ML021560564

Response to Request for Additional Information (RAI) Related to Scoping and Screening Methodology and to Aging Management of Auxiliary Systems

ML021560564
Person / Time
Site:	Peach Bottom
Issue date:	05/21/2002
From:	Gallagher M Exelon Nuclear
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
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Download: ML021560564 (30)

Text

Exelon N\\tdeay 20o

ýxelon Way Ke nett Square, PA 19348 www.exe oncoTp.com Nuclear 10CFR54 May 21, 2002 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Peach Bottom Atomic Power Station, Units 2 and 3 Facility Operating License Nos. DPR-44 and DPR-56 NRC Docket Nos, 50-277 and 50-278

References:

Response to Request for Additional Information (RAI) Related to Scoping and Screening Methodology and to Aging Management of Auxiliary Systems

1) Letter from R. K. Anand (USNRC) to M. P. Gallagher (Exelon), dated January 23, 2002

2) Letter from R. K. Anand (USNRC) to M. P. Gallagher (Exelon), dated February 6, 2002

3) Letter from M. P. Gallagher (Exelon) to U.S. Nuclear Regulatory Commission, dated February 28, 2002

4) Letter from M. P. Gallagher (Exelon) to U.S. Nuclear Regulatory Commission, dated May 6, 2002

Dear Sir/Madam:

Reference letters 1) and 2) requested additional information to enable the NRC staff to complete its review. Reference letters 3) and 4) committed to providing the information requested by RAIs 2.1.2-3, 2.1.2-4, and 3.3-1 by May 27, 2002. Exelon Generation Company, LLC (Exelon) hereby submits the enclosed responses to RAIs 2.1.2-3, 2.1.2-4, and 3.3-1. For your convenience, Attachment 1 restates the questions from Reference letters 1) and 2) and provides our responses.

If you have any questions or require additional information, please do not hesitate to call.

I declare under penalty of perjury that the foregoing is true and correct.

Respectfully, Executed on 2.-

Michael P. Gallagher Director, Licensing & Regulatory Affairs Mid-Atlantic Regional Operating Group

Enclosures:

Affidavit, Attachment 1 cc:

H. J. Miller, Administrator, Region I, USNRC A. C. McMurtray, USNRC Senior Resident Inspector, PBAPS Exe I n,.

ATTACHMENT 1

Response to RAI Related to Scoping and Screening Methodology and to Aging Management of Auxiliary Systems Page 1 of 28 Exelon Generation Company, LLC (Exelon)

License Renewal Application (LRA)

Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3 Request for Additional Information RAI 2.1.2-3 System and Structure Scoping Criteria (S.eismin II/1)

An applicant needs to consider nonsafety-related (NSR) piping systems which are not connected to safety-related (SR) piping, but have a spatial relationship such that their failure could adversely impact on the performance of an intended safety function. For this piping system configuration, the applicant has two options when performing its scoping evaluation; a mitigative option or a preventive option. With respect to the mitigative approach, the applicant must demonstrate that plant mitigative features (e.g., pipe whip restraints, jet impingement shields, spray and drip shields, seismic supports, flood barriers, etc.) are provided which protect SR structures, systems and components (SSCs) from a failure of NSR piping segments. When evaluating the failure modes of NSR piping segments and the associated consequences, age related degradation must be considered. The staff notes that pipe failure evaluations typically do not consider age-related degradation when determining pipe failure locations. Rather, pipe failure locations are normally postulated based on high stress. Industry operating experience has shown that age-related pipe failures can, and do, occur at locations other than the high stress locations postulated in most pipe failure analyses. Therefore, to utilize the mitigative option, an applicant should demonstrate that the mitigating devices are adequate to protect SR SSCs from failures of NSR piping segments at any location where age-related degradation is plausible. If this level of protection can be demonstrated, then only the mitigative features need to be included within the scope of license renewal, and the piping segments need not be included within the scope.

However, if an applicant cannot demonstrate that the mitigative features are adequate to protect safety-related SSCs from the consequences of non-safety-related pipe failures, then the applicant should utilize the preventive option, which requires that the entire non-safety-related piping system be brought into the scope of license renewal and an AMR be performed on the components within the piping system. Finally, an applicant may determine that in order to ensure adequate protection of the SR SSC, a combination of mitigative features and NSR SSCs must be brought within scope. Regardless, it is incumbent upon the applicant to provide adequate justification for the approach taken with respect to scoping of NSR SSCs in accordance with the Rule. Therefore the applicant is requested to identify which option is used for NSR piping systems which are not connected to SR piping, but have a spatial relationship such that their failure could adversely impact on the performance of an intended safety function.

For each NSR piping system which would normally be included within the scope of license renewal, but is excluded because mitigative features have been credited for protecting SR SSCs from the failure of the NSR piping system, please identify the following:

a. the mitigative feature(s) that is credited for protection.

b. the hazard (e.g., failure mechanisms and postulated failure locations) for which the mitigative feature(s) is providing protection.

Response to RAI Related to Scoping and Screening Methodology and to Aging Management of Auxiliary Systems Page 2 of 28

c. a summary discussion (including references, such as reports, analyses, calculations, etc.)

of the basis for the conclusion that the mitigative feature(s) is adequate to protect SR SSCs.

RAI 2.1.2-4 Given the methodology used to identify piping systems that meet the 54.4(a)(2) scoping criterion, there may be other non-safety-related systems, structures or components ( NSR SSCs) which should be included within the scope of license renewal. For these other NSR SSCs an applicant can exercise the mitigative option, the preventive option, or a combination, in order to address the scoping issue. For each NSR SSC identified as meeting the 54.4(a)(2) scoping criterion, list which option or combination of options is being credited. For those NSR SSCs which exercise the mitigative option further indicate:

a. the mitigative feature(s) that is credited for protection,

b. the hazard (e.g., failure mechanisms and postulated failure locations) for which the mitigative feature(s) is providing protection, and

c. a summary discussion (including references, such as reports, analyses, calculations, etc.)

of the basis for the conclusion that the mitigative feature(s) is adequate to protect safety-related SSCs.

