ML050040315

License Renewal Application - Responses to NRC Requests for Additional Information Regarding Sections 2.3.2, 2.3.4, and B2. 1.32

ML050040315
Person / Time
Site:	Nine Mile Point
Issue date:	12/21/2004
From:	O'Connor T Constellation Energy Group
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NMP1L 1902, TAC MC3272, TAC MC3273
Download: ML050040315 (50)

Text

Constellation Energy-Nine Mile Point Nuclear Station RO. Box 63 Lycoming, New York 13093 December 21, 2004 NMP1L 1902 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

SUBJECT:

Nine Mile Point Units 1 and 2 Docket Nos. 50-220 and 50-410 Facility Operating License Nos. DPR-63 and NPF-69 License Renewal Application - Responses to NRC Requests for Additional Information Regarding Sections 2.3.2, 2.3.4, and B2. 1.32 (TAC Nos. MC3272 and MC3273)

Gentlemen:

By letter dated May 26, 2004, Nine Mile Point Nuclear Station, LLC (NMPNS) submitted an application to renew the operating licenses for Nine Mile Point Units I and 2.

In a letter dated November 17, 2004, the NRC requested additional information regarding the information contained in Sections 2.3.2, 2.3.4, and B2.1.32 of the License Renewal Application.

The NMPNS responses to these requests for additional information are provided in. Attachment 2 provides a list of the regulatory commitments associated with this submittal.

If you have any questions about this submittal, please contact Peter Mazzaferro, NMPNS License Renewal Project Manager, at (315) 349-1019.

renor Ti o y J. O'C nnor P/

General Manager TJO/DEV/jm

D

I Page 2 NMP1L 1902 STATE OF NEW YORK

TO WIT:

COUNTY OF OSWEGO I, Timothy J. O'Connor, being duly sworn, state that I am Nine Mile Point Plant General Manager, and that I am duly authorized to execute and file this supplemental information on behalf of Nine Mile Point Nuclear Station, LLC. To the best of my knowledge and belief, the statements contained in this submittal are true and correct. To the extent that these statements are not based on my personal knowledge, they are based upon information provided by other Nine Mile Point employees and/or consultants. Such information has been revie in accordance with company practice and I believe it to be reliable.

Subscribed and sworn before me, a Notary Public in and for the tate of New York and County of Oswego, this cl day of.bec-rnabcg

, 2004.

WITNESS my Hand and Notarial Seal:

Notary Public My Commission Expires:

-M CLARK N~tIyPc~n~oNew Yor Date Attachments:

1. Responses to NRC Requests for Additional Information (RAT) Regarding Sections 2.3.2, 2.3.4, and B2. 1.32 of the License Renewal Application

2. List of Regulatory Commitments cc:

Mr. S. J. Collins, NRC Regional Administrator, Region I Mr. G. K. Hunegs, NRC Senior Resident Inspector Mr. P. S. Tam, Senior Project Manager, NRR Mr. N. B. Le, License Renewal Project Manager, NRR Mr. J. P. Spath, NYSERDA

ATTACHMENT 1 Nine Mile Point Nuclear Station Responses to NRC Requests for Additional Information (RAI) Regarding Sections 2.3.2, 2.3.4. and B2.1.32 of the License Renewal Application This attachment provides Nine Mile Point Nuclear Station, LLC (NMPNS) responses to the requests for additional information contained in the NRC letter dated November 17, 2004, regarding Sections 2.3.2, 2.3.4, and B2.1.32 of the License Renewal Application (LRA). For each identified LRA section, the NRC RAI is repeated, followed by the NMPNS response for Nine Mile Point Unit I (NMPI) and/or Nine Mile Point Unit 2 (NMP2), as applicable.

Revisions to the LRA are described where appropriate. The revisions are highlighted by shading unless otherwise noted.

LRA Section 2.3.2, Engineered Safety Features Systems RAI-3.2-1 In Table 3.2.2.A-1 of the License Renewal Application (LRA) the applicant has identified no aging effectsfor wrought stainless steel bolting in an air environnment. The applicant is requested to discuss how cracking and loss ofpre-load resulting in loss of mechanical closure integrity is managed for these bolts. In addition the applicant is requested to address how the aging effects are mnanagedfor inaccessible bolts.

Response

The wrought austenitic stainless steel bolting in an air environment in LRA Table 3.2.2.A-1 is in the NMP1 Containment Spray System. Since the environment was identified in the aging management review (AMR) as air, cracking and loss of preload were not identified as aging effects for wrought austenitic stainless steel bolting. The maximum typical operating temperature (based on the internal environments assigned to components in this system) is

< 140 F. Loss of preload would not typically be an aging effect requiring management for bolting in low temperature systems. NUREG-1801 only specifies loss of preload as an aging effect requiring management for components in the reactor vessel and internals and reactor coolant pressure boundary. The only mechanisms for cracking affecting wrought austenitic stainless steel bolting are stress corrosion cracking and cyclic loading (fatigue). Stress corrosion cracking and thermal fatigue are not aging effects requiring management for wrought austenitic stainless steel at temperatures less than 140CF. Therefore, loss of mechanical closure integrity is not an aging effect requiring management for bolting in the NMP 1 Containment Spray System.

Page 1 of 47

With respect to inaccessible bolts, there are no bolts in the NMP1 Containment Spray System that are inaccessible for examination. The only aging effect requiring management for any bolting in the Containment Spray System is loss of material for carbon or low alloy steel bolting, yield strengths > 100 ksi, in an air environment. This aging effect is managed by the Systems Walkdown Program (described in LRA Section B2.1.33), which performs visual examinations of accessible surfaces for loss of material. The inspection criteria of the Systems Walkdown Program require that bolted joints be inspected for corrosion of external surfaces, and will be enhanced to add inspection for evidence of leakage, which does not require the bolted joints to be disassembled. This enhancement is described in LRA Section B2.1.33 (page B-65), under the "Parameters Monitored/Inspected" heading.

RAI-3.2-2 In Table 3.2.2.A-1 of the LRA, the applicant has identified loss of material as ai aging effect for carbon and low alloy steel (yield strength <100 ksi) and ductile/malleable cast iron filters/strainers in a treated water (<140F), low flow environnent. The applicant has also identified ASME Section ISI, one-time inspection and the water chemnistry controlprogranis for managing this aging effect. The applicant is requested to discuss (a) the periodic visual, surface, and/or voltunetric examination and pressure tests for this component within the ASME Section,ISIprogrami (b) monitoring and controlling concentrations of kiown detrimental chemical species below levels kIown to cause degradation as they relate to carbon or low alloy steel and ductile/malleable cast iron filters in the environment identified above (c) the basisfor selecting a representative sample for the one-time inspection.

Response

The carbon and low alloy steel (yield strength <lOOksi) and ductile/malleable cast iron filters/strainers in a treated water (<1400F), low flow environment, in LRA Table 3.2.2.A-1, applies to the four (4) Containment Spray Pump Discharge Strainers (STR-80-09, STR-80-1 0, STR-80-29, and STR-80-30). The internals of these strainers were removed as part of the modification to address NRC Bulletin 96-003, "Potential Plugging of Emergency Core Cooling Suction Strainers by Debris in Boiling-Water Reactors." Additionally, the strainer bodies are made of carbon steel such that the "ductile/malleable cast iron" component of the material description doesn't apply.

(a) These are ASME Section XI Class 2 components. As such, the bodies of the strainers are subject only to the VT-2 examination under examination category C-H, "All Pressure Retaining Components." The VT-2 examination is conducted during the system pressure test during each inspection period. VT-2 examinations are conducted to detect evidence of leakage only.

(b) LRA Table 3.2.2.A-1 indicates that the subject strainers are exposed to a treated water (temperature <1400F), low flow environment. The water source is torus water, so the environment for these strainers should have been identified as demineralized untreated water, low flow. The chemistry action levels and sampling frequencies for the torus water specified in procedure S-CTP-V666, "Auxiliary Systems Chemistry," are provided in the table below.

Page 2 of 47

Parameter Action Level 1 Sampling Frequency Conductivity 5 IS/cm Quarterly Chloride/Sulfate 200 ppb Quarterly Total Organic Content (TOC) 1000 ppb Quarterly These limits are identical to those specified in Electric Power Research Institute (EPRI) TR-103515-R2, "BWR Water Chemistry Guidelines - 2000 Revision," dated February 2000.

(c) As presented in LRA Sections A1.1.28 and B2.1.20, the One-Time Inspection Program is a new aging management program (AMP) commitment for NMPNS that is to be implemented prior to the period of extended operation. This commitment was made in the original LRA submittal, as supplemented by NMPNS letter NMP1L 1880 dated October 29, 2004. As indicated in the October 29, 2004 letter, the method of selecting the representative sample will be consistent with EPRI TR-107514, "Age-Related Degradation Inspection Method and Determination."

LRA Revisions LRA Section 3.2.2.A.1 (page 3.2-4), under the "Environments" heading, is revised to add the following environment:

"Demineralized Untreated Water, Low Flow" LRA Table 3.2.2.A-1 is revised to reflect this change, as shown on the following page.

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1. I Table 3.2.2.A-1 Engineered Safety Features Systems NMP1 Containment Spray System - Summary of Aging Management Evaluation Aging Effect NUREG-Component intended Material Environment R ing Aging Management 1801 Table I Notes Type Function eqtigProgram Volume 2 Item Management Item Filters/Strainers PB Carbon or Low Demineralized Loss of Material ASME Section Xi Q

(cont'd)

Alloy Steel Untreated Inservice Inspection (Yield Strength Water, Low (Subsections IWB.

< 100 Ksi)

Flow IWC. IWD) Program One-Time Inspection Program Water Chemistry Control Proaram Page 4 of 47

RAI-3.2-3 In Table 3.2.2.A-1 of the LRA the applicant has identified no aging effects for wrought stainless steelfilters and strainers in a treated water (<140 0F) loivflow environment. The applicant is requested to discuss the tests and inspections to assure that the treated water remainsfree of contaminants.

Response

As noted in LRA Table 3.2.2.A-1, the Water Chemistry Control Program is one of the AMPs credited for managing the carbon steel subcomponents associated with this component type.

This NMP1 program is responsible for ensuring that treated water remains free of contaminants.

The NMP1 Water Chemistry Control Program is described in LRA Section B2.1.2, as supplemented by NMPNS letter NMP1L 1880 dated October 29, 2004.

