NRC LR-ISG-2012-02, the last sentence in LRA Section 3.2.2.2.3.6, "Stainless Steel Piping, Piping Components, Piping Elements, and Tanks- Internal Condensation," previously revised by FENOC letter dated August 17,2011 (ML11231A966), is revised to read as follows:

3.2.2.2.3.6 Stainless Steel Piping, Piping Components, Piping Elements, and Tanks -Internal Condensation Loss of material from pitting and crevice corrosion could occur for stainless steel piping, piping components, piping elements, and tanks exposed to internal condensation. Moist air is enveloped by the NUREG-1801 Chapter IX definition of condensation. At Davis-Besse, Joss of material for stainless steel piping, piping components, piping elements, and tanks that are exposed internally to moist air will be managed by the plant-specific Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Program~xcept for the borated water storage tank (BWSTJ that is managed bv the Aboveground Steel Tanks Inspection Program.

Enclosure L-14-085 Page 4 of 70 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table 3.2.1 3.2-17 3.2.1-08 "Discussion" In response to the updated guidance regarding the issue of atmospheric storage tanks described in NRC LR-ISG-2012-02, the "Discussion" column for Item Number 3.2.1-08 in LRA Table 3.2.1, "Summary of Aging Management Programs for Engineered Safety Features Systems Evaluated in Chapter V of NUREG-1801 ,"

previously revised by FENOC letter dated August 17, 2011 (ML11231A966), is revised to read as follows:

[continued on next page]

Enclosure L-14-085 Page 5 of 70 Table 3.2.1 Summary of Aging Management Programs for Engineered Safety Features Systems Evaluated in Chapter V of NUREG-1801 Further Item Aging Aging Management Component/Commodity Evaluation Discussion Number Effect/Mechanism Programs Recommended 3.2.1-08 Stainless steel piping, piping Loss of material A plant-specific aging Yes, plant- Consistent with NUREG-1801.

components, piping elements, due to pitting and management program specific Loss of material due to pitting and tank internal surfaces crevice corrosion is to be evaluated.

and crevice corrosion in stainless exposed to condensation steel piping, piping components, (internal) piping elements, and tanks that are exposed to moist air (internal) will be managed by the plant-specific Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Program except as noted below.

Loss of material for the internal surface of the borated water storage tank (BWSD will be managed b11: the Aboveground Steel Tanks Inspection Program.

Further evaluation is documented in Section 3.2.2.2.3.6.

Enclosure L-14-085 Page 6 of 70 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table 3.2.1 3.2-38 3.2.1-49 "Discussion" In response to the updated guidance regarding the issue of atmospheric storage tanks described in NRC LR-ISG-2012-02, the "Discussion" column for Item Number 3.2.1-49 in LRA Table 3.2.1, "Summary of Aging Management Programs for Engineered Safety Features Systems Evaluated in Chapter V of NUREG-1801 ," is revised to read as follows:

[continued on next page]

Enclosure L-14-085 Page 7 of 70 Table 3.2.1 Summary of Aging Management Programs for Engineered Safety Features Systems Evaluated in Chapter V of NUREG-1801 Further Item Aging Aging Management Component/Commodity Evaluation Discussion Number Effect/Mechanism Programs Recommended 3.2.1-49 Stainless steel piping, piping Loss of material Water Chemistry No Consistent with NUREG-1801.

components, piping elements, due to pitting and Loss of material for stainless and tanks exposed to treated crevice corrosion steel piping, piping components, borated water piping elements, and tanks that are exposed to treated borated water is managed by the PWR Water Chemistry Program except as noted below.

This item is also applied to stainless steel heat exchanger components and separators that are exposed to treated borated water.

In addition, the One-Time Inspection will provide verification of the effectiveness of the PWR Water Chemistry Program to manage loss of material.

Loss of material for the internal surface of the borated water storage tank (BWSD that is exposed to treated borated water is managed b'f. the Aboveground Steel Tanks Inspection Program.

Enclosure L-14-085 Page 8 of 70 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table 3.2.1 3.2-43 New row In response to the updated guidance regarding the issue of recurring internal corrosion described in NRC LR-ISG-2012-02, LRA Table 3.2.1, "Summary of Aging Management Programs for Engineered Safety Features Systems Evaluated in Chapter V of NUREG-1801 ," is revised to include a new row as follows:

Table 3.2.1 Summary of Aging Management Programs for Engineered Safety Features Systems Evaluated in Chapter V of NUREG-1801 Further Item Aging Aging Management Component/Commodity Evaluation Discussion Number Effect/Mechanism Programs Recommended 3.2.1-66 Metallic gJgJng, eieing Loss of material A elant-seecific aging Yes, [Note: Item Number 3.2.1-66 is comeonents, and tanks due to recurring management erogram elant-seecific from the revision to exeosed to raw water or waste internal corrosion is to be evaluated to (See Subsection NUREG-1800 (SRP-LR~

water address recurring 3.2.2.2.9~ identified in LR-ISG-2012-02.[

internal corrosion Not aoolicable.

Davis-Besse has no in-scoee comeonents subiect to recurring internal corrosion in the engineered safet'f. features S'f.Stems, therefore the a[2[2/icable NUREG-1801/ines from LR-ISG-2012-02 were not used.

Enclosure L-14-085 Page 9 of 70 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table 3.2.2-4 3.2-68 Eight existing rows One new row In response to the updated guidance regarding the issues of atmospheric storage tanks and corrosion under insulation described in NRC LR-ISG-2012-02, LRA Table 3.2.2-4, "Aging Management Review Results- Decay Heat Removal and Low Pressure Injection System," previously revised by FENOC letter dated September 16, 2011 (Ml 11264A059), is revised to read as follows:

Table 3.2.2-4 Aging Management Review Results - Decay Heat Removal and Low Pressure Injection System NUREG-

.~ging Effect Aging Row Component Intended 1801, Table 1 Material Environment Requiring Management Notes No. Type Function(s) Volume 2 Item Management Program Item Pressure Stainless Air-outdoor Loss of F

-- Bolting boundary Steel (External) material Bolting Integrity NA NA 0215 Structural Stainless Air-outdoor Loss of F

-- Bolting Integrity Steel (External) material Bolting Integrity NA NA 0215 Pressure Stainless Air-outdoor Loss of External Surfaces G

-- Piping boundary Steel (External) material Monitoring NA NA 0215 Structural Stainless Air-outdoor Loss of External Surfaces G

-- Piping Integrity Steel (External) material Monitoring NA NA 0215

Enclosure L-14-085 Page 10 of 70 Table 3.2.2-4 Aging Management Review Results - Decay Heat Removal and Low Pressure Injection System NUREG-Aging Effect Aging Row Component Intended 1801, Table 1 Material Environment Requiring Management Notes No. Type Function(s) Volume2 Item Management Program Item IRspeG#eR ef IRteFRa! S~;~rlaGes tR AfiSG9#8R991;1S Tank-BWST Pressure Stainless Moist air Loss of PipiRg aRfi E 113 V.D1-29 3.2.1-08 (DB-T10) boundary Steel (Internal material O~;~GtiRg 0210 Aboveground Steel Tanks Inspection GRe f:..me Treated IRspeGtioo Tank-BWST Pressure Stainless Loss of E 114 borated water Aboveground V.D1-30 3.2.1-49 (DB-T10) boundary Steel material ~

(Internal) Steel Tanks Inspection TaRk S~IST Treated (OS T10) PF9SSU"9 StaiR!ess Less ef PWRWater 115 I:Je~;~Rdaf}' Steel I:JeFated wateF materia! CRemistry v.o1 ao 3.2.1 49 -A-(.!Rtemal)

Not Used Tank-BWST Pressure Stainless Air-outdoor Loss of External Surfaces G

-- (DB-T10) boundary Steel (External) material Monitoring NA NA 0215 Aboveground Tank-BWST Pressure Stainless Concrete Loss of G

--- (DB-T10l boundart Steel (Externall material Steel Tanks N/A N/A 0216 lnseection

Enclosure L-14-085 Page 11 of 70 Affected LRA Section LRAPage No. Affected Paragraph and Sentence Table 3.2.2 3.2-118 Two new notes Plant-Specific Notes In response to the updated guidance regarding the issues of atmospheric storage tanks and corrosion under insulation described in NRC LR-ISG-2012-02, two new plant-specific notes are added to LRA Table 3.2.2, "Plant-Specific Notes," to read as follows:

Plant-Specific Notes:

0215 For outdoor insulated come.onents, corrosion under insulation (CUll is managed b'f. the External Surfaces Monitoring Program.

0216 For storage tanks sue.e.orted on earthen or concrete foundations, corrosion ma'{. occur at inaccessible locations, such as the tank bottom.

Enclosure L-14-085 Page 12 of 70 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Section 3.3.2.1.14 3.3-19 Deleted "Aging Management Programs" bullet In response to the updated guidance regarding the issues of atmospheric storage tanks and Fire Water System flow blockage described in NRC LR-ISG-2012-02, the Aging Management Programs subsection of LRA Section 3.3.2.1.14, "Fire Protection System," previously revised by FENOC letter dated January 31, 2014, is revised to read as follows:

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

Abovegro1::1nd Stee! Tanks J.nspectfon 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 Coatings and Linings Monitoring Program

Enclosure L-14-085 Page 13 of 70 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Section 3.3.2.1.15 3.3-20 New "Environments" bullet In response to the updated guidance regarding the issue of atmospheric storage tanks described in NRC LR-ISG-2012-02, LRA Section 3.3.2.1.15, "Fuel Oil System," is revised to read as follows:

Environments Subject mechanical components of the Fuel Oil System are exposed to the following normal operating environments:

Air-indoor uncontrolled

Air-outdoor

Concrete

Fueloil

Soil

Enclosure L-14-085 Page 14 of 70 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Section 3.3.2.2.16 3.3-47 New Section In response to the updated guidance regarding the issue of recurring internal corrosion described in NRC LR-ISG-2012-02, new LRA Section 3.3.2.2.16, "Loss of Material Due to Recurring Internal Corrosion," is added to read as follows:

3.3.2.2.16 Loss of Material Due to Recurring Internal Corrosion The GALL Report recommends further evaluation to manage recurring internal corrosion aging effects.

Loss of material due to recurring internal corrosion has been identified in the Service Water (SW) System at Davis-Besse. Ultrasonic thickness measurements performed on SW piping identified segments that were below procedural limits.