3-3 Aging Management of Auxiliary Systems RAI 3.3-1 Clarify whether any of the auxiliary systems discussed in Section 3.3 of the LRA are within the category of seismic II over I SSCs as described in position C.2 of Regulatory Guide 1.29.

Based on the information provided in Section 2.1.2.1 of the LRA, it appears that the applicant has included the pipe supports for seismic II over I piping systems in the scope of license renewal. However, the seismic II over I piping segments are not included within the scope of license renewal. The staff's concern is that seismic II over I piping, though seismically supported, would be subjected to the same plausible aging effects as safety-related piping. For example, depending on piping material, geometrical configuration, operation condition such as water chemistry, temperature, flow velocity, and external environment, erosion and corrosion may be plausible aging effects for some seismic II over I piping. Those effects, if not properly managed, could result in age-related failures and adversely impact the safety functions of safety-related SSCs. The applicant is requested to provide justification for not including the seismic II over I piping segments within the scope of license renewal. Specifically, the applicant is requested to address how plausible aging effects associated with those piping systems, if any, will be appropriately managed.

Combined Response to RAI 2.1.2-3, 2.1.2-4 and 3.3-1:

A review was performed to identify non-safety-related (NSR) piping systems which are not connected to safety-related (SR) piping but have a spatial relationship such that their failure could adversely impact on the performance of an intended safety function. The methodology

Response to RAI Related to Scoping and Screening Methodology and to Aging Management of Auxiliary Systems Page 3 of 28 was to identify those piping systems which were not in the scope of license renewal and which contained a fluid that could potentially adversely impact a SR system if the pressure boundary function degraded. These systems were designated as hazard systems. Then the spatial relationships were established to identify where these hazard systems could impact the SR structures, systems, and components (SSCs). The spatial relationships were established based on plant drawings, the component record list, and plant walkdowns. The interactions were evaluated for credibility based on the spatial proximity of the hazard systems and any SR SSCs. When the interaction was determined to be credible, the system was added to the scope of License Renewal because it then satisfied the scoping criterion 10CFR54.4(a)(2).

Operating experience review of non-fluid containing systems performed for the systems included in the scope of license renewal has shown no failures due to aging have occurred for these materials and environments. Additionally, non-fluid containing components cannot affect safety-related SSC due to leakage or spray.

For some systems that were already in the scope of license renewal, the system boundary was expanded to include portions of the system that were not safety-related.

Tables 2.1.2-3-1 and 2.1.2-3-2 list the results of these evaluations for expanded and additional systems in the scope of license renewal to meet the 10CFR54.4(a)(2) scoping criterion. The NSR components of these systems were found to be in spatial proximity to SR components such that an age related failure of the NSR component could impact the performance of an intended safety function. The component supports were already included in the scope of license renewal as described on page 2-8 of the LRA. The preventive option was used for this evaluation.

This RAI response includes the evaluation for NSR piping and other NSR components that may potentially impact SR SSCs; therefore, the RAI responses for RAI 2.1.2-3 and 2.1.2-4 were combined. This response also addresses similar information requested in RAI 3.3-1.

Response to RAI Related to Scoping and Screening Methodology and to Aging Management of Auxiliary Systems Page 4 of 28 Table 2.1.2-3-1 Table 2.1.2-39-2 Sysietm Grup Auxiliary Systems:

Systems with expanded License Renewal Boundary due to increased scope of criterion 1 OCFR54.4(a)(2)

Systems added to the scope of License Renewal due to increased scope of criterion 10CFR54.4(a)(2)

Syistem Service Water System Reactor Building Closed Cooling Water System Reactor Water Cleanup System Chilled Water System Water Treatment System Plant Equipment and Floor Drain System Process Sampling System Auxiliary Steam System Condensate Transfer Refueling Water Storage and Transfer Torus Water Cleanup System Sys~ewmGrup Sysem Reactor Coolant Systems:

Reactor Pressure Vessel Instrumentation System Engineered Safety Features Systems:

Core Spray System Residual Heat Removal System Auxiliary Systems:

Fuel Pool Cooling and Cleanup System Control Rod Drive System Electrical and I&C Systems:

Radiation Monitoring System I

Response to RAI Related to Scoping and Screening Methodology and to Aging Management of Auxiliary Systems Page 5 of 28 The following table identifies those structures in which the NSR to SR interactions could potentially occur. There were spatial relationships identified for NSR and SR SSCs in these structures.

Table 2.1.2-9-3 Structures containing NSR Components with potential interaction with SR components c

LRA Section description Containment Structure 2.4.1 Reactor Building Structure 2.4.2 Radwaste Building and Reactor Auxiliary Bay 2.4.3 Nitrogen Storage Building 2.4.9 Diesel Generator Building 2.4.10 Circulating Water Pump Structure 2.4.11 The aging management reviews for the new systems and expansion of existing systems in the scope of License Renewal resulted in crediting some of the aging management activities that were already credited for license renewal. These are listed in Table 2.1.2-3-4.

Table 2.1.2-3-5 is the new Aging Management Activity that was added to address one-time inspections for the new scope.