The subject filter strainers are in the Containment Spray system. The water source is torus water, so the environment for these strainers should have been identified as demineralized untreated water, low flow. The chemistry action levels and sampling frequencies for the torus water are provided in the response to RAI 3.2-2 above. These limits are identical to those specified in EPRI TR-103515-R2, "BWR Water Chemistry Guidelines - 2000 Revision," dated February 2000.

RAI-3.2-4 In Table 3.2.2.A-1 of the LRA, the applicant has identified cracking as an aging effect for wrought austenitic stainless steelflow elements and valves in a raw water environment. The applicant has proposed to manage this aging effect by the open-cycle cooling water system program. The applicant is requested to discuss the visual, VT or other inspection mnethods for these components. In addition the applicant is requested to discuss thefrequency of these inspections, acceptance criteria and the bases thereof

Response

LRA Table 3.2.2.A-1 is in error with respect to identifying cracking as an aging effect for wrought austenitic stainless steel components in a raw water environment. Consistent with NUREG-1801 guidelines (i.e., Item VII.C1.1-a), the aging effect for this material/environment combination should be loss of material due to pitting corrosion, crevice corrosion, microbiologically influenced corrosion, and biofouling.

LRA Table 3.2.2.A-1 correctly credits the Open-Cycle Cooling Water System (OCCWS)

Program for components in a raw water environment. The current program descriptions for the OCCWS Program (LRA Sections A1.1.29 and B2.1.10) will be modified to include an enhancement to develop procedures to address loss of material for the NMPI Containment Spray Raw Water System. The required enhancement will be implemented prior to the period of extended operation. The OCCWS Program Attribute Assessment (PAA) addresses program Page 5 of 47

implementation at NMPNS relative to the requirements of Appendix A of NUREG-1800. The OCCWS PAA is available on-site at NMPNS for review.

LRA Revisions.

LRA Table 3.2.2.A-1 is revised, as shown on the following page, to remove the lines for "Cracking" of "Flow Elements" (LRA page 3.2-38) and "Valves" (LRA page 3.2-43) fabricated of wrought austenitic stainless steel in a raw water, low flow environment. Thus, only "Loss of Material" remains as an aging effect requiring management (AERM) for these components in that material/environment combination.

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a Table 3.2.2.A-1 Engineered Safety Features Systems NMPI Containment Spray System - Summary of A ing Management Evaluation Component Intended Material Environment Aging Effect Aging Management NUREG-Table I Notes Type Function Requiring Program 1801 Item Management Volume 2 Ite m Flow Elements PB Wrought Raw Water, Loss of Material Open Cycle Cooling Vll.C1.2-a 3.3.1.A-17 C, 2 Austenitic Low Flow Water System Stainless Steel Program Table 3.2.2.A-1 Engineered Safety Features Systems NMP1 Containment Spray System - Summary of Aging Management Evaluation Component Intended Material Environment Aging Effect Aging Management NUREG-Table I Notes Type Function Requiring Program 1801 Item Management Volume 2

_ _ _ _ _ _ _ _ _ _ _Ite m

Valves PB Wrought Raw Water, Loss of Material Open Cycle Cooling VII.C1.2-a 3.3.1.A-17 A

Austenitic Low Flow Water System Stainless Steel Program Page 7 of 47

In LRA Section A.1.1.29 (page Al-13), the following is added at the end of the program description:

"Enhancements to the Open-Cycle Cooling Water System Program are required to include development of procedures to address loss of material for the NMP I Containment Spray System. The enhancements are scheduled for completion prior to the period of extended operation."

In LRA Section B2.1.10 (page B-24), under the "Enhancements" heading, "None" is replaced by the following:

"Enhancements to the Open-Cycle Cooling Water System Program are required to include development of procedures to address loss of material for the NMPl Containment Spray System. The enhancements are scheduled for completion prior to the period of extended operation."

RAI-3.2.5 In Table 3.2.2.A-1 of the LRA, the applicant has identified loss of material as an aging effect for gray cast iron ptumps in a raw vater enviroitnment. This aging effect is proposed to be managed by the open-cycle cooling water system program and the selective leaching of materials program. The applicant is requested to discuss (a) the visual, VT or other inspection methodsfor this component as well as the frequency of inspections acceptance criteria and the bases thereof (b) bases for sampling of components and the inspection method to detect selective leaching. Also indicate whether or not hardness tests would be performed.

Response

(a)

For the four gray cast iron pumps of the NMP1 Containment Spray System subject to AMR, the aging effect requiring management is loss of material. The aging mechanisms to be managed by the Open-Cycle Cooling Water System Program include crevice corrosion, erosion, galvanic corrosion, general corrosion, microbiologically influenced corrosion, and pitting corrosion. This program will be enhanced to specify the inspection method (e.g.

visual, VT, or other) and frequency before the period of extended operation. Sections Al.1.29 and B2.1.10 of the LRA will be revised to reflect this enhancement (see the response to RAI 3.2-4).

(b)

For the four gray cast iron pumps of the NMP 1 Containment Spray System subject to AMR, the pump bowls are vulnerable to the same aging mechanisms as identified in the response to Part (a) above, plus selective leaching.

As presented in LRA Sections A1.1.33 and B2.1.21, the implementation of the Selective Leaching of Materials Program is discussed in the program description for the One-Time Inspection Program (see LRA Section B2.1.20). The basis for selecting a representative sample for the one-time inspection is as follows (from LRA Section B2.1.20, as supplemented by NMPNS letter NMP1L 1880 dated October 29, 2004):

Page 8 of 47

"The process for identifying the population of potentially affected components will be based upon common characteristeics of the components, such as material of construction, fabrication process, operating environment, and aging effects. From the selected population, a sample size will be determined to provide a 90 percent confidence that 90 percent of the population does not have the degradation mechanism present. This terminology and methodology are consistent with EPRI TR-107514, 'Age Related Degradation Inspection Method and Determination."'

A determination of whether hardness tests are necessary will be made at the time of One-Time Inspection Program implementation. This is consistent with LRA Section B2.1.20 (page B-43), which states: "Inspection techniques may include a one-time visual inspection and hardness measurement."

Hardness testing will be considered as a possible inspection technique if visual examination techniques alone cannot determine if selective leaching severe enough to affect the component intended function is occurring. The use of field hardness testing will also be contingent on the accessibility of the affected component surfaces to perform the test.

Hardness testing on components susceptible to selective leaching may be appropriate if the component configuration and geometry allows. Tubing and other components such as valves with complex internal geometry do not provide adequate physical access to internal surfaces requiring examination to allow accurate measurements to be made.

The Selective Leaching of Materials Program is a new program that will be developed and implemented prior to the period of extended operation. The Selective Leaching of Materials Program is addressed in the One-Time Inspection Program Attribute Assessment (PAA), which addresses program implementation at NMPNS relative to the requirements of Appendix A of NUREG-1800. The One-Time Inspection PAA is available on-site at NMPNS for review.

RAI-3.2-6 In Table 3.2.2.A-1 of the LRA, the applicant has identified loss of material as an aging effect for copper alloys (zinc <15%) valves in a wetted air (<140 CF) environment. This aging effect vill be managed by the open-cycle cooling water system program. The applicant is requested to discuss the visual VT or other inspection methods for this component as lvell as the frequency of inspections, acceptance criteria and the bases thereof In addition the applicant is requested to provide its operating experience with these copper alloy valves in this environment.

Response

NMPNS has determined that the material/environment combination of copper alloy (zinc content Cl 5%) valves in an environment of air, moisture or wetting, temperature <1400F. should have no aging effects requiring management with the exception of loss of heat transfer. Loss of heat transfer applies only to components with an intended function of heat transfer, which does not apply to the subject valves. LRA Table 3.2.2.A-1 will be revised to indicate that the line item of valves, with a material of copper alloy (zinc content <15%), and in an environment of air, Page 9 of 47

moisture or wetting, temperature <140 F, has no aging effects requiring management and, therefore, no AMP is required for this line item.

NMP1 has valves with a material of copper alloy (zinc content *15%) in an environment of raw water, low flow. NMP has significant operating experience supporting the conclusion that there are no aging effects requiring management for this material/environment combination, other than loss of heat transfer for components with a heat transfer intended function. However, the aging effect of loss of material was assigned to this material/environment combination based on data in the literature and industry experience. Therefore, copper alloy (zinc content *15%) valves in an environment of raw water, low flow have the aging effect of loss of material with the Open-Cycle Cooling Water Program as the AMP. A new activity under the Open-Cycle Cooling Water Program is designated to manage loss of material for these valves. This activity is also currently assigned to manage loss of material for the copper alloy (zinc content <15%) valves in an environment of air, moisture or wetting, temperature <1400F, which is to be changed. The new activity will manage loss of material for all components in a raw water environment in the Containment Spray System. Details of the inspections to be performed have not been determined. Inclusion of the containment spray system in the description of the scope of the Open-Cycle Cooling Water Program, and identification of this new activity as an enhancement to the Open-Cycle Cooling Water Program were inadvertently omitted from LRA Appendix Al.1.29 and B2.1.10. LRA Appendix Al.1.29 and B2.1.10 will be revised to include the Containment Spray System in the description of the scope of the program, and to describe the enhancements to develop new activities to inspect for loss of material for components in the NMPI Containment Spray System.

LRA Revisions See the response to RAI 3.2-4 for changes to LRA Sections A1.1.29 and B2.1.10 regarding enhancements to the Open-Cycle Cooling Water System Program.

LRA Table 3.2.2.A-1 (page 3.2-43) is revised to remove the aging effect and aging management program for Copper Alloy valves in a moist air environment, as shown on the following page.

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I, Table 3.2.2.A-1 Engineered Safety Features Systems NMPI Containment Spray System - Summary of Aling Management Evaluation Component Intended Material Environment Aging Effect Aging Management NUREG-Table I Notes Type Function Requiring Program 1801 Item Management Volume 2 Item Valves PB Copper Alloys Air with None None None (Zinc *15%)

Moisture or

Wetting, temperature

< 1400F Page 11 of 47

4 RAI-3.2-7 In Table 3.2.2.A-2 bf the LRA, the applicant has identified cracking as an aging mechanisn for wrought austenitic stainless steelfilters and strainers in a treated water (temperature >140 0F but <212 0F) lowflow environment. This aging effect would be managed by the one-time inspection and the water chemistry control progranis. The applicant is requested to discuss the specific tests and inspections, frequency of inspections and acceptance criteria to assure that the strainers and filters perform their intendedfunction in the environment identified above.

