ML050660380

Gca AMR Database Files

ML050660380
Person / Time
Site:	Nine Mile Point
Issue date:	03/03/2005
From:	Le N NRC/NRR/DRIP/RLEP
To:
Le N. B., NRR/DRIP/RLEP, 415-1458
Shared Package
ML050660377	List: ML050660380 ML050660384
References
Download: ML050660380 (222)

Text

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 1 Hsu Page 3.1-46, component: bottom head: This question addresses the bottom but applies generically to the Question 3.1.1A-1H1: How does applicant manage cracking with fatigue monitoring program? LRA. The LRA Table will be revised to change the aging effect from 09/10/2004 Volume 2 item and Table 1 item do not address cracking also. (Note : this question applies to cracking to cumulative fatigue damage for those rows that credit all the items which use fatigue monitoring program to manage cracking aging effect.) the Fatigue Monitoring Program.

LR Contact Petras NRC Tracking Number 3.1.1A-1H1 Assigned Department/ License Renewal Individual Petras Date Closed 09/16/2004 Table 3.1.2.A-1 LRA Section 2 Hsu Page 3.1-46, component : nozzles, aging effect: cracking, AMP: ASME Section XI, ISI: See response to issue one with regards to cracking vs. fatigue issue Question 3.1.1A-1H2: GALL identifies ASME ISI (IWB/C/D) and Water chemistry control to Neither GALL IVA1.3-a, -b nor -d specify XI.M2 as an AMP to 09/10/2004 manage cracking. Why does applicant not credit water chemistry for this item? What is the manage their respective AERMs. Note E is used since NMP credits correct Table 1 item since 3.1.1-1 does not manage cracking effect? Why does applicant use XI.M1 vice X.M1 per GALL row IV.A1.3-d.

Note E for this item? Note IV.A1.3-d is for cumulative fatigue damage. The cracking should use IV.A1.3-b.

LR Contact Petras NRC Tracking Number 3.1.1A-1H2 Assigned Department/ License Renewal Individual Petras Date Closed 09/16/2004 Table 3.1.2.A-1 LRA Section Thursday, March 03, 2005 Page 1 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 3 Hsu Page 3.1-46, component: nozzles, aging effect: cracking, AMP: BWR Feedwater Nozzle See responses for questions 1 and 2. Note E is used since NMP program, fatigue monitoring program credits XI.M5 and X.M1 vice just X.M1 per GALL row IV.A1.3-d.

09/10/2004 NMP doesnt identify 3.1.1-27 since this AERM is covered by 3.1.1-1 Question 3.1.1A-1H3: Why does applicant use NOTE E for this item? Why does applicant identify 3.1.1-1 instead of 3.1.1-27? Why does applicant identify IV.A1.3-d instead of IV.A1.

b? Question 3.1.1A-1H1 is applied to this item also LR Contact Petras NRC Tracking Number 3.1.1A-1H3 Assigned Department/ License Renewal Individual Petras Date Closed 09/16/2004 Table 3.1.2.A-1 LRA Section 4 Hsu Page 3.1-47, component: penetrations. (a) There are no cast iron components in this system.

09/10/2004 Question 3.1.1A-1H4: Please provide the drawings or bills of material for cast iron used in the (b) The Material column in the tables in section 3 of the NMP 1 an RCS. GALL does not identify cast iron for RCS. Please explain the GALL consistency. NMP 2 LRA identifies generic material types as evaluated in the Material & Environment White Paper. This type is identified in the AMR as CLASSL: Carbon or Low Alloy Steel (Yield< 100ksi) or Ductile/Malleable Cast Iron The LRA table will be revised to remove Ductile/Malleable Cast Iron the ductile cast iron is not present.

LR Contact Hoppe NRC Tracking Number 3.1.1A-1H4 Assigned Department/ License Renewal Individual Poehler Date Closed 09/16/2004 Table 3.1.2.A-1 LRA Section Thursday, March 03, 2005 Page 2 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 5 Hsu Page 3.1-52, component: top head (leak detection lines) No. There are instrument lines attached to the RPV these are covered in the RXVI system.

09/10/2004 Question 3.1.1A-8H1: There is a vessel flange leak detection line. Are there any other detection lines at the Top head?

LR Contact Petras NRC Tracking Number 3.1.1A-8H1 Assigned Department/ License Renewal Individual Petras Date Closed 09/16/2004 Table 3.1.2.A-1 LRA Section 6 Hsu Page 3.1-67, component: pumps, environment: treated water or steam >=482F This is an environment group as defined in the White Paper. There is no difference in AERMs between water and steam and therefore 09/10/2004 Question 3.1.1A-23H1: The GALL specified environment is 550F reactor coolant water. The they are grouped together.

steam environment is not applied to this item. This is a general question for other items.

LR Contact Petras NRC Tracking Number 3.1.1A-23H1 Assigned Department/ License Renewal Individual Petras Date Closed 09/16/2004 Table 3.1.2.A-4 LRA Section Thursday, March 03, 2005 Page 3 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 9 Hsu Page 3.1-55, component: Vessel Shell Welds (including attachment welds), material Nickel Note E is used since NMP credits XI.M1 in addition to the GALL based alloys, Aging effect: cracking required programs for row IV A1.2-e. BWRVIP is implemented by 09/10/2004 NER-1M-076 which directs ISI inspections of the H9 weld in the core Question 3.1.1A-28H1: Explain why NOTE E is used instead of NOTE A. This item is for support structure.

vessel shell attachment welds. Explain BWR vessel internal program is used for which part o the vessel welds LR Contact Petras NRC Tracking Number 3.1.1A-28H1 Assigned Department/ License Renewal Individual Petras Date Closed 09/16/2004 Table 3.1.2.A-1 LRA Section Thursday, March 03, 2005 Page 4 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 11 Woodfield For table 1 line item 3.5.1.A-03, the GALL components are penetration sleeves, penetration Structural Steel ( Carbon & Low Alloy Steel) in Demineralized bellows, and dissimilar metal welds. Explain the rational for using Structural Steel as the Untreated Water, Low Flow in LRA Table 3.5.2.A-1 is a like -

09/10/2004 component type in table 2 where the associated table 1 item is 3.5.1.A-03. Explain the material & environment grouping for several different components reasoning for the assignment of intended function codes for penetration sleeves, penetration including the carbon steel penetration sleeves/bellows grouping from bellows and dissimilar welds. Explain why a Demineralized untreated water, low flow GALL.

environment is the only water environment experienced by penetration sleeves and penetratio This is the only water environment for these components in this bellows. (Ref. Pages 3.5-69 and 3.5-70 of the LRA) structure.

Note: Structural Steel is way too broad of term Carbon / Low alloy steel has many applications with several differen FOLLOW-UP QUESTION 10/14/04: intended functions in the Primary Containment Structure. The intended functions can be generally associated with the Explain if the Unit 1 Primary Containment has any penetration bellows. corresponding Aging Management Program - NUREG 1801 Vol. 2 If it does, provide all the types of fluid environments to which the inside of these bellows are Item and LRA Table 1 Items associated with the material and exposed and the associated system the bellows is in. environment (component type) identified in the Table 2s.

This includes all structural steel that is in contact with demineralized untreated water, temperature less than < 140 Deg. F, low flow. All liners, beams, columns, base plates and any other structural shapes that are continuously in contact with water are included in this asset This asset also includes all structural portions of penetrations in contact with treated water.

FOLLOW-UP RESPONSE:

The Unit 1 Primary Containment has penetration bellows.

They are on several systems with fluid temperatures greater than 150°F. The bellows are not in contact with the process fluid. The process pipe is insulated and a guard pipe is installed under the bellows. The environment is air on both sides of the bellows. (A drawing of the penetration structures was provided to the reviewer while in the Crofton office.)

LR Contact Hoppe NRC Tracking Number 3.5.1.A-03W1 Assigned Department/ License Renewal Individual Hoppe Date Closed Table 3.5.1.A LRA Section Thursday, March 03, 2005 Page 5 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 12 Woodfield In LRA table 3.5.2.A-1 (table 2) on page 3.5-66 for component airlocks, the GALL item is Cast Iron material is not present in the air locks.

II.B4.2-a. GALL item II.B4.2-a is for carbon steel material. Explain how the line item for See response to Inspection Open Issue #4 09/10/2004 airlocks can be consistent with GALL with the material shown as carbon or low alloy steel (yie strength<100Ksi) and Ductile/malleable Cast Iron.

Note: this question applies to equipment hatches in table 3.5.2.A-1 on LRA page 3.5-66 also.

LR Contact Hoppe NRC Tracking Number 3.5.1.A-04W1 Assigned Department/ License Renewal Individual Poehler Date Closed 09/16/2004 Table 3.5.2.A-1 LRA Section 13 Woodfield In LRA table 3.5.2.A-1 (table 2) on page 3.5-66 for component airlocks, the GALL item is Cast Iron Material is not present in the airlocks. See response to II.B4.2-b. GALL item II.B4.2-b is for carbon steel material. Explain how the line item for Issue 4.

09/10/2004 airlocks can be consistent with GALL with the material shown as carbon or low alloy steel (yie strength<100Ksi) and Ductile/malleable Cast Iron.