Table 2.1.2-3-4 Aging Management Activities described in PBAPS LRA that are credited for systems with increased scope due to criterion 1 OCFR54.4 (a)(2)

Aging Management Activity LRA Appendix B Section Reactor Coolant System Chemistry B.1.2 Closed Cooling Water Chemistry B.1.3 Condensate Storage Tank Chemistry Activities B.1.4 Torus Water Chemistry Activities B.1.5 Fuel Pool Chemistry Activities B.1.6 Table 2* 1.2-3-5 Aging Management Activities that were added due to increased scope of criterion 10CFR54.4 (a)(2)

Aging Management Activity LRA Appendix B Section One-Time Piping Inspection Activities B.3.3 (Submitted with response to RAI B1.13-1)

Response to RAI Related to Scoping and Screening Methodology and to Aging Management of Auxiliary Systems Page 6 of 28 The following tables present, in a six column tabular format, the components and component groups subject to aging management review, the component intended functions, the environment, materials of construction, the aging effects, and the activities credited to manage the aging effects for the additional systems and the expanded systems as a result of this review. The sheltered environment was excluded from these tables because there were no aging effects identified and therefore no requirement for aging management activities. For the expanded systems, some of the line items presented here are already in the LRA tables, but are included here for completeness of the components that were added as a result of this review.

Response to RAI Related to Scoping and Screening Methodology and to Aging Management of Auxiliary Systems Page 7 of 28 System: Reactor Pressure Vessel Instrumentation System

Title:

Aging Management Review Results for component groups in the Reactor Pressure Vessel Instrumentation System Component Component Environment Material of Aqinq Effect Aqinq Manaqement Group Intended Construction Activity Function I

Casting and Forging Pressure Boundary Reactor Water Stainless Steel Loss of Material Reactor Water Chemistry Valve Bodies B.1.2 Casting and Forging Pressure Boundary Reactor Water Stainless Steel Cracking Reactor Water Chemistry Valve Bodies B.1.2 Piping Pressure Boundary Reactor Water Stainless Steel Loss of Material Reactor Water Chemistry Pipe B.1.2 Tubing Piping Pressure Boundary Reactor Water Stainless Steel Cracking Reactor Water Chemistry

° Pipe B.1.2 Tubing Piping Specialties Pressure Boundary Reactor Water Stainless Steel Loss of Material Reactor Water Chemistry Filter bodies B.1.2 Piping Specialties Pressure Boundary Reactor Water Stainless Steel Cracking Reactor Water Chemistry

° Filter bodies B.1.2

Response to RAI Related to Scoping and Screening Methodology and to Aging Management of Auxiliary Systems Page 8 of 28 System: Core Spray System

Title:

Aging Management Review Results for component groups in the Core Spray System Component Component Environment Material of Aqinq Effect Aqinq Management Group Intended Construction Activity

_Function Casting and Forging Pressure Boundary Condensate Carbon Steel Loss of Material CST Chemistry Valve Bodies Storage Water B.1.4 Casting and Forging Pressure Boundary Condensate Stainless Steel Loss of Material CST Chemistry Valve Bodies Storage Water B.1.4 Casting and Forging Pressure Boundary Condensate Stainless Steel Cracking CST Chemistry Valve Bodies Storage Water B.1.4 Casting and Forging Pressure Boundary Reactor Water Stainless Steel Loss of Material RCS Chemistry Valve Bodies B.1.2 Casting and Forging Pressure Boundary Reactor Water Stainless Steel Cracking RCS Chemistry 0

Valve Bodies B.1.2 Piping Pressure Boundary Condensate Carbon Steel Loss of Material CST Chemistry Pipe Storage Water B.1.4 Piping Pressure Boundary Condensate Stainless Steel Loss of Material CST Chemistry

"* Pipe Storage Water B.1.4

"* Tubing Piping Pressure Boundary Condensate Stainless Steel Cracking CST Chemistry Pipe Storage Water B.1.4 Tubing Piping Pressure Boundary Reactor Water Stainless Steel Loss of Material RCS Chemistry Pipe B.1.2 Tubing Piping Pressure Boundary Reactor Water Stainless Steel Cracking RCS Chemistry Pipe B.1.2 Tubing

Response to RAI Related to Scoping and Screening Methodology and to Aging Management of Auxiliary Systems Page 9 of 28 System: Residual Heat Removal System

Title:

Aging Management Review Results for component groups in the Residual Heat Removal System Component Component Environment Material of Aqi n Effect Aqinq Management Group Intended Construction Activity Function Casting and Forging Pressure Boundary Condensate Carbon Steel Loss of Material CST Chemistry Valve Bodies Storage Water B.1.4 Casting and Forging Pressure Boundary Condensate Stainless Steel Loss of Material CST Chemistry Valve Bodies Storage Water B.1.4 Casting and Forging Pressure Boundary Condensate Stainless Steel Cracking CST Chemistry Valve Bodies Storage Water B.1.4 Piping Pressure Boundary Condensate Carbon Steel Loss of Material CST Chemistry Pipe Storage Water B.1.4 Tubing Piping Pressure Boundary Condensate Stainless Steel Loss of Material CST Chemistry Pipe Storage Water B.1.4 Tubing Piping Pressure Boundary Condensate Stainless Steel Cracking CST Chemistry Pipe Storage Water B.1.4 Tubing

Response to RAI Related to Scoping and Screening Methodology and to Aging Management of Auxiliary Systems Page 10 of 28 System: Fuel Pool Cooling System

Title:

Aging Management Review Results for component groups in the Fuel Pool Cooling System Component Component Environment Material of Aciinq Effect IAgiinq Managemnent Group Intended 1Construction Activity FunctionI Casting and Forging Pressure Boundary Fuel Pool Water Carbon Steel Loss of Material Fuel Pool Chemistry Valve Bodies B.1.6 Pump Casings Casting and Forging Pressure Boundary Fuel Pool Water Stainless Steel Loss of Material Fuel Pool Chemistry Valve Bodies B.1.6 Casting and Forging Pressure Boundary Fuel Pool Water Stainless Steel Cracking Fuel Pool Chemistry