Response

The components addressed by this AMR line item are the two Core Spray Pump suction strainers located in the torus. Torus water is managed under the Water Chemistry Control Program, which is described in LRA Section B2.1.2, as supplemented by NMPNS letter NMPIL 1880 dated October 29, 2004. The chemistry action levels and sampling frequencies for the torus water are provided in the response to RAI 3.2-2. These limits are identical to those specified in EPRI TR-103515-R2, "BWR Water Chemistry Guidelines - 2000 Revision."

The One-Time Inspection Program is described in LRA Section B2.1.20, as supplemented by NMPNS letter NMP1L 1880 dated October 29, 2004. The One-Time Inspection Program is a new program that will be implemented prior to the period of extended operation. As such, the procedures needed to answer this question have not yet been developed. However, the One-Time Inspection Program will be consistent with NUREG-1801,Section XI.M32 (One-Time Inspection) when implemented. The One-Time Inspection Program Attribute Assessment (PAA) addresses program implementation at NMPNS relative to the requirements of Appendix A of NUREG-1 800. The One-Time Inspection PAA is available on-site at NMPNS for review.

RAI-3.2-8 In Table 3.2.2.A-2 of the LRA, the applicant has identified no aging effects for copper alloys (zinc > 15%) and aluminum bronze heat exchangers components in a lubricating oil environment. The applicant is requested to discuss its inspection and test activities to ensure that the lubricating oil renmains free of contaminants and water content.

Response

Lube oil samples from the NMP 1 Core Spray Pump motor cooler (i.e., heat exchanger) oil subsystems are obtained on an annual basis in accordance with site procedure N1-CTP-V520, "Lube Oil Sampling," and the oil sample results are evaluated and trended. Any indication of an anomalous condition or adverse trend will result in an investigation under the site corrective action program.

Page 12 of 47

RAI-3.2-9 In Table 3.2.2.A-2 of the LRA, th6 applicant has indicated loss of material as an aging effectfor gray cast iron piping andfittings as an aging effect in an air environment. It is proposed to manage this aging effect by the system ivalkdown program. Since this aging management program is applicable to accessible exterior surfaces only the applicant is requested to discuss how degradation on inaccessible internal surfaces ofpiping and fittings will be managed.

Response

LRA Table 3.2.2.A-2 contains an error. On page 3.2-46, there is a line item for external aging management of gray cast iron piping. There is, in actuality, no gray cast iron piping in this system. As can be seen on page 3.2-47, there are gray cast iron pumps. The pump bowls are made of gray cast iron and are managed by the Water Chemistry Control, One-Time Inspection, and Selective Leaching Programs. There are no accessible external surfaces for these sub-components; therefore, the Systems Walkdown Program is not applicable.

LRA Table 3.2.2.A-2 will be revised to delete the line item for gray cast iron piping and fittings.

LRA Revisions LRA Table 3.2.2.A-2 (page 3.2-46) is revised to remove the line for gray cast iron piping and fittings, as shown on the following page.

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aI gi Table 3.2.2.A-2 Engineered Safety Features Systems NMPI Core Sp ay System - Su mary of Aging M nagement Evaluation Aging Effect NUREG-Component Intended rial Environment Requiring Aging Management 1801 Table I Notes TpFucinManagement Program Volume 2 Item

___Ite m

Piping and PB Carbon or Low Air Loss of Material Systems Walkdown V.E.1-b 3.2.1.A-10 A, 4 Fittings Alloy Steel Program (Yield Strength Air with Loss of Material One-Time Inspection V.D2.1-e 3.2.1.A-03 A

< 100 Ksi) and Moisture or Program 3.2.1.A-05 Ductile/Malleable

Wetting, Cast Iron temperature

< 1400F Treated Water, Loss of Material One-Time Inspection V.D2.1-a 3.2.1.A-02 B

Temperature Program 21400F, but

< 2120F, Low Water Chemistry Flow Control Program Wrought Air with Loss of Material One-Time Inspection V.D2.1-e 3.2.1.A-05 A

Austenitic Moisture or Program Stainless Steel

Wetting, temperature

< 1400F Treated Water, Cracking ASME Section XI V.D2.1-c 3.2.1.A-16 E

temperature Inservice Inspection 21400 F, but (Subsections IWB,

< 2120F, Low IWC, IWD) Program Flow Water Chemistry Control Program Page 14 of 47

RAI-3.2-1 0 In Table 3.2.2.A-2 of the LRA, the applicant has identified loss of material as an aging effectfor gray cast iron pump components in a treated water environment (temperature >140 TF but

<212 F), low flow environment. The applicant is requested to provide (a) the basis for selecting a representative sample for the one-time inspection (b) inspection methods to detect selective leaching. Also indicate whether or not hardness tests would be performed.

Response

(a)

The basis for selecting a representative sample for the one-time inspection is as follows (from LRA Section B2.1.20, as supplemented by NMPNS letter NMP1 L 1880 dated October 29, 2004):

"The process for identifying the population of potentially affected components will be based upon common characteristics of the components, such as material of construction, fabrication process, operating environment, and aging effects. From the selected population, a sample size will be determined to provide a 90 percent confidence that 90 percent of the population does not have the degradation mechanism present. This terminology and methodology are consistent with EPRI TR-107514, 'Age Related Degradation Inspection Method and Determination."'

(b)

The inspection methods used to detect selective leaching will be consistent with LRA Section B2.1.20 (page B-43), which states: "Inspection techniques may include a one-time visual inspection and hardness measurement."

Hardness testing will be considered as a possible inspection technique if visual examination techniques alone cannot determine if selective leaching severe enough to affect the component intended function is occurring. The use of field hardness testing will also be contingent on the accessibility of the affected component surfaces to perform the test. Hardness testing on components susceptible to selective leaching may be appropriate if the component configuration and geometry allows. Tubing and other components such as valves with complex internal geometry do not provide adequate physical access to internal surfaces requiring examination to allow accurate measurements to be made.

The One-Time Inspection Program, which includes the Selective Leaching of Materials Program, is a new program that will be developed and implemented prior to the period of extended operation. The One-Time Inspection Program Attribute Assessment (PAA) addresses program implementation at NMPNS relative to the requirements of Appendix A of NUREG-1800. The One-Time Inspection Program PAA is available on-site at NMPNS for review.

Page 15 of 47

RAI-3.2-1 1 In Table 3.2.2.A-3 of the LRA, the applicant has identified cracking and loss of iaterialfor the carbon or low allow'steel (yield strength >100 ksi) bolting in non-borated water environment (temperature >212 7F). These aging effects would be managed by the fatigue monitoring program and the.ASME Section XISI (subsections IJB, IWC anzdIWD) Programs. The applicant is requested to discuss how loss ofpre-load resulting in mechanical closure integrity would be managed for these bolts. In addition the applicant is requested to discuss the aging management of inaccessible bolts.

Response

The carbon or low allow steel (yield strength >100 ksi) bolting in non-borated water environment (temperature 2 212'F) described in LRA Table 3.2.2.A-3 consists of closure bolting in the Emergency Cooling System.

ASME Section XI requires visual (VT-1) and volumetric examination of Class 1 and 2 bolts greater than 2 inch diameter and VT-1 examination of Class 1 bolts 2 inches and less in diameter.

Class 2 bolts 2 inches and less in diameter and Class 3 bolts are subject to a VT-2 examination for leakage. Joint leakage would be detected by both the VT-2 and VT-I examinations. The VT-1 examinations would detect loss of material due to general corrosion, which is a consequence ofjoint leakage. Volumetric examination would detect cracking caused by stress corrosion cracking or any other mechanism, such as cyclic loading or fatigue. Note that the emergency cooling system has no bolts larger than 2 inches in diameter.

A site design specification provides guidelines for determining bolt torques, which control preloads. These guidelines are referenced in site mechanical maintenance procedures used for preventive and corrective maintenance.

There are no bolts that are inaccessible for examination. ASME Section XI allows a VT-I examination of the bolted joint while the bolting is in-place under tension.

The LRA will be changed to credit the Fatigue Monitoring Program with managing the aging effect of cumulative fatigue damage, rather than cracking, for the bolts. This is part of a generic LRA change to replace cracking with cumulative fatigue damage as the aging effect managed by the Fatigue Monitoring Program. As such, the Fatigue Monitoring Program will no longer be credited for managing the aging effect of cracking. This change will be reflected in an LRA supplemental letter to be submitted by NMPNS by February 28, 2005.

Page 16 of 47

RAI-3.2-12 Il LRA Table 3.2.2.A-3 the applicant has credited the preventive maintenance program for managing the aging effects of cracking and loss ofimaterial of vrought austenitic stainless steel heat exchanger components in moist air (temperature > 140 0F) environment. Thle applicant is requested to provide the folloiving informnation for these heat exchanger components:

(a) parameters monitored or inspected (b) nmethods of detection of the aging effects (c) frequency of inspections including monitoring and trending (d) acceptance criteria and their bases

Response

The subject wrought austenitic stainless steel heat exchangers in a moist air (temperature 2 1400F) environment listed in LRA Table 3.2.2.A-3 consist of the four NMP1 Emergency Condensers. The aging effects requiring management are cracking and loss of material.

By letter NMP1L 1892 dated December 6, 2004, NMPNS submitted supplemental information related to LRA Section 3.1 which included revisions to the aging management programs for the NMP1 Emergency Condensers. Specifically, LRA Table 3.1.1.A item numbers 3.1.1.A-03 and 3.1.1.A-09 were revised to indicate that the Emergency Condensers were managed by a combination of the Water Chemistry Control, ASME Section XI Inservice Inspection (Subsections IWB, IWC and IWD) and Preventive Maintenance Programs.

Continuous radioactivity monitoring of the emergency condenser vent is also provided in the Control Room. Also, a justification for not performing eddy current testing of the condenser tubes was provided. These changes will be reflected in LRA Table 3.2.2.A-3.

Since the Water Chemistry Control and ASME Section XI Programs are well established in the industry and credited in NUREG-1 801, and since the NMPNS programs are consistent with the guidelines described in NUREG-1 801 with justified exceptions, the four categories of information requested above will be provided for the Preventive Maintenance Program only.

