ML021970005
| ML021970005 | |
| Person / Time | |
|---|---|
| Site: | Surry, North Anna  |
| Issue date: | 02/01/2002 |
| From: | Christian D Virginia Electric & Power Co (VEPCO) |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| -nr, 01-686A, LR/MWH R0 | |
| Download: ML021970005 (24) | |
Text
VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 February 1, 2002 United States Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001 Serial No.:
01-686A LR/MWH RO Docket Nos.:
50-280/281 50-338/339 License Nos.: DPR-32/37 NPF-4/7 Gentlemen:
VIRGINIA ELECTRIC AND POWER COMPANY (DOMINION)
SURRY AND NORTH ANNA POWER STATIONS UNITS 1 AND 2 REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATIONS In an October 22, 2001 letter, the NRC requested additional information regarding the license renewal applications (LRAs) for Surry and North Anna Power Stations. The attachment to this letter contains the responses to the Requests for Additional Information (RAIs) associated with Section 2.1 of the LRA.
Should you have any questions regarding this submittal, please contact Mr. J. E.
Wroniewicz at (804) 273-2186.
ery truly yours, 9.Q David A. Christian Senior Vice President - Nuclear Operations and Chief Nuclear Officer Attachment Commitments made in this letter: None 97/6k V
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Serial No.: 01-686A SPS/NAPS LR - Response to RAI cc page 1 of 4 cc:
U. S. Nuclear Regulatory Commission Region II Sam Nunn Atlanta Federal Center 61 Forsyth Street, SW Suite 23T85 Atlanta, GA 30303-8931 Mr. M. J. Morgan NRC Senior Resident Inspector North Anna Power Station Mr. R. A. Musser NRC Senior Resident Inspector Surry Power Station Mr. J. E. Reasor, Jr.
Old Dominion Electric Cooperative Innsbrook Corporate Center 4201 Dominion Blvd.
Suite 300 Glen Allen, VA 23060 Ms. Ellie Irons, EIR Program Manager Virginia Dept. of Environmental Quality 629 East Main St., 6th FI Richmond, VA 23219 Mr. David Paylor, Program Coordinator Virginia Dept. of Environmental Quality P.O. Box 10009 Richmond, VA 23240-0009 Mr. Joe Hassell, Environmental Manager Virginia Dept. of Environmental Quality Water Division P.O. Box 10009 Richmond, VA 23240-0009 Mr. Gerard Seely, Jr., Director Virginia Dept. of Environmental Quality Piedmont Regional Office 4949-A Cox Road Glen Allen, VA 23060
Serial No.: 01-686A SPS/NAPS LR - Response to RAI cc page 2 of 4 Mr. Gregory Clayton, Regional Director Virginia Dept. of Environmental Quality Northern Virginia Regional Office 13901 Crown Ct.
Woodbridge, VA 22193 Mr. Frank Fulgham, Program Manager Virginia Dept. of Agriculture & Consumer Services Office of Plant & Pest Services 1100 Bank St.
Richmond, VA 23219 Mr. David Brickley, Agency Director Virginia Dept. of Conservation & Recreation 203 Governor St.
Richmond, VA 23219 Mr. William Woodfin, Director Virginia Dept. of Game & Inland Fisheries 4010 West Broad St.
Richmond, VA 23230 Mr. Robert Hicks, Director Virginia Dept. of Health Office of Environmental Health Services 1500 East Main St., Room 115 Richmond, VA 23219 Ms. Kathleen S. Kilpatrick, Director Virginia Dept. of Historic Resources State Historic Preservation Office 2801 Kensington Ave.
Richmond, VA 23221 Dr. Ethel Eaton, Archeologist Senior Virginia Dept. of Historic Resources State Historic Preservation Office 2801 Kensington Ave.
Richmond, VA 23221
Serial No.: 01-686A SPS/NAPS LR - Response to RAI cc page 3 of 4 Mr. Robert W. Grabb, Assistant Commissioner Virginia Marine Resources Commission 2600 Washington Ave.