& Valve Bodies B.1.6 Casting and Forging Pressure Boundary Fuel Pool Water Cast Iron Loss of Material Fuel Pool Chemistry Valve Bodies B.1.6 Heat Exchangers Pressure Boundary Fuel Pool Water Carbon Steel Loss of Material Fuel Pool Chemistry Shell B.1.6 Heat Exchangers Pressure Boundary Raw Water Carbon Steel Loss of Material One-Time Inspection Channel Head B.3.3 Piping Pressure Boundary Fuel Pool Water Carbon Steel Loss of Material Fuel Pool Chemistry Pipe B.1.6 Piping Pressure Boundary Fuel Pool Water Stainless Steel Loss of Material Fuel Pool Chemistry Pipe B.1.6 Tubing_

Piping Pressure Boundary Fuel Pool Water Stainless Steel Cracking Fuel Pool Chemistry Pipe B.1.6 Tubing Piping Specialties Pressure Boundary Fuel Pool Water Carbon Steel Loss of Material Fuel Pool Chemistry Thermowells B.1.6 Vessel Pressure Boundary Fuel Pool Water Stainless Steel Loss of Material Fuel Pool Chemistry Surge Tank B.1.6 Vessel Pressure Boundary Fuel Pool Water Stainless Steel Cracking Fuel Pool Chemistry Surge Tank B.1.6

Response to RAI Related to Scoping and Screening Methodology and to Aging Management of Auxiliary Systems Page 11 of 28 System: Control Rod Drive System

Title:

Aging Management Review Results for component groups in the Control Rod Drive System Component Component Environment i

Material of Aqinq Effect Aging Management Group Intended Construction Activitv

_______________________F-unction Casting and Forging Pressure Boundary Condensate Carbon Steel Loss of Material CST Chemistry Valve Bodies Storage Water B.1.4 Casting and Forging Pressure Boundary Condensate Stainless Steel Loss of Material CST Chemistry Valve Bodies Storage Water B.1.4 Casting and Forging Pressure Boundary Condensate Stainless Steel Cracking CST Chemistry Valve Bodies Storage Water B.1.4 Piping Pressure Boundary Condensate Carbon Steel Loss of Material CST Chemistry Pipe Storage Water B.1.4 Tubing Piping Pressure Boundary Condensate Stainless Steel Loss of Material CST Chemistry Pipe Storage Water B.1.4 Tubing Piping Pressure Boundary Condensate Stainless Steel Cracking CST Chemistry Pipe Storage Water B.1.4 Tubing Piping Specialties Pressure Boundary Condensate Stainless Steel Loss of Material CST Chemistry Filter bodies Storage Water B.1.4 Flow Elements Restricting orifices Piping Specialties Filter bodies Flow Elements Restricting orifices Pressure Boundary Condensate Storage Water Stainless Steel Cracking CST Chemistry B.1.4 C _________________________________________

L _______________________________________

Title:

Aging Response to RAI Related to Scoping and Screening Methodology and to Aging Management of Auxiliary Systems Page 12 of 28 System: Radiation Monitoring System Management Review Results for component groups in the Radiation Monitoring System Component Component Environment Material of Aaing Effect Aqing Management Group Intended Function Construction ActivitV Casting and Forging Pressure Boundary Raw Water Carbon Steel Loss of Material One-Time Piping Inspection B.3.3 0

Valve Bodies Casting and Forging Pressure Boundary Raw Water Stainless Steel Loss of Material One-Time Piping Inspection Valve Bodies B.3.3 Pump Casings Casting and Forging Pressure Boundary Raw Water Stainless Steel Cracking One-Time Piping Inspection Valve Bodies B.3.3 Pump Casings Casting and Forging Pressure Boundary Raw Water Bronze Loss of Material One-Time Piping Inspection B.3.3 Valve Bodies Casting and Forging Pressure Boundary Raw Water Bronze Cracking One-Time Piping Inspection B.3.3 Valve Bodies Piping Pressure Boundary Raw Water Carbon Steel Loss of Material One-Time Piping Inspection B.3.3 Pipe Piping Pressure Boundary Raw Water Stainless Steel Loss of Material One-Time Piping Inspection Pipe B.3.3 Tubing Piping Pressure Boundary Raw Water Stainless Steel Cracking One-Time Piping Inspection Pipe B.3.3 Tubing Piping Pressure Boundary Raw Water Copper Loss of Material One-Time Piping Inspection Pipe B.3.3 Tubing Piping Pressure Boundary Raw Water Copper Cracking One-Time Piping Inspection Pipe B.3.3 Tubing Piping Specialties Pressure Boundary Raw Water Stainless Steel Loss of Material One-Time Piping Inspection B.3.3 Restricting Orifice viping bpecialties a

Restricting Orifice Pressure Boundary Raw Water Stainless Steel Cracking One-Time Piping Inspection B.3.3 I

_ L___

__I

Response to RAI Related to Scoping and Screening Methodology and to Aging Management of Auxiliary Systems Page 13 of 28 System: Service Water System

Title:

Aging Management Review Results for component groups in the Service Water System Component Component Environment Material of Aqiinq Effect Aqiinq Manaqement Group Intended Function I.Construction Activity Casting and Forging Pressure Boundary Raw Water Carbon Steel Loss of Material One-Time Piping Inspection Valve Bodies B.3.3 Pump Casings Casting and Forging Pressure Boundary Raw Water Bronze Loss of Material One-Time Piping Inspection Valve Bodies B.3.3 Casting and Forging Pressure Boundary Raw Water Cast Iron Loss of Material One-Time Piping Inspection Valve Bodies B.3.3 Casting and Forging Pressure Boundary Raw Water Brass Loss of Material One-Time Piping Inspection Valve Bodies B.3.3 Casting and Forging Pressure Boundary Raw Water Brass Cracking One-Time Piping Inspection 9