(a)

The Preventive Maintenance Program includes temperature monitoring of water in the emergency cooling steam and return lines adjacent to the Emergency Condensers and in the shell of the Emergency Condensers. As such, the parameters monitored are temperature of the water at the inlet and outlet of the condensers and on the shell side of the condensers.

(b)

The methods of detection of the aging effects of cracking and loss of material are through the potential impacts to system temperatures. This is consistent with the guidelines provided in NUREG-1 801, Volume 2, item number IV.C1.4-a.

(c)

Temperature monitoring of the Emergency Condensers is conducted continuously through installed instrumentation, with local indications and alarms in the control room. Twice a year, the temperature data is collected and analyzed to determine if any detrimental effects have occurred.

Page 17 of 47

SU (d)

The temperature monitoring procedure contains separate acceptance criteria for the steam inlet piping, emergency condenser shell water, and condensate return line piping. The acceptance criteria are based upon design analyses to prevent damage to the piping and condensers.

LRA Revisions The required changes to LRA Table 3.2.2.A-3 (pages 3.2-52 and 3.2-53) and to the Notes for Tables 3.2.2.A-1 through 3.2.2.B-6 (page 3.2-113) are shown on the following pages.

Page 18 of 47

Table 3.2.2.A-3 Engineered Safety Features Systems NMPI Emergency Cooling System - Summary of Aging Management Evaluation Aging Effect NUREG-Component Intended AgMaterial Environment Requiring Management 1801 Table I Notes.

TpFucinManagement Program Volume 2 Item Heat HT Wrought Treated Water Cracking, Loss ASME Section Xi IV.C1.4-a, 3.1.1.A-09 B. 16 Exchangers PB Austenitic or Steam, of MWterial Inservice InspectiOn...

Stainless Steel temperature (Subsections IWB; 2212 0F, but IWC and IWD)

< 4820F Preventive Maintenance Program Water Chemistry Control Program Treated Water Cracking, Loss ASME Section Xi IV.C1.4-al 3.1.1.A-09 B 16 or Steam, of Material Inservice Inspection temperature (Subsections IWBl 2482*F IWC and IWD)

Preventive Maintenance Program Water Chemistry Control Proqram PB Wrought Air with Cracking, Loss ASME Section Xi G

Austenitic Moisture or of Material inservice Inspection Stainless Steel

Wetting, (Subsections 1WB3 temperature IWC and IWD)

>14O0 F Preventive Maintenance Program Page 19 of 47

.1 Table 3.2.2.A-3 Engineered Safety Features Systems NMP1 Emergency ooling System - Summary of Aging Management Evaluation Aging ffectNUREG-Component Intended Material Environmen Requiring Aging Management 1801 Table N

Type Function ManaglEvionenemeirnt Program volume 2 Item Noe I__

M anagement___

Item '_

Heat PB (cont'd)

Wrought Treated Water, Cracking, Loss ASME Section Xi IV.C1.4-a1 3.1.1.A-09 B, 16 Exchangers Austenitic Temperature of Material insdivice Inspection b

(cont'd)

Stainless Steel 140F, but (Subsections IWB, (cont'd)

< 2120F IWC and IWD)

Preventive Maintenance Program Water Chemistry Control Program Treated Water Cracking, Loss ASME Section XI IV.C1.4-al 3.1.1.A-09 B. 16 or Steam, Material Inservice Inspection B

temperature (Subsections IWBi4 2212°F, but IWC and IWD)

< 4820F Preventive Maintenance Program Water Chemistry Control Program Page 20 of 47

II t*

Table 3.2.2.A-3 Engineered Safety Features Systems NMP1 Emergency Cooling System - Summary of Agi g Management Evaluation Aging Effect NUREG-Component Intended Material Environment Requiring Aging Management 1801 Table I Notes Type Function Matrilnnvrometmequrng Program Volume 2 Item ManagmentItem Heat PB (cont'd)

Wrought Treated Water Cracking, Loss ASME Section Xl IV.C1.4-a) 3.1.1.A-09 B, 16 Exchangers Austenitic or Steam, of faterial Inservice Inspection i

(cont'd)

Stainless Steel temperature (Subsections 1WB, (cont'd)

-4820F IWC and IWD)

Preventive Maintenance Program Water Chemistry Control Program Notes for Tables 3.2.2.A-1 through 3.2.2.B-6: (p 3.2-113)

16.

This row applies to the Emergency Condensers, which fe-atur all Welded constructionfTl are no-Class 1 component-sthat undergo an Inservice Inspection Testing Program pressure test and utilize a Preventive Maintenance Program procedure for temperature monitoring. Continuous radiation monitoring of the condenser vent via an installed radiation monitor is also credited. Additionally, the Water Chemistry Control Program is credited for these components.

Page 21 of 47

IC, RAI-3.2-1 3 In LRA Table 3.2.2.A-3 the applicant credits the system walkdoiwn program and water chemistry control program for managing the aging effects of cracking and loss of materialfor non-safety related piping, fittings and equipment in treated water or steam environment (temperatures rangingfrom <140 T to >212 °F but <482 F), lowflow environnients. The applicant is requested to provide the following with respect to the system wvalkdowvn program:

(a) parameters monitored or inspected (b) frequency of inspections and the bases thereof (c) acceptance criteria

Response

The AMR line item identified above addresses the Emergency Cooling System drain lines outboard of the isolation valves to the main steam lines.

(a)

The parameters monitored by walkdown inspections currently include:

• Surface corrosion for the "Loss of Material" aging effect of LRA Table 3.2.2.A-3

• Surface cracking, leakage, and indications of leakage for the "Cracking" aging effect of LRA Table 3.2.2.A-3 (b)

The frequency of inspection of the parameters monitored for the Emergency Cooling System is once per refuel cycle. This frequency was determined to be adequate based on system operating experience since the aging effects are typically caused by aging mechanisms over the long-term. Therefore, the inspections will be able to identify and correct any adverse aging effect prior to the loss of intended function.

(c)

The acceptance criterion for the system walkdown inspections is no evidence of aging. If any evidence is observed (i.e., corrosion, surface cracking, or leakage), the site corrective action program is utilized to evaluate the condition for impact on component and system functions, and to identify appropriate corrective action.

RAI-3.2-14 In LRA Table 3.2.2.A-3 the applicant indicated no aging effects for tanks made ofpure aluminum alloys and alwtninum alloys with manganese, niagnesium and magnesium plus silicon in a treated wvater (temperature <140 0F) environment. The applicant is requested to provide the following information (a) ASTM designation or specific alloy content of the material (b) basis for arriving at the conclusion that no aging effects occur in this environment (for example, provide reference EPRI, or ASTM or similar documents which provide data to support this conclusion).

Response

There are two tanks in the NMP 1 Emergency Cooling System that are made of aluminum alloy with magnesium in a treated water (temperature <140'F) environment. These tanks (TANK Page 22 of 47

09 and TANK-60-10) provide the demineralized water make-up to the emergency condensers and are in-scope and subject to AMR.

(a)

The tanks are made of wrought-aluminum alloy 5052-H34, which is essentially pure aluminum with 2.5% magnesium and 0.25% chromium.

(b)

Aluminum alloyed with magnesium has good corrosion resistance in a treated water (temperature <1400F) environment and resists stress corrosion cracking. Reference Section 2.1.7 and Section 4 of Appendix A of EPRI TR-1 14882, "Non-Class 1 Mechanical Implementation Guideline and Mechanical Tools," Revision 3.

RAI-3.2-15 In Table 3.2.2.A-3 of the LRA, the applicant credits ASME Section Xl7Slprograin, one-time inspection and water chemistry control program for managing the aging effect cracking of aliwninum alloy (containing copper or zinc as the primary alloying elements) valves in a treated water (temperature <140 7F) environment. The applicant is requested to provide thefollowing information (a) ASTM designation or specific alloy content of the material (b7 basis for concluding that cracking is the only aging effect in this environment. Provide EPRI, ASTM or similar documentary references which support this conclusion.

Response

There are six valves in the NMP1 Emergency Cooling System that are made of aluminum alloy (containing copper or zinc as the primary alloying elements) in a treated water (temperature

<140'F) environment. These valves (BV-60-01, BV-60-02, VLV-60-07, VLV-60-08, VLV 11 and VLV-60-12) are in-scope and subject to AMR.

(a)

The valves are made of aluminum alloy SB-26 (no grade).

(b)

Aluminum alloyed with copper or zinc as the primary alloying elements is resistant to general corrosion in a treated water (temperature <1400F) environment, but is susceptible to stress corrosion cracking. Reference EPRI TR-1 14882, "Non-Class 1 Mechanical Implementation Guideline and Mechanical Tools," Revision 3.

RAI-3.2-16 In Table 3.2.2.B-3 of the LRA, the applicant credits the systeni valkdoiwn program for managing the loss of material aging effect of carbon or low allow steel (yield strength >100 ksi) and martensitic precipitation hardened and superferritic stainless steel bolting in a mnoist air (temperature <140 "F) environnient. Tle applicant is requested to provide the following information (a) test or analytical data such as EPRI or ASTM docutments which support the conclusion that loss of material is the only aging effect which would occur in this environment and SCC, loss ofpre-load and cracking will not occur (b) inspection niethods, frequency of inspections and acceptance criteria associated with the system walkdoivn program are equivalent to the bolting integrity program recommended in the GALL report.

Page 23 of 47

Response

There is no bolting with the materiallenvironment combinations of carbon or low allow steel (yield strength >100 ksi) and martensitic precipitation hardened and superferritic stainless steel bolting in a moist air (temperature < 140'F) environment in LRA Table 3.2.2.B-3 (NMP2 Low Pressure Core Spray Systems). However, these material/environment combinations are found in Table 3.2.2.B-1 (NMP2 Hydrogen Recombiner System), Table 3.2.2.B-2 (NMP2 High Pressure Core Spray System), and Table 3.2.2.B-6 (NMP2 Standby Gas Treatment System), with loss of material managed by the Systems Walkdown Program.

EPRI NP-5769, "Degradation and Failure of Bolting in Nuclear Power Plants," Table 1-4, lists incidents of stress corrosion cracking in nuclear power plants. For martensitic stainless steels, there are two incidents documented. One incident at LaCrosse, a BWR, involved 12%

Chromium reactor vessel closure studs. Contributing factors to the failure were an aqueous environment during an outage, improper heat treatment, and galvanic action resulting from silver plating breakdown. The other incident was for Type 410 stainless steel valve studs at Rancho Seco, with improper heat treatment the only listed contributing factor. The service temperature for the valve studs was not provided. The only experience listed for precipitation hardenable bolting material is in a reactor internals environment, which is a high temperature environment.