LR Contact Hoppe NRC Tracking Number 3.5.1.A-05W1 Assigned Department/ License Renewal Individual Poehler Date Closed 09/16/2004 Table 3.5.2.A-1 LRA Section Thursday, March 03, 2005 Page 6 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 14 Woodfield For table 1 line item 3.5.1.A-12, the GALL states that further evaluation is recommended if NUREG 1801 Item B1.1.1-a is shown on the next page.

corrosion is significant for inaccessible areas of steel elements: liner plate and containment The four conditions are addressed as follows:

09/10/2004 shell. Also, in GALL chapter II line item B1.1.1-a (page II B1-3) the GALL states that for 1. NMP unit 1 was designed and constructed with equivalent codes inaccessible areas (embedded containment steel shell or liner), loss of material due to as specified in the GALL.

corrosion is not significant if four specific conditions are satisfied. The GALL then lists the fou 2. The concrete is monitored in accordance with the ISI and SM conditions. The GALL states that if any of the four conditions cannot be satisfied, then a plant programs at NMP specific aging management program for corrosion is required. Provide an explanation for eac 3. Not applicable to the NMP design.

of the four conditions explaining how they are satisfied at Nine Mile Point Unit 1. 4. Not applicable to a BWR design.

LR Contact Hoppe NRC Tracking Number 3.5.1.A-12W1 Assigned Department/ License Renewal Individual Hoppe Date Closed 09/30/2004 Table 3.5.1.A-12 LRA Section 15 Woodfield For table 1 line item 3.5.1.A-12, the GALL components are steel elements: liner plate and LRA grouped like material, environments and AERM and assigned containment shell. Explain the rational for using Structural Steel as the component type in tab programs associated with GALL rows. The liner is steel plate and 09/10/2004 2 where the associated table 1 item is 3.5.1.A-12. Reference page 3.5-69 and 3.5-70 of the has a pressure boundary IF. It has the same aging mechanisms an LRA. Explain the reasoning for the assignment of intended function codes for liner plate and effects as other steel shapes and plates designated as CLASS L.

containment shell when called out as structural steel in table 2. GALL II.B.1.1.1-a simply states Steel elements: identifies primary containment components, the AERM and program, as does the LRA LR Contact Hoppe NRC Tracking Number 3.5.1.A-12W2 Assigned Department/ License Renewal Individual Hoppe Date Closed 09/24/2004 Table 3.5.1.A-12 LRA Section Thursday, March 03, 2005 Page 7 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 16 Woodfield Provide a document/procedure showing that expansion joints, piping, and valves will be 1) p. 3-5 Piping (mechanical) consists of large-bore vacuum inspected for loss of material under the ASME Section XI Inservice Inspection (Subsection breaker piping, and small bore piping associated with the vacuum 09/10/2004 IWE) Program as stated on pages 3.5-66, 3.5-68 and 3.5-71 of the LRA. Provide examples breaker check valves. Portions of the large-bore piping are inspecte where these components are made of ductile/malleable cast iron. as part of the IWE program. Pages 212, 372, and 478 from NMP1-IWE-003-10, Ten Year Containment Inservice Inspection Schedule show the particular line items for the vacuum breaker piping.

Portions of the lines that are accessible for visual examination are inspected as required by examination category E-A from ASME Section XI, Article IWE. This examination category requires a general visual examination of all accessible surfaces. The external surfaces of these lines external to the torus, and the internal junction of these lines with the torus and vent line, are accessible for visual examination.

P. 3.5 Expansion joints do not have a separate line item in NMP1-IWE-003-10, but accessible surfaces are included as part of the vacuum breaker piping.

P. 3.5 Valves (mechanical) includes both large bore valves associated with the vacuum breaker piping, and small bore valves associated with vacuum breaker check valves. The bolting of the large-bore valves is in ASME Section XI, Subsection IWE examination category E-A, which requires a general visual examination of the bolted joint.

Small-bore piping and valves (p. 3.5-68 and 3.5-71) is exempt from inspection under the IWE or IWB/IWC/IWD inservice inspection programs; therefore, the One-Time Inspection Program was credited in the Primary Containment AMR with managing loss of material of this piping.

2) Cast Iron material is not present in the primary containment structure (see response to Open Issue #4).

LR Contact Hoppe NRC Tracking Number 3.5.1.A-12W3 Assigned Department/ License Renewal Individual Hoppe Date Closed 10/13/2004 Table 3.5.2.A-1 LRA Section Thursday, March 03, 2005 Page 8 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 18 Woodfield For table 3.5.1.A (table 1) line item 3.5.1.A-19, the GALL components are steel elements: The drywell head is shown on drawings 1-CISI-1003 sh 1-4. The drywell head and downcomer pipes with aging due to fretting and lock up from wear. The drawing clearly shows the head attached to the flange with bolts.

09/10/2004 applicant states that fretting and lock up are not applicable for these components because the These bolts prevent head motion relative to the drywell itself.

components are not subject to relative motion. Provide drawings showing the relative location Additionally, fretting and lock up are not aging effects that require of these components in NMP Unit 1 and how they are restrained. management as stated in the Material - Environment White Paper.

The downcomer pipes are shown on drawings F-48001-C and F-48018-C. They are clearly shown to be braced and would not be subjected to any relative motion.

LR Contact Hoppe NRC Tracking Number 3.5.1.A-19W1 Assigned Department/ License Renewal Individual Hoppe Date Closed 09/24/2004 Table 3.5.1.A LRA Section Thursday, March 03, 2005 Page 9 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 19 Woodfield Table 3.5.1.A (table 1) line item 3.5.1.A-20 has been associated in table 2 with GALL items GALL Table 5 page 31 identifies All groups, except group 6 III.A2.2-a, III.A3.2-a, and III.A4.2-a for a variety of components, such as fasteners, expansion structures with multiple GALL item numbers such as GALL items 09/10/2004 anchors and doors. GALL items III.A2.2-a, III.A3.2-a and III.A4.2-a all list structure and/or III.A2.2-a, III.A3.2-a and III.A4.2-a.

component as: STEEL COMPONENTS: ALL STRUCTURAL STEEL. Explain how the GALL Volume I page A-5 table associates these rows with the group applicant interpreted the meaning of this GALL component definition and give an itemized list type structures for steel elements; AERM is general corrosion and of NMP Unit 1 components that the applicant feels are covered by the GALL line item. AMP is SMP.

Steel components (CLASS L) associated with the Structures and Component Supports such as Structural steel, fasteners, doors, expansion anchors are of the sam material group with similar AERM and AMP. The structural components were grouped to align with the GALL, material class, AERM and AMP.

List of components include all steel components WSLR in the buildings WSLR not already covered by a current LR AMP.

LR Contact Hoppe NRC Tracking Number 3.5.1.A-20W1 Assigned Department/ License Renewal Individual Hoppe Date Closed 09/17/2004 Table 3.5.1.A LRA Section Thursday, March 03, 2005 Page 10 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 20 Woodfield Table 3.5.1.A (table 1) line item 3.5.1A-20 components are: ALL GROUPS EXCEPT GROUP The rock anchors were drilled and grouted in the bedrock directly 6: ACCESSIBLE INTERIOR/EXTERIOR CONCRETE AND STEEL COMPONENTS. In table underneath the reactor building foundation. GALL row assignment 09/10/2004 3.5.2.A-2 (table 2) on page 3.5-76, component ROCK ANCHORS (CARBON AND LOW was conservative. The convention for the use of inaccessible areas ALLOY STEEL) IN SOIL BELOW THE GROUND WATER TABLE is associated with line item is for components internal to the structure such as the containment 3.5.1A-20. Explain how rock anchors below the water table are considered accessible steel liner below the floor in a PWR to use adjacent accessible area to components. monitor potential AERM.

The anchors are adjacent to the exterior surface of the reinforced concrete foundation LR Contact Hoppe NRC Tracking Number 3.5.1.A-20W2 Assigned Department/ License Renewal Individual Hoppe Date Closed 09/24/2004 Table 3.5.1.A LRA Section 21 Woodfield In table 3.5.2.A-2 on page 3.5-76 for component Structural Steel (Carbon and Low Alloy Steel The reactor building serves as a secondary containment to provide in Air, one of the intended functions is PB (pressure boundary). Explain how the structural ste an essentially leak tight barrier when the primary containment is 09/10/2004 performs its pressure boundary function. open. A portion of the side of the structure is steel siding.

LR Contact Hoppe NRC Tracking Number 3.5.1.A-20W3 Assigned Department/ License Renewal Individual Hoppe Date Closed 09/17/2004 Table 3.5.2.A-2 LRA Section Thursday, March 03, 2005 Page 11 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 22 Woodfield Table 3.5.1.A (table 1) line item 3.5.1A-20 components are: ALL GROUPS EXCEPT GROUP Structural steel in soil above and below the GWT includes the wall 6: ACCESSIBLE INTERIOR/EXTERIOR CONCRETE AND STEEL COMPONENTS. In table restraints installed to brace the Screenhouse substructure external 09/10/2004 3.5.2.A-8 (table 2) on page 3.5-88, components STRUCTURAL STEEL IN SOIL ABOVE AND wall BELOW THE GROUND WATER TABLE is associated with line item 3.5.1A-20. Explain how structural steel in soil above and below the water table is considered an accessible steel See response to ID # 20. Previously approved which states that:

component.

The GALL row assignment was conservative. The convention for th use of inaccessible areas is for components internal to the structure such as the containment liner below the floor in a PWR to use adjacent accessible area to monitor potential AERM.

LR Contact Hoppe NRC Tracking Number 3.5.1.A-20W4 Assigned Department/ License Renewal Individual Hoppe Date Closed 09/24/2004 Table 3.5.1.A LRA Section 23 Woodfield In table 3.5.2.A-9 on page 3.5-90 for component Doors in Air, the intended function is SNSR The intended function Structural support for NSR is the description (structural support for NSR). Explain how the door performs its structural support for NSR for 10 CFR 54 criteria (a)(2), Non-Safety affecting Safety. Doors in 09/10/2004 function. SR structures are WSLR for (a)(2) as a minimum.

The component door includes the door frame. The door frame provides support for the door.