Valve Bodies B.3.3 Piping Pressure Boundary Raw Water Carbon Steel Loss of Material One-Time Piping Inspection 0

Pipe B.3.3 Piping Pressure Boundary Raw Water Copper Loss of Material One-Time Piping Inspection Pipe B.3.3 Tubing Piping Pressure Boundary Raw Water Copper Cracking One-Time Piping Inspection Pipe B.3.3 Tubing Piping Specialties Pressure Boundary Raw Water Carbon Steel Loss of Material One-Time Piping Inspection Thermowells B.3.3

Response to RAI Related to Scoping and Screening Methodology and to Aging Management of Auxiliary Systems Page 14 of 28 System: Reactor Building Closed Cooling Water System

Title:

Aging Management Review Results for component groups in the Reactor Building Closed Cooling Water System Component Component Environment Material of A1inq Effect Aging Management Group Intended Function Construction Activity Casting and Forging Pressure Boundary Closed Cooling Carbon Steel Loss of Material CCW Chemistry Valve Bodies Water B.1.3 Pump Casings Casting and Forging Pressure Boundary Closed Cooling Stainless Steel Loss of Material CCW Chemistry Valve Bodies Water B.1.3 Casting and Forging Pressure Boundary Closed Cooling Stainless Steel Cracking CCW Chemistry Valve Bodies Water B.1.3 Casting and Forging Pressure Boundary Closed Cooling Bronze Loss of Material CCW Chemistry Valve Bodies Water B.1.3 Casting and Forging Pressure Boundary Closed Cooling Cast Iron Loss of Material CCW Chemistry Valve Bodies Water B.1.3 Casting and Forging Pressure Boundary Closed Cooling Brass Loss of Material CCW Chemistry Valve Bodies Water B.1.3 Casting and Forging Pressure Boundary Closed Cooling Brass Cracking CCW Chemistry Valve Bodies Water B.1.3 Heat Exchangers Pressure Boundary Closed Cooling Carbon Steel Loss of Material CCW Chemistry Shell Water B.1.3 Heat Exchangers Pressure Boundary Raw Water Carbon Steel Loss of Material One-Time Piping Inspection Channel heads B.3.3 Piping Pressure Boundary Closed Cooling Carbon Steel Loss of Material CCW Chemistry Pipe Water B.1.3 Piping Pressure Boundary Closed Cooling Stainless Steel Loss of Material CCW Chemistry Pipe Water B.1.3 Tubing Piping Pressure Boundary Closed Cooling Stainless Steel Cracking CCW Chemistry Pipe Water B.1.3 Tubing Piping Pressure Boundary Closed Cooling Copper Loss of Material CCW Chemistry Pipe Water B.1.3

Response to RAI Related to Scoping and Screening Methodology and to Aging Management of Auxiliary Systems Page 15 of 28 Component Comp~onent Environment Material of Aging Effect Aqingq Management Group Intended Function Construction Activitv Piping Pressure Boundary Closed Cooling Copper Cracking CCW Chemistry Pipe Water B.1.3 Piping Specialties Pressure Boundary Closed Cooling Carbon Steel Loss of Material CCW Chemistry Thermowells Water B.1.3 Piping Specialties Pressure Boundary Closed Cooling Stainless Steel Loss of Material CCW Chemistry Restricting Orifice Water B.1.3 Piping Specialties Pressure Boundary Closed Cooling Stainless Steel Cracking CCW Chemistry Restricting Orifice Water B.1.3 Vessel Pressure Boundary Closed Cooling Carbon Steel Loss of Material CCW Chemistry Head Tank Water B.1.3 Chemical Addition Tank

Response to RAI Related to Scoping and Screening Methodology and to Aging Management of Auxiliary Systems Page 16 of 28 System: Reactor Water Cleanup System

Title:

Aging Management Review Results for component groups in the Reactor Water Cleanup System Component Component Environment Material of Aqin, Effect Aging Management Group Intended Function Construction Activit Casting and Forging Pressure Boundary Reactor Coolant Carbon Steel Loss of Material RCS Chemistry Valve Bodies B.1.2 Casting and Forging Pressure Boundary Reactor Coolant Stainless Steel Loss of Material RCS Chemistry Valve Bodies B.1.2 Pump Casings Casting and Forging Pressure Boundary Reactor Coolant Stainless Steel Cracking RCS Chemistry Valve Bodies B.1.2 Pump Casings Casting and Forging Pressure Boundary Reactor Coolant Cast Iron Loss of Material RCS Chemistry Valve Bodies B.1.2 Heat Exchangers Pressure Boundary Reactor Coolant Carbon Steel Loss of Material RCS Chemistry Shell B.1.2 Heat Exchangers Pressure Boundary Reactor Coolant Carbon Steel Loss of Material RCS Chemistry Channel heads B.1.2 Heat Exchangers Pressure Boundary Reactor Coolant Stainless Steel Loss of Material RCS Chemistry Channel heads B.1.2 Heat Exchangers Pressure Boundary Reactor Coolant Stainless Steel Cracking RCS Chemistry Channel heads B.1.2 Piping Pressure Boundary Reactor Coolant Carbon Steel Loss of Material RCS Chemistry Pipe B.1.2 Piping Pressure Boundary Reactor Coolant Stainless Steel Loss of Material RCS Chemistry Pipe B.1.2 Tubing Ping Pressure Boundary Reactor Coolant Stainless Steel Cracking RCS Chemistry

• Pipe B.1.2

• Tubing Piping Specialties Pressure Boundary Reactor Coolant Stainless Steel Loss of Material RCS Chemistry SThermowells B.1.2