For carbon and low alloy steel bolting with yield strength > 100 ksi, EPRI NP-5769, Table 1-4, lists numerous instances of stress corrosion cracking. Most of these incidents are in high temperature applications such as steam generator manway closure studs and main steam isolation valve studs. There were a few incidents involving carbon and low alloy steam generator and reactor vessel support anchor bolts. Contributing factors for these incidents included water leakage, excessive preload, or both.

All the incidents documented in EPRI NP-5769 for either material type involved either excessive preload or improper material and virtually all were in a wetted environment caused by active bolted joint leakage. The environment of the NMP bolts in question does not involve an active bolted joint leak. Bolting in these systems was assigned to an environment of moist air (temperature < 140 0F) because some in-scope portions of these systems are located within the primary containment which has a warm, humid atmosphere where condensation can occur during shutdown. However, the bolts in these systems for which the Systems Walkdown Program has been assigned to manage loss of material are located in the Reactor Building. The NMP2 High Pressure Core Spray System has a portion of its piping inside the primary containment.

However, this piping is part of the reactor coolant pressure boundary and is, therefore, included in the ASME Section XI Inservice Inspection (Subsections IWB, IWC, and IWD) Program, along with the associated closure bolting. Bolting covered by ASME Section XI is included in a different LRA Table 3.2.2.B-2 line item. The balance of the High Pressure Core Spray System piping, along with most of the piping in the other two systems (Hydrogen Recombiner and Standby Gas Treatment) is located outside primary containment. The appropriate environment for these bolts is air rather than moist air (temperature < 140TF). In an air environment, carbon or low allow steel (yield strength >100 ksi) has the aging effect of loss of material, while martensitic precipitation hardened and superferritic stainless steel have no aging effects requiring management. This change will be made for LRA Tables 3.2.2.B-1, 3.2.2.B-2, and 3.2.2.B-6.

Page 24 of 47

The material specification for the bolting corresponding to the LRA line item for martensitic precipitation hardened and superferritic stainless steel bolting in moist air (temperature < 140'F) environments is ASTM A193 Grade B6, which has a minimum specified tempering temperature of 11 000F. Material with this heat treatment would have a yield strength of approximately 100 ksi. The material specification for the bolting corresponding to the LRA line items for carbon or low allow steel (yield strength >100 ksi) bolting in a moist air (temperature < 140'F) environment in LRA Tables 3.2.2.B-1, 3.2.2.B-2, and 3.2.2.B-6 is ASTM A193 Grade B7, which has a minimum tempering temperature of I100lF. Yield strengths for Type 4140 steel bar, which is a steel grade that meets A193 chemical requirements, are below 150 ksi when tempered at 11 000F. Therefore, for both material types, the material yield strengths will not exceed 150 ksi. NUREG-1801,Section XI.M18, "Bolting Integrity," under parameters monitored/inspected, identifies that cracking must be monitored only for bolts with yield strengths exceeding 150 ksi.

Therefore, the fact that cracking is not identified as an aging effect for the subject bolts is not inconsistent with NUREG-1 801.

Loss of preload would not typically be an aging effect requiring management for bolting in low temperature systems. NUREG-1801 only specifies loss of preload as an aging effect requiring management for components in the reactor vessel and intemals and reactor coolant pressure boundary. For closure bolting in Engineered Safety Features (ESF) systems, NUREG-1801 only addresses carbon and low alloy steel bolting in high-pressure or high temperature systems. The bolting with the material/environment combinations of carbon or low alloy steel (yield strength

>100 ksi) and martensitic precipitation hardened and superferritic stainless steel bolting in a moist air (temperature < 140°F), which will be changed to air, are not in high temperature or high pressure systems. Furthermore, NUREG-1801 does not identify loss of preload even for ESF bolts in high temperature, high pressure systems. Therefore, the determination that loss of preload does not apply to the subject bolts is consistent with the GALL.

With regard to the Systems Walkdown Program, a visual inspection of the accessible external surfaces of the in-scope systems and components, including bolting, is performed at a frequency of once each refueling cycle. The acceptance criterion is no evidence of aging observed. If indications of corrosion, surface cracking, or leakage are observed, the site corrective action program is utilized to evaluate the condition for impact on component and system functions, and to identify appropriate corrective action.

The Bolting Integrity Program described in NUREG-1 801, Section Xl.M 8, invokes ASME Section XI, IWB-2500 for Class 1 bolts and IWC-2500 for Class 2 bolts. The subject bolts are non-class bolts and are not subject to inservice inspection under ASME Section XI. Other than for bolting greater than 2 inches in diameter, ASME Section XI, IWC-2500 would require only a VT-2 examination for Class 2 bolts as part of examination category B-P, "all pressure retaining components." Therefore, visual inspections conducted under the Systems Walkdown Program would not be inferior to ASME Section XI inspections for Class 2 bolts 2 inches in diameter or less. The Bolting Integrity Program described in NUREG-1801, Section Xl.M18, does not describe requirements for inspection of non-ASME bolting. Therefore, the use of the Systems Walkdown Program is equivalent to the guidance provided in NUREG-1801.

Page 25 of 47

LRA Revisions LRA Tables 3.2.2.B-1 (page 3.2-67), 3.2.2.B-2 (page 3.2-70), and 3.2.2.B-6 (page 3.2-107) are revised to change the bolting environment from "Air with Moisture or Wetting, temperature

< 1400F" to "Air," as shown on the following pages.

Page 26 of 47

f

,~

A 1'

• Table 3.2.2.B-1 Engineered Safety Features Systems NMP2 Hydrogen Rec ombiner System - Summary of Ag ing Management Evaluation NUREG-Component Intended Aging Effect Aging Management 1801 Table I Noe Type Function Material Environment Requiring Program Volme 2 Item Notesl ManagementPrgaVoue2 Im Ite m Bolting PB Carbon or Low Air Loss of Material Systems Walkdown G

Alloy Steel Program (Yield Strength 2100 Ksi)

Martensitic, Air None None None Precipitation Hardenable, and Superferritic Stainless Steels Page 27 of 47

Table 3.2.2.B-2 Engineered Safety Features Systems NM P2 High Pressure Core Spray System - Summary of Aging Management Evaluation Aging Effect NUREG-Component Intended Maeil Evrnet Rqiig Aging Management 1801 Table I Noe Type Function Mat l

Environmen Requring ram VNotesm Management Prgrmtolme2 Im Bolting PB Carbon or Low Air Loss of Material Systems Walkdown G

Alloy Steel (Yield Program Strength 2100 Ksi)_

Closure Cracking Fatigue Monitoring G

Bolting for Program Non-Borated Loss of Material ASME Section XI G

Water Inservice Inspection Systems with (Subsections IWB, operating IWC, IWD) Program temperatures 22120F Martensitic, Air None None None Precipitation Hardenable, and Superferritic Stainless Steels Page 28 of 47

rl Table 3.2.2.8-6 Engineered Safety Features Systems NMP2 Standby Gas Treatment System - Summary of A! ing Management Evaluation Component Intended Material Environment AgRequiring Egffc R

Table 2

Notes Type Function Management Program Volume 2 Item

_ _ _Ite m_

Bolting PB Carbon or Low Air Loss of Systems Walkdown G

Alloy Steel (Yield Material Program Strength i100 Page 29 of 47

LRA Section 2.3.4, Steam and Power Conversion Systems RAI-3.4-1 In Table 3.4.2.A-1, the applicant has identified cracking and loss ofstrength as the aging effects forpoly'merpipiing andfittinigs in a treated water (temperature <140 "F) environmenit. These aging effects are proposed to be managed by the preventive mainztenianice program. The applicant is requested to identify (a) the specific polymeric materials for these components (b) basisfor concluding that no other aging effects occur in this environment (c) specific tests and inspection miethods for these components including the frequency of inspections, and (d) acceptance criteria for determining loss of strength of the polymers, and the bases thereof

Response

There are three components in the NMP1 Condensate System that are made of an elastomer material and subject to a treated water (temperature <140'F) environment. These components are expansion joints (EXJBJ-49-08, EXJBJ-49-09 and EXJBJ-49-10) located at the suction of the Condensate Pumps.

(a)

The expansion joints are made of rubber (Chlorobutyl elastomer with polyester fabric and metal reinforcement).

(b)

Rubber in a treated water (temperature <140'F) environment is very resistant to wear and hardening, but is susceptible to cracking and loss of strength. Treated water can cause elastomer degradation, and hardening can occur when the water temperature increases above 1301F. This conclusion is based upon industry reports EPRI TR-1 14882, "Non-Class 1 Mechanical Implementation Guideline and Mechanical Tools," Revision 3, and EPRI TR-1 14881, "Aging Effects for Structures and Structural Components (Structural Tools)," Revision 1.

(c)

The expansion joints are currently visually inspected periodically and replaced on a five-year frequency.

(d)

The Preventive Maintenance Program does not include specific acceptance criteria for the loss of strength parameter since the expansion joints are replaced on a five-year frequency.

The replacement frequency, however, was determined by considering the operating conditions and environment. These same factors also contribute to loss of strength.

Therefore, the current replacement frequency ensures that the expansion joints are replaced prior to their loss of intended function.

Page 30 of 47

RAI-3.4-2 In Table 3.4.2.A-1, the applicant states that loss of naterial of gray cast iron plumps in a treated water (temperature <140 T) environment will be managed by the one-time inspection, selective leaching of niaterials and water chenmistry control aging management programs. The applicant is requested to discuss:

• visual, VT or other inspection methods, frequency of inspections, acceptance criteria and the bases thereof

• bases for sampling of the pumps to detect selective leaching whlzether or not hardness tests vill be performed

Response

(a)

For the gray cast iron pumps with an internal environment of treated water (temperature

<140'F) (i.e., the two Condensate Transfer pumps), the aging effect requiring management is loss of material. The aging mechanisms to be managed by the One-Time Inspection Program and the Water Chemistry Control Program include crevice corrosion, general corrosion, and pitting corrosion. The One-Time Inspection Program is a new license renewal (LR) AMP commitment for NMP that is to be implemented prior to the period of extended operation. This commitment was made in the original LRA submittal, as supplemented byNMPNS letter NMP1L 1880 dated October 29,2004. As such, program documents or procedures specific to managing the aging mechanisms (i.e. crevice corrosion, general corrosion, and pitting corrosion) that specify inspection methods and acceptance criteria for the two Condensate Transfer pumps do not currently exist. The frequency of any future inspections for the aging mechanisms of crevice corrosion, general corrosion, and pitting corrosion will be based on the findings of the One-Time Inspection Program. However, as stated in LRA Appendix B2.1.20, the One-Time Inspection Program will be implemented consistent with NUREG-1801,Section XI.M32.