Newport News, VA 23607 Dr. John Olney, Associate Professor Virginia Institute of Marine Science School of Marine Science Gloucester Point, VA 23062 Mr. John Simkins Virginia Dept. of Transportation Environmental Division 1401 East Broad St.
Richmond, VA 23219 Mr. Robert Burnley Virginia Economic Development Partnership 901 East Byrd St.
Richmond, VA 23219 Mr. William F. Stephens, Director Virginia State Corporation Commission Division of Energy Regulation 1300 East Main St., 4th Fl., Tyler Bldg.
Richmond, VA 23219 Mr. Michael Cline, State Coordinator Commonwealth of Virginia Department of Emergency Management 10501 Trade Rd.
Richmond, VA 23236-3713 Mr. Terry Lewis, County Administrator P.O. Box 65 Surry, VA 23883 Mr. Lee Lintecum Louisa County Administrator P.O. Box 160 Louisa, VA 23093
Serial No.: 01-686A SPS/NAPS LR - Response to RAI cc page 4 of 4 Mr. Douglas C. Walker Acting Spotsylvania County Administrator P.O. Box 99 Spotsylvania, VA 22553 Ms. Brenda G. Bailey, County Administrator P.O. Box 11 Orange, VA 22960 Chairman Reeva Tilley Virginia Council on Indians P.O. Box 1475 Richmond, VA 23218 Mr. Don Lillywhite, Director Economics Information Services Virginia Employment Commission State Data Center 703 East Main St., Room 213 Richmond, VA 23219 Mr. Alan Zoellner Government Information Department Swem Library College of William and Mary Landrum Dr.
P.O. Box 8794 Williamsburg, VA 23187-8794 Mr. Walter Newsome Government Information Resources Alderman Library University of Virginia 160 McCormick Rd.
P.O. Box 400154 Charlottesville, VA 22904-4154
Serial No.: 01-686A SPS/NAPS LR - Response to RAI COMMONWEALTH OF VIRGINIA
) )
COUNTY OF HENRICO
)
The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by David A. Christian who is Senior Vice President and Chief Nuclear Officer of Virginia Electric and Power Company. He has affirmed before me that he is duly authorized to execute and file the foregoing document in behalf of that Company, and that the statements in the document are true to the best of his knowledge and belief.
Acknowledged before me this _A day of
,2001.
My Commission Expires:
.3 1
Notary Public (SEAL)
Docket Nos. 50-280/281 50-338/339 Serial No.: 01-686A Attachment Page 1 of 18 Attachment License Renewal - Response to RAI Serial No. 01-686A Response to Request for Additional Information Dated October 22, 2001 Surry and North Anna Power Stations, Units 1 and 2 License Renewal Applications Section 2.1 Virginia Electric and Power Company (Dominion)
Docket Nos. 50-280/281 50-338/339 Serial No.: 01-686A Attachment Page 2 of 18 Section 2.1, "Scoping and Screening Methodology" RAI 2.1-1:
During the scoping and screening methodology audit conducted at the applicant's engineering offices from September 10-14,
- 2001, the audit team reviewed implementation procedures and Engineering reports which describe the scoping and screening methodology implemented by the applicant. On the basis of this review, the audit team determined that the Criterion 2 report did not provide a clear description and account of all essential activities in the scoping and screening process related to the determination of Criterion 2 systems, structures, and components (SSCs). While the audit team determined that the actual process implemented by the applicant was conducted in accordance with the requirements of 10 CFR Part 54, the team also concluded that the applicant needs to update these procedures to reflect the actual scoping and screening process upon which the applicant relies. The applicant indicated that they were continuing to develop an implementation program to address the continued use of the scoping and screening process and to incorporate the existing implementation guidance and lessons learned reports from the initial license renewal application (LRA) effort into such a process.
The applicant is requested to confirm that its engineering renewal scoping and screening procedures affected by this issue will be updated to clearly reflect the actual process used, and to specify the time-frame during which this update will be accomplished.
As part of the response to this issue please summarize the actual process which was implemented for the LRA scoping and screening of Criterion 2 SSCs.