The component door provides support for itself with its frame.

LR Contact Hoppe NRC Tracking Number 3.5.1.A-20W5 Assigned Department/ License Renewal Individual Hoppe Date Closed 09/17/2004 Table 3.5.2.A-9 LRA Section Thursday, March 03, 2005 Page 12 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 24 Woodfield In table 3.5.2.A-11 on page 3.5-93 for component type block wall in air, the aging managemen As stated in Appendix A & B the Masonry Wall program is program listed is masonry wall program. The table 3.5.1.A (table 1) line item listed is 3.5.1.A- implemented through the Structures Monitoring Program. LRA table 09/10/2004

20. The aging management program shown in table 1 for line item 3.5.1.A-20 is Structures 3.5.2.A-11, Block Wall in Air row will be revised to indicate Table 1 Monitoring. The discussion states that the applicant is consistent with GALL. Also, the GALL item 3.5.1.A-24 instead of 3.5.1.A-20 item listed in table 2 for block wall in air on page 3.5-93 is III.A3.3-a, which is not listed in table 5 of the GALL for line item 20. Explain how the masonry wall program callout is consistent wit the GALL callout of structures monitoring program and how GALL III.A3.3-a is associated with GALL line item 20.

LR Contact Hoppe NRC Tracking Number 3.5.1.A-20W6 Assigned Department/ License Renewal Individual Hoppe Date Closed 09/24/2004 Table 3.5.2.A-11 LRA Section 25 Woodfield In table 3.5.2.A-10 on page 3.5-92 for component type Structural Steel, note C is called out, Note C was used because there is a separate unique structure which means component is different. However, the component (structural steel) is not differen category in the GALL for BWR Vent Stack (Group 9 Structure).

09/10/2004 with respect to the listed GALL item (III.A3.2-a) and table 1 item (3.5.1.A-20). Structural Stee However, Group 9 does not include any steel components. Because for Vent Stack is not a specific group in the GALL. However, for other line items where there are no listed steel components, we assigned the steel structural steel is the component in other buildings not specifically called out in the GALL components to 3.5.1.A-20 with a note C and additional plant specific groups, the applicant used note A. Explain why note C was used for the vent stack structural note 2.

steel and note A was used for other buildings not listed in the groups in the Gall.

LR Contact Hoppe NRC Tracking Number 3.5.1.A-20W7 Assigned Department/ License Renewal Individual Hoppe Date Closed 10/05/2004 Table 3.5.2.A-10 LRA Section Thursday, March 03, 2005 Page 13 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 26 Woodfield In table 3.5.2.A-1 on page 3.5-67 for component type fasteners in demineralized untreated Fasteners in demineralized untreated water, low flow are located in water, low flow, the applicant calls out note E, different aging management program. The the Torus and as a result of the Mark I Containment Program, many 09/10/2004 applicant has called out the AMP ASME Section XI Inservice Inspection (Subsection IWE) modifications have been performed at Nine Mile Point Nuclear Program to manage the loss of material for this component instead of the structures monitorin Station - Unit 1 (Unit 1). These include: Y-Quenchers, Vent header program per GALL. The intended function of this fastener component is called out as SFS deflectors, Downcomer tie straps, Saddles, Catwalk removal, Relief (Structural/Functional Support). Since this components function is not PB (pressure valve vacuum breakers, Torus attached piping and Resupport of boundary), provide the location in the LRA appendix B AMP description or basis document for relief valve discharge lines.

the IWE program where this inspection is added to the scope of the program. Provide drawin The PAA for Unit 1 IWE discusses the Torus and other components showing examples of these fasteners in this environment. in section 1.2.

Follow-Up Qusetion on 10/7/2004: Response to Follow-Up Question on 10/7/2004:

In NMPs response to this question, NMP still states that AMP ASME Section XI Inservice The procedure is NMP 1- IWE - 003 - 10.

Inspection (Subsection IWE) will be used to manage the aging of fasteners in a demineralized untreated water, low flow environment instead of the structures monitoring program. Provide Section 2.0 directs general visual examination for all areas, and the name and number of the current or future procedure associated with ASME Section XI ISI detailed visual examination for areas more susceptible to corrosion, subsection IWE where the required inspection of these fasteners in a demineralized untreated that manage the AERM water environment is stated to be performed.

This document provides the First Interval Ten-Year Containment Inservice Inspection Plan and Schedule for Nine Mile Point Nuclear Power Station, Unit 1. The Schedule identifies those components (including integral attachments) which are classified ASME Code Class MC, and have been selected for nondestructive examination, as set forth in the ASME Boiler and Pressure Vessel Code.

LR Contact Hoppe NRC Tracking Number 3.5.1.A-20W8 Assigned Department/ License Renewal Individual Hoppe Date Closed 10/13/2004 Table 3.5.2.A-1 LRA Section Thursday, March 03, 2005 Page 14 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 27 Woodfield The applicant states in the discussion for table 3.5.1.A item number 3.5.1.A-21 that ground Groundwater testing is currently performed every six (6) months. No water test data confirms that a below grade aggressive environment does not exist at NMP Un evidence of aggressive ground water has been found at NMPNS 09/10/2004

1. Explain how often the ground water testing will be performed to validate this statement. Th (pH<5.5, or >550 ppm chlorides). Loss of material due to corrosion applicant also states that concrete components were designed and constructed to recognized is not an applicable aging effect for inaccessible steel (i.e.,

codes and standards. Provide original concrete design specifications indicating the concrete embedded steel, reinforcing steel). The concrete is designed to ACI requirements. NMP has operating experience where groundwater inleakage has occurred and ASTM standards which preclude the degradation of concrete through cracks in exterior below grade concrete walls. Repairs have been made from the reinforcing steel and other embedded steel. These standards insure interior side of these walls to prevent further inleakage. However, no repairs have been made the adequate concrete cover over embedded steel, the low water-the outside waterproofing of these walls. Outer layers of reinforcing bars in these walls are st cement ratio, and the high alkaline environment of concrete exposed to a raw water environment, soil above the water table environment or soil below the Additionally, concrete at NMPNS is not exposed to aggressive water table environment. The reinforcing bars are made from carbon steel with yield strength groundwater Per Section 2.3.1.4 of the Technical Basis for Material-less than 100 ksi. NMPs document: Technical Basis for Material-Environment Group Inputs t Environment Group Inputs to the ConRAD Database, corrosion of the Conrad (white paper) indicates that CLASL (carbon steel with yield strength below 100 Ks the reinforcing steel is potentially a significant aging mechanism only in soil above and below the water table (SOILA, SOILB), and in raw water (RAW) is an existin if the steel is exposed to aggressive groundwater (pH<5.5, or >550 material-environment interaction at NMP. In the analysis section of the white paper, for mater ppm chlorides) We do not concur with the belief that reinforcing code CLASL in SOILA, SOILB and RAW environments, the aging effect of loss of material du steel contained within concrete should be subject to an aging to corrosion requires aging management per NMP. The project team believes the outer layers management review. Per Section 2.3.1.4 of the Technical Basis for of reinforcing bars in below grade exterior concrete walls of structures where water inleakage Material-Environment Group Inputs to the ConRAD Database, has occurred need an AMR in table 2 for this material/environment interaction. If the applican corrosion of the reinforcing steel is potentially a significant aging does not concur, provide a technical basis for not performing this additional AMR for exposed mechanism only if the steel is exposed to aggressive groundwater reinforcing bars. (pH<5.5, or >550 ppm chlorides). NMP DER-NM-1998-159 states that the crack exhibit seasonal groundwater intrusion. Because the Additional information requested on 10/5/2004: groundwater intrusion is a seasonal problem, the reinforcing steel has not been subjected to corrosion. The DER states that no Follow-up Questions for NMP on AMR Items 27 and 56 evidence of reinforcing steel corrosion has been seen on the inside (From Jon Woodfield for David Jeng of the NRC Division of Engineering, Mechanical and Civi of the tunnels. Had the conditions stated above not been accurate, Engineering Branch (EMEB)) evidence of the corrosion of the reinforcing steel would have been observed. The exterior concrete which is in contact with the soil is subject to inspection when excavated based on the existing To evaluate the NMP responses to AMR audit items 27 and 56, the NRC EMEB staff requests Structures Monitoring Program. At the time of excavation, the outer the following information from the applicant. surface will be subject to inspection and any repairs will be made.

The groundwater intrusion has been captured by the sites corrective

1. Inspect or provide the most current inspection reports for the reinforced concrete tunnel action program and therefore will be monitored. The engineering structures identified on Nine Mile Point drawing number 12177-EC-60C-3 and other similar in- evaluation performed to close out the DER states that the structural scope tunnel structures with known cracking degradations and seeping or leaking of integrity of the tunnel has not been compromised by the appearance measurable waters through the structural walls. of the cracks and the intrusion of the groundwater. The structure has not lost its ability to perform any of its intended functions relied

2. Determine through direct inspection the extent and sizes of concrete cracks including crac upon for license renewal.

sizes, crack spacings, percentages of though wall/slab cracks, percentages of crack lengths a a fraction of the longitudinal dimension of the tunnel structures.

3. Identify any observable leeching of Calcium Hydroxide or other chemical materials and an signs of loss of material via corrosion of reinforcing steel embedded in concrete.

4. Identify and describe the extent and severity of vertical tunnel cracks, as well as obvious unusual structural degradation or excessive deformations of the affected tunnels.

Thursday, March 03, 2005 Page 15 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified

5. Determine historically and currently the amount and the rate of flow of the incoming leakin water and describe how the water is disposed, also describe any observed structural settleme or bulging of structural walls.