(b)

As presented in LRA Sections A1.1.33 and B2.1.21, the implementation of the Selective Leaching of Materials Program is discussed in the program description for the One-Time Inspection Program (see LRA Sections A1.1.28 and B2.1.20). As stated above, the One-Time Inspection Program is a new LR AMP commitment for NMP that is to be implemented prior to the period of extended operation. As such, program documents or procedures specific to managing the aging mechanism of selective leaching for the two Condensate Transfer pumps do not currently exist. However, as stated in LRA Section B2.1.21, the Selective Leaching Program will be implemented consistent with NUREG-1801,Section XI.M33.

(c)

A determination of whether hardness tests are necessary will be made at the time of the One-Time Inspection Program implementation. This is consistent with LRA Section B2.1.20, which states: "Inspection techniques may include a one-time visual inspection and hardness measurement."

Page 31 of 47

Hardness testing will be considered as a possible inspection technique if visual examination techniques alone cannot determine if selective leaching severe enough to affect the component intended function is occurring. The use of field hardness testing will also be contingent on the accessibility of the affected component surfaces to perform the test.

Hardness testing on components susceptible to selective leaching may be appropriate if the component configuration and geometry allows. Tubing and other components such as valves with complex internal geometry do not provide adequate physical access to internal surfaces requiring examination to allow accurate measurements to be made.

RAI-3.4-3 Izn Table 3.4.2.A-1, the applicant has identified no aging effects for the wrought austenitic stainless steel tanks in a treated water (temperature <140 F, lowv-flowv) environment. The applicant is requested to provide details of hoiv these tanks are supported and the material conmposition of tle piping andfittings connected to tie tanks. Also discuss the operating history of these tanks.

Response

The two Condensate Surge and Storage Tanks are mounted on a concrete floor in the Turbine Auxiliary Extension Building. The tanks are secured to the floor to prevent lateral movement with sixteen 2-/4 inch, equally-spaced anchor bolts on a 30'-6" diameter bolt circle, with the bolt circle being removed 3" from the outside diameter of each individual tank. Management of the aging effects for these concrete anchor bolts is addressed in LRA Table 3.5.2.C-1 (component type is "Fasteners (Carbon and Low Alloy Steel) in Air," on page 3.5-140).

The material composition of the piping and fittings attached to these two tanks is dependant on the particular line. The supply lines to the Control Rod Drive and Condensate Transfer Systems are wrought austenitic stainless steel (Seamless Stainless Steel -A376 Type 304). The supply line to the Main Condenser is aluminum alloy (Standard Aluminum Alloy Pipe ASTM B241 Alloy 3003 with H12 or H18 Temper or Alloy 6061 with T6 Temper). While wrought austenitic stainless steel piping is a component type identified in LRA Table 3.4.2.A-1, there is no piping component type identified for the Aluminum Alloy piping in Table 3.4.2.A-1. LRA Table 3.4.2.A-I will be revised to include an aluminum alloy material for the component type of "Piping and Fittings."

The plant operating experience database was reviewed for occurrences of non-conforming conditions for the two Condensate Surge and Storage Tanks. No non-conformances were found in the site corrective action program database.

LRA Revisions LRA Table 3.4.2.A-1 is revised to add an aluminum alloy material for the component type "Piping and Fittings," as shown on the following page.

Page 32 of 47

Table 3.4.2.A-1 Steam and Power Conversion System NMP1 Condensate and Condensate Transfer Svstem - Summa. v of Aging Manaqeme nt Evaluation Aging Effect NUREG-Component Intended Material Environment Requiring Aging Management 1801 Table I Notes TpFucinManagement Program Volume 2 Item Piping and PB Aluminum Alloy Treated Water, Cracking One-Time Inspection K

Fittings Temperature Program

< 1400 F Water Chemistry Control Program Page 33 of 47

RAI-3.4-4 In Table 3.4.2.A-1, the applicant states that cracking in aluminum alloy (with copper or zincJ valves subjected to a treated water (temperature <140 7F) environment vill be managed by one-time inspection and chemistry control programs. The applicant is requested to discuss the bases for not considering selective leaching as an aging effect. Also discuss the operating history of these valves in this environment.

Response

The basis for not including the aging effect of "selective leaching" for the material "Aluminum alloys containing copper or zinc as primary alloying elements" in an environment of treated water (temperature <140'F) is the zinc content of the valves involved. These particular valves have a zinc content of less than 15%. As such, any copper-zinc alloy material with <15% zinc is not susceptible to selective leaching. Since these valves are an aluminum alloy, however, they still would not be susceptible to selective leaching even if the zinc content was >15%.

Industry operating experience and the plant operating experience database were reviewed for instances where components of this aluminum alloy might have experienced failures due to corrosion. No such applicable failures were found in the industry information reviewed or in the plant database. A keyword search of the corrective action program database was also performed.

Again, no failures due to corrosion of components fabricated of this aluminum alloy were found.

RAI-3.4-5 In Table 3.4.2.A-2, the applicant states that cracking and loss of material in carbon steel (yield strength <100 ksi) and ductile malleable cast iron bolting subjected to non-borated water (temperature >212 0F) environment will be managed by the fatigue monitoring and ASME Section AIISIprograms. Tie applicant is requested to discuss hov thefatigue monitoring program would be applicable to the non-safety related bolting outside the pressure boundary to manage cracking in bolting. The fatigue monitoring program may not be adequate by itself It is the staffs position that a bolting and torquing program is needed in addition to thefatigue monitoring program in order to identify cracking before there is loss of mechanical closure integrity and/or leakage.

Response

The LRA will be changed to credit the Fatigue Monitoring Program with managing the aging effect of cumulative fatigue damage, rather than cracking, for the bolts. This is part of a generic LRA change to replace cracking with cumulative fatigue damage as the aging effect managed by the Fatigue Monitoring Program. As such, the Fatigue Monitoring Program will no longer be credited for managing the aging effect of cracking. This change will be reflected in an LRA supplemental letter to be submitted by NMPNS by February 28, 2005.

The LRA line item for bolting, material of "Carbon Steel, Low Alloy Steel (yield strength < 100 ksi)," environment of "Closure Bolting for Non-Borated Water Systems with Operating Page 34 of 47

Temperature Ž2120F," and an aging effect of "Cracking," will be aligned with GALL Item VIII.H.2-b, "Closure Bolting in High Pressure or High-Temperature Systems (Steam and Power Conversion System)." Ductile/malleable iron will be removed from the material description since none of the bolts are actually ductile or malleable iron. The aging effect for GALL Item VIII.H.2-b is cracking due to cyclic loading and stress corrosion cracking. There is no GALL item for loss of preload of bolting in Steam and Power Conversion Systems.

Both cracking and loss of material would be managed by examinations performed under the ASME Section XI Inservice Inspection, Subsections IWB IWC and IWD Program, which are consistent with the examinations specified in GALL Section XL.MI 8, "Bolting Integrity Program." ASME Section XI requires VT-i and volumetric examination of Class l and 2 bolts greater than 2 inches in diameter and VT-1 examination of Class 1 bolts 2 inches and less in diameter. Class 2 bolts 2 inches and less in diameter and Class 3 bolts are subject to a VT-2 examination for leakage. Joint leakage would typically occur prior to a loss of mechanical closure integrity of the bolted joint, and would be detected by both the VT-2 and VT-i examinations. The VT-I examinations would detect loss of material due to general corrosion which is a consequence ofjoint leakage. VT-2 examinations detect evidence of leakage, which would result in the condition being corrected prior to the occurrence of loss of material or cracking. For larger bolts, volumetric examination would detect cracking caused by stress corrosion cracking or any other mechanism, such as cyclic loading or fatigue, before mechanical closure integrity is lost.

A site design specification provides guidelines for determining bolt torques, which control preloads. These guidelines are referenced in site mechanical maintenance procedures used for preventive and corrective maintenance.

RAI-3.4-6 In Table 3.4.2.A-2, the applicant states that there are no aging effects associated with carbon steel and ductile and malleable cast ironflowv elements, piping, fittings, pumps, and valves in a lubricating oil environment. The applicant is requested to address how it is ensured that there are no contaminants in the lubricating oil. A one-time inspection of these components may be necessary to ensure that no degradation has occurred.

Response

The specific components that fall under the component types listed above pertain to the lubricating oil subsystem for the NMP1 motor driven feedwater pumps.

Samples from the motor driven feedwater pump lube oil subsystem are obtained on a quarterly basis in accordance with Chemistry Technical Procedure N1-CTP-V520, "Lube Oil Sampling,"

and the oil sample results are evaluated and trended. Any indication of an anomalous condition or adverse trend will result in an investigation under the site corrective action program.

In addition, even though not credited due to the determination of a very low susceptibility of the applicable components to any aging effects (i.e., "None" in LRA Table 3.4.2.A-2) for the material/environment combination of carbon steel and ductile and malleable cast iron in lube oil, Page 35 of 47

Preventive Maintenance Program procedures provide instructions for periodically inspecting the gear box and lube oil coolers, as well as for centrifuging the oil, replenishing the oil supply, and changing out the oil filters.

Based on the oil quality controls already in place and on the feedwater pump lube oil subsystem maintenance and inspections already being performed, an additional one-time inspection of the oil subsystem components is not warranted.

RAI-3.4-7 In Table 3.4.2.A-2, the applicant states that cracking and loss of material in non-safely related piping, fittings and equipment in treated water or steam (temperature >212 "F blat <482 "F), low flow environment will be managed by the system walkdown and water chemistry control program. The applicant is requested to address how it would be ensured that no loss of material and cracking are occurring in the interior and inaccessible surfaces since the system walkdown program only manages the degradation on accessible exterior surfaces. It is the staff's position that a one-timie inspection of these components is neededfor this purpose.

Response

The Systems Walkdown Program is described in LRA Section B2.1.33. The Water Chemistry Control Program is described in LRA Section B2.1.2. The Water Chemistry Control Program mitigates loss of material and cracking on the interior and inaccessible surfaces of the system.