Dominion Response:
In a follow-up telephone conversation, the NRC clarified that RAI 2.1-1 relates to a statement in the Dominion Criterion 2 report that excludes certain non-safety related equipment from license renewal scope even though its failure could result in the loss of a safety-related component. The exclusionary statement was intended to be applied whenever the CLB evaluations demonstrate acceptable consequences because the safety-related function(s) have not been compromised.
For example, high-energy line failures outside of Containment have been evaluated as part of the CLB. As stated in North Anna UFSAR Section 3C.2.1, "If such an accident resulted merely in the loss of one or more components, while 100% redundancy of its function exists elsewhere, the design of the system was considered adequate." On the basis of this statement, the high-energy lines that are not subject to augmented inspections were excluded from further consideration under Criterion 2. The Surry high energy lines outside of Containment were treated in the same manner based upon a similar statement presented in Surry UFSAR 14B.2.1.
These high-energy lines and other exclusions are addressed and have been verified to
Docket Nos. 50-280/281 50-338/339 Serial No.: 01-686A Attachment Page 3 of 18 be bounded by the revised methodology presented in the responses to RAIs 2.1-3 and 2.1-4.
Dominion has revised the Criterion 2 Report to delete reference to this exclusionary statement and has supplemented the guidance with the methodology outlined in the responses to RAIs 2.1-3 and 2.1-4.
Docket Nos. 50-280/281 50-338/339 Serial No.: 01-686A Attachment Page 4 of 18 RAI 2.1-2:
In both LRAs, Section 2.1.3.6, "Criterion 2 Report," item b, the applicant states, in part, that non-safety-related (NSR) piping that is attached to safety-related (SR) piping and that is required to be seismically designed and supported up to the first equivalent anchor point beyond the SR/NS or SR/non-seismically qualified (NSQ) boundary, has not been identified during screening.
In both LRAs, Section 2.1.3.6, item c, the applicant, in part, states that "[i]t should be noted that NS and NSQ mechanical components (e.g., piping, tanks, ducting) have not been included within the scope of license renewal for Seismic Il/I because the failure of this equipment during a seismic event has not been postulated in the CLB."
The audit team discussed these issues with the applicant and requested specific clarification regarding the applicants approach to scoping and screening NSR SSCs in accordance with the requirements of 10CFR54.4(a)2. The audit team determined that the applicant did, in fact, bring into scope those SR/NS and SR/NSQ piping segments up through the first equivalent anchor point beyond the SR/NS or SR/NSQ boundary as part of their scoping and screening methodology implementation process, but did not uniquely identify those segments on the applicable plant drawings differently than the SR piping to which they were attached.
However, the staff is requesting that the applicant document the fact that it did include SR/NS and SR/NSQ piping segments up through the first equivalent anchor point beyond the SR/NS or SR/NSQ boundary and describe the implementation process used to include those SSCs.
Dominion Response:
As stated in Section 2.1.3.6 of the LRA, NS/NSQ piping that is attached to SR piping and that is seismically designed and supported up to the first equivalent anchor point beyond the SRPNS or SR/NSQ boundary is included within the scope of the license renewal. Although these NS/NSQ piping segments are not uniquely identified during the screening process or highlighted on LR drawings, applicable aging effects on these piping segments are managed along with the adjoining SR piping.
The supports for the NS/NSQ piping segments are also included within the scope of license renewal as stated in Section 2.1.3.6 of the LRA.
Docket Nos. 50-280/281 50-338/339 Serial No.: 01 -686A Attachment Page 5 of 18 RAI 2.1-3:
In addition to the SR/NS and SR/NSQ piping segments discussed above, an applicant needs to consider 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 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 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.
If an applicant SR SSCs from the consequences of NSR pipe failures, then the applicant should utilize the preventive option, which requires that the entire NSR 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 non-safety-related 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
Docket Nos. 50-280/281 50-338/339 Serial No.: 01-686A Attachment Page 6 of 18
- 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.