Reduced wall thickness of piping segments were evaluated utilizing the corrective action program. Piping and associated components have been replaced as required. In addition. the program has been effective in identifying biofouling through the regular measurements of flow rate and differential pressure. For example. in 2009. the ECCS Room Cooler #2 was identified as possibly having marginal biofouling due to an increased differential pressure. The problem ultimately was found to be corrosion in nearby supply and return piping which has been replaced. In another example. preventive maintenance is performed each refueling outage to inspect/clean piping and monitor for MIC through UT wall thickness measurements in the Service Water supply piping to Auxiliary Feedwater. System monitoring is performed by periodic testing of safety-related components within the SW System and monitoring of system parameters by Engineering and Operations personnel. These tests measure and compare (as-applicable) pressure. temperature. differential pressure. and flow rate to design values. If the measured parameters are outside of the test acceptance criteria. appropriate measures are in place to inspect the components and determine the cause for foulin..9.;.

Loss of material due to corrosion. erosion and pitting; and fouling and flow blockage of service water piping and piping components are monitored.

inspected. and corrected. Nondestructive examination methods are used to detect fouling and Joss of material. prior to any loss of component intended functions. Nondestructive examination methods include visual inspections (VT) and ultrasonic testing (UT). Examination methods are chosen for any particular inspection activity based in part on the results of previous inspections. When visual inspections are used to detect loss of material. the inspection technique is

Enclosure L-14-085 Page 15 of 70 capable of detecting surface irregularities that could indicate wall loss to below nominal pipe wall thickness due to corrosion and corrosion product deposition.

Where such irregularities are detected. follow-up volumetric wall thickness examinations are performed.

Service water piping corrosion and heat exchanger inspections and performance is monitored and trended with frequencies adjusted depending upon the trends observed.

Inspection procedures include acceptance criteria such as allowable wall thickness. maximum allowable tube blockage. and biofouling and silt deposit limits. Acceptance criteria are based on code requirements. design basis calculations. or analyses of system or component performance. or maintenance historv. The Open-Cycle Cooling Water Program utilizes the corrective action program to document degradation and to evaluate corrosion rates so the piping and related components are cleaned or replaced prior to a loss of function.

Enclosure L-14-085 Page 16 of 70 Affected LRA Section LRAPage No. Affected Paragraph and Sentence Table 3.3.1 3.3-75 3.3.1-40 "Discussion" In response to the updated guidance regarding the issue of atmospheric storage tanks described in NRC LR-ISG-2012-02, the "Discussion" column for Item Number 3.3.1-40 in LRA Table 3.3.1, "Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of NUREG-1801 ," is revised to read as follows:

Table 3.3.1 Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of NUREG-1801 Further Item Aging Aging Management Component/Commodity Evaluation Discussion Number Effect/Mechanism Programs Recommended 3.3.1-40 Steel tanks in diesel fuel oil Loss of material Aboveground Steel No Consistent with NUREG-1801, system exposed to air - outdoor due to general, Tanks With 9XG9ptfeRS.

(external) pitting, and crevice Loss of material in the stee! fire corrosion wa#ef. S#e.<!BJ9 #aRk ,iR ~J,<=e PF-etastieR System aREi the steel diesel oil storage tank in the Fuel Oil System that aFe !§. exposed to air- outdoor (external) aFe !§.

managed by the Aboveground Steel Tanks Inspection Program.

Enclosure L-14-085 Page 17 of 70 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table 3.3.1 3.3-93 3.3.1-68 "Discussion" In response to the updated guidance regarding the issue of Fire Water System flow blockage described in NRC LR-ISG-2012-02, the "Discussion" column for Item Number 3.3.1-68 in LRA Table 3.3.1, "Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of NUREG-1801 ,"is revised to read as follows:

[continued on next page]

Enclosure L-14-085 Page 18 of 70 Table 3.3.1 Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of NUREG-1801 Further Item Aging Aging Management Component/Commodity Evaluation Discussion Number Effect/Mechanism Programs Recommended 3.3.1-68 Steel piping, piping Loss of material Fire Water System No Consistent with NUREG-1801.

components, and piping due to general, Except as noted below, loss of elements exposed to raw water pitting, crevice, and material and flow blockage in microbiologically steel piping, piping components, influenced and piping elements that are corrosion, and exposed to raw water in the Fire fouling Water System is managed by the Fire Water Program.

This item is also applied to heat exchanger components and tanks that are exposed to raw water in the Fire Protection System.

For steel (including gray cast iron) piping, piping components, and piping elements that are exposed to raw water in the Fire Protection System (Diesel) and in the Station Plumbing, Drains, and Sumps System, loss of material will be detected and characterized by the Collection, Drainage, and Treatment Components Inspection Program.

Enclosure L-14-085 Page 19 of 70 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table 3.3.1 3.3-95 3.3.1-70 "Discussion" In response to the updated guidance regarding the issue of Fire Water System flow blockage described in NRC LR-ISG-2012-02, the "Discussion" column for Item Number 3.3.1-70 in LRA Table 3.3.1, "Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of NUREG-1801 ,"is revised to read as follows:

[continued on next page]

Enclosure L-14-085 Page 20 of 70 Table 3.3.1 Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of NUREG-1801 Further Item Aging Aging Management Component/Commodity Evaluation Discussion Number Effect/Mechanism Programs Recommended 3.3.1-70 Copper alloy piping, piping Loss of material Fire Water System No Consistent with NUREG-1801.

components, and piping due to pitting, Except as noted below, loss of elements exposed to raw water crevice, and material and flow blockag_e in microbiologically copper alloy piping, piping influenced components, and piping corrosion, and elements that are exposed to raw fouling water in the Fire Water System is managed by the Fire Water Program.

For copper alloy piping, piping components, and piping elements, and heat exchanger components that are exposed to raw water in the Fire Protection System (Diesel), loss of material will be detected and characterized by the Collection, Drainage, and Treatment Components Inspection Program.

Enclosure L-14-085 Page 21 of 70 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table 3.3.1 3.3-115 New row In response to the updated guidance regarding the issue of recurring internal corrosion described in NRC LR-ISG-2012-02, a new row is added to LRA Table 3.3.1, "Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of NUREG-1801 ,"to read as follows:

Table 3.3.1 Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of NUREG-1801 Further Item Aging Aging Management Component/Commodity Evaluation Discussion Number Effect/Mechanism Programs Recommended 3.3.1-127 Metallic {2i{2ing, {2i{2ing Loss of material A {21ant-s{2ecific aging Yes, [Note: Item Number 3.3.1-127 is com{2onents, and tanks due to recurring management {2rogram {21ant-s{2ecific from the revision to ex{2osed to raw water or waste internal corrosion is to be evaluated to (See Subsection NUREG-1800 (SRP-LRl water address recurring 3.3.2.2.8l identified in LR-ISG-2012-02.[

internal corrosion Consistent with LR-ISG-2012-02.

Loss of material due to recurring internal corrosion in stee1{2i{2ing,

{2i{2ing com{2onents, and {2i{2ing elements that are ex{2osed to raw water (internall is managed b'i 0{2en-C'{_cle Cooling Water Program.

Further evaluation is documented in Section 3.3.2.2.16.

Enclosure L-14-085 Page 22 of 70 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table 3.3.2-1 3.3-116 "Notes" for row numbers 6, 110 and 142 thru 3.3-143 Four new rows In response to the updated guidance regarding the issue of corrosion under insulation described in NRC LR-ISG-2012-02, LRA Table 3.3.2-1, "Aging Management Review Results- Auxiliary Building HVAC System,"

previously revised by FENOC letter dated June 3, 2011 (ML11159A132), is revised to read as follows:

Table 3.3.2-1 Aging Management Review Results- Auxiliary Building HVAC System NUREG-Aging Effect Aging Row Component Intended 1801, Table 1 Material Environment Requiring Management Notes No. Type Function(s) Volume 2 Item Management Program Item Pressure Air-outdoor Loss of B 6 Bolting Steel Bolting integrity Vil.i-i 3.1.1-43 boundary (External} material 0344 Pressure Copper Air-outdoor Loss of External Surfaces G 110 Piping NA NA boundary Alloy (External) material Monitoring 0344 Copper Pressure Air-outdoor Loss of External Surfaces G 142 Valve Body Alloy NA NA boundary (External) material Monitoring 0344

>15% Zn Pressure Condensation

--- Bolting boundact Steel (Externall Cracking Bolting Integrity NA NA tJ.

Pressure Condensation Loss of §

--- Bolting boundact Steel (Externall material Bolting Integrity VII.D-1 3.3.1-44 0345

Enclosure L-14-085 Page 23 of 70 Table 3.3.2-1 Aging Management Review Results- Auxiliary Building HVAC System NUREG-Aging Effect Aging Row Component Intended 1801, Table 1 Material Environment Requiring Management Notes No. Type Function(s) Volume2 Item Management Program Item Pressure Condensation Loss of

--- Bolting boundat:x:

Steel (Externall e.reload Bolting Integrity NA NA fi Pressure Condensation Loss of External Surfaces ~

--- Duct boundat:x:

Steel (Externall material Monitoring V/1.1-11 3.3.1-58 0345

Enclosure L-14-085 Page 24 of 70 Affected LRA Section LRAPage No. Affected Paragraph and Sentence Table 3.3.2-2 3.3-145 "Notes" for row numbers 2, 6, 11, 32, 36, thru 40, 44, 50, 81 and 86 3.3-159 In response to the updated guidance regarding the issue of corrosion under insulation described in NRC LR-ISG-2012-02, LRA Table 3.3.2-2, "Aging Management Review Results- Auxiliary Building Chilled Water System," is revised to read as follows:

Table 3.3.2*2 Aging Management Review Results -Auxiliary Building Chilled Water System NUREG*

Aging Effect Aging Row Component Intended 1801, Table 1 Material Environment Requiring Management Notes No. Type Function(s) Volume 2 Item Management Program Item Structural Copper Condensation Loss of E 2 Bolting Bolting Integrity V!I.F1-16 3.3.1-25 Integrity Alloy (External) material 0345 Structural Condensation Loss of B 6 Bolting Steel Bolting Integrity VII.D-1 3.3.1-44 Integrity (External) material 0345 Flexible Structural Stainless Condensation Loss of External Surfaces E 11 VII.F1-1 3.3.1-27 Connection Integrity Steel (External) material Monitoring 0345 Structural Stainless Condensation Loss of External Surfaces E 32 Orifice VII.F1-1 3.3.1-27 Integrity Steel (External) material Monitoring 0345 Structural Copper Condensation Loss of External Surfaces E 36 Piping VII.F1-16 3.3.1-25 Integrity Alloy (External) material Monitoring 0345

Enclosure L-14-085 Page 25 of 70 Table 3.3.2-2 Aging Management Review Results -Auxiliary Building Chilled Water System NUREG-Aging Effect Aging Row Component Intended 1801, Table 1 Material Environment Requiring Management Notes No. Type Function(s) Volume2 Item Management Program Item Structural Condensation Loss of External Surfaces A 40 Piping Steel Vll.1-11 3.3.1-58 Integrity (External) material Monitoring 0345 Pump casing

-Chilled Structural Gray Condensation Loss of External Surfaces A 44 Water Pump Vll.1-11 3.3.1-58 Integrity Cast Iron (External) material Monitoring 0345 (DB-P92-1 &