Especially for the low flow portions of the Feedwater/High Pressure Coolant Injection (HPCI)

System, it was deemed that the Systems Walkdown Program would be sufficient for components subject to AMR for criterion 10 CFR 54.4(a)(2) only, to prevent these components from failing to perform their license renewal intended function to "Prevent Failure from Affecting SR Equipment." This determination was made since the Systems Walkdown Program will identify any leakage or structural challenges resulting from inspections for the aging effects of loss of material and cracking and institute corrective actions as necessary. However, since the One-Time Inspection Program is already being utilized for the other low flow portions of the Feedwater/HPCI System, it will be expanded to include the piping and components in-scope for LR and subject to AMR to meet criterion 10 CFR 54.4(a)(2) as well. The LRA will be revised to reflect this expansion of the One-Time Inspection Program.

LRA Revisions LRA Table 3.4.2.A-2 (pages 3.4-36 and 3.4-37) is revised to add the One-Time Inspection Program for the NSR piping, fittings, and equipment of the NMP1 Feedwater/HPCI System that are subject to low flow environments as shown on the following page.

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Table 3.4.2.A-2 Steam and Power Conversion System NMP1 FeedwaterlHigh Pre sure Coolant Injec ion System - Summary of Aging Manage ent Evaluation NUREG-Component Intended Ageil Eniomnt R

iing Efec Aging Management 1801 Table I Noe Type Function Material Environment Requiring Program Voume 2 e

Management Prgrmtolme2 Im NSR piping, PFASRE Any Demineralized

Cracking, One Time Inspection fittings, and Untreated Water Loss of Material Program equipment Treated Water, Systems Walkdown temperature Program

.F Water Chemistry Treated Water, Control Program temperature

< 1400F, Low Flow Treated Water, temperature 214 00F, but

< 2120F Treated Water, temperature 214 00F, but

< 212 0F, Low Flow Treated Water or

Steam, temperature

Ž2120F, but

< 4820F, Low Flow Treated Water or

Steam, temperature a4820F, Low Flow Page 37 of 47

RAI-3.4-8 In Table 3.4.2.A-3, the applicant has identified no aging effects requiring managementfor carbon steel, Iow alloy steel (yield strength <100 ksi) and ductile/malleable cast iron piping, tanks and valves in a dried air or gas environment. The applicant is requested to address the tests and inspections which ensure that there are no contaminants and moisture in the dry air and gas.

Response

As described in LRA Section 2.3.4.A.4, the specific components being addressed in LRA Table 3.4.2.A-3 are the carbon dioxide (CO2) storage tanks and associated piping and fittings, valves and bolting that supply the CO2 to the fire protection system.

Since the pressurized, liquefied CO2 flashes to a gaseous state at atmospheric pressure, the only possible way for moisture or contaminants to enter the CO2 storage tank is during the delivery process from the CO2 vendor's tank truck. Preventive maintenance procedures controlling this delivery process ensure that the tank fill line from the tank truck is completely purged of moisture and contaminants with CO2 before the new supply of CO2 is admitted to the CO2 storage tank.

Based on this controlled process, tests and inspections of the CO2 storage tank are not required to ensure that the dry air or gas is free of moisture or contaminants.

?3/4 RAI-3.4-9 In Table 3.4.2.B-2, the applicant states that cracking and loss of strength ofpolymeric piping and fittings in a treated water (temperature <140 0F), lowvflow environment will be managed by preventive maintenance program. 7he applicant is requested to provide thlefollowving:

• comnposition and/or mechanical and chlemicalproperties of the polymer

• miethods of inspection

• frequency of inspections and acceptance criteria and bases thereof

• operating history of these components

Response

The subject elastomeric piping and fittings in a treated water (temperature <140'F), low flow environment contained in LRA Table 3.4.2.B-2 consist of expansion joints associated with piping connected to the two Condensate Storage Tanks.

(a)

The composition of the elastomeric expansion joints is rubber.

(b)

The methods of inspection associated with these expansion joints are visual, dimensional and durometer readings.

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(c)

Inspection of the expansion joints is performed every two years. Replacement of the components is scheduled for every 20 years. The acceptance criteria for the various methods are as follows.

Visual Inspection

• No excessive and deep cracking or cuts of outer cover exposing reinforcing wire, body.

rings or fabric.

• No blistering or local areas of deformation or ply separation.

• No leakage or weeping through bellows or at flange connections.

• No soft or gummy areas.

• No mechanical damage due to maintenance or operating activity.

• If expansion joint has a liner, liner is not damaged.

• Structural members and attachment hardware is not damaged and maintains structural integrity.

Dimensional Inspection

• Face to face dimensions are within design tolerances.

Durometer Reading

• Readings between 50 - 80 (Shur scale).

The inspections and acceptance criteria for the expansion joints are based upon approved vendor manuals.

(d)

The license renewal operating experience database was reviewed for failures of any of the expansion joints associated with the two Condensate Storage Tanks. No such failures were found in this database.

In addition, the site corrective action program database was reviewed for any occurrences of non-conforming conditions associated with the expansion joints of the two Condensate Storage Tanks. One corrective action report was written as a result of the latest inspection (January 2004). This report identified signs of aging occurring but not to the extent that immediate action was necessary. The expansion joints were found to be leak-free and structurally intact.

LRA Revisions LRA Table 3.4.2.B-2 (page 3.4-48) is revised to change the Piping and Fittings material from "Polymer" to "Elastomer," as shown on the following page.

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Table 3.4.2.6-2 Steam and Power Conversion System NMP2 Condensate System - Summary of Aging Management Evaluation Aging ffectNUREG-Component Intended Ageil Eniomnt Rqiinggffc Aging Management 1801 Table I Notes Type Function MateriaroEnv ngram Volquime 2 n

Item Management Prgrmtolme2 Im Piping and NFS Elastomer Treated Water, Cracking Preventive J

Fittings temperature Maintenance

< 140'F, Low Program Flow Loss of Strength Preventive J

Maintenance P ro g ra m_

Page 40 of 47

RAI-3.4-10 In Table 3.4.2.B-1, the applicant has identified no aging effects for nickel based alloy piping and fittings in an air environment. The applicant is requested to address how it would be ensured that there are no contaminants in the air which may cause degradation of nickel alloy piping and fitting.

Response

LRA Table 3.4.2.B-1 for the NMP2 Main Condenser Air Removal System does not contain any line item entries for nickel based alloy piping and fittings in an air environment. The only nickel based alloy piping and fittings addressed in LRA Section 3.4 appear in Table 3.4.2.A-4 for the NMP1 Main Steam System; specifically, the six "ADS Expansion Joint - Bellows Joint" labeled with component identification numbers of EXJBJ-66-OIR through EXJBJ-66-06R on Drawing LR-1 8002-C, Sheet 1. NMPNS assumes that this issue pertains to these components.

These components are located in the drywell and have been conservatively identified as being subjected to an environment of "Air." During normal plant operations, however, the dryvell actually has a nitrogen inerted environment. This environment ensures that there are no contaminants in the "air" that might contribute to degradation of the nickel bases alloy components.

RAI-3.4-11 In Table 3.4.2.B-2, the applicant states that cracking, hardening, shrinkage, and loss of strength ofpolymeric tanks in an air environment will be managed by the systems walkdoiwn program.

The applicant is requested to address thefollowing:

• composition and/or chemical and mechanical properties of the polymer

• methods of inspections and/or examination of inaccessible, interior surfaces to detect degradation since the system walkdown program manages aging effects on exterior, accessible surfaces only

• description of the tank support including the attachments.

• material of the piping andfitting connected to the tanks

Response

(a)

The component type of "Tanks" contained in LRA Table 3.4.2.B-2 (page 3.4-49) consists of the two 450,000 gallon Condensate Storage Tanks housed in the Condensate Storage Tank Building. The polymer type is fiberglass. The fiberglass is composed of Altac 382 resin. The tanks are further supported by cable made of 7/8" diameter PVC surrounding the outside diameter.

(b)

The Condensate Storage Tank internals, which are subjected to an environment of "Treated Water, temperature <1400F, Low Flow," will be inspected per the One-Time Inspection Program, as indicated in LRA Table 3.4.2.B-2.

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The methods of detection utilized by the One-Time Inspection Program have not been specifically determined at this time but are expected to include a visual inspection and a hardness test if appropriate. The One-Time Inspection Program is described in LRA Section B2.1.20 and will be implemented prior to the period of extended operation.

Hardness testing will be considered as a possible inspection technique if visual examination techniques alone cannot determine if selective leaching severe enough to affect the component intended function is occurring. The use of field hardness testing will also be contingent on the accessibility of the affected component surfaces to perform the test.

Hardness testing on components susceptible to selective leaching may be appropriate if the component configuration and geometry allows. Tubing and other components such as valves with complex internal geometry do not provide adequate physical access to internal surfaces requiring examination to allow accurate measurements to be made.

(c)

The Condensate Storage Tanks are anchored to the floor slab of the Condensate Storage Tank Building via 64 epoxy coated carbon steel clips and 1-inch diameter A307 bolting and nuts.

(d)

The Condensate Storage Tanks include nozzles made of fiberglass. Connected to these nozzles are rubber expansion joints or flanges, depending upon the specific line. The piping and fittings connected to the expansion joints or flanges are made of carbon steel or stainless steel depending upon the specific line.

LRA Section B2.1.32, Preventive Maintenance Program RAI B2.1.32-1 (A) The descriptions of several elements in AMP B2.1.32, "Preventive Maintenance Program (PMP), " are too brief and generalfor the staff to review the effectiveness and adequacy of the PMP. Tie applicant is requested to provide more specific detailed information for the following four elements of the AMP in accordance with the guidelines delineated in Appendix A of NUREG-1 800.

(1) Parameters Monitored/Inspected (2) Detection of Aging Effects (3) Monitoring and Trending (specified schedule)

(4) Acceptance Criteria (B) The applicant stated in the LRA that the aging effects of (1) piping and fittings in the NMP2 Control Building HVAC System (Table 3.3.2.B-9, Page 209), and (2) valves in the NMPI Radioactive Waste System (Table 3.3.2.A-14, Page 149) are to be managed by this PMP. As an example, the applicant is requested to provide specific information related to the four elements of the PMP listed in (A) above for the management of aging effects of (l) piping andfittings, and (2) valves indicated above, to demonstrate the effectiveness and adequacy of this PMP.