Dominion Response:
The methodology implemented by Dominion for scoping of systems, structures, and components (SSCs) meeting the 10CFR54.4(a)(2) criterion is described in the license renewal application in Section 2.1.2.2 "Criterion 2
- Non-Safety-Related Affecting Safety-Related" with further details provided in Section 2.1.3.6 "Criterion 2 Report". As identified in the application, the scoping for 10CFR54.4(a)(2) did not include non-safety related mechanical components, such as piping, tanks, valves, etc., that are considered Seismic Il/I since the failure of these components during a seismic event is not postulated in the current licensing basis. Based on discussions with the NRC staff, the scope under 10CFR54.4(a)(2) is not limited to seismic Il/I supports.
Therefore, Dominion has modified the scope of license renewal for Surry and North Anna to include non-safety related SSC that have a spatial relationship with SSC within the scope of license renewal based on 10CFR54.4(a)(1) and whose failure could impact the performance of an intended safety function.
Non-safety related components have been included within the scope of license renewal using the preventive option described in the request for additional information.
Components that have been considered for inclusion within the scope of license renewal in response to this RAI include piping, valves, tanks, pumps, and other mechanical system equipment.
To determine the non-safety related SSC to be added to the scope of license renewal, the plant structures and spaces that contain both safety-related and non-safety related SSC were identified. These structures are listed in Table 2.1-3-1, and are described in LRA Section 2.4.
After the structures/spaces were identified, the equipment database was reviewed to determine the mechanical systems containing non-safety related components withih these structures and spaces.
From this list of systems, a determination was made whether an assumed failure of the non-safety related components within these systems could impact the performance of an intended function for any SSC in-scope for 10CFR54.4(a)(1) {Criterion 1}. Failure modes considered in the evaluation were pipe whip and jet impingement for high energy systems and fluid leakage, fluid spray, and component displacement (such that physical contact could occur with SSC in-scope for Criterion 1) for all systems. The component-level intended functions of limited structural integrity and pressure boundary were identified for these non-safety related components. The limited structural integrity function is defined as the capability of a component to maintain sufficient integrity to prevent physical interaction with spatially oriented safety-related components.
The pressure boundary function definition is applied to prevent leakage and spray that could affect safety-related components.
Docket Nos. 50-280/281 50-338/339 Serial No.: 01-686A Attachment Page 7 of 18 Table 2.1-3-1:
Structures Containing Non-safety Related Components with Potential Spatial Orientation to Safety-Related Components North Anna Surry Auxiliary Building Auxiliary Building Auxiliary Feedwater Pump House Containment Casing Cooling Pump House Containment Spray Pump Building Containment Fuel Building Fuel Building Fuel Oil Pump House Fuel Oil Pump House High Level Intake Structure Intake Structure Low Level Intake Structure Main Steam Valve House Main Steam Valve House Quench Spray Pump House Service Building Service Building Safeguards Building Safeguards Building Turbine Building Service Water Pump House Service Water Valve House Turbine Building Industry and site operating experience reviews have been conducted to identify potential concerns with aging of non-fluid containing components. No failures due to aging were identified in these reviews. This operating experience is consistent with the results of aging management reviews performed for in-scope components of the same material exposed to the same environments.
Based on this operating experience review, it was concluded that there are no credible aging effects that would result in loss of the limited structural integrity function for non-fluid containing components.
Additionally, non-fluid containing components cannot affect safety-related SSC due to leakage or spray. Therefore, since these non-fluid containing components can not affect the function of safety-related SSC, they were not included within the scope of license renewal for this review. Non-safety related components, whose failure could not impact intended functions based on their location relative to safety-related SSC, were also not included within the scope of license renewal for this review.
The mechanical systems that include components that have been determined to be within the scope of license renewal based on this approach are listed in Tables 2.1-3-2 and 2.1-3-3. Table 2.1-3-2 identifies systems that were previously within the scope of license renewal for which the license renewal evaluation boundary has been extended to include additional components as a result of this review. Table 2.1-3-3 identifies the systems added to the scope of license renewal as a result of this review.