6. The applicant is to describe its past disposition or corrective actions taken to deal with the observed degradation of the tunnel structures and provide a description of its long term plann or in-place disposition method(s) of the tunnel cracking and leaking issue.

Finally, the applicant is requested to justify its rationale for insisting that no AMP is needed for the cracking/leaking deficiencies experienced to date for Nine Mile Point tunnels from the plan LRA perspective.

LR Contact Hoppe NRC Tracking Number 3.5.1.A-21W1 Assigned Department/ License Renewal Individual Hoppe Date Closed 10/27/2004 Table 3.5.1.A LRA Section Thursday, March 03, 2005 Page 16 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 28 Woodfield The applicant states in the discussion for table 3.5.1.A item number 3.5.1.A-23 that crack The discussion for table 3.5.1.A item number 3.5.1.A-23 states that initiation and growth due to SCC and loss of material due to crevice corrosion is not applicable crack initiation and growth due to SCC and loss of material due to 09/10/2004 for liners at NMP Unit 1. The applicant then gives reasons why it believes these aging effects crevice corrosion is not applicable for liners at NMP Unit 1. This is are not applicable, sighting treated water as a reason. The GALL report specifies a Water due to the low temperature of the non-borated Treated Water.

Chemistry Program and monitoring of the spent fuel pool water level to manage the crack Stainless steel in non-borated treated water < 140 degrees F is not initiation and loss of material for liners. The project team believes that an aging management susceptible to SCC and LOM due to crevice corrosion. Therefore, evaluation (AMR) should be provided in table 3.5.2.A (table 2) for these components and the NMP does not agree with the project teams assessment as stated table 1 line item 3.5.1.A-23 discussion should state consistent with GALL with an exception. above. Revisions to the LRA tables are not required.

Explain the reasoning for an aging effect not being applicable when there is an aging management program in place to manage the effect. Response to Follow-Up Question on 10/7/2004:

Follow-Up Question Received on 10/7: NMP will revise the LRA and AMR to credit Chemistry AMP for AERM for stainless steel in water.

In NMPs response to this question, NMP uses the temperature being less than 140 degrees of the non-borated treated water in the Unit 1 spent fuel pool as a reason for crack initiation an growth due to SCC and loss of material due to crevice corrosion not being an applicable aging effect of the spent fuel pool liner. The GALL chapter III line item A5.2-b on page III A5-10 lists an environment of only exposed to water for stainless steel liners where this aging effect is t be managed. The GALL is not concerned with water temperatures. Also, the Program Attribute Assessment (PAA) for the Unit 1 Water Chemistry Control Program states that the Nine Mile Point Unit 1 Water Chemistry Control Program manages cracking (stress corrosion cracking), loss of material (general corrosion), and fouling in components subject to aging management review by controlling the internal environment of systems and components. The PAA also states that the scope of the NMP Unit 1 Water Chemistry Control Program includes the control of water chemistry in other in-scope plant structures and components such as the Torus, Condensate Storage Tank, and Spent Fuel Pool. NMP has clearly stated that it is managing crack initiation and growth due to SCC and loss of material due to crevice corrosion for the spent fuel pool liner with its Unit 1 Water Chemistry Control Program. The project team believes that an aging management evaluation (AMR) should be provided in table 3.5.2.A (tab

2) for the spent fuel pool liner and the table 1 line item 3.5.1.A-23 discussion should state consistent with GALL with an exception. Explain the reasoning for an aging effect not being applicable when the NMP Unit 1 Water Chemistry Control Program clearly states that it manages that effect for the spent fuel pool.

LR Contact Hoppe NRC Tracking Number 3.5.1.A-23W1 Assigned Department/ License Renewal Individual Hoppe Date Closed 10/27/2004 Table 3.5.1.A LRA Section Thursday, March 03, 2005 Page 17 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 29 Woodfield In table 3.5.1.A (table 1) for line item 24 on page 3.5-50 the GALL specifies a Masonry Wall The NMP Masonry Wall Program (MWP) is one part of the NMP Program to manage aging of masonry block walls. The applicant states in the discussion that Structures Monitoring Program (SMP) as stated in the LRA. Each 09/10/2004 is consistent with GALL. However, the applicant has rolled its Masonry Wall Program into its AMP in GALL does not have to have an equal and independent site structures monitoring program. Explain why the structures monitoring program is not program. The NMP SMP addresses the GALL Section XI.S5.

discussed in the discussion area for this table 1 line item as the AMP to manage the aging of The objective of the masonry wall program is to manage aging masonry walls. effects so that the evaluation basis remains valid to the period of extended operation.

For masonry block walls GALL recommends XI.S5.NMP simply implements XI.S5 via the site structures monitoring program, which is consistent with GALL.

LR Contact Hoppe NRC Tracking Number 3.5.1.A-24W1 Assigned Department/ License Renewal Individual Hoppe Date Closed 09/24/2004 Table 3.5.1.A LRA Section Thursday, March 03, 2005 Page 18 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 30 Woodfield In LRA table 3.5.2.A-2 (table 2) on page 3.5-72 for component block wall in air, one of the Masonry block walls in the Unit 1 Reactor building are located aroun intended functions listed is PB (Pressure Boundary). Explain in what capacity the masonry wa stairs, elevator shafts, air lock and track bay. PB IF is Provide an 09/10/2004 performs a pressure boundary function. essential leak tight barrier, which is an IF of the reactor building as the secondary containment.

Follow-Up Question Received on 10/7:

FOLLOW-UP RESPONSE:

In NMPs response to this question, NMP still states that the intended function of the block wa in air on page 3.5-72 is pressure boundary. Explain how porous block wall units prevent the NMP has identified masonry walls within the scope of license passage of air or gases through them. Explain the design of the Unit 1 Reactor Building such renewal subject to aging management review for this structure.

that block walls in conjunction with the metal siding are part of the secondary containment.

LRA page 2.4-5 states that for the NMP Unit 1 Reactor Building, metal wall panels and roofing Masonry block walls in the Unit 1 Reactor building are located aroun above the operating floor are leak tight. No discussion is provided for block walls. stairs, elevator shafts, air lock and track bay. PB IF is "Provide an essential leak tight barrier," which is an IF of the reactor building as the secondary containment. Masonry walls are cable of supporting minimal differential pressure for liquid and gases, whether hollow, hollow and filled or solid. The use of masonry blocks is minimal for PB IF and therefore not mentioned in the brief structure description.

LR Contact Hoppe NRC Tracking Number 3.5.1.A-24W2 Assigned Department/ License Renewal Individual Hoppe Date Closed Table 3.5.2.A-2 LRA Section Thursday, March 03, 2005 Page 19 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 31 Woodfield In LRA table 3.5.2.A-2 (table 2) on page 3.5-77 for component torus support columns, the (a) There are no cast iron torus support columns.

GALL item is III.B1.3.1-a. GALL item III.B1.3.1-a is for carbon steel material. Explain how the 09/10/2004 line item for torus support columns can be consistent with GALL with the material shown as (b) The Material column in the tables in section 3 of the NMP 1 an carbon or low alloy steel (yield strength<100Ksi) and Ductile/malleable Cast Iron. NMP 2 LRA identifies generic material types as evaluated in the Material & Environment White Paper. This type is identified in the AMR as CLASSL: Carbon or Low Alloy Steel (Yield< 100ksi) or Ductile/Malleable Cast Iron The LRA table will be revised to remove Ductile/Malleable Cast Iron the ductile cast iron is not present.

LR Contact Hoppe NRC Tracking Number 3.5.1.A-32W1 Assigned Department/ License Renewal Individual Hoppe Date Closed 09/16/2004 Table 3.5.2.A-2 LRA Section Thursday, March 03, 2005 Page 20 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 33 Nguyen NMP credits System Walkdown Program for managing accessible external surfaces of The Systems Walkdown Program is applicable to the following structures and components within the scope of license renewal (WSLR) and are subject to NMP1 systems: City Water, Compressed Air, Control Room HVAC, 09/10/2004 AMR including EDGs bolting. Identify the list of system and structures WSLR that this AMP i Core Spray, Condensate System, Containment Systems, applicable. Are all the accessible external surface of all carbon steels components listed in th Containment Spray, Control Rod Drive, Reactor Water Cleanup, existing program for applicable systems to be covered by the System Walkdown Program. Emergency Diesel Generator, Emergency Cooling, Fire Detection What is the acceptance criteria for the program. And Protection, Hydrogen Water Chemistry, Spent Fuel Pool Filtering And Cooling, Feedwater/HPCI, Main Generator And Additional Information Required: Auxiliary System, Main Steam, Miscellaneous Non Contaminated Address the acceptance criteria for the System Walkdown Program and discuss which Vents And Drains Neutron Monitoring, Reactor Building HVAC, components are addressed by this program Reactor Building Closed Loop Cooling, Radwaste Building HVAC, Radwaste System, Shutdown Cooling, Service Water, and Turbine Building HVAC.

For the NMP1 systems listed above, all accessible external surfaces of carbon steel components will become part of the system engineers walkdown routine and will be inspected for LOM degradation on a periodic basis.

The Systems Walkdown Program does not currently include specific acceptance criteria for applicable parameters. A list of walkdown attributes is available to system engineers for use in developing walkdown checklists. The systems walkdown check lists will be developed or enhanced to meet these attributes before the period of extended operations.

FOLLOW-UP RESPONSE:

Per Section B2.1.33 of the LRA the "Systems Walkdown Program does not currently include specific acceptance criteria for applicable parameters. A list of walkdown attributes is available to system engineers for use in developing walkdown checklists."