2)

Strainer Structural Gray Condensation Loss of External Surfaces A 50 Vll.1-11 3.3.1-58 (body) Integrity Cast Iron (External) material Monitoring 0345 Structural Copper Condensation Loss of External Surfaces E 81 Valve Body VII.F1-16 3.3.1-25 Integrity Alloy (External) material Monitoring 0345 Structural Gray cast Condensation Loss of External Surfaces A 86 Valve Body Vll.1-11 3.3.1-58 Integrity Iron (External) material Monitoring 0345

Enclosure L-14-085 Page 26 of 70 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table 3.3.2-14 3.3-313 "Aging Effect Requiring Management" thru 3.3-334 Row 118 changed to "Not Used" In response to the updated guidance regarding the issues of Fire Water System flow blockage and atmospheric storage tanks described in NRC LR-ISG-2012-02, LRA Table 3.3.2-14, "Aging Management Review Results- Fire Protection System," previously revised by FENOC letters dated September 16, 2011 (ML11264A059),

October 7, 2011 (ML11285A064), October 21, 2011 (ML11298A097), November 23, 2011 (ML11335A223) and January 31, 2014, is revised to read as follows:

Table 3.3.2-14 Aging Management Review Results - Fire Protection System NUREG-Aging Effect Aging Row Component Intended 1801, Table 1 Material Environment Requiring Management Notes No. Type Function(s) Volume 2 Item Management Program item Heat Exchanger (channel)-

Loss of Fire Water Pressure Raw water

-- Storage Tank boundary Steel

{Internal) material and Fire Water VII.G-24 3.3.1-68 c Flow blockage Heat Exchanger (DB-E52)

Heat Exchanger (tubes)- Fire Loss of Pressure Stainless Raw water

-- Water Storage boundary Steel (Internal) material and Fire Water VII.G-24 3.3.1-68 c Tank Heat Flow blockage Exchanger (DB-E52)

Enclosure L-14-085 Page 27 of 70 Table 3.3.2-14 Aging Management Review Results - Fire Protection System NUREG-Aging Effect Aging Row Component Intended 1801, Table 1 Material Environment Requiring Management Notes No. Type Function{s) Volume2 Item Management Program Item Heat Exchanger (tubesheet) -

Loss of Fire Water Pressure Raw water

-- Storage Tank boundary Steel (Internal) material and Fire Water VII.G-24 3.3.1-68 c Flow blockage Heat Exchanger (DB-E52)

Loss of Pressure Gray Raw water 31 Hydrant material and Fire Water VII.G-24 3.3.1-68 A boundary Cast Iron (Internal)

Flow blockage Loss of Pressure Raw water 36 Orifice Steel material and Fire Water VII.G-24 3.3.1-68 A boundary (Internal)

Flow blockage Loss of Raw water 38 Orifice Throttling Steel material and Fire Water VII.G-24 3.3.1-68 A (Internal)

Flow blockage Loss of Pressure Copper Raw water 39 Piping material and Fire Water VII.G-12 3.3.1-70 A boundary Alloy (Internal)

Flow blockage Loss of Pressure Gray Raw water 42 Piping material and Fire Water VII.G-24 3.3.1-68 A boundary Cast Iron (Internal)

Flow blockage Loss of Pressure Raw water 54 Piping Steel material and Fire Water VII.G-24 3.3.1-68 A boundary (Internal)

Flow blockage

Enclosure L-14-085 Page 28 of 70 Table 3.3.2-14 Aging Management Review Results- Fire Protection System NUREG-Aging Effect Aging Row Component Intended 1801, Table 1 Material Environment Requiring Management Notes No. Type Function(s) Volume2 Item Management Program Item Loss of Structural Raw water 63 Piping Steel material and Fire Water VII.G-24 3.3.1-68 A integrity (Internal)

Flow blockag_e Pump Casing Loss of

- Electric Fire Pressure Gray Raw water 67 material and Fire Water VII.G-24 3.3.1-68 A Pump (DB-P5- boundary Cast Iron (Internal)

Flow blockag_e 1}

Pump Casing Loss of

- Diesel Fire Pressure Gray Raw water 72 material and Fire Water VII.G-24 3.3.1-68 A Pump (DB-P5- boundary Cast Iron (Internal)

Flow blockag_e 2)

Pump Casing

-Fire Water Loss of Storage Tank Pressure Gray Raw water 74 material and Fire Water VII.G-24 3.3.1-68 A Recirculation boundary Cast Iron (Internal)

Flow blockag_e Pump (DB-P114}

Copper Loss of Pressure Raw water 84 Spray Nozzle Alloy> material and Fire Water VII.G-12 3.3.1-70 A boundary (Internal) 15%Zn Flow blockag_e Copper Loss of Raw water 95 Spray Nozzle Spray Alloy> material and Fire Water VII.G-12 3.3.1-70 A (Internal) 15% Zn Flow blockag_e Copper Loss of Structural Raw water 103 Spray Nozzle Alloy> material and Fire Water VII.G-12 3.3.1-70 A integrity (Internal) 15%Zn Flow blockag_e

Enclosure L-14-085 Page 29 of 70 Table 3.3.2-14 Aging Management Review Results - Fire Protection System NUREG-Aging Effect Aging Row Component Intended 1801, Table 1 Material Environment Requiring Management Notes No. Type Function(s) Volume2 Item Management Program Item Loss of Strainer Pressure Gray Raw water 106 material and Fire Water VII.G-24 3.3.1-68 A (body) boundary Cast Iron (Internal)

Flow blockage Loss of Strainer Pressure Raw water 110 Steel material and Fire Water VII.G-24 3.3.1-68 A (body) boundary (Internal)

Flow blockage Copper Loss of Strainer Raw water 113 Filtration Alloy> material and Fire Water VII.G-12 3.3.1-70 A (screen) (External) 15%Zn Flow blockage Loss of Strainer Stainless Raw water 115 Filtration material and Fire Water VII.G-19 3.3.1-69 A (screen) Steel (External}

Flow blockage Tank- Fire Loss of Water Storage Pressure Raw water 117 Steel material and Fire Water VII.G-24 3.3.1-68 A Tank (DB- boundary (Internal)

Flow blockage T81)

"l=aRk Fire Water Storage TaRk (DB ABO'I8~1:1Rfi Pf8SSI:IF9 Air o1:1t£1oor Loss of ...tlr 118 Steol Stoet ?:aRks Vll.l=l1 11 3.3.1 4()

+8:11 BOI:IRfiary (ExtorRal} material lRSfJOGtiOR 0033 Not Used Loss of Pressure Copper Raw water 126 Tubing material and Fire Water VII.G-12 3.3.1-70 A boundary Alloy (Internal)

Flow blockage

Enclosure L-14-085 Page 30 of70 Table 3.3.2-14 Aging Management Review Results - Fire Protection System NUREG-Aging Effect Aging Row Component Intended 1801, Table 1 Material Environment Requiring Management Notes No. Type Function(s) Volume2 Item Management Program Item Loss of Pressure Raw water 130 Tubing Steel material and Fire Water VII.G-24 3.3.1-68 A boundary (Internal)

Flow blockage Loss of Structural Raw water 134 Tubing Steel material and Fire Water VII.G-24 3.3.1-68 A integrity (Internal)

Flow blockage Loss of Pressure Copper Raw water 138 Valve Body material and Fire Water VII.G-12 3.3.1-70 A boundary Alloy (Internal)

Flow blockage Copper Loss of Pressure Raw water 146 Valve Body Alloy> material and Fire Water VII.G-12 3.3.1-70 A boundary (Internal) 15% Zn Flow blockage Loss of Pressure Gray Raw water 154 Valve Body material and Fire Water VII.G-24 3.3.1-68 A boundary Cast Iron (Internal)

Flow blockage Loss of Pressure Raw water 163 Valve Body Steel material and Fire Water VII.G-24 3.3.1-68 A boundary (Internal)

Flow blockage Loss of Structural Copper Raw water 167 Valve Body material and Fire Water VII.G-12 3.3.1-70 A integrity Alloy (Internal)

Flow blockage Loss of Structural Gray Raw water 170 Valve Body material and Fire Water VII.G-24 3.3.1-68 A integrity Cast Iron (Internal)

Flow blockage

Enclosure L-14-085 Page 31 of 70 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table 3.3.2-15 3.3-346 "Notes" for row 28 One new row In response to the updated guidance regarding the issue of atmospheric storage tanks described in NRC LR-ISG-2012-02, LRA Table 3.3.2-15, "Aging Management Review Results- Fuel Oil System," previously revised by FENOC letters dated April 29, 2011 (ML11126A016), May 24, 2011 (ML11151A090), June 3, 2011 (ML11159A132) and January 31, 2014, is revised to read as follows:

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

Oil Storage Pressure Air-outdoor Loss of 28 Steel Steel Tanks VII.H1-11 3.3.1-40 A Tank (DB- boundary (External) material Inspection 0333 T45)

Tank- Diesel Aboveground Oil Storage Pressure Concrete Loss of G

--- Tank (DB- boundart Steel (Externall material Steel Tanks lns12.ection NA NA 0346 T45l

Enclosure L-14-085 Page 32 of 70 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table 3.3.2-26 3.3-466 "Notes" for rows 16, 33, 57, 65, 122, 134, thru 140 and 147 3.3-482 Two new rows In response to the updated guidance regarding the issues of corrosion under insulation and recurring internal corrosion described in NRC LR-ISG-2012-02, LRA Table 3.3.2-26, "Aging Management Review Results- Service Water System," previously revised by FENOC letters dated April 29, 2011 (ML11126A016), September 16, 2011 (ML11264A059), October 7, 2011 (ML11285A064), March 9, 2012 (ML12094A383) and January 31, 2014, is revised to read as follows:

Table 3.3.2-26 Aging Management Review Results - Service Water System NUREG-Aging Effect Aging Row Component Intended 1801, Table 1 Materia! Environment Requiring Management Notes No. Type Function(s) Volume2 Item Management Program Item Pressure Condensation Loss of 8 16 Bolting Steel Bolting Integrity VII.D-1 3.3.1-44 boundary (External) material 0345 Structural Condensation Loss of 8 33 Bolting Steel Bolting Integrity VII.D-1 3.3.1-44 integrity (External) material 0345 Pressure Condensation Loss of External Surfaces A 57 Piping Steel Vll.l-11 3.3.1-58 boundary (External) material Monitoring 0345 Structural Condensation Loss of External Surfaces A 65 Piping Steel Vll.l-11 3.3.1-58 integrity (External) material Monitoring 0345

Enclosure L-14-085 Page 33 of 70 Table 3.3.2-26 Aging Management Review Results - Service Water System NUREG-Aging Effect Aging Row Component Intended 1801, Table 1 Material Environment Requiring Management Notes No. Type Function(s) Volume2 Item Management Program Item Pressure Gray Condensation Loss of External Surfaces A 122 Valve Body Vll.l-11 3.3.1-58 boundary Cast Iron (External) material Monitoring 0345 Pressure Condensation Loss of External Surfaces A 134 Valve Body Steel Vll.l-11 3.3.1-58 boundary (External} material Monitoring 0345 Structural Gray Condensation Loss of External Surfaces A 140 Valve Body Vll.l-11 3.3.1-58 integrity Cast Iron (External} material Monitoring 0345 Structural Condensation Loss of External Surfaces A 147 Valve Body Steel Vll.l-11 3.3.1-58 integrity (External} material Monitoring 0345 VII.C1.A- 3.3.1-Pressure Raw water Loss of Open-C't_cle 400 127 £

--- Piping boundart Steel (lnternall material Cooling Water (GALL (GALL 0347 R21 R21 VI/.C1.A- 3.3. 1-Structural Raw water Loss of Open-C't_cle 400 127 £

--- Piping integrit't.