Docket Nos. 50-280/281 50-338/339 Serial No.: 01 -686A Attachment Page 8 of 18 Table 2.1-3-2:
Systems with Increased License Renewal Boundary Due to Expansion of Criterion 2 Scope North Anna Auxiliary Steam (AS)
Boron Recovery (BR)
Component Cooling (CC)
Chilled Water (CD)
Chemical and Volume Control (CH)
Condensate (CN)
Containment Vacuum (CV)
Circulating Water (CW)
Drains Aerated (DA)
Drains - Building Services (DB)
Drains Gaseous (DG)
Fuel Pit Cooling (FC)
High Radiation Sampling (HRS)
Liquid Waste (LW)
Main Steam (MS)
Primary Grade Water (PG)
Quench Spray (QS)
Reactor Coolant (RC)
Radwaste (RW)
Steam Drains (SD)
Safety Injection (SI)
Sampling (SS)
Secondary Vents (SV)
Vents Gaseous (VG)
Vacuum Priming (VP)
Water Treatment (WT)
Surry North Anna Auxiliary Steam (AS)
Bearing Cooling (BC)
Boron Recovery (BR)
Component Cooling (CC)
Chemical and Volume Control (CH)
Condensate (CN)
Containment Vacuum (CV)
Circulating Water (CW)
Drains Aerated (DA)
Drains Gaseous (DG)
Fuel Pit Cooling (FC)
Gaseous Waste (GW)
Heating (HS)
Main Steam (MS)
Primary Grade Water (PG)
Plumbing (PL)
Reactor Coolant (RC)
Recirculation and Transfer (RT)
Steam Drains (SD)
Safety Injection (SI)
Sampling (SS)
Secondary Vents (SV)
Vents Aerated (VA)
Vents Gaseous(VG)
Vacuum Priming (VP)
Ventilation (VS)
Docket Nos. 50-280/281 50-338/339 Serial No.: 01-686A Attachment Page 9 of 18 Table 2.1-3-3:
Systems Added to the Scope of Licensing Renewal Due to Expansion of License Renewal Scope North Anna Surry Bearing Cooling (BC)
Chilled Water (CD)
Decontamination (DC)
Decontamination (DC)
Gaseous Waste (GW)
Liquid Waste (LW)
Water Treatment (WT)
An aging management evaluation was performed for the non-safety related mechanical components that were determined to be within the scope of license renewal.
This review consisted of an evaluation of the effects of aging and identification of activities credited for managing the applicable aging effects based on the results of aging management reviews performed for components of the same material and exposed to the same internal and external environments. This evaluation concluded that the aging effects of loss of material and/or cracking require management and that there are no additional material and environment combinations beyond those currently considered in the application.
The following aging management activities are credited to manage aging effects on external surfaces of in-scope components added as a result of this review:
"* Boric Acid Corrosion Surveillance (LRA Section B2.2.3)
"* General Condition Monitoring Activities (LRA Section B2.2.9)
"* Infrequently Accessed Area Inspection Activities (LRA Section B2.1.2)
The following aging management activities are credited to manage aging effects on internal surfaces of in-scope components added as a result of this review:
"* Chemistry Cont'rol Program for Primary Systems (LRA Section B2.2.4)
"* Chemistry Control Program for Secondary Systems (LRA Section B2.2.5)
"* Secondary Piping and Component Inspection (LRA Section B2.2.16)
"* Service Water System Inspections (LRA Section B2.2.17)
"* Work Control Process (LRA Section B2.2.19)
The aging management activities credited with managing these aging effects are currently described in the license renewal application in the indicated section. These aging management activities are adequate to manage the effects of aging for components within the expanded scope of license renewal for Criterion 2.
A summary of the results of the aging management evaluation for the systems within the scope of license renewal as a result of the expansion of scope for Criterion 2 are provided in Table 2.1-3-4 for North Anna and 2.1-3-5 for Surry.
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Docket Nos. 50-280/281(.