As indicated within Section 1.2 of "Units 1 & 2 Systems Walkdown Program Attribute Assessment," the components within the scope of the Systems Walkdown Program for the NMP1 systems listed above "will be accessible external surfaces of structures and component within the scope of license renewal and subject to aging management review. The inspections will look for loss of material, material degradation, and leakage. The system-specific AMRs are the basis for the license renewal scope of the Systems Walkdown Program." The license renewal scope, where not already included i the program, will be added prior to entry into the Period of Extended Operation.

LR Contact Nold NRC Tracking Number 3.3.1.A-05.DN 2 Thursday, March 03, 2005 Page 21 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified Assigned Department/ License Renewal Individual Nold Date Closed 10/27/2004 Table 3.3.1.A LRA Section 34 Nguyen For several EDGs SSCs, NMP only credits Closed-Cycle Cooling Water System Program. The Selective Leaching Program only needs to be invoked along wit GALL requires both Closed-Cycle Cooling Water System and Selective Leaching of Material the Closed-Cycle Cooling Water System Program for Gray Cast 09/10/2004 Program. Explain why Selective Leaching of Material Program is excluded from the AMPs for Iron and for Copper Alloys with Zn > 15% This has been done the EDGs SSCs. consistently for the Gray Cast Iron components exposed to Treated Water in the NMP1 Emergency Diesel Generator System. For the material of Carbon or Low Alloy Steel (Yield Strength < 100 Ksi) an Ductile/Malleable Cast Iron exposed to Treated Water, Temperature < 140ºF, the AERM of LOM due to Selective Leaching does not exist and the Closed-Cycle Cooling Water System Program is sufficient to manage the AERM of LOM.

LR Contact Nold NRC Tracking Number 3.3.1.A-15 DN 1 Assigned Department/ License Renewal Individual Nold Date Closed 09/15/2004 Table 3.3.1.A LRA Section Thursday, March 03, 2005 Page 22 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 35 Nguyen For several EDGs SSCs, NMP only credits Open-Cycle Cooling Water System Program. The Selective Leaching Program only needs to be invoked along wit GALL requires both Open-Cycle Cooling Water System and Selective Leaching of Material the Open-Cycle Cooling Water System Program for Gray Cast Iron 09/10/2004 Program. Explain why Selective Leaching of Material Program is excluded from the AMPs for and Copper Alloys (Zinc >15%) and Aluminum Bronze . This has the EDGs SSCs. been done consistently for the Gray Cast Iron and Copper Alloys (Zinc >15%) and Aluminum Bronze components exposed to Raw Water in the NMP1 Emergency Diesel Generator System. For the materials of Carbon or Low Alloy Steel (Yield Strength < 100 Ksi) and Ductile/Malleable Cast Iron; Wrought Austentic Stainless Steel; and Copper Alloys (Zinc 15%) exposed to Raw Water the AERM of LOM due to Selective Leaching does not exist and the Open-Cycle Cooling Water System Program is sufficient to manage the AERM of LOM.

LR Contact Nold NRC Tracking Number 3.3.1.A-17 DN 1 Assigned Department/ License Renewal Individual Nold Date Closed 09/15/2004 Table 3.3.1.A LRA Section Thursday, March 03, 2005 Page 23 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 36 Nguyen NMP (under Tanks, Table 3.3.2.A-7 Page 3.3-130 and 131) identify fuel oil as its environment The Environment of Fuel Oil (FO) is defined as including some wate GALLs environment include fuel oil and water as contaminant. Explain why water contamina or moisture. The first paragraph of Section 4.1.20 of the Material-09/10/2004 is excluded from the environment? Environment Group white paper, reads for Fuel Oil The environment is diesel fuel oil. The fuel oil is assumed to be contaminated with some water or moisture. Therefore, water contaminant is not excluded from the environment. The fact that some water contaminant is to be expected in the Fuel Oil and included in the definition thereof, can be found in LRA Table 3.0-1.

Since Fuel Oil is defined within the LRA there is no need to make revisions to Table 3.3.2.A-7.

LR Contact Nold NRC Tracking Number 3.3.1.A-07DN 1 Assigned Department/ License Renewal Individual Nold Date Closed 09/16/2004 Table 3.3.2.A-7 LRA Section Thursday, March 03, 2005 Page 24 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 37 Nguyen The One-Time Inspection Program is used to confirm that aging effects is rare. The piping Table 3.3.1.A, Item Number 3.3.1.A-05 pertains to the external and fitting in EDG exhaust is known to be subject to loss of material due to corrosion. Explain surfaces of carbon steel components of the diesel fuel oil system an 09/10/2004 how One-Time Inspection Program will detect the aging of exhaust piping and fittings in EDG emergency diesel generator systems. The aging management of Also, NMP1 credit Preventive Maintenance Program for loss of material aging. Explain the these diesel generator components is addressed with the Generator inconsistency between 2 units. Emergency Systems (EGS) Aging Management Review for NMP1.

Since the piping and fittings in EDG exhaust are known to be subjec to loss of material due to corrosion, it is accurate to conclude that th One-Time Inspection program was wrongly assigned to manage the aging of the NMP2 EDGs exhaust piping and fittings. As the "Issue Description" indicates, invoking the One-time Inspection Program fo the EDGs exhaust piping of NMP2 is inconsistent with the use of the Prevenative Maintenance Program for managing the aging effects o NMP1s EDGs exhaust piping.

The AMR for the NMP2 Emergency Diesel Generator System (EGS will be revised to change the AMP for the EDG exhaust piping component (i.e. 2EGS*EXH-PIPING-CS) from the One-Time Inspection Program to the Preventative Maintenance Program (PMP). Activity N-N2PMP-011, "New Preventive Maintenance Program To Monitor LOM For EGS System" was already in the LR database (but not used) and will be used as the PMP Activity for inspection of the NMP2 EDG exhaust piping. Table 3.3.2.B-29 (Page 3.3-271) and Section 3.3.2.B.29 (Page 3.3-71) of the LRA wil need to be revised to reflect the use of the Preventative Maintenanc Program.

LR Contact Nold NRC Tracking Number 3.3.1 B-5 DN 1 Assigned Department/ License Renewal Individual Nold Date Closed 10/27/2004 Table 3.3.1.B LRA Section Thursday, March 03, 2005 Page 25 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 38 Nguyen For Piping and Fittings (Table 3.3.2.B-29, Page 3.3-271), the GALLs environment of treated water temperature is different with NMPs in which it only applicable to 95F. NMPs is >140 FAC has been judged to be not a valid AERM due to the elevated 09/10/2004 but <212F. Explain any impact of higher temperature on aging effects. temperatures. There is no operating experience at nuclear power plants where FAC has been found in treated water at temperatures less than 212oF. Based on this, FAC has not been included as an AERM in Table 3.3.2.B-29 against the subject Piping and Fittings due to the elevated temperatures.

Since the material is Carbon Steel, Low Alloy Steel, and Ductile/Malleable Cast Iron with Yield Strengths Less Than 100 Ksi, the AERM of crack initiation and growth by the mechanism of stress corrosion cracking (SCC) is not applicable due to the elevated temperatures. SCC would be applicable if the material was wrought austentic stainless steel or cast austentic stainless steel.

The AERM of LOM as delineated in the LRA Tables, includes general corrosion, pitting and crevice corrosion as specified in GALL row VII.C2.1-a. Based on this and the above, there are no other agin effects that need to be included in LRA Table 3.3.2.B-29 due to the elevated treated water temperatures.

LR Contact Nold NRC Tracking Number 3.3.1 B-15 DN 1 Assigned Department/ License Renewal Individual Nold Date Closed 09/16/2004 Table 3.3.2.B-29 LRA Section Thursday, March 03, 2005 Page 26 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 39 Hsu In the NMP LRA Table 3.1.2.Y, the applicant proposes to manage cracking by using fatigue See response to Issue 1 monitoring program. The GALL report recommends that ISI program and water chemistry 09/08/2004 program are used to manage cracking in general.

Please clarify how to use fatigue monitoring program to manage cracking.

LR Contact Hoppe NRC Tracking Number 3.1.1A-0H5 Assigned Department/ License Renewal Individual Hoppe Date Closed 09/16/2004 Table 3.1.1.A LRA Section Thursday, March 03, 2005 Page 27 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 41 Woodfield For table 1 line item 3.5.1.B-03, the GALL components are penetration sleeves, penetration 1. Structural steel in table 3.5.2.B-1 is the generic material term bellows, and dissimilar metal welds. Explain the rational for using Structural Steel as the used for the carbon or low alloy steel components in 3.5.1.B-03 and 09/13/2004 component type in table 2 where the associated table 1 item is 3.5.1.B-03. Explain the other Table 1 items.

reasoning for the assignment of intended function codes for penetration sleeves, penetration bellows and dissimilar welds. Explain why a Demineralized untreated water, low flow 2. The Intended functions are for all components in that material environment is the only water environment experienced by penetration sleeves and penetratio group, not just for the penetration sleeves, penetration bellows, and bellows. (Ref. Pages 3.5-100 and 3.5-101 of the LRA) dissimilar metal welds.

Note: Structural Steel is way too broad of term

3. Demineralized untreated water, low flow is not the only Follow-Up Question Received on 10/7: environment; 3.5.1.B-03 is also identified for the same material grou in an Air environment, (page 3.5-100).

Explain if the Unit 2 Primary Containment has any penetration bellows. If it does, provide all t Note: Identification of the NUREG 1801 Volume 2 Item in the LRA types of fluid environments to which the inside of these bellows are exposed and the associat Table 2s identifies the components. It is appropriate to group like system the bellows is in. materials, environments for the applicable discipline sections in the LRA.