• Restricting Orifice

• Flow Elements

Response to RAI Related to Scoping and Screening Methodology and to Aging Management of Auxiliary Systems Page 17 of 28 Component Cornonent Environment Material of Aqina Effect Aqinq Manaqement Grou p Intended Function Construction Activit Piping Specialties Pressure Boundary Reactor Coolant Stainless Steel Cracking RCS Chemistry Thermowells B.1.2 Restricting Orifice Flow Elements Piping Specialties Pressure Boundary Reactor Coolant Carbon Steel Loss of Material RCS Chemistry 0

Flow Elements B.1.2

Response to RAI Related to Scoping and Screening Methodology and to Aging Management of Auxiliary Systems Page 18 of 28 System: Chilled Water System

Title:

Aging Management Review Results for component groups in the Chilled Water System Component Component Environm-enit i

Material of Aqinpc Effect

Aciinc, Group Intended Function Construction IManaqemnent Activity Casting and Forging Pressure Boundary Closed Cooling Carbon Steel Loss of Material CCW Chemistry Valve Bodies Water B.1.3 Casting and Forging Pressure Boundary Closed Cooling Stainless Steel Loss of Material CCW Chemistry Valve Bodies Water B.1.3 Casting and Forging Pressure Boundary Closed Cooling Stainless Steel Cracking CCW Chemistry Valve Bodies Water B.1.3 Casting and Forging Pressure Boundary Closed Cooling Bronze Loss of Material CCW Chemistry Valve Bodies Water B.1.3 Casting and Forging Pressure Boundary Closed Cooling Brass Loss of Material CCW Chemistry Valve Bodies Water B.1.3 Casting and Forging Pressure Boundary Closed Cooling Brass Cracking CCW Chemistry Valve Bodies Water B.1.3 Casting and Forging Pressure Boundary Closed Cooling Cast Iron Loss of Material CCW Chemistry Valve Bodies Water B.1.3 Heat Exchanger Pressure Boundary Closed Cooling Copper Loss of Material CCW Chemistry Drywell Coolers Water B.1.3 (Tubes)

Heat Exchanger Pressure Boundary Closed Cooling Copper Cracking CCW Chemistry Drywell Coolers Water B.1.3 (Tubes)

Heat Exchanger Pressure Boundary Closed Cooling Copper Loss of Material CCW Chemistry Drywell Coolers Water B.1.3 (Headers)

Heat Exchanger Pressure Boundary Closed Cooling Copper Cracking CCW Chemistry Drywell Coolers Water B.1.3 (Headers)

Heat Exchanger Drywell Coolers (Connections)

Pressure Boundary Closed Cooling Water Carbon Steel Loss of Material CCW Chemistry B.1.3 L _________________

J _____________________

Response to RAI Related to Scoping and Screening Methodology and to Aging Management of Auxiliary Systems Page 19 of 28 Component Cornoonent Environment Material of Aqinq Effect Aqinq Group Intended Function Construction Manaqement M

Activity Piping Pressure Boundary Closed Cooling Carbon Steel Loss of Material CCW Chemistry Pipe Water B.1.3 Piping Pressure Boundary Closed Cooling Copper Loss of Material CCW Chemistry

"* Pipe Water B.1.3

"* Tubing Piping Pressure Boundary Closed Cooling Copper Cracking CCW Chemistry Pipe Water B.1.3 Tubing Piping Specialties Pressure Boundary Closed Cooling Bronze Loss of Material CCW Chemistry Flow Elements Water B.1.3

Response to RAI Related to Scoping and Screening Methodology and to Aging Management of Auxiliary Systems Page 20 of 28

Title:

Aging System: Water Treatment System Management Review Results for component groups in the Water Treatment System Component Component Environment Material of Aqinci Effect Aging Management Group Intended Function Construction Activitv Casting and Forging Pressure Boundary Demineralized Carbon Steel Loss of Material Demineralized Water Chemistry Valve Bodies Water B.1.4 Casting and Forging Pressure Boundary Demineralized Stainless Steel Loss of Material Demineralized Water Chemistry Valve Bodies Water B.1.4 Casting and Forging Pressure Boundary Demineralized Stainless Steel Cracking Demineralized Water Chemistry Valve Bodies Water B.1.4 Casting and Forging Pressure Boundary Demineralized Bronze Loss of Material Demineralized Water Chemistry

& Valve Bodies Water B.1.4 Casting and Forging Pressure Boundary Demineralized Brass Loss of Material Demineralized Water Chemistry Valve Bodies Water B.1.4 Casting and Forging Pressure Boundary Demineralized Brass Cracking Demineralized Water Chemistry Valve Bodies Water B.1.4 Piping Pressure Boundary Demineralized Carbon Steel Loss of Material Demineralized Water Chemistry Pipe Water B.1.4 Piping Pressure Boundary Demineralized Stainless Steel Loss of Material Demineralized Water Chemistry

° Pipe Water B.1.4 Tubing Piping Pressure Boundary Demineralized Stainless Steel Cracking Demineralized Water Chemistry

° Pipe Water B.1.4

° Tubing

Response to RAI Related to Scoping and Screening Methodology and to Aging Management of Auxiliary Systems Page 21 of 28 System: Plant Equipment & Floor Drain System

Title:

Aging Management Review Results for component groups in the Plant Equipment & Floor Drain System ComPonent Component Environment 7

Material of Aqinq Effect Aqinq ManaAement Group Intended Function Construction Activity Casting and Forging Pressure Boundary Sump Water Carbon Steel Loss of Material One-time Piping Inspection Valve Bodies B.3.3 Piping Pressure Boundary Sump Water Carbon Steel Loss of Material One-time Piping Inspection Pipe B.3.3 Piping Specialties Pressure Boundary Sump Water Carbon Steel Loss of Material One-time Piping Inspection Flow Element B.3.3

Title:

Aging Response to RAI Related to Scoping and Screening Methodology and to Aging Management of Auxiliary Systems Page 22 of 28 System: Process Sampling System Management Review Results for component groups in the Process Sampling System Component Component Environment Material of Aginq Effect Aging Management Group Intended Function Construction Activit.