50-338/339 Serial No.: 01-686A Attachment Page 10 of 18 Table 2.1-3-4: Aging Management Evaluation Results for Systems within the Expanded Scope of License Renewal - North Anna System(s)
Intended Material Environment Aging Effect Aging Management Activity Function Group____
_________________s)______
BR, DG, HRS, RH, SS, VG, CH, FC, PG, QS, General Condition Monitoring RC, SI, WT, DA, DB, Stainless Steel Activities DC, LW, RW, AS, BD, LSI, PB (external Air Loss of Material FW, ES, MS, SD, CC, surfaces)
Infrequently Accessed Area CN, CW, SW, CD, CV, Inspection Activities GW, RC, SV, VP, BC
,Carbon Steel, Boric Acid Corrosion Surveillance 2 MS, SD, CC, CN, DBE Low-alloy Steel, Air General Condition Monitoring CW, SW, CD, CV, VA1 LSI, PB and Cast Iron Borated Water Loss of Material Activities GW, RC, SV, VP, BC (external Leakage Infrequently Accessed Area surfaces)
Inspection Activities Boric Acid Corrosion Surveillance 2 WT, DB, AS, BD, FW, Copper Alloys Air General Condition Monitoring ES, MS, SD, CN, CC, LSI, PB (external Borated Water Loss of Material Activities CW, SW, CD, CV, GW,sufc)
Leakage Infrequently Accessed Area Inspection Activities SSubsystem of the DA system.
2 For components inside Containment only
Table 2.1-3-4: Aging Management Evaluation Results for Systems within the Expanded Scope of License Renewal - North Anna Intended Material System(s)
Function GroupMs)
Environment Aging Effect Aging Management Activity Chemistry Control Program for Cracking Primary Systems Stainless Steel Work Control Process BR, DG, HRS, RH, S LSI, PB (internal Treated Water Gsurfaces)
Chemistry Control Program for Loss of Material Primary Systems Work Control Process Stainless Steel Chemistry Control Program for CH, FC, PG, QS, RC, LSI, PB (internal Treated Water Loss of Material Primary Systems SI, WT surfaces)
Work Control Process Carbon Steel, Low-alloy Steel, Raw (Potable)
Cast Iron; Copper Water WT LSI, PB Alloys; and Treated Water Loss of Material Work Control Process Stainless Steel (Chemical mixing (internal and injection) surfaces)
Stainless Steel DA, DB, DC, LW, RW LSI, PB (internal Raw Water Loss of Material Work Control Process surfaces)
Carbon Steel, Low-alloy Steel, Cast Iron and DB LSI, PB Copper Alloys Raw Water Loss of Material Work Control Process (internal surfaces)
Docket Nos. 50-280/281('
50-338/339 Serial No.: 01-686A Attachment Page 11 of 18
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Table 2.1-3-4: Aging Management Evaluation Results for Systems within the Expanded Scope of License Renewal - North Anna System(s)
Intended Material Environment Aging Effect Aging Management Activity Function Group____
__s)_
Chemistry Control Program for Cracking Secondary Systems
(>1 40 F)Work Control Process AS, BD, FW, ES, MS, Stainless Steel Treated Water /
1400 F)
Work Control Process SD, CNLSI, PB (internalSta SD, CN surfaces)
Steam Chemistry Control Program for Loss of Material Secondary Systems Work Control Process Carbon Steel, Chemistry Control Program for Low-alloy Steel, Secondary Systems AS, BD, FW, ES, MS, LSI, PB Cast Iron; and Treated Water Loss of Material Secondary Piping and Component SD, CN Copper Alloys Steam Inspection (internal surfaces)
Work Control Process Carbon Steel, Low-alloy Steel, Cast Iron; Copper Chemistry Control Program for CC LSI, PB Alloys; and Treated Water Loss of Material Primary Systems Stainless Steel Work Control Process (internal surfaces)
Carbon Steel, Low-alloy Steel, Cast Iron; Copper Service Water System Inspections CW, SW LSI, PB Alloys; and Raw (Lake) Water Loss of Material Stainless Steel Work Control Process (internal surfaces)
Docket Nos. 50-280/281(
50-338/339 Serial No.: 01-686A Attachment Page 12 of 18
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Docket Nos. 50-280/281(