Steel (lnternall material Cooling Water (GALL (GALL 0347 R21 R2l

Enclosure L-14-085 Page 34 of 70 Affected LRA Section LRAPage No. Affected Paragraph and Sentence Table 3.3.2 3.3-549 Four new notes Plant-Specific Notes In response to the updated guidance regarding the issues of corrosion under insulation, atmospheric storage tanks and recurring internal corrosion described in NRC LR-ISG-2012-02, four new plant-specific notes are added to LRA Table 3.3.2, "Plant-Specific Notes," previously revised by FENOC letter dated January 31, 2014, to read as follows:

Plant-Specific Notes:

0344 For outdoor insulated comeonents, corrosion under insulation (CUll is managed b'f. the External Surfaces Monitoring Program.

0345 For indoor insulated comeonents exeosed to condensation (because the in-scoee comeonent is oeerated below the dew eointl, corrosion under insulation (CUll is managed b'f. the External Surfaces Monitoring Program.

0346 For storage tanks sue.eorted on earthen or concrete foundations, corrosion ma( occur at inaccessible locations, such as the tank bottom.

0347 Loss of Material due to recurring internal corrosion in the Service Water S'{.stem is managed b'f. the Oeen-C'{.cle Cooling Water Program.

Enclosure L-14-085 Page 35 of 70 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Section 3.4.2.1.2 3.4-3 New (,!Environments" bullet New "Aging Management Programs" bullet In response to the updated guidance regarding the issue of atmospheric storage tanks described in NRC LR-ISG-2012-02, LRA Section 3.4.2.1.2, "Condensate Storage System," is revised to read as follows:

Environments The subject mechanical components of the Condensate Storage System are exposed to the following normal plant operating environments:

Air-indoor uncontrolled

Air with steam and water leakage

Concrete

Moist air

Treated water Aging Management Programs The following aging management programs manage the aging effects for the subject mechanical components of the Condensate Storage System:

Aboveground Steel Tanks Inspection Program

Bolting Integrity Program

External Surfaces Monitoring Program

One-Time Inspection

PWR Water Chemistry Program

Enclosure L-14-085 Page 36 of 70 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Section 3.4.2.2.2.1 3.4-7 2"d sEmtence Last sentence In response to the updated guidance regarding the issue of atmospheric storage tanks described in NRC LR-ISG-2012-02, LRA Section 3.4.2.2.2.1, "Steel Piping, Piping Components, Piping Elements, Tanks, and Heat Exchangers-Treated Water and Steam," is revised to read as follows:

3.4.2.2.2.1 Steel Piping, Piping Components, Piping Elements, Tanks, and Heat Exchangers-Treated Water and Steam Loss of material due to general, pitting and crevice corrosion could occur for steel piping, piping components, piping elements, tanks, and heat exchanger components exposed to treated water and for steel piping, piping components, and piping elements exposed to steam. At Davis-Besse, loss of material due to general, pitting, and crevice corrosion for steel (including gray cast iron) piping, piping components, piping elements, tanks, and heat exchanger components that are exposed to treated water (including steam) is managed by the PWR Water Chemistry Program except for the condensate storage tanks (08- T31-1. -2). that are managed bv the Aboveground Steel Tanks Inspection Program. The PWR Water Chemistry Program manages loss of material through periodic monitoring and control of contaminants. The One-Time Inspection will provide verification of the effectiveness of the PWR Water Chemistry Program to manage loss of material. The Aboveground Steel Tanks Inspection Program manages loss of material through one-time and periodic inspections.

Enclosure L-14-085 Page 37 of70 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table 3.4.1 3.4-15 3.4.1-06 "Discussion" In response to the updated guidance regarding the issue of atmospheric storage tanks described in NRC LR-ISG-2012-02, the "Discussion" column for Item Number 3.4.1-06 in LRA Table 3.4.1, "Summary of Aging Management Programs for Steam and Power Conversion Systems Evaluated in Chapter VIII of NUREG-1801 ," is revised to read as follows:

[continued on next page]

Enclosure L-14-085 Page 38 of 70 Table 3.4.1 Summary of Aging Management Programs for Steam and Power Conversion Systems Evaluated in Chapter VIII of NUREG-1801 Further Item Aging Aging Management Component/Commodity Evaluation Discussion Number Effect/Mechanism Programs Recommended 3.4.1-06 Steel and stainless steel tanks Loss of material Water Chemistry and Yes, detection of Consistent with NUREG-1801.

exposed to treated water due to general One-Time Inspection aging effects is Loss of material due to general, (steel only) pitting to be evaluated pitting, and crevice corrosion in and crevice the steel condensate storage corrosion tanks (DB-T31-1, 2) that are exposed to treated water is managed by the PV'lR Water GRem,i8tfy Aboveground Steel Tanks Inspection Program. +he GRe 'Hme !RSfJeGtieR wi# f3F6'Afie

~r.e#fiGa#-.ieR a~ #:le effeGii~Re88 ef

le PWR Watet: Gl=lemi8tfy Pregr:am te maRa9e .'088 ef matet:ial.

For loss of material for stainless steel tanks that are exposed to treated water, refer to Item Number 3.4.1-16.

Further evaluation is documented in Section 3.4.2.2.2.1.

Enclosure L-14-085 Page 39 of 70 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table 3.4.1 3.4-40 New row In response to the updated guidance regarding the issue of recurring internal corrosion described in NRC LR-ISG-2012-02, a new row is added to LRA Table 3.4.1, "Summary of Aging Management Programs for Steam and Power Conversion Systems Evaluated in Chapter VIII of NUREG-1801 ,"to read as follows:

Table 3.4.1 Summary of Aging Management Programs for Steam and Power Conversion Systems Evaluated in Chapter VIII of NUREG-1801 Further Item Aging Aging Management Component/Commodity Evaluation Discussion Number Effect/Mechanism Programs Recommended 3.4.1-61 Metallic gJQing, QiQing Loss of material A Qlant-sQecific aging Yes, [Note: Item Number 3.4.1-61 is com12onents, and tanks due to recurring management 12rogram Qlant-sQecific from the revision to ex12osed to raw water or waste internal corrosion is to be evaluated to (See Subsection NUREG-1800 (SRP-LRl water address recurring 3.4.2.2.6l identified in LR-ISG-2012-02.[

internal corrosion Not aQQiicable.

Davis-Besse has no in-sco12e com12onents subject to recurring internal corrosion in the steam and f20wer conversion s~stems, therefore the af2f2/icable NUREG-1801 lines from LR-/SG-2012-02 were not used.

Enclosure L-14-085 Page 40 of 70 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table 3.4.2-2 3.4-54 Rows 8, 9 and 10 thru 3.4-56 One new row In response to the updated guidance regarding the issue of atmospheric storage tanks described in NRC LR-ISG-2012-02, LRA Table 3.4.2-2, "Aging Management Review Results- Condensate Storage System,"

previously revised by FENOC letter dated September 16, 2011 (ML11264A059), is revised to read as follows:

Table 3.4.2-2 Aging Management Review Results - Condensate Storage System NUREG-Aging Effect Aging Row Component Intended 1801, Table 1 Material Environment Requiring Management Notes No. Type Function(s) Volume Item Management Program 21tem Aboveground Steel Tanks Tank- /nsQection Condensate Pressure Moist air Loss of IAspestiaA af 8

storage tanks boundary Steel (Internal) material IAteFAal S1:1Ffases NA NA G (DB-T31-1, 2) iA MissellaAea~:~s PipiA§ aAd n,,,..t;..,,..

Tank- Aboveground Condensate Pressure Treated water Loss of Steel Tanks g 9 Steel VIII.E-40 3.4.1-06 storage tanks boundary (Internal) material lnsQection GRe- -A-(DB-T31-1, 2) T;n-"'"1""'

Enclosure L-14-085 Page 41 of 70 Table 3.4.2-2 Aging Management Review Results - Condensate Storage System NUREG-Aging Effect Aging Row Component Intended 1801, Table 1 Material Environment Requiring Management Notes No. Type Function(s) Volume Item Management Program 21tem

+aRk-GeReeRsate staFage taRks PffJSSI::J(f) Treatee water Less ef PWRWater 10 (06 T311, 2) Steel 'IUI.E 4() 3.4.1 ()) -A-13mmeary (.If! terRal) material Ghemistry Not Used Tank-Aboveground Condensate Pressure Concrete Loss of G

--- storage tanks boundar'{.

Steel (Externall material Steel Tanks NA NA 0416 lns{lection (08-T31-1 2)

Enclosure L-14-085 Page 42 of 70 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table 3.4.2 3.4-111 New note Plant-Specific Notes In response to the updated guidance regarding the issue of atmospheric storage tanks described in NRC LR-ISG-2012-02, a new plant-specific note is added to LRA Table 3.4.2, "Plant-Specific Notes," previously revised by FENOC letter October 31, 2011 (ML11306A066), to read as follows:

Plant-Specific Notes:

0416 For storage tanks supported on earthen or concrete foundations. corrosion mav occur at inaccessible locations. such as the tank bottom.

Enclosure L-14~085 Page 43 of 70 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Section A.1.2 A-10 Entire Section In response to the updated guidance regarding the issue of atmospheric storage tanks described in NRC LR-ISG-2012-02, LRA Section A.1.2, "Aboveground Steel Tanks Inspection Program," previously revised by FENOC letters dated May 24, 2011 (ML11151A090), and July 22, 2011 (ML11208C274 ), is replaced in its entirety to read as follows:

A.1.2 Aboveground Steel Tanks Inspection Program The Aboveground Steel Tanks Inspection Program manages the effects of loss of material and cracking on the outside and inside surfaces of aboveground tanks constructed on concrete or soil. Tanks included in the program are the steel diesel fuel oil storage tank (outdoor tank) and the stainless steel borated water storage tank (outdoor tank) and the steel condensate storage tanks (indoor tanks). If the tank exterior is fully visible, the tank's outside surfaces may be inspected under the program for inspection of external surfaces (GALL Report AMP XI.M36) for visual inspections recommended in this AMP; surface examinations are conducted in accordance with the recommendations of this AMP. This program credits the standard industry practice of coating or painting the external surfaces of steel tanks as a preventive measure to mitigate corrosion. The program relies on periodic inspections to monitor degradation of the protective paint or coating. Tank inside surfaces are inspected by visual or surface examinations as required to detect applicable aging effects.