Casting and Forging Pressure Boundary Steam Carbon Steel Loss of Material RCS Chemistry Valve Bodies B.1.2 Casting and Forging Pressure Boundary Reactor Coolant Carbon Steel Loss of Material RCS Chemistry Valve Bodies B.1.2 Casting and Forging Pressure Boundary Fuel Pool Water Carbon Steel Loss of Material Fuel Pool Chemistry Valve Bodies B.1.6 Casting and Forging Pressure Boundary Closed Cooling Carbon Steel Loss of Material CCW Chemistry Valve Bodies Water B.1.3 Casting and Forging Pressure Boundary Steam Stainless Steel Loss of Material RCS Chemistry Valve Bodies B.1.2 Casting and Forging Pressure Boundary Steam Stainless Steel Cracking RCS Chemistry Valve Bodies B.1.2 Casting and Forging Pressure Boundary Reactor Coolant Stainless Steel Loss of Material RCS Chemistry Valve Bodies B.1.2 Casting and Forging Pressure Boundary Reactor Coolant Stainless Steel Cracking RCS Chemistry Valve Bodies B.1.2 Casting and Forging Pressure Boundary Fuel Pool Water Stainless Steel Loss of Material Fuel Pool Chemistry Valve Bodies B.1.6 Casting and Forging Pressure Boundary Fuel Pool Water Stainless Steel Cracking Fuel Pool Chemistry Valve Bodies B.1.6 Casting and Forging Pressure Boundary Closed Cooling Stainless Steel Loss of Material CCW Chemistry Valve Bodies Water B.1.3 Casting and Forging Pressure Boundary Closed Cooling Stainless Steel Cracking CCW Chemistry Valve Bodies Water B.1.3 Casting and Forging Pressure Boundary Reactor Coolant Brass Loss of Material RCS Chemistry Valve Bodies B.1.2 Casting and Forging Pressure Boundary Reactor Coolant Brass Cracking RCS Chemistry Valve Bodies B.1.2 Casting and Forging Pressure Boundary Closed Cooling Bronze Loss of Material CCW Chemistry

° Valve Bodies Water B.1.3 Piping Pressure Boundary Steam Carbon Steel Loss of Material RCS Chemistry 0

Pipe B.1.2

Response to RAI Related to Scoping and Screening Methodology and to Aging Management of Auxiliary Systems Page 23 of 28 Component Component Environment Material of Aqinq Effect Aqing Management Group Intended Function Construction Activity Piping Pressure Boundary Reactor Coolant Carbon Steel Loss of Material RCS Chemistry 0

Pipe B.1.2 Piping Pressure Boundary Fuel Pool Water Carbon Steel Loss of Material Fuel Pool Chemistry Pipe B.1.6 Piping Pressure Boundary Closed Cooling Carbon Steel Loss of Material CCW Chemistry Pipe Water B.1.3 Piping Pressure Boundary Steam Stainless Steel Loss of Material RCS Chemistry Pipe B.1.2 Tubing Piping Pressure Boundary Steam Stainless Steel Cracking RCS Chemistry Pipe B.1.2 Tubing Piping Pressure Boundary Reactor Coolant Stainless Steel Loss of Material RCS Chemistry Pipe B.1.2 Tubing Piping Pressure Boundary Reactor Coolant Stainless Steel Cracking RCS Chemistry

"* Pipe B.1.2

"° Tubing Piping Pressure Boundary Fuel Pool Water Stainless Steel Loss of Material Fuel Pool Chemistry Pipe B.1.6 Tubingq Piping Pressure Boundary Fuel Pool Water Stainless Steel Cracking Fuel Pool Chemistry Pipe B.1.6 Tubing Piping Pressure Boundary Closed Cooling Stainless Steel Loss of Material CCW Chemistry Pipe Water B.1.3 Tubing Piping Pressure Boundary Closed Cooling Stainless Steel Cracking CCW Chemistry Pipe Water B.1.3 Tubing

Response to RAI Related to Scoping and Screening Methodology and to Aging Management of Auxiliary Systems Page 24 of 28 System: Auxiliary Steam System

Title:

Aging Management Review Results for component groups in the Auxiliary Steam System Component Component Environment Material of Aqinq Effect Aqinq Group Intended Function Construction Manaqement Activity Casting and Forging Pressure Boundary Auxiliary Steam Carbon Steel Loss of Material One-Time Piping Inspection Valve Bodies B.3.3 Steam Traps Strainer Bodies Casting and Forging Pressure Boundary Condensed Steam Carbon Steel Loss of Material One-Time Piping Inspection Pump Casings B.3.3 Valve Bodies Steam Traps Strainer Bodies Casting and Forging Pressure Boundary Auxiliary Steam Bronze Loss of Material One-Time Piping Inspection Valve Bodies B.3.3 Casting and Forging Pressure Boundary Condensed Steam Bronze Loss of Material One-Time Piping Inspection Valve Bodies B.3.3 Casting and Forging Pressure Boundary Auxiliary Steam Cast Iron Loss of Material One-Time Piping Inspection Valve Bodies B.3.3 Steam Traps Strainer Bodies Casting and Forging Pressure Boundary Condensed Steam Cast Iron Loss of Material One-Time Piping Inspection Valve Bodies B.3.3 Steam Traps