FOLLOW-UP RESPONSE:

There are no penetration bellows in the Unit 2 Primary Containment LR Contact Hoppe NRC Tracking Number 3.5.1.B-03W1 Assigned Department/ License Renewal Individual Hoppe Date Closed Table 3.5.1.B LRA Section Thursday, March 03, 2005 Page 28 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 42 Woodfield In LRA table 3.5.2.B-1 (table 2) on page 3.5-96 for component airlocks, the GALL item is (a) There are no cast iron components in the airlocks.

II.B4.2-a. GALL item II.B4.2-a is for carbon steel material. Explain how the line item for 09/13/2004 airlocks can be consistent with GALL with the material shown as carbon or low alloy steel (yie (b) The Material column in the tables in section 3 of the NMP 1 an strength<100Ksi) and Ductile/malleable Cast Iron. Explain why the Unit 2 Airlocks have so NMP 2 LRA identifies generic material types as evaluated in the many more intended functions then the Unit 1 Airlock. Explain the acronym RS in intended Material & Environment White Paper. This type is identified in the function, since it is not in LRA table 2.0-1. AMR as CLASSL: Carbon or Low Alloy Steel (Yield< 100ksi) or Note: this question applies to hatches in table 3.5.2.B-1 on LRA page 3.5-98 also. Ductile/Malleable Cast Iron The LRA table will be revised to remove Ductile/Malleable Cast Iron the ductile cast iron is not present.

The design differences between unit 1 and unit 2 account for the different number of intended functions identified between unit 2 and unit 1 for the airlocks.

RS intended function is Radiation Shielding. RD in table 2.0-1 will b revised to RS.

LR Contact Hoppe NRC Tracking Number 3.5.1.B-04W Assigned Department/ License Renewal Individual Hoppe Date Closed 09/15/2004 Table 3.5.1.B LRA Section Thursday, March 03, 2005 Page 29 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 43 Woodfield In LRA table 3.5.2.B-1 (table 2) on page 3.5-98 for Hatches (contd), the aging effect listed is The hatch material is subject to general corrosion and therefore loss Loss of Material and the table 1 item listed is 3.4.1.B-04. The project team believes the aging of material.

09/13/2004 effect should be loss of leak tightness and the table 1 item 3.5.1.B-05. The aging manageme Loss of leak tightness is applied for the hatch seals program should be the Appendix J Program only to be consistent with GALL II.B.2-b. Explain Appendix J and IWE are both used for the hatches and seals why the applicant used the aging effect, AMP and table 1 item as shown in the table. Seals are identified in 3.5.1.B-06 and as Polymer in air in table 3.5.2.B-1 on page 3.5-99.

The hatch design will be reviewed and either the LRA table 3.5.1.B o 3.5.2.B-1 will be revised.

LR Contact Hoppe NRC Tracking Number 3.5.1.B-05W1 Assigned Department/ License Renewal Individual Hoppe Date Closed 10/16/2004 Table 3.5.1.B LRA Section 44 Woodfield For table 1 line item 3.5.1.B-12, the GALL states that further evaluation is recommended if NUREG 1801 Item B2.2.2-a is shown on the next page.

corrosion is significant for inaccessible areas of steel elements: liner plate and containment The four conditions are addressed as follows:

09/13/2004 shell. Also, in GALL chapter II line item B2.2.2-a (page II B2-11) the GALL states that for 1. NMP unit 2 was designed and constructed with equivalent codes inaccessible areas (embedded containment steel shell or liner), loss of material due to as specified in the GALL.

corrosion is not significant if four specific conditions are satisfied. The GALL then lists the fou 2. The concrete is monitored in accordance with the ISI and SM conditions. The GALL states that if any of the four conditions cannot be satisfied, then a plant programs at NMP specific aging management program for corrosion is required. Provide an explanation for eac 3. Not applicable to the NMP design.

of the four conditions explaining how they are satisfied at Nine Mile Point Unit 2. 4. Not applicable to a BWR design.

LR Contact Hoppe NRC Tracking Number 3.5.1.B-12W1 Assigned Department/ License Renewal Individual Hoppe Date Closed 10/27/2004 Table 3.5.1.B LRA Section Thursday, March 03, 2005 Page 30 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 45 Woodfield For table 1 line item 3.5.1.B-12, the GALL components are steel elements: liner plate and See response to question # 41.

containment shell. Explain the rational for using Structural Steel as the component type in tab 09/13/2004 2 where the associated table 1 item is 3.5.1.B-12. Reference page 3.5-100 of the LRA. Expla 1. Structural steel in table 3.5.2.B-1 is the generic material term the reasoning for the assignment of intended function codes for liner plate and containment used for the carbon or low alloy steel components in 3.5.1.B-12 and shell when called out as structural steel in table 2. other Table 1 items.

2. The Intended functions are for all components in that material group, not just for liner plate and containment shell.

Identification of the NUREG 1801 Volume 2 Item in the LRA Table 2s identifies the components. It is appropriate to group like materials, environments for the applicable discipline sections in the LRA LR Contact Hoppe NRC Tracking Number 3.5.1.B-12W2 Assigned Department/ License Renewal Individual Hoppe Date Closed 09/30/2004 Table 3.5.1.B LRA Section Thursday, March 03, 2005 Page 31 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 46 Woodfield In table 3.5.2.B-1 for component type Drywell Head on page 3.5-97 of the LRA, the material (a) There are no cast iron components in the drywell head.

listed is carbon or low alloy steel (yield strength <100 Ksi) and ductile/malleable cast iron.

09/13/2004 Provide examples where these components are made of ductile/malleable cast iron. (b) The Material column in the tables in section 3 of the NMP 1 an NMP 2 LRA identifies generic material types as evaluated in the Material & Environment White Paper. This type is identified in the AMR as CLASSL: Carbon or Low Alloy Steel (Yield< 100ksi) or Ductile/Malleable Cast Iron The LRA table will be revised to remove Ductile/Malleable Cast Iron the ductile cast iron is not present.

LR Contact Hoppe NRC Tracking Number 3.5.1.B-12W3 Assigned Department/ License Renewal Individual Hoppe Date Closed 09/16/2004 Table 3.5.1.B LRA Section 48 Woodfield For table 3.5.1.B (table 1) line item 3.5.1.B-19, the GALL components are steel elements: The drywell head is shown on drawing EV-1A. The drawing clearly drywell head and downcomer pipes with aging due to fretting and lock up from wear. The shows the head attached to the flange with bolts. These bolts 09/13/2004 applicant states that fretting and lock up are not applicable for these components because the prevent head motion relative to the drywell itself. Additionally, frettin components are not subject to relative motion. Provide drawings showing the relative location and lock up are not aging effects that require management as stated of these components in NMP Unit 2 and how they are restrained. in the Material - Environment White Paper. The downcomer pipes are shown on drawings EV-79A and EV-1C. They are clearly shown to be braced and would not be subjected to any relative motion.

LR Contact Hoppe NRC Tracking Number 3.5.1.B-19W1 Assigned Department/ License Renewal Individual Hoppe Date Closed 10/13/2004 Table 3.5.1.B LRA Section Thursday, March 03, 2005 Page 32 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 49 Woodfield Table 3.5.1.B (table 1) line item 3.5.1.B-20 has been associated in table 2 with GALL items Revised per comment TCH 10/07/04 III.A1.2-a, III.A2.2-a, III.A3.2-a, and III.A4.2-a for a variety of components, such as fasteners, 09/13/2004 expansion anchors, metal siding, mechanical penetrations and doors. GALL items III.A1.2-a, See No. 19. which stated:

III.A2.2-a, III.A3.2-a and III.A4.2-a all list structure and/or component as: STEEL GALL Table 5 page 31 identifies All groups, except group 6 COMPONENTS: ALL STRUCTURAL STEEL. Explain how the applicant interpreted the structures with multiple GALL item numbers such as GALL items meaning of this GALL component definition and give an itemized listing of NMP Unit 2 III.A2.2-a, III.A3.2-a and III.A4.2-a.

components that the applicant feels are covered by the GALL line item. GALL Volume I page A-5 table associates these rows with the group type structures for steel elements; AERM is general corrosion and Follow-Up Question Received on 10/7: AMP is SMP.

Steel components (CLASS L) associated with the Structures and In NMPs response to this question, NMP makes reference to GALL Volume II page A-5. The Component Supports such as correct reference is GALL Volume I page A-5. Provide a new response with the correct Structural steel, fasteners, doors, siding and expansion anchors are reference and this response will be acceptable. of the same material group with similar AERM and AMP. The structural components were grouped to align with the GALL, materia class, AERM and AMP.

List of components include all steel components WSLR in the buildings WSLR not already covered by a current LR AMP.

LR Contact Hoppe NRC Tracking Number 3.5.1.B -20W1 Assigned Department/ License Renewal Individual Hoppe Date Closed 10/13/2004 Table 3.5.1.B LRA Section Thursday, March 03, 2005 Page 33 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 50 Woodfield Table 3.5.1.B (table 1) line item 3.5.1B-20 components are: ALL GROUPS EXCEPT GROUP See response to 20 & 22 6: ACCESSIBLE INTERIOR/EXTERIOR CONCRETE AND STEEL COMPONENTS. In table 09/13/2004 3.5.2.B-2 (table 2) on page 3.5-108 and table 3.5.2.B-6 on page 3.5-122, component GALL row assignment was conservative. The convention for the us MECHANICAL PENETRATIONS (THIMBLES) IN SOIL BELOW THE GROUND WATER of inaccessible areas is for components internal to the structure suc TABLE is associated with line item 3.5.1b-20. Explain how mechanical penetrations below th as the containment liner below the floor in a PWR to use adjacent water table are considered accessible steel components. accessible area to monitor potential AERM.