For storage tanks supported on earthen or concrete foundations. corrosion may occur at inaccessible locations. such as the tank bottom. AccordinglY. verification of the effectiveness of the program is performed to ensure that significant degradation in inaccessible locations is not occurring and that the component's intended function is maintained during the period of extended operation. An acceptable verification program consists of thickness measurements of the tank bottom surface.

The Aboveground Steel Tanks Inspection Program includes preventive measures to mitigate corrosion by protecting the external surface of steel components per standard industrv practice and with sealant or caulking at the interface of concrete and the diesel fuel oil storage tank. The Aboveground Steel Tanks Inspection Program is a condition monitoring program that consists of periodic visual inspections of tank external surfaces, and volumetric examinations of tank

Enclosure L-14-085 Page 44 of 70 bottoms. Additional opportunistic tank bottom inspections will be performed whenever the tanks are drained. The tank bottom inspections will verify the effectiveness of the program bv measuring the thickness of the tank bottoms to ensure that significant degradation is not occurring.

Tank inspections are conducted in accordance with Table 4a. "Tank Inspection Recommendations." of License Renewal Interim Staff Guidance (LR-ISG)

LR-ISG-2012-02.

Enclosure L-14~085 Page 45 of 70 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Section A.1.15 A-14 2"d paragraph, 4th sentence New 3rd paragraph In response to the updated guidance regarding the issue of corrosion under insulation described in NRC LR-ISG-2012-02, LRA Section A.1.15, "External Surfaces Monitoring Program," previously revised by FENOC letter dated August 17, 2011 (ML11231A966), is revised to read as follows:

The External Surfaces Monitoring Program is a condition monitoring program that consists of periodic visual inspections and surveillance activities of component external surfaces to manage cracking and loss of material. The program includes components located in plant systems within the scope of license renewal that are constructed of aluminum, copper alloy (copper, brass, bronze, and copper-nickel), stainless steel (including CASS), and steel (carbon and low-alloy steel and cast iron) materials. Cracking and loss of material from the external surfaces of these metals will be evidenced by surface irregularities, leakage, or localized discoloration and be detectable prior to loss of intended function. Surfaces that are inaccessible or not readily visible during either normal plant operations or refueling outages, such as surfaces that are fnsu!ated, are inspected opportunistically during the period of extended operation. Surfaces that are accessible are inspected at a frequency not to exceed one refueling cycle.

System inspection and walkdown documentation includes inspection parameters and acceptance criteria for polymers, elastomers and metallic components as applicable. This documentation is retained in plant records.

Outdoor insulated components. and indoor insulated components exposed to condensation (because the in-scope component is operated below the dew point). have portions of the insulation inspected or removed to determine whether the exterior surface of the component is degrading or has the potential to degrade. A minimum of 20 percent of the in-scope piping length. or 20 percent of the surface area for components whose configuration does not conform to a 1-foot axial length determination (e.g., valve. accumulator). is inspected after the insulation is removed. Alternatively any combination of a minimum of 25 1-foot axial length sections and components for each material tvpe is inspected.

Inspection locations should focus on the bounding or lead components most susceptible to aging because of time in service. severity of operating conditions (e.g.. amount of time that condensate would be present on the external surfaces of the component). and lowest design margin. The inspections will be conducted

Enclosure L-14-085 Page 46 of 70 during each 10-year period of the PEO. The following are alternatives to removing insulation:

a. Subsequent inspections may consist of examination of the exterior surface of the insulation with sufficient acuity to detect indications of damage to the jacketing or protective outer layer of the insulation when the results of the initial inspection meet the following criteria:

i. No loss of material due to general. pitting. or crevice corrosion. beyond that which could have been present during initial construction is observed. and ii. No evidence of SCC is observed.

If the external visual inspections of the insulation reveal damage to the exterior surface of the insulation or jacketing. or there is evidence of water intrusion through the insulation (e.g.. water seepage through insulation seams/joints). periodic inspections under the insulation should continue as conducted for the initial inspection.

b. Removal of tightly adhering insulation that is impermeable to moisture is not required unless there is evidence of damage to the moisture barrier. If the moisture barrier is intact. the likelihood of corrosion under insulation (CUI) is low for tightly adhering insulation. Tightly adhering insulation is considered to be a separate population from the remainder of insulation installed on in-scope components. The entire population of in-scope piping that has tightly adhering insulation is visually inspected for damage to the moisture barrier with the same frequency as for other tvges of insulation inspections. These inspections are not credited towards the inspection quantities for other types of insulation.

Enclosure L-14-085 Page 47 of 70 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Section A.1.18 A-15 Entire section In response to the updated guidance regarding the issue of Fire Water System flow blockage described in NRC LR-ISG-2012-02, LRA Section A.1.18, "Fire Water Program," is revised in its entirety to read as follows:

A.1.18 Fire Water Program The Fire Water Program (a sub-program of the overall Fire Protection Program) is an existing program that applies to the fire water supply and water-based suppression systems. which include sprinklers, nozzles. fittings, valve bodies. fire pump casings. hydrants. hose stations. standpipes. a water storage tank. and aboveground. buried and underground piping and components. This program is a condition monitoring program.

The Fire Water Program manages loss of material due to corrosion. including MIG. fouling. and flow blockage because of fouling. This program manages the aging effects through the use of flow testing and visual inspections performed in accordance with the 2011 Edition of NFPA 25. Testing or replacement of sprinklers that have been in place for 50 years is performed in accordance with the 2011 Edition of NFPA 25. In addition to NFPA codes and standards. portions of the water-based fire protection system that are: (a) normally dry but periodically subjected to flow (e.g., dry-pipe or preaction sprinkler system components) and (b) cannot be drained or allow water to collect are to be subjected to augmented testing beyond that specified in NFPA 25. including: (a) periodic full flow tests at the design pressure and flow rate or internal visual inspections and (b) volumetric wall-thickness examinations. Flow testing and visual inspections are performed at intervals specified in the 2011 Edition of NFPA 25. The water-based fire protection system is normally maintained at required operating pressure and is monitored such that loss of system pressure is immediately detected and corrective actions initiated.

Enclosure L-14-085 Page 48 of 70 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Section A.1.41 A-50 4th paragraph In response to the updated guidance regarding the issue of periodic inspections of internal surfaces described in NRC LR-ISG-2012-02, the 41h paragraph of LRA Section A.1.41, "Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Program," previously revised by FENOC letter dated August 17, 2011 (ML11231A966), is revised to read as follows:

The Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Program includes opportunistic inspections, when components are opened for maintenance, repair, or surveillance to ensure that the existing environmental conditions are not causing material degradation that could result in a loss of component intended function during the period of extended operation. At a minimum. in each 10-year period during the period of extended operation. a representative sample of 20 percent of the population (defined as components having the same material, environment. and aging effect combination) or a maximum of 25 components per population is inspected. Where practical, the inspection includes a representative sample of the system population and focuses on the bounding or lead components most susceptible to aging because of time in service and severity of the operating conditions. This minimum sample size does not override the opportunistic basis of this aging management program.

Enclosure L-14-085 Page 49 of 70 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table A-1 A-55 Commitment No. 1 - new enhancement In response to the updated guidance regarding the issue of atmospheric storage tanks described in NRC LR-ISG-2012-02, LRA Table A-1, "Davis-Besse License Renewal Commitments," license renewal future Commitment No. 1, previously revised by FENOC letters dated May 24, 2011 (ML11151A090 ), and April 19, 2013 (ML13114A254), is revised to include a new enhancement, as follows:

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

Number Schedule Comments 1I Enhance the Aboveground Steel Tanks Inspection Program to: Prior to LRA A.1.2 October 22, 2016

Include tank inse.ections conducted in accordance with 8.2.2 Table 4a, "Tank lnse.ection Recommendations," of License and and Renewal Interim Staff Guidance LR-ISG-2012-02, "Aging Management of Internal Surfaces, Fire Water S't,stems, FENOC Responses to Atmose.heric Storage Tanks, and Corrosion Under Insulation." Letters NRCRAis L-11-153, 8.2.2-1 from aRfi NRC Letter L-13-160 dated and April20, 2011, L-14-085 aRfi A.1-1 from NRC Letter dated

Enclosure L-14-085 Page 50 of 70 Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Implementation Commitment Source Section No./

Number Schedule Comments March 26, 2013...

and NRC LR-ISG-2012-02

Enclosure L-14-085 Page 51 of 70 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table A-1 A-58 Commitment No. 8 - new enhancement In response to the updated guidance regarding the issue of corrosion under insulation described in NRC LR-ISG-2012-02, LRA Table A-1, "Davis-Besse License Renewal Commitments," license renewal future Commitment No.8, previously revised by FENOC letters dated August 17, 2011 (ML11231A966) and April19, 2013 (ML13114A254), is revised to include a new enhancement as follows:

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

Number Schedule Comments 8 Enhance the External Surfaces Monitoring Program to: Prior to LRA A.1.15 October 22, 2016

lns{2ect or remove {20rtions of insulation from outdoor 8.2.15 insulated com{2onents, and indoor insulated com{2onents and and ex{2osed to condensation (because the in-sco{2e com{2onent is o{2erated below the dew {2ointl, to determine whether the FENOC Responses to exterior surface of the com{2onent is degrading or has the Letters NRC RAts

{20tentia/ to degrade. lns{2ect a minimum of 20 {2ercent of the L-11-153, 3.3.2.2.5-1 and in-sco{2e l2.il2.ing length, or 20 {2ercent of the surface area for L-11-166, 8.2.2-2 from com{2onents whose configuration does not conform to a L-11-238._ NRC Letter 1-foot axial length determination (e.g., valve, accumulatorl, aRfi dated after the insulation is removed. Alternativel't. an'(. combination L-13-160 April 20, 2011, of a minimum of 25 1-foot axial length sections and and 3.3.2-2 from com{2onents for each material t't.l2e is ins{2ected. lns{2ection L-14-085 NRC Letter locations should focus on the bounding or lead com{2onents dated most susceotible to aaina because of time in service

Enclosure L-14-085 Page 52 of 70 Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Implementation Commitment Source Section No./

Number Schedule Comments severit't.. of oe.erating conditions (e. g., amount of time that May 2, 2011, condensate would be e.resent on the external surfaces of the 3.3.2.2.5-2 from come.onentl, and lowest design margin. The inse.ections will NRC Letter be conducted during each 10-'t_ear e.eriod of the PEO. The dated following are alternatives to removing insulation:

July 12, 2011,

a. Subsequent inse.ections ma't_ consist of examination of Supplemental the exterior surface of the insulation with sufficient acuit't..