° Strainer Bodies Casting and Forging Pressure Boundary Condensed Steam Brass Loss of Material One-Time Piping Inspection

° Valve Bodies B.3.3 Casting and Forging Pressure Boundary Condensed Steam Brass Cracking One-Time Piping Inspection

° Valve Bodies B.3.3 Heat Exchangers Pressure Boundary Auxiliary Steam Copper Loss of Material One-Time Piping Inspection B.3.3 Unit Heaters (Tubes)

Heat Exchangers Pressure Boundary Auxiliary Steam Copper Cracking One-Time Piping Inspection B.3.3 Unit Heaters (Tubes)

Unit Heaters (Headers and Connections)

P'ressure Boundary Auxiliary Steam Carbon Steel Loss of Material One-Time Piping Inspection B.3.3

.1 ______________

1 ______________

L ______________

Response to RAI Related to Scoping and Screening Methodology and to Aging Management of Auxiliary Systems Page 25 of 28 Component Component Environment t

Material of Aqincq Effect Aqinq Group Intended Function Construction i

Manaqement Activitv Heat Exchangers Pressure Boundary Auxiliary Steam Copper Loss of Material One-Time Piping Inspection B.3.3 Ventilation Heaters (Tubes)

Heat Exchangers Pressure Boundary Auxiliary Steam Copper Cracking One-Time Piping Inspection B.3.3 Ventilation Heaters (Tubes)

Heat Exchangers Pressure Boundary Auxiliary Steam Carbon Steel Loss of Material One-Time Piping Inspection B.3.3 Ventilation Heaters (Headers and Connections)

Piping Pressure Boundary Auxiliary Steam Carbon Steel Loss of Material One-Time Piping Inspection B.3.3 Pipe Piping Pressure Boundary Condensed Steam Carbon Steel Loss of Material One-Time Piping Inspection B.3.3 Pipe Piping Pressure Boundary Auxiliary Steam Stainless Steel Loss of Material One-Time Piping Inspection B.3.3 Tubinq Piping Pressure Boundary Auxiliary Steam Stainless Steel Cracking One-Time Piping Inspection B.3.3 0

Tubinq Piping Pressure Boundary Auxiliary Steam Copper Loss of Material One-Time Piping Inspection B.3.3

& Tubing Piping Pressure Boundary Condensed Steam Copper Loss of Material One-Time Piping Inspection B.3.3 Tubing Piping Pressure Boundary Auxiliary Steam Copper Cracking One-Time Piping Inspection B.3.3 Tubing Piping Pressure Boundary Condensed Steam Copper Cracking One-Time Piping Inspection B.3.3 Tubing Vessels Pressure Boundary Auxiliary Steam Carbon Steel Loss of Material One-Time Piping Inspection B.3.3 Tanks Vessels Pressure Boundary Condensed Steam Carbon Steel Loss of Material One-Time Piping Inspection B.3.3 Tanks

Response to RAI Related to Scoping and Screening Methodology and to Aging Management of Auxiliary Systems Page 26 of 28 System: Condensate Transfer System

Title:

Aging Management Review Results for component groups in the Condensate Transfer System Component Component Environment Material of Aqinq Effect Aqinq Manaqement Group Intended Function Construction Activitv Casting and Forging Pressure Boundary Condensate Stainless Steel Loss of Material CST Chemistry Valve Bodies Storage Water B.1.4 Casting and Forging Pressure Boundary Condensate Stainless Steel Cracking CST Chemistry Valve Bodies Storage Water B.1.4 Piping Pressure Boundary Condensate Stainless Steel Loss of Material CST Chemistry Pipe Storage Water B.1.4 Tubing Piping Pressure Boundary Condensate Stainless Steel Crckin rCQT (k

+-

• Pipe

• Tubing Storage Water I

I 'I 1 I IOLl y B.1.4 I ______________

L ________________

Pipe

° Tubinq J

zj

Response to RAI Related to Scoping and Screening Methodology and to Aging Management of Auxiliary Systems Page 27 of 28 System: Refueling Water Storage and Transfer System

Title:

Aging Management Review Results for component groups in the Refueling Water Storage and Transfer System Com[ponent Component o

Environment Material of Aqinq Effect 1

Aqinq Manaqement Grou.

Intended n io Construction nActivit Pressure Boundary Condensate Storage Water Stainless Steel Loss of Material B.1.4 1

1-

-f 4

Pressure Boundary Condensate Storage Water Stainless Steel Cracking CST Chemistry B.1.4 CST Chemistry B.1.4 L ________________

J ________________

.1 ________________

1 _____________

Piping 0

Pipe Piping Pipe

Response to RAI Related to Scoping and Screening Methodology and to Aging Management of Auxiliary Systems Page 28 of 28 System: Torus Water Cleanup System

Title:

Aging Management Review Results for component groups in the Torus Water Cleanup System Component Component

Environment Material of Aginq Effect i

Aqing Manaqement SGroup Intended Fci Construction Activity Casting and Forging Pressure Boundary Torus Water Carbon Steel Loss of Material Torus Water Chemistry Valve Bodies B.1.5 Casting and Forging Pressure Boundary Torus Water Stainless Steel Loss of Material Torus Water Chemistry Valve Bodies B.1.5 Casting and Forging Pressure Boundary Torus Water Stainless Steel Cracking Torus Water Chemistry Valve Bodies B.1.5 Piping Pressure Boundary Torus Water Carbon Steel Loss of Material Torus Water Chemistry Pipe B.1.5 Piping Pressure Boundary Torus Water Stainless Steel Loss of Material Torus Water Chemistry Pipe B.1.5 Tubing Piping Pressure Boundary Torus Water Stainless Steel Cracking Torus Water Chemistry Pipe B.1.5 Tubing