LR Contact Hoppe NRC Tracking Number 3.5.1.B-20W2 Assigned Department/ License Renewal Individual Hoppe Date Closed 09/30/2004 Table 3.5.1.B LRA Section 51 Woodfield In table 3.5.2.B-2 on page 3.5-110 for component Structural Steel (Carbon and Low Alloy Stee See response to ID # 21 which states that:

in Air, one of the intended functions is PB (pressure boundary). Explain how the structural ste 09/01/113 performs its pressure boundary function. The reactor building serves as a secondary containment to provide an essentially leak tight barrier when the primary containment is open. A portion of the side of the structure is steel siding. The structural steel has the same IF as the structure.

LR Contact Hoppe NRC Tracking Number 3.5.1.B-20W3 Assigned Department/ License Renewal Individual Hoppe Date Closed 09/24/2004 Table 3.5.1.B LRA Section Thursday, March 03, 2005 Page 34 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 52 Woodfield In table 3.5.2.B-3 on page 3.5-111 and table 3.5.2.B-4 on page 3.5-115 for component Fasteners will typically have the same intended function as the Fasteners in Air, the intended function is SP (shelter/protection). Explain how the fasteners structure / component they are used on. A SR structure will have an 09/13/2004 perform their shelter/protection to safety-related components function. IF of Shelter & Protect. Structural steel and structural fasteners and reinforced concrete will have the same IF.

LR Contact Hoppe NRC Tracking Number 3.5.1.B-20W4 Assigned Department/ License Renewal Individual Hoppe Date Closed 09/24/2004 Table 3.5.1.B LRA Section 53 Woodfield In table 3.5.2.B-4 on page 3.5-115, table 3.5.2.B-5 on page 3.5-117, table 3.5.2.B-6 on page See # 23 previously approved which states that:

3.5-120 and table 3.5.2.B-12 on page 3.5-135 for component Doors in Air, the intended functio 09/13/2004 is SNSR (structural support for NSR). Explain how the Doors perform their structural support The intended function Structural support for NSR is the description for NSR function. for 10 CFR 54 criteria (a)(2), Non-Safety affecting Safety. Doors in Also applies to doors on page 3.5-89. SR structures are WSLR for (a)(2) as a minimum.

The component door includes the door frame. The door frame provides support for the door.

The component door provides support for itself with its frame.

LR Contact Hoppe NRC Tracking Number 3.5.1.B-20W5 Assigned Department/ License Renewal Individual Hoppe Date Closed 09/24/2004 Table 3.5.2.B-4 LRA Section Thursday, March 03, 2005 Page 35 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 54 Woodfield In table 3.5.2.B-6 on page 3.5-121 for component expansion/grout anchors in Air, the intended Fasteners and expansion anchors will have the same Intended function is FP (flood protection). Explain how the anchors perform their flood protection function as the components they fasten. In this case expansion 09/13/2004 function. anchors are used to fasten the elastomer boot portion of flood penetrations in man holes.

LR Contact Hoppe NRC Tracking Number 3.5.1.B -20W6 Assigned Department/ License Renewal Individual Hoppe Date Closed 09/30/2004 Table 3.5.2.B-6 LRA Section 55 Woodfield In table 3.5.2.B-8 on page 3.5-126 for component type Structural Steel, note C is called out, Note C was used because there is a separate unique structure which means component is different. However, the component (structural steel) is not differen category in the GALL for BWR Vent Stack (Group 9 Structure).

09/13/2004 with respect to the listed GALL item (III.A3.2-a) and table 1 item (3.5.1.A-20). Structural Stee However, Group 9 does not include any steel components. Because for Vent Stack is not a specific group in the GALL. However, for other line items where there are no listed steel components, we assigned the steel structural steel is the component in other buildings not specifically called out in the GALL components to 3.5.1.B-20 with a note C and additional plant specific groups, the applicant used note A. Explain why note C was used for the vent stack structural note 2. The same methodology was used in evaluation of the steel and note A was used for other buildings not listed in the groups in the Gall. Expansion/Grouted anchors and the Fasteners.

Note: The same question applies to the components expansion/grouted anchors and fastener shown on page 3.5-126.

LR Contact Hoppe NRC Tracking Number 3.5.1.B-20W7 Assigned Department/ License Renewal Individual Hoppe Date Closed 10/05/2004 Table 3.5.2.B-8 LRA Section Thursday, March 03, 2005 Page 36 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 56 Woodfield The applicant states in the discussion for table 3.5.1.B item number 3.5.1.B-21 that ground Groundwater testing is currently performed every six (6) months. No water test data confirms that a below grade aggressive environment does not exist at NMP Un evidence of aggressive ground water has been found at NMPNS 09/13/2004

2. Explain how often the ground water testing will be performed to validate this statement. Th (pH<5.5, or >550 ppm chlorides). Loss of material due to corrosion applicant also states that concrete components were designed and constructed to recognized is not an applicable aging effect for inaccessible steel (i.e.,

codes and standards. Provide original Unit 2 concrete design specifications indicating the embedded steel, reinforcing steel). The concrete is designed to ACI concrete requirements. NMP has operating experience where groundwater inleakage has and ASTM standards which preclude the degradation of concrete occurred through cracks in exterior below grade concrete walls. Repairs have been made fro reinforcing steel and other embedded steel. These standards insure the interior side of these walls to prevent further inleakage. However, no repairs have been the adequate concrete cover over embedded steel, the low water-made to the outside waterproofing of these walls. Outer layers of reinforcing bars in these wa cement ratio, and the high alkaline environment of concrete are still exposed to a raw water environment, soil above the water table environment or soil Additionally, concrete at NMPNS is not exposed to aggressive below the water table environment. The reinforcing bars are made from carbon steel with yiel groundwater Per Section 2.3.1.4 of the Technical Basis for Material-strength of less than 100 ksi. NMPs document: Technical Basis for Material-Environment Environment Group Inputs to the ConRAD Database, corrosion of Group Inputs to the Conrad (white paper) indicates that CLASL (carbon steel with yield streng the reinforcing steel is potentially a significant aging mechanism only below 100 Ksi) in soil above and below the water table (SOILA, SOILB), and in raw water if the steel is exposed to aggressive groundwater (pH<5.5, or >550 (RAW) is an existing material-environment interaction at NMP. In the analysis section of the ppm chlorides) We do not concur with the belief that reinforcing white paper, for material code CLASL in SOILA, SOILB and RAW environments, the aging steel contained within concrete should be subject to an aging effect of loss of material due to corrosion requires aging management per NMP. The project management review. Per Section 2.3.1.4 of the Technical Basis for team believes the outer layers of reinforcing bars in below grade exterior concrete walls of Material-Environment Group Inputs to the ConRAD Database, structures where water inleakage has occurred need an AMR in table 2 for this corrosion of the reinforcing steel is potentially a significant aging material/environment interaction. If the applicant does not concur, provide a technical basis fo mechanism only if the steel is exposed to aggressive groundwater not performing this additional AMR for exposed reinforcing bars. (pH<5.5, or >550 ppm chlorides). NMP DER-NM-1998-159 states that the crack exhibit seasonal groundwater intrusion. Because the Additional information requested on 10/5/2004: groundwater intrusion is a seasonal problem, the reinforcing steel has not been subjected to corrosion. The DER states that no Follow-up Questions for NMP on AMR Items 27 and 56 evidence of reinforcing steel corrosion has been seen on the inside (From Jon Woodfield for David Jeng of the NRC Division of Engineering, Mechanical and Civi of the tunnels. Had the conditions stated above not been accurate, Engineering Branch (EMEB)) evidence of the corrosion of the reinforcing steel would have been observed. The exterior concrete which is in contact with the soil is subject to inspection when excavated based on the existing To evaluate the NMP responses to AMR audit items 27 and 56, the NRC EMEB staff requests Structures Monitoring Program. At the time of excavation, the outer the following information from the applicant. surface will be subject to inspection and any repairs will be made.

The groundwater intrusion has been captured by the sites corrective

1. Inspect or provide the most current inspection reports for the reinforced concrete tunnel action program and therefore will be monitored. The engineering structures identified on Nine Mile Point drawing number 12177-EC-60C-3 and other similar in- evaluation performed to close out the DER states that the structural scope tunnel structures with known cracking degradations and seeping or leaking of integrity of the tunnel has not been compromised by the appearance measurable waters through the structural walls. of the cracks and the intrusion of the groundwater. The structure has not lost its ability to perform any of its intended functions relied

2. Determine through direct inspection the extent and sizes of concrete cracks including crac upon for license renewal.

sizes, crack spacings, percentages of though wall/slab cracks, percentages of crack lengths a a fraction of the longitudinal dimension of the tunnel structures.

3. Identify any observable leeching of Calcium Hydroxide or other chemical materials and an signs of loss of material via corrosion of reinforcing steel embedded in concrete.

4. Identify and describe the extent and severity of vertical tunnel cracks, as well as obvious unusual structural degradation or excessive deformations of the affected tunnels.

Thursday, March 03, 2005 Page 37 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified

5. Determine historically and currently the amount and the rate of flow of the incoming leakin water and describe how the water is disposed, also describe any observed structural settleme or bulging of structural walls.

6. The applicant is to describe its past disposition or corrective actions taken to deal with the observed degradation of the tunnel structures and provide a description of its long term plann or in-place disposition method(s) of the tunnel cracking and leaking issue.

Finally, the applicant is requested to justify its rationale for insisting that no AMP is needed for the cracking/leaking deficiencies experienced to date for Nine Mile Point tunnels from the plan LRA perspective.