RAJ 0/N-352 to detect indications of damage to the jacketing or from e.rotective outer /a't_er of the insulation when the results NRC Region Ill of the initial inse.ection meet the following criteria:

/P-71002

i. No Joss of material due to general, e.itting, or Inspection, crevice corrosion, be't_ond that which could have aRfi been e.resent during initial construction is A.1-1 from observed, and NRC Letter ii. No evidence of SCC is observed. dated March 26, If the external visual inse.ections of the insulation reveal 2013L damage to the exterior surface of the insulation or jacketing, or there is evidence of water intrusion through and the insulation (e.g., water seee.age through insulation NRC LR-JSG-seams/jointsl, e.eriodic inse.ections under the insulation 2012-02 should continue as conducted for the initial inse.ection.

b. Removal of tight/"{_ adhering insulation that is im_Q_ermeable to moisture is not reauired unless there is

Enclosure L-14-085 Page 53 of 70 Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Implementation Commitment Source Section No./

Number Schedule Comments evidence of damage to the moisture barrier. If the moisture barrier is intact, the likelihood of corrosion under insulation (CUll is low for tightl't. adhering insulation. Tightl't. adhering insulation is considered to be a se12.arate l2.0l2.ulation from the remainder of insulation installed on in-sco12.e com12.onents. The entire l2.012.Uiation of in-sco12.e 12.i12.ing that has tightl't. adhering insulation is visuall't. ins12.ected for damage to the moisture barrier with the same freg_uenc't. as for other t'{Qes of insulation ins12.ections. These ins12.ections are not credited towards the ins12.ection quantities for other t't.12.es of insulation.

Enclosure L-14-085 Page 54 of70 Affected LRA Section LRAPage No. Affected Paragraph and Sentence Table A-1 A-55 Commitment No. 10 In response to the updated guidance regarding the issue of Fire Water System flow blockage described in NRC LR-ISG-2012-02, LRA Table A-1, "Davis-Besse License Renewal Commitments," license renewal future Commitment No. 10, previously revised by FENOC letter dated April 19, 2013 (ML13114A254), is revised to read as follows:

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

Number Schedule Comments 10 Enhance the Fire Water Program to: Prior to LRA A.1.18 October 22, 2016

,QeFferFR perteEiiG uft..o;aseRiG tes#Rg f&.c w.a,l.l thiskRess of 8.2.18 repffJseRtaU*Je abov-e groumi water SI:Jf3f3f8SsioR pipiRg tl=lat is and and Rot periofiisa#.y flew tested b~:~t GORtaiRs, Sf /=las GORtaiRed, stagRaRt water. The IJ!t.o;asoRiG testiRg witt be peFferFROd (3fio,c to FENOC Response§. to the pe#od of. e*eRded Of30FatiOR aRd at 8f3(3F6(3ffato iRto,o,ta.fs Letter§. NRCRAI theffJaf:t.o,c, based OR eRgiReefi.Rg evaf.I:JatioR of. the iRitia,l ffJ&I:f!.ts. L-13-160 A.1-1 from and NRC Letter

PerforFR at /east ORO Of3f30rWRiStiG Of foGI:JSOd 'riS!Ja.l iRSf30GtiOR L-14-085 dated of. the iRtefRal s~:~Ffase of. bl:f.cied fire wate,c pipiRg aRd of. siFRi.Jar March 26, 2013 abov-e fJFeiJRd fi..ce watef pipiRg, v,,tthiR the fi'ro yea,c pe,o:.Jod (3Fio,o:

to tho pe,ctod of. o*eRded Of30ratioR, to GORfi.."FR w.l=lethor and GORfiitiORS OR tho iRtemat SIJFfaGO Of. ab0 11-fJ f}COIJRd fiffJ watef NRC LR-ISG-pipiRfj GaR be O~apolated to be iRfiiGaf..i'rO Of. GORfiitiOR6 OR tho 2012-02 iRte,o:.Ra.l SIJFfaGO of. b!JfiOd fire watef pipiRfj.

Enclosure L-14-085 Page 55 of 70 Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Implementation Commitment Source Section No./

Number Schedule Comments

Include inse.ections and testing conducted in accordance with Ae.e.endix D, Table 4a, "Fire Water S"t,stem lnse.ection and Testing Recommendations," of License Renewal Interim Staff Guidance LR-ISG-2012-02, "Aging Management of Internal Surfaces, Fire Water S"t,stems, Atmose.heric Storage Tanks, and Corrosion Under Insulation."

Include augmented testing and inse.ections be"t,ond those of Table 4a for e.ortions of water-based fire e.rotection S"t,stem come.onents that are (al normall't. dr"t, but e.eriodicall"t, subjected to flow (e.g., dr"t,-e.ie.e or e.reaction se.rinkler S'f.Stem come.onentsl and (bl cannot be drained or allow water to collect:

1. In each 5-'t,ear interval, beginning 5 "t,ears e.rior to the e.eriod of extended oe.eration, a flow test or flush sufficient to detect e.otential flow blockage will be conducted, or a visual inse.ection of 100 e.ercent of the internal surface of e.ie.ing segments will be conducted.

2. In each 5-"t,ear interval of the e.eriod of extended oe.eration, 20 e.ercent of the length of e.ie.ing segments that cannot be drained or e.ie.ing segments that allow water to collect will be subject to volumetric wall thickness inse.ections.

Measurement e.oints are obtained to the extent that each e.otential degraded condition can be identified (e.g., general corrosion, MICl. The 20 e.ercent of e.ie.ing that is inse.ected in each 5-vear interval will be in different locations than

Enclosure L-14-085 Page 56 of 70 Table A-1 Davis-Besse License Renewal Commitments Related LRA Item Implementation Commitment Source Section No./

Number Schedule Comments previously inspected piping.

If the results of a 100-percent internal visual inspection are acceptable, and the segment is not subsequent/'{_ wetted, no further augmented tests or inspections are necessar'{_.

Perform representative sprinkler head sampling (laboratory field service testing) or replacement prior to 50 years in-service (installed), and at 10-year intervals thereafter, in accordance with the 2011 Edition of NFPA 25, or until there are no untested sprinkler heads that will see 50 years of service through the end of the period of extended operation.

P.eFfafFR 9f313eFh:IRis#G fi,-:e viatef S1:1Pf3f.y- amJ wate,o:. eased SI:IP(3fessieR system tRiema,l fRSf3eG#eRs eaGR l-ome a fi..-:e wateF Sl::lf3f3*'7'- e,o:. wale,..:. eased S1:1Pf3.<:essteR system fjRGJI::Jfi.iRg fiFe pl:lmps} ts e.-:eas-Refi. fe,o:. fe13aif e.,o:. matRieRaRGe. :r::Rese iRie,o:.Ra!

P.4SI:Jat iRSf3eG#eRS FRI:JSI ee fi.emeRsl-.o:.atefi. te ee: ~~

repfeseRia#ve et wateJ= S1:1Pf3*'7'- aRfi. walef easefi. si:IP(3.<:essieR

,(esa#eRs, 2-) peffafmefi. eRa FeaseRaete easis (fFeffi:JeRGy}, aRfi.

3} sapae.<e et e"t~ati:JatiRg wa# IRiskRess aRfi. flew sapaei-!ity.. It IRe iRtefRal fRSf3eG#eRS GaRRel ee Gemp,lelefi. eta Fepf6SeRia#w:J sampte, IReR wtfaseRiG tes#Rg fRSf3eGtieRS w#,( ee I:JSefi. te semptele IRe rep.o:.eseRiativ-e sampte.

Enclosure L-14-085 Page 57 of 70 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Table B-2 B-18 "Aboveground Steel Tanks Inspection Program" row In response to the updated guidance regarding the issue of atmospheric storage tanks described in NRC LR-ISG-2012-02, LRA Table B-2, "Consistency of Davis-Besse Aging Management Programs with NUREG-1801 ,"for the "Aboveground Steel Tanks Inspection Program," previously revised by FENOC letter dated May 24, 2011 (ML11151A090), is revised to read as follows:

Table B-2 Consistency of Davis-Besse Aging Management Programs with NUREG-1801 (continued)

Consistent Consistent with New/ with Plant- Enhancement Program Name NUREG-Existing NUREG- Specific Required 1801 with 1801 Exceptions Aboveground Steel Tanks Inspection -¥eB Program Existing Yes

-- -- Yes Section 8.2.2

Enclosure L-14-085 Page 58 of 70 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Section 8.2.2 B-25 Entire section In response to the updated guidance regarding the issue of atmospheric storage tanks described in NRC LR-ISG-2012-02, LRA Section 8.2.2, "Aboveground Steel Tanks Inspection Program," previously revised by FENOC letter dated May 24, 2011 (ML11151A090), is replaced in its entirety to read as follows:

8.2.2 ABOVEGROUND STEEL TANKS INSPECTION PROGRAM Program Description The Aboveground Steel Tanks Inspection Program manages the effects of Joss of material and cracking on the outside and inside surfaces of aboveground tanks constructed on concrete or soil. Tanks included in the program are the steel diesel fuel oil storage tank (outdoor tank) and the stainless steel borated water storage tank (outdoor tank) and the steel condensate storage tanks (indoor tanks). If the tank exterior is fullv visible, the tank's outside surfaces mav be inspected under the program for inspection of external surfaces (GALL Report AMP XI.M36) for visual inspections recommended in this aging management program: surface examinations are conducted in accordance with the recommendations of this AMP. This program credits the standard industry practice of coating or painting the external surfaces of steel tanks as a preventive measure to mitigate corrosion. The program relies on periodic inspections to monitor degradation of the protective paint or coating. Tank inside surfaces are inspected by visual or surface examinations as required to detect applicable aging effects.

For storage tanks supported on earthen or concrete foundations, corrosion mav occur at inaccessible locations, such as the tank bottom. AccordinglY. verification of the effectiveness of the program is performed to ensure that significant degradation in inaccessible locations is not occurring and that the component's intended function is maintained during the period of extended operation. An acceptable verification program consists of thickness measurements of the tank bottom surface.

The Aboveground Steel Tanks Inspection Proqram includes preventive measures to mitigate corrosion by protecting the external surface of steel components per standard industrv practice and with sealant or caulking at the interface of concrete and the diesel fuel oil storage tank. The Aboveground Steel Tanks

Enclosure L-14-085 Page 59 of 70 Inspection Program is a condition monitoring program that consists of periodic visual inspections of tank external surfaces. and volumetric examinations of tank bottoms. Additional opportunistic tank bottom inspections will be performed whenever the tanks are drained. The tank bottom inspections will verifv the effectiveness of the program by measuring the thickness of the tank bottoms to ensure that significant degradation is not occurring.

NUREG-1801 Consistency The Aboveground Steel Tanks Inspection Program is an existing Davis-Besse program that, with enhancement. will be consistent with the 10 elements of an effective aging management program as described in NUREG-1801,Section XI.M29. Aboveground Metallic Tanks." as revised by License Renewal Interim Staff Guidance (LR-ISG) LR-ISG-2012-02.

Exceptions to NUREG-1801:

None.

Enhancements:

The following enhancements will be implemented in the identified program elements prior to the period of extended operation:

Parameters Monitored or Inspected. Detection of Aging Effects. and Acceptance Criteria Include tank inspections conducted in accordance with Table 4a, "Tank Inspection Recommendations. " of License Renewal Interim Staff Guidance LR-ISG-2012-02.

Include a volumetric examination of tank bottoms to detect evidence of loss of material due to crevice. general, or pitting corrosion. or to confirm a lack thereof. The enhancement will include establishing the examination technique. the inspection locations, and the acceptance criteria for the examination of the tank bottoms. Unacceptable inspection results will be entered into the Corrective Action Program. Additional opportunistic tank bottom inspections will be performed whenever the tanks are drained.

Operating Experience The Aboveground Steel Tanks Inspection Program is an ongoing program for which plant operating experience has shown the system walkdowns to effectively manage the effects of corrosion on the external surfaces of the diesel fuel oil

Enclosure L-14-085 Page 60 of 70 storage tank. The visual inspection methods are consistent with accepted industry practices.

The system walkdown activities have identified numerous cases of paint degradation. including flaking. blistering. peeling. and chipping throughout the plant. This confirms that the visual inspections are capable of detecting the condition of painted surfaces. No cases of corrosion degradation specific to the tank exterior surfaces were identified.

In 2002. an inspection of the exterior of the diesel fuel oil storage tank revealed rust and corrosion at the base flange of the tank and corroded bolts at the lower access plate at the base of the tank. The work order system was used to address painting and preservation of the corroded areas of the tank.

In 2012. during a preventive maintenance task. it was discovered that there was no visible moisture barrier between the bottom of the diesel fuel oil storage tank and the concrete support pad for the tank. Also. areas of corrosion were discovered on the external horizontal flange at the bottom of the tank. The preventive maintenance task included an ultrasonic test (UT) examination of the tank bottom. A work order was created to install a moisture barrier at the base of the diesel fuel oil storage tank. Sand blasting was performed on the tank bottom flange, bottom to shell weld. and the concrete pad around the flange to remove the corrosion from the tank external flange and prepare the surfaces for priming.

An industrial primer and joint sealant were applied according to the manufacturer's instructions and FENOC procedures. coating the bottom to shell weld. the tank bottom flange. the gap between the tank bottom flange and the concrete pad. and the concrete pad several inches beyond the edge of the bottom flange. The sealant installation was completed on December 13, 2012. In addition. an internal inspection of the tank was performed to measure the remaining bottom plate thickness of the diesel fuel oil storage tank. The nominal thickness of the tank floor was 0. 250 inches. The results of the UT readings showed that the average minimum measured bottom thickness was 0.247 inches. The minimum measured bottom thickness was 0.244 inches. There were no UT examination runs where plate thinning of 10 percent or greater was observed during the inspection. A description of this operating experience was submitted to the NRC by FENOC letter dated December 20. 2012 (ML12361A2550).

A review did not identify any plant-specific operating experience related to the effects of corrosion on the BWST or on the condensate storage tanks.

Enclosure L-14-085 Page 61 of 70 Conclusion The Aboveground Steel Tanks Inspection Program has been demonstrated to be capable of managing loss of material for the accessible external surfaces of the borated water storage tank. the condensate storage tanks. and the diesel fuel oil storage tank. The continued implementation of the Aboveground Steel Tanks Inspection Program. with enhancement. provides reasonable assurance that the effects of aging will be managed such that the tanks will continue to perform their intended function consistent with the current licensing basis for the period of extended operation.

Enclosure L-14-085 Page 62 of 70 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Section 8.2.15 B-72 and B-73 Program Description, 2"d paragraph NURIEG-1801 Consistency Enhancements - "Scope of Program" and "Detection of Aging Effects" In response to the updated guidance regarding the issue of corrosion under insulation described in NRC LR-ISG-2012-02, the "Program Description,"

"NUREG-1801 Consistency" and "Enhancements" subsections of LRA Section 8.2.15, "External Surfaces Monitoring Program," previously revised by FENOC letter dated August 17, 2011 (ML11231A966), are revised to read as follows:

Program Description The External Surfaces Monitoring Program manages the aging of external surfaces, and internal surfaces in cases where environment is the same, of mechanical components within the scope of license renewal.

The External Surfaces Monitoring Program is a condition monitoring program that consists of periodic visual inspections and surveillance activities of component external surfaces to manage cracking and loss of material. The program includes components located in plant systems within the scope of license renewal that are constructed of aluminum, copper alloy (copper, brass, bronze, and copper-nickel), stainless steel (including CASS), and steel (carbon and low-alloy steel and cast iron) materials. Cracking and loss of material from the external surfaces of these metals will be evidenced by surface irregularities, leakage, or localized discoloration and be detectable prior to loss of intended function. Surfaces that are inaccessible or not readily visible during either normal plant operations or refueling outages, st:Jeh as st:Jrfaeos that aro inst:J!atod, will be inspected opportunistically during the period of extended operation. Surfaces that are accessible will be inspected at a frequency not to exceed one refueling cycle.

Outdoor insulated components. and indoor insulated components exposed to condensation (because the in-scope component is operated below the dew point). have portions of the insulation inspected or removed to determine whether the exterior surface of the component is degrading or has the potential to degrade. System inspection and walkdown documentation will include inspection parameters and acceptance criteria for polymers, elastomers and metallic components as applicable. This documentation will be retained in plant records.

Enclosure L~14~085 Page 63 of 70 NUREG-1801 Consistency The External Surfaces Monitoring Program is an existing Davis-Besse program that, with enhancement, will be consistent with the ten elements of an effective aging management program as described in NUREG-1801,Section XI.M36, "External Surfaces Monitoring of Mechanical Components." as revised by License Renewal Interim Staff Guidance (LR-ISG) LR-ISG-2012-02.

Enhancements:

The following enhancements will be implemented in the identified program elements prior to the period of extended operation.

Scope of Program Systems that credit the External Surfaces Monitoring Program for license renewal but which do not have Maintenance Rule intended functions will be added to the scope of the program.

Outdoor insulated components. and indoor insulated components exposed to condensation (because the in-scope component is operated below the dew point). have portions of the insulation inspected or removed to determine whether the exterior surface of the component is degrading or has the potential to degrade.

Detection of Aging Effects Surfaces that are inaccessible or not readily visible during either normal plant operations or refueling outages, such as surfaces that are insulated, will be inspected opportunistically during the period of extended operation.

Surfaces that are accessible will be inspected at a frequency not to exceed one refueling cycle.

Outdoor insulated components. and indoor insulated components exposed to condensation (because the in-scope component is operated below the dew point). have portions of the insulation inspected or removed to determine whether the exterior surface of the component is degrading or has the potential to degrade. A minimum of 20 percent of the in-scope piping length. or 20 percent of the surface area for components whose configuration does not conform to a 1-foot axial length determination (e.g..

valve. accumulator). is inspected after the insulation is removed.

Alternatively any combination of a minimum of 25 1-foot axial length sections and components for each material type is inspected. Inspection locations should focus on the bounding or lead components most

Enclosure L-14-085 Page 64 of 70 susceptible to aaina because of time in service, severity of operating conditions (e.g., amount of time that condensate would be present on the external surfaces of the component). and lowest design margin. The inspections will be conducted during each 10-year period of the PEO. The following are alternatives to removing insulation:

a. Subsequent inspections may consist of examination of the exterior surface of the insulation with sufficient acuity to detect indications of damage to the jacketing or protective outer layer of the insulation when the results of the initial inspection meet the following criteria:

i. No loss of material due to general. pitting, or crevice corrosion.

beyond that which could have been present during initial construction is observed, and ii. No evidence of SCC is observed.

If the external visual inspections of the insulation reveal damage to the exterior surface of the insulation or jacketing, or there is evidence of water intrusion through the insulation (e.g., water seepage through insulation seams/joints). periodic inspections under the insulation should continue as conducted for the initial inspection.

b. Removal of tightly adhering insulation that is impermeable to moisture is not required unless there is evidence of damage to the moisture barrier. If the moisture barrier is intact, the likelihood of corrosion under insulation (CUI) is low for tightly adhering insulation. Tightly adhering insulation is considered to be a separate population from the remainder of insulation installed on in-scope components. The entire population of in-scope piping that has tightly adhering insulation is visually inspected for damage to the moisture barrier with the same frequency as for other types of insulation inspections. These inspections are not credited towards the inspection quantities for other types of insulation.

Enclosure L-14-085 Page 65 of 70 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Section 8.2.18 B-81 and B-82 Program Description, 2"d paragraph NURIEG-1801 Consistency Enhancements - "Detection of Aging Effects" In response to the updated guidance regarding the issue of Fire Water System flow blockage described in NRC LR-ISG-2012-02, the "Program Description,"

"NUREG-1801 Consistency" and "Enhancements"- "Detection of Aging Effects" subsections of LRA Section 8.2.18, "Fire Water Program," are replaced in their entirety, to read as follows:

Program Description The Fire Water Program (a sub-program of the overall Fire Protection Program}

is an existing program that applies to the fire water supply and water-based suppression systems. which include sprinklers. nozzles. fittings. valve bodies. fire pump casings. hydrants. hose stations. standpipes. a water storage tank. and aboveground. buried and underground piping and components. The Fire Water Program is a condition monitoring program that comprises tests and inspections in accordance with applicable National Fire Protection Association (NFPA) codes and standards.

The Fire Water Program manages Joss of material due to corrosion. including MIG. fouling, and flow blockage because of fouling. This program manages the aging effects through the use of flow testing and visual inspections performed in accordance with the 2011 Edition of NFPA 25. Testing or replacement of sprinklers that have been in place for 50 vears is performed in accordance with the 2011 Edition of NFPA 25. In addition to NFPA codes and standards. portions of the water-based fire protection system that are: (a} normally drv but periodically subjected to flow (e.g., dry-pipe or preaction sprinkler system components) and {b) cannot be drained or allow water to collect are to be subjected to augmented testing beyond that specified in NFPA 25. including: (a) periodic full flow tests at the design pressure and flow rate or internal visual inspections and (b) volumetric wall-thickness examinations. Flow testing and visual inspections are performed at intervals specified in the 2011 Edition of NFPA 25. The water-based fire protection system is normally maintained at

Enclosure L-14-085 Page 66 of 70 required operating pressure and is monitored such that loss of system pressure is immediately detected and corrective actions initiated.

NUREG-1801 Consistency The Fire Water Program is an existing Davis-Besse program that. with enhancement. will be consistent with the ten elements of an effective aging management program as described in NUREG-1801.Section XI.M27, "Fire Water System." as revised by License Renewal Interim Staff Guidance (LR-ISG)

LR-ISG-2012-02.

Enhancements:

The following enhancements will be implemented in the identified program elements prior to the period of extended operation.

Detection of Aging Effects The program will be enhanced to include inspections and testing conducted in accordance with Appendix D. Table 4a. "Fire Water System Inspection and Testing Recommendations." of License Renewal Interim Staff Guidance LR-ISG-2012-02.

The program will be enhanced to include augmented testing and inspections beyond those of Table 4a for portions of water-based fire protection system components that are (a) normally dry but periodically subjected to flow (e.g., dry-pipe or preaction sprinkler system components) and (b) cannot be drained or allow water to collect:

1. In each 5-year interval. beginning 5 years prior to the period of extended operation. a flow test or flush sufficient to detect potential flow blockage will be conducted. or a visual inspection of 100 percent of the internal surface of piping segments will be conducted.

2. In each 5-year interval of the period of extended operation, 20 percent of the length of piping segments that cannot be drained or piping segments that allow water to collect is subject to volumetric wall thickness inspections. Measurement points are obtained to the extent that each potential degraded condition can be identified (e.g .. general corrosion. MIG). The 20 percent of piping that is inspected in each 5-year interval will be in different locations than previously inspected piping.

Enclosure L-14-085 Page 67 of 70 If the results of a 1DO-percent internal visual inspection are acceptable.

and the segment is not subsequently wetted. no further augmented tests or inspections are necessary.

The program will be enhanced to perform representative sprinkler head sampling Oaboratorv field service testing) or replacement prior to 50 years in-service (installed). and at 10-year intervals thereafter. in accordance with the 2011 Edition of NFPA 25. or until there are no untested sprinkler heads that will see 50 years of service through the end of the period of extended operation.

Enclosure L-14-085 Page 68 of 70 Affected LRA Section LRA Page No. Affected Paragraph and Sentence Section 8.2.41 B-81 and B-82 Program Description, 4th and 6th paragraphs Scope, 2"d paragraph Detection of Aging Effects (all)

Monitoring and Trending (all)

In response to the updated guidance regarding the issue of periodic inspections of internal surfaces described in NRC LR-ISG--2012-02, the "Program Description," "Scope," "Detection of Aging Effects" and "Monitoring and Trending" subsections of LRA Section 8.2.41, "Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Program," previously revised by FENOC letters dated May 24, 2011 (ML11151A090), June 3, 2011 (ML11159A132), and August 17, 2011 (ML11231A966), are revised to read as follows:

Program Description [4th paragraph]

The Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Program will include opportunistic inspections, when components are opened for maintenance, repair, or surveillance to ensure that the existing environmental conditions are not causing material degradation that could result in a loss of component intended function during the period of extended operation. At a minimum. in each 10-year period during the period of extended operation. a representative sample of 20 percent of the population (defined as components having the same material. environment. and aging effect combination) or a maximum of 25 components per population will be inspected. Where practical.

the inspection will include a representative sample of the system population and will focus on the bounding or lead components most susceptible to aging because of time in service and severity of the operating conditions. This minimum sample size will not override the opportunistic basis of this aging management program.

Program Description [6th paragraph]

The Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Program is a new condition-monitoring program. At least ono inspection of oach matorja/

and onvironmont combina#on wi!l bo conducted vlithin tho 10 year period prior to the period of oxtondod operation.

Enclosure L-14-085 Page 69 of 70 Scope [2"d paragraph]

The program will include baseline inspections followed by opportunistic inspections, when components are opened for maintenance, repair, or surveillance to ensure that the existing environmental conditions are not causing material degradation that could result in a loss of component intended function during the period of extended operation. This program includes indication of boric acid wastage on internal surfaces. In addition. this program will include periodic inspections of a representative sample.

Detection of Aging Effect [entire section]

The Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Program provides for detection of aging effects prior to the loss of component intended function. Base!fne inspectiens for each materia! and environment combination vJithlR the scope of the program wH! be conducted prior to the period of e>ftended operatlon at !ocations with conditions !fke!y to e>fhibft the aging effects of concern in the identified envkonments.

When required by the ASME Code, inspections are conducted in accordance with the applicable code requirements. In the absence of applicable code requirements, visual inspections are performed of metallic and polymeric component surfaces using plant specific procedures implemented by inspectors qualified through plant-specific programs.

Subsequently, o Opportunistic visual inspections will be conducted when components are opened for any reason, including maintenance, repair, or surveillance, and surfaces are available for inspection. Visual inspections will be performed by qualified personnel and will be supplemented by other established nondestructive examination (NDE) techniques, as appropriate. At a minimum. in each 10-year period during the period of extended operation. a representative sample of 20 percent of the population (defined as components having the same material. environment. and aging effect combination) or a maximum of 25 components per population will be inspected. Where practical. the inspection will include a representative sample of the system population and will focus on the bounding or lead components most susceptible to aging because of time in service and severity of the operating conditions. This minimum sample size will not override the opportunistic basis of this AMP.

For non-metallic (elastomeric) components, established visual examination techniques, as well as physical manipulation or prodding, will be performed by qualified personnel on a sample population of subject components to identify evidence of hardening, loss of strength (change in material properties) and loss of material. The sample population for physical manipulation is 10 percent of

Enclosure L-14-085 Page 70 of 70 available surface area, including known suspect locations. These tactile inspections are also performed on an opportunistic basis, whenever components are opened for maintenance, repair, or surveillance.

At least one inspection of each material and environment combination will bo conducted w-ithin tho ton year period prior to tho period of extended operation.

Any ovidonco of degradation vi-IJ! bo documented and ova!uated through tho Corrocti*ro Action Program.

Monitoring and Trending [section replaced in its entirety]

The Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Program uses standardized monitoring and trending activities to track degradation.

Deficiencies are documented using approved processes and procedures such that results can be trended. Inspections are performed at frequencies identified in "Detection of Aging Effects" program element.

v t e Letter Sequence Other
TAC:ME4640, Steam Generator Tube Integrity (Approved, Closed)
Initiation Request, Request, Request, Request Acceptance... Supplement, Supplement, Supplement, Supplement, Supplement Administration Withholding Request Acceptance Meeting Questions 28 February 2011 17 February 2011 17 March 2011 21 March 2011 18 March 2011 5 April 2011 30 March 2011 20 April 2011 2 May 2011 19 May 2011 20 June 2011 11 July 2011 12 July 2011 21 July 2011 21 July 2011 27 July 2011 11 August 2011 12 September 2011 9 September 2011 22 September 2011 11 October 2011 8 November 2011 22 November 2011 2 December 2011 2 December 2011 2 December 2011 27 December 2011 13 December 2011 21 December 2011 29 December 2011 12 July 2011 12 July 2011 12 July 2011 23 January 2012 30 January 2012 19 January 2012 1 February 2012 9 February 2012 27 January 2012 21 February 2012 22 February 2012 2 March 2012 27 February 2012 22 February 2012 24 February 2012 16 February 2012 27 February 2012 15 May 2012 28 February 2012 2 April 2012 ... further results Answers 18 March 2011 23 March 2011 23 March 2011 15 April 2011 20 April 2011 5 May 2011 24 May 2011 3 June 2011 24 June 2011 17 June 2011 22 July 2011 26 August 2011 17 August 2011 16 September 2011 7 October 2011 21 October 2011 9 November 2011 23 November 2011 5 April 2012 25 May 2012 14 June 2012 5 July 2012 11 July 2012 16 August 2012 16 August 2012 7 September 2012 2 November 2012 20 November 2012 20 December 2012 21 January 2013 12 February 2013 28 February 2013 14 March 2013 19 April 2013 21 May 2013 17 May 2013 4 June 2013 31 January 2014 11 March 2014 3 July 2014 29 July 2014 16 September 2014 28 October 2014 28 January 2015 15 April 2011 29 April 2011 9 March 2012 25 May 2012 Results Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval Other: L-11-114, Drawing No. M-042B, Rev. 35, Sampling System Sh. 2 Local Grab Samples, L-11-131, Drawing No. LR-OS041A2, Revision 1, Operational Schematic Emergency Diesel Generator Systems., L-11-334, Reply to Request Additional Information for the Review of the License Renewal Application Amendment No. 21, L-12-337, Review of the Safety Evaluation Report with Open Items Related to the License Renewal, L-12-444, Submittal of Contractor Equivalent Margins Assessments for Reactor Vessel Welds (Nonproprietary Versions), L-12-456, Notification of Closure of Commitments Related to the Review of the License Renewal Application, L-13-257, Notification of Completion of a License Renewal Commitment Related to the Review of License Renewal Application TAC No. ME4640) and License Renewal Application Amendment No. 45), L-13-330, License Renewal Application Amendment No. 46 - Annual Update, L-13-341, Review of the Safety Evaluation Report Related to the License Renewal of Davis-Besse Nuclear Power Station, L-14-085, License Renewal Application (TAC No. ME4640) Amendment No. 48, L-14-206, License Renewal Application Amendment No. 50 - Annual Update, L-15-120, Notification of Completion of License Renewal Commitments Related to the Review of the Davis-Besse Nuclear Power Station, Unit No. 1, License Renewal Application and License Renewal Application Amendment No. 55, L-15-139, License Renewal Reactor Vessel Internals Inspection Plan, L-15-214, License Renewal Application Amendment No. 59 - Annual Update, L-15-309, License Renewal Application Amendment No. 60, L-15-310, C-CSS-099.20-069, Rev 0, Shield Building Laminar Cracking Limits., ML102450565, ML111050091, ML11110A089, ML11110A091, ML11110A092, ML11110A093, ML11110A094, ML11110A095, ML11110A105, ML11110A106, ML11110A107, ML11122A014, ML11126A017, ML11126A018, ML11126A019, ML11126A020, ML11126A021, ML11126A022, ML11126A023, ML11126A024, ML11126A025, ML11126A026, ML11126A032, ML11126A033, ML11126A034, ML11126A035, ML11126A036, ML11126A037, ML11126A038, ML11126A039, ML11126A040, ML11126A041, ML11126A042, ML11126A043... further results
MONTHYEAR2011-02-25 [Table View]

L-14-085, License Renewal Application (TAC No. ME4640) Amendment No. 48

Text

SUBJECT:

Attachment:

Enclosure:

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