50-338/339 Serial No.: 01 -686A Attachment Page 13 of 18 Table 2.1-3-4: Aging Management Evaluation Results for Systems within the Expanded Scope of License Renewal - North Anna System(s)
Intended Material Environment Aging Effect Aging Management Activity Function Group_
__s)_
Carbon Steel, Low-alloy Steel, Chemistry Control Program for Cast Iron; Copper Primary Systems1 CD LSI, PB Alloys; and Treated Water Loss of Material Chemistry Control Program for Stainless Steel Secondary Systems 2 (internal Work Control Process surfaces)
Carbon Steel, Low-alloy Steel, CV, VA3, GW, RC4, S, PB Cast Iron; Copper Air / Gas (with VP LSI, PB Alloys; and potential for liquid Loss of Material Work Control Process Stainless Steel or steam)
(internal surfaces)
Carbon Steel, Low-alloy Steel, Cast Iron; Copper Chemistry Control Program for BC LSI, PB Alloys; and Treated Water Loss of Material Secondary Systems Stainless Steel Work Control Process (internal surfaces)
SFor CD components in support of Containment Air Coolers 2 For CD components in support of Control Room Cooling 3 Subsystem of the DA system.
4 Normally isolated RC system components
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(t Table 2.1-3-5:
Aging Management Evaluation Results for Systems within the Expanded Scope of License Renewal - Surry System(s)
Intended Material Environment Aging Effect Aging Management Activity Function Group(s)
Environment AgingEffect AgingManagementActivity BR, DG, RH, SS, VG, General Condition Monitoring CH, FC, PG, CS, RC, SI, Activities WT, DA, DC, LW, VA, Stainless Steel AS, BD, FW, ES, MS, LSI, PB (external Air Loss of Material SD, CC, CN,, CW, SW, surfaces)
RT, CD, CV, GW, RC, Infrequently Accessed Area SV, VP, BC, HS, PL Inspection Activities WT, PL, AS, BD, CN, Carbon Steel, Boric Acid Corrosion Surveillance 1 FW, ES, HS, MS, SD, Low-alloy Steel, Air General Condition Monitoring CC, CD, CV, GW, RC, LSI, PB and Cast Iron Borated Water Loss of Material Activities VS, VA, VP, BC, CW, (external Leakage Infrequently Accessed Area SW, SV surfaces)
Inspection Activities WT, PL, AS, BD, CN, Boric Acid Corrosion Surveillance' FW, ES, HS, MS, SD, Copper Alloys Air General Condition Monitoring CC, CD, CV, GW, RC, LSI, PB (external Borated Water Loss of Material Activities VS, VA, VP, BC, CW, surfaces)
Leakage Infrequently Accessed Area SW, SV Inspection Activities Stainless Steel Chemistry Control Program for BR, DG, RH, SS, VG LSI, PB (internal Treated Water Cracking Primary Systems surfaces)
(>1400 F)
Work Control Process
' For components inside Containment only Docket Nos. 50-280/281(
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Docket Nos. 50-280/281(
50-338/339 Serial No.: 01-686A Attachment Page 15 of 18 Table 2.1-3-5:
Aging Management Evaluation Results for Systems within the Expanded Scope of License Renewal - Surry System(s)
Intended Material Environment Aging Effect Aging Management Activity Function Group(s)
Enionet AgnEfcAigMaaemn
_ctvt Stainless Steel Chemistry Control Program for BR, DG, RH, SS, VG LSI, PB (internal Treated Water Loss of Material Primary Systems surfaces)
Work Control Process
,Stainless Steel Chemistry Control Program for RT, S1, WT LSI, PB (internal Treated Water Loss of Material Primary Systems surfaces)
Work Control Process Carbon Steel, Low-alloy Steel, Raw Water Cast Iron; Copper (Potable)
WT LSI, PB Alloys; and Treated Water Loss of Material Work Control Process Stainless Steel (Chemical mixing (internal or injection) surfaces)
Stainless Steel DA, DC, LW LSI, PB (internal Raw Water Loss of Material Work Control Process surfaces)
Carbon Steel, Low-alloy Steel, Cast Iron; Copper PL LSI, PB Alloys; and Raw Water Loss of Material Work Control Process Stainless Steel (internal surfaces)