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Response

(A) The following provides more specific detailed information for the four elements of the Preventive Maintenance (PM) Program identified in the RAI.

(1) Parameters MIonitored/Inspected There are no prevention, mitigation, or performance monitoring activities in the PM Program credited for License Renewal. Rather, they are condition monitoring activities that inspect for visual signs of degradation or test for leaks. Surface conditions of components are monitored through visual inspection and examination for evidence of defects and age-related degradation. Components in selected portions of systems are monitored through visual inspection. The inspections detect aging effects which, if left unmanaged, would lead to degradation of the components' intended function(s). Examples of the component, type of inspections, and parameters monitored under the PM Program are as follows:

Unit Component(s)

Inspection Parameter Procedure Type /

Parameter 1

Fuel Pool heat Visual /

Evidence of various N1-MMP-054-405 exchanger tubes Condition forms of corrosion and tube sheets I

Various carbon Visual /

Evidence of various NI -MMP-GEN-200 steel valve Condition forms of internal internals and and/or external externals corrosion I

Reactor Building Visual /

Evidence of various Nl-MPM-GEN-005 and Dry Well Condition forms of internal Sump Pump corrosion 1

RX Building Visual /

Evidence of corrosion NI-MPM-GEN-551 Emergency Condition of carbon steel; Ventilation and cracking, hardening, Control Room shrinkage and loss of Emergency strength of polymers Ventilation Fan 1

Unit 1 Reactor Visual /

Evidence of general N1-TSP-202-001 Building Charcoal Condition corrosion of housing Filter Housings internals 1

13.8 & 4.16KV Visual /

Presence of motor S-EPM-GEN-081 Motors Condition cooler fouling 2

Ventilation Visual /

Presence of general N2-EPM-GEN-V780 Heaters Condition corrosion on heater internals Page 43 of 47

,W.

_

Unit Component(s)

Inspection Parameter Procedure Type /

Parameter 2

Unit Coolers Visual /

Inspection for fouling N2-EPM-GEN-V781 Condition and various forms of corrosion 2

Motor Operated Visual /

Internal inspection N2-EPM-GEN-V786 Actuators and Condition for general corrosion Dampers of damper and actuator 2

Air Handling Unit Visual /

Inspection for signs N2-MPM-GEN-Cooling Cools Condition & of fouling, and testing SA562 & N2-MPM-Test /

for leakage HVC-V554 Refrigerant Leakage Most PM Program implementing procedures will require enhancement to include/annotate those parameters credited for aging management.

This program attribute will be consistent with the generic attribute descriptions in Appendix A of the NUREG-1800 upon program enhancements.

(2) Detection of Aging Effects The aging effects requiring management for the components within the scope of the PM Program are detected by visual inspection and examination of surfaces of components for evidence of defects and age-related degradation. The activities that are performed to detect aging effects requiring management are identified in the specific PM procedures that perform the PM. The procedures are developed based on vendor recommendations and operating experience that forms the basis for the inspections performed and the frequency of the inspections such that aging effects are detected prior to a loss of the components' intended function(s). NMPNS administrative procedures provide for overall control of the PM Program and identification of how PMs are to be established, documented, scheduled, and optimized for the benefit of equipment and system reliability. Most PM Program procedures will require an enhancement to include/annotate the aging effect being detected.

This program attribute will be consistent with the generic attribute description in Appendix A of NUREG-1 800 upon completion of program enhancements.

(3) Monitoring and Trending The PM Program is a condition-monitoring program executed on a specified schedule.

Results of the tasks performed are documented in the corresponding implementing procedures. These procedures include a review and evaluation of the results. The PM Program requires an enhancement to specifically include monitoring and trending, as appropriate, for age-related degradation.

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¶ e t This program attribute will be consistent with the generic attribute description in Appendix A of NUREG-1800 upon completion of program enhancemnents.

(4) Acceptance Criteria Acceptance criteria for visual inspection and examination of components are provided in the PM Program implementing procedures. The acceptance criteria are related to the aging effects requiring management and are dependent on each individual inspection and examination considering the aging effect being managed. Implementing procedures will be enhanced to include more specific and detailed acceptance criteria, as appropriate.

This program attribute will be consistent with the generic attribute description in Appendix A of NUREG-1800 upon program enhancements.

(B)

The specific information requested in the RAI is provided below.

NMP2 Control Building HVAC System (Table 3.3.2.B-9, Page 3.3-209) - Piping and Fittings Note: The PM Program activities credited for managing the aging of the NMP2 Control Building HVAC piping and fittings are currently not incorporated in the applicable implementing procedures. As such, the following responses provide the type of information to be added to the procedures as part of the committed enhancements.

(1) Parameters Monitored/Inspected The noted table identifies steel and polymer materials in air and raw water environments. Losses of material and elastomer degradation are the parameters to be monitored. Enhancements to the implementing procedures will be made that direct monitoring of in-scope piping and fitting components for signs of aging, such as loss of material, cracking, and deformation of polymers. These procedure enhancements will align the program with the NUREG-1800 criterion.

(2) Detection of Aging Effects Piping and fitting components that are subject to aging management rely mainly on visual inspection and examination of surfaces to detect age related degradation.

Implementing procedures will be enhanced to direct visual inspections to look for corrosion, microbiological degradation, cracking and deformation of polymer components. These procedure enhancements will align the program with the NUREG-1800 criterion.

(3) Monitoring and Trending (specified schedule)

The visual inspections to be performed will be accomplished on a specified schedule that is based upon the expected rate of aging degradation and operating experience.

Since the inspections will provide mainly non-quantifiable results, specific trending of data is not applicable. Rather, the number and extent of occurrences may prove to be a Page 45 of 47

more beneficial attribute to trend. Enhancements to the implementing procedures will specify the appropriate frequency and parameters to trend. These procedure enhancements will align the program with the NUREG-1800 criterion.

(4) Acceptance Criteria Acceptance criteria for visual inspections will be provided in each applicable implementing procedure. In general, any evidence of a degradation mechanism occurring (i.e., corrosion beginning to form; surface cracking observed) will result in the acceptance criteria not being met. A corrective action report would be initiated and the impact of the degradation would be assessed for immediate and long-term operation of the component. Enhancements to the implementing procedures will include acceptance criteria that are based upon current industry information and practices.

These procedure enhancements will align the program with the NUREG-1 800 criterion.

NMPI Radioactive Waste System (Table 3.3.2.A-14, Page 3.3-149) - Valves Note: The PM Program activities credited for managing the aging of the NMP1 Radioactive Waste System valves are currently not incorporated in the applicable implementing procedures. As such, the following responses provide the type of information to be added to the procedures as part of the committed enhancements.

(1) Parameters Monitored/Inspected The noted table identifies loss of material and cracking for various steel and alloy valves in water environments. The parameters to be monitored are loss of material and cracking. Enhancements to the implementing procedures will be made to monitor/inspect for these parameters. These procedure enhancements will align the program with the NUREG-1800 criterion.

(2) Detection of Aging Effects Valves that are subject to aging management rely mainly on visual inspection and examination of surfaces to detect age related degradation. Implementing procedures will be enhanced to direct visual inspections to look for corrosion, microbiological degradation, cracking. These procedure enhancements will align the program with the NUREG-1 800 criterion.

(3) Monitoring and Trending (specified schedule)

The visual inspections to be performed will be accomplished on a specified schedule that is based upon the expected rate of aging degradation and operating experience.

Since the inspections will provide mainly non-quantifiable results, specific trending of data is not applicable. Rather, the number and extent of occurrences may prove to be a more beneficial attribute to trend. Enhancements to the implementing procedures will specify the appropriate frequency and parameters to trend. These procedure enhancements will align the program with the NUREG-1 800 criterion.

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(4) Acceptance Criteria Acceptance criteria for visual inspections will be provided in each applicable implementing procedure. In general, any evidence of a degradation mechanism occurring (i.e., corrosion beginning to form; surface cracking observed) will result in the acceptance criteria not being met. A corrective action report would be initiated and the impact of the degradation would be assessed for immediate and long-term operation of the component. Enhancements to the implementing procedures will include acceptance criteria that are based upon current industry information and practices.

These procedure enhancements will align the program with the NUREG-1800 criterion.

RAI B2.1.32-2 The applicant states that enhancements to the PMP will be made which would revise existing procedures. These enhancements wouldprovide the level of detail and specificity needed for staff review of the PMP. They would affect the main elements of the program inclludilg the scope, preventive actions, parameters monitored, detection of aging effects, monitoring and trending and acceptance criteria. These enhancenients are scheduled to be completed prior to the period of extended operation.

ihe staff views these as major enhanicemiienits which voutld require review and approval prior to implementation of the PMP. The staff therefore requests the applicant to provide a commitment that these enhancements would be completed on a schedule which would allow sufficient timefor staff reviewv and approval prior to theperiod of extended operation.

Response

This concern was also raised during the review of the AMPs by the NRC Audit Team. The question was AMP Issue 30 and the response provided was as follows:

"As with any commitment NMPNS makes to the NRC, the resolution and/or implementation are subject to review by the NRC. Specifically for new aging management programs (AMP), the NRC can utilize Inspection Procedure 71003 Post-Approval Site Inspection for License Renewal, to verify that outstanding commitments have been met. This procedure also includes specific wording whereby the assistance of NRR/DRIP/RLEP can be utilized to ensure the licensee commitments have been met.

Currently there is no specific notification to the NRC required when a commitment has been satisfied. Consistent with the industry, NMP would prefer that any review of new AMPs be conducted as part of the inspection process."

The commitment to enhance appropriate maintenance procedures that exist within the PM Program is made commensurate with the inclusion of statements to that effect within Appendices A and B of the LRA. Enhancements will be reviewed and approved using approved NMPNS administrative procedures. Once made, all maintenance activity enhancements will be readily available for review by the NRC prior to the period of extended operation.

Page 47 of 47

W.

ATTACHMENT 2 List of Revulatorv Commitments The following table identifies those actions committed to by Nine Mile Point Nuclear Station, LLC (NMPNS) in this submittal. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.

REGULATORY COMMITMENT I DUE DATE Implement an enhanced Open-Cycle Cooling Water System August 22,2009 Program that addresses loss of material for the NMPI Containment Spray System.

Submit LRA revisions that generically replace "cracking" February 28, 2005 with "cumulative fatigue damage" as the aging effect managed by the Fatigue Monitoring Program.

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