LR Contact Hoppe NRC Tracking Number 3.5.1.B-21W1 Assigned Department/ License Renewal Individual Hoppe Date Closed 10/27/2004 Table 3.5.1.B LRA Section Thursday, March 03, 2005 Page 38 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 57 Woodfield The applicant states in the discussion for table 3.5.1.B item number 3.5.1.B-23 that crack See response to # 28 which states that:

initiation and growth due to SCC and loss of material due to crevice corrosion is not applicable 09/13/2004 for liners at NMP Unit 2. The applicant then gives reasons why it believes these aging effects The discussion for table 3.5.1.B item number 3.5.1.B-23 states that are not applicable, sighting treated water as a reason. The GALL report specifies a Water crack initiation and growth due to SCC and loss of material due to Chemistry Program and monitoring of the spent fuel pool water level to manage the crack crevice corrosion is not applicable for liners at NMP Unit 2. This is initiation and loss of material for liners. The project team believes that an aging management due to the low temperature of the non-borated Treated Water.

evaluation should be provided in table 3.5.2.B (table 2) for these components and the table 1 Stainless steel in non-borated treated water < 140 degrees F is not line item 3.5.1.B -23 discussion should state consistent with GALL with an exception. Explain susceptible to SCC and LOM due to crevice corrosion. Therefore, the reasoning for an aging effect not being applicable when there is an aging management NMP does not agree with the project teams assessment as stated program in place to manage the effect. above. Revisions to the LRA tables are not required.

Follow-Up Question Received on 10/7: FOLLOW-UP RESPONSE:

In NMPs response to this question, NMP uses the temperature being less than 140 degrees NMP will revise the LRA and AMR to credit Chemistry AMP for of the non-borated treated water in the Unit 2 spent fuel pool as a reason for crack initiation an AERM for stainless steel in water.

growth due to SCC and loss of material due to crevice corrosion not being an applicable aging effect. The GALL chapter III line item A5.2-b on page III A5-10 lists an environment of only exposed to water for stainless steel liners where this aging effect is to be managed. The GALL is not concerned with water temperatures. Also, the Program Attribute Assessment for the Unit 2 Water Chemistry Control Program states that the Nine Mile Point Unit 2 Water Chemistry Control Program manages cracking (stress corrosion cracking), loss of material (general corrosion), and fouling in components subject to aging management review by controlling the internal environment of systems and components. The PAA also states that th scope of the NMP Unit 2 Water Chemistry Control Program includes the control of water chemistry in other in-scope plant structures and components such as the Torus, Condensate Storage Tank, and Spent Fuel Pool. NMP has clearly stated that it is managing crack initiatio and growth due to SCC and loss of material due to crevice corrosion for the spent fuel pool lin with its Unit 2 Water Chemistry Control Program. The project team believes that an aging management evaluation (AMR) should be provided in table 3.5.2.B (table 2) for the spent fuel pool liner and the table 1 line item 3.5.1.B-23 discussion should state consistent with GALL w an exception. Explain the reasoning for an aging effect not being applicable when the NMP U 2 Water Chemistry Control Program clearly states that it manages that effect for the spent fue pool.

LR Contact Hoppe NRC Tracking Number 3.5.1.B -23W1 Assigned Department/ License Renewal Individual Hoppe Date Closed Table 3.5.1.B LRA Section Thursday, March 03, 2005 Page 39 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 58 Woodfield In table 3.5.1.B (table 1) for line item 24 on page 3.5-63 the GALL specifies a Masonry Wall See response to # 29:

Program to manage aging of masonry block walls. The applicant states in the discussion that The NMP Masonry Wall Program (MWP) is one part of the NMP 09/13/2004 is consistent with GALL. However, the applicant has rolled its Masonry Wall Program into its Structures Monitoring Program (SMP) as stated in the LRA. Each structures monitoring program. Explain why the structures monitoring program is not AMP in GALL does not have to have an equal and independent site discussed in the discussion area for this table 1 line item as the AMP to manage the aging of program. The NMP SMP addresses the GALL Section XI.S5.

masonry walls. The objective of the masonry wall program is to manage aging effects so that the evaluation basis remains valid to the period of extended operation.

For masonry block walls GALL recommends XI.S5.NMP simply implements XI.S5 via the site structures monitoring program, which is consistent with GALL LR Contact Hoppe NRC Tracking Number 3.5.1.B-24W1 Assigned Department/ License Renewal Individual Hoppe Date Closed 10/27/2004 Table 3.5.1.B LRA Section 59 Hsu Page 3.1-46 No, the internals of the BWR are a saturated system. Water is at the Component : bottom head, E: treated water or steam. bottom, steam at the top and a mixture somewhere in between.

09/13/2004 GALL identified reactor coolant water only. Does the bottom head subject to steam environment?

LR Contact Petras NRC Tracking Number 3.1.1A-1H5 Assigned Department/ License Renewal Individual Petras Date Closed 09/16/2004 Table 3.1.2.A-1 LRA Section Thursday, March 03, 2005 Page 40 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 60 Hsu Page 3.1-46: CNS spreadsheet that describes this information was provided to the Component: nozzles. auditor.

09/13/2004 Please provide clarification that which AMP & environment are applied to which nozzle.

LR Contact Petras NRC Tracking Number 3.1.1A-1H6 Assigned Department/ License Renewal Individual Petras Date Closed 09/16/2004 Table 3.1.2.A-1 LRA Section 61 Hsu Page 3.1-46 & 47 This information was provided to the auditor Component: Nozzle safe ends 09/13/2004 Please clarify which AMP & environment are applied to which nozzle.

GALL IV.A1.4-a identifies reactor coolant water environment. The applicant identifies treated water or steam environmen.

Clarify whether the steam environment applies for this component.

LR Contact Petras NRC Tracking Number 3.1.1A-1H7 Assigned Department/ License Renewal Individual Petras Date Closed 09/16/2004 Table 3.1.2.A-1 LRA Section Thursday, March 03, 2005 Page 41 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 64 Hsu Page 3.1-51 The top head is in a steam environment Component: top head 09/13/2004 GALL IV.A1.4-a identifies steam environment. The applicant identifies treated water or steam Clarify whether the treated water environment applies for this component or not LR Contact Petras NRC Tracking Number 3.1.1.A-1H8 Assigned Department/ License Renewal Individual Petras Date Closed 09/17/2004 Table 3.1.2.A-1 LRA Section 65 Hsu Page 3.1-52 Note B is assigned because the Xi.M1 program takes some Component: top head exceptions to the GALL specified program (code case year) 09/13/2004 Explain why NOTE B is used instead of NOTE A. The GALL identified plant specific programs LR Contact Petras NRC Tracking Number 3.1.1A-8H2 Assigned Department/ License Renewal Individual Petras Date Closed 09/16/2004 Table 3.1.2.A-1 LRA Section Thursday, March 03, 2005 Page 42 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 66 Hsu Page 3.1-52 Same as Issue 65 Component: top head (nozzles) 09/13/2004 Applicant identifies NOTE 10. NOTE 10 states that top head nozzles are not identified in NUREG-1801 for this GALL row number.

GALL item IV.A1.1-a identifies Top head nozzles (vent, top head spray or RCIC, and spare) with loss of material/general, pitting, and crevice corrosion.

Does applicant address this item? If not, please explain why this item is not addressed in LRA LR Contact Petras NRC Tracking Number 3.1.1.A-H9 Assigned Department/ License Renewal Individual Petras Date Closed 09/16/2004 Table 3.1.2.A-1 LRA Section 67 Hsu Page 3.1-53 There is no Cast Iron in the RCS system. There is no FAC because Component: valves these valves are in a low (no) flow environment (these are the reacto 09/13/2004 Applicant identifies material of cast iron. Please provide drawing or bills of material for this ite safety valves.) See Issue 4 used in RCS and identify the cast iron valves function in RCS. Explain GALL consistency (NOTE A).

Applicant identifies carbon/low-alloy steel exposed internally to treated water/steam with low flow. Please explain how to define low flow and justify why FAC is not considered.

LR Contact Petras NRC Tracking Number 3.1.1.A-H10 Assigned Department/ License Renewal Individual Petras Date Closed 09/16/2004 Table 3.1.2.A-1 LRA Section Thursday, March 03, 2005 Page 43 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 68 Hsu Page 3.1-56 All components in water environment. (BWR internal system is a Component: CRD Assemblies saturated system so there is some mixture of water and steam).

09/13/2004 Page 3.1-56:

Component: control rod guide tubes, core plate and bolts Page 3.1-57, 58 Component: core shroud, core shroud head bolts and collars Page 3.1-59 (core spray lines and spargers), 3.1-60 (in-core inst. Dry tubes & guide tubes), 3.

61 (top guides)

GALL identifies high purity water environment. The applicant identifies treated water or steam Clarify whether the steam environment applies for this component or not.

LR Contact Petras NRC Tracking Number 3.1.1.A-31H1 Assigned Department/ License Renewal Individual Petras Date Closed 09/16/2004 Table 3.1.2.A-2 LRA Section 70 Hsu Page 3.1-60 (steam dryer) Steam Dryers inspected by Augmented ISI Section 6.2.7.

Explain how to manage steam dryer with BWR vessel internals program. Please explain whic Inspections defined by NER-1M-080 Rev. 2. BWRVIP project is 09/13/2004 part of BWR VIP handles steam dryer. Steam dryer is an NSR component? developing I & E guidelines for the steam dryers and NMP is committed to implementing these. Yes, the steam dryers are NSR.

LR Contact Petras NRC Tracking Number 3.1.1.A-31H3 Assigned Department/ License Renewal Individual Petras Date Closed 09/16/2004 Table 3.1.2.A-2 LRA Section Thursday, March 03, 2005 Page 44 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 71 Hsu Page 3.1-63 (temperature equalizing columns) This is an error in the LRA, these components are not