Stainless Steel Chemistry Control Program for AS, BD, CN, FW, ES, LSI, PB (internal Treated Water /
Cracking Secondary Systems HS, MS, SD surfaces)
SteamWork Control Process
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Table 2.1-3-5:
Aging Management Evaluation Results for Systems within the Expanded Scope of License Renewal - Surry System(s)
Intended Material Environment Aging Effect Aging Management Activity Function Group(s)
Environment AgingEffect AgingManagementActivity Stainless Steel Chemistry Control Program for AS, BD, CN, FW, ES, LSI, PB (internal Treated Water /
Loss of Material Secondary Systems Dsurfaces)
Work Control Process Carbon Steel, Chemistry Control Program for Low-alloy Steel, Secondary Systems AS, BD, CN, FW, ES, LSI, PB Cast Iron; and Treated Water/
Loss of Material Secondary Piping and Component HS, MS, SD Copper Alloys Steam Inspection (internal surfaces)
Work Control Process Carbon Steel, Low-alloy Steel, Cast Iron; Copper Chemistry Control Program for CC, CD LSI, PB Alloys; and Treated Water Loss of Material Primary Systems Stainless Steel Work Control Process (internal surfaces)
Carbon Steel, Low-alloy Steel, CV, GW, RC', SV, VA, Cast Iron; Copper Air / Gas (with LSI, PB Alloys; and potential for liquid Loss of Material Work Control Process Stainless Steel or steam)
(internal surfaces)
Normally isolated RC system components
(
Docket Nos. 50-280/281(.
50-338/339 Serial No.: 01 -686A Attachment Page 16 of 18
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Docket Nos. 5 2818 50-338/339 Serial No.: 01-686A Attachment Page 17 of 18 Table 2.1-3-5:
Aging Management Evaluation Results for Systems within the Expanded Scope of License Renewal - Surry System(s)
Intended Material Environment Aging Effect Aging Management Activity Function Group(s)
Carbon Steel, Low-alloy Steel, Cast Iron; Copper Chemistry Control Program for BC, VS LSI, PB Alloys; and Treated Water Loss of Material Secondary Systems Stainless Steel Work Control Process (internal surfaces)
Carbon Steel, Low-alloy Steel, Raw (Brackish)
Service Water System Inspections CW, SW LSI, PB Cast Iron; Copper Water Loss of Material Work Control Process Alloys; and Stainless Steel
Docket Nos. 50-280/281 50-338/339 Serial No.: 01 -686A Attachment Page 18 of 18 RAI 2.1-4:
Given the methodology used to identify piping systems that meet the 10 CFR 54.4(a)(2) scoping criterion, the staff is concerned that there may be other non-safety-related mechanical or structural components which would normally be included within the scope of license renewal, but are excluded because mitigative features have been credited for protecting SR SSCs from the failure of the NSR mechanical or structural component.
If such credit is being taken, please identify these NSR mechanical or structural components and 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
- 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 Dominion Response:
As identified in the application, the scoping for 1 OCFR54.4(a)(2) did not include non safety related mechanical components, such as piping, tanks, valves, etc., that are considered Seismic Il/I since the failure of these components during a seismic event is not postulated in the current licensing basis. For details of the changes made to the scoping results for non-safety related SSC meeting the 1 OCFR54.4(a)(2) scoping criterion, refer to the response to RAI 2.1-3, which is inclusive of mechanical components other than piping.
Non-safety related structural components have been identified for inclusion within the scope of license renewal as described in the license renewal application in Section 2.1.2.2 "Criterion 2 - Non-Safety-Related Affecting Safety-Related" with further details provided in Section 2.1.3.6 "Criterion 2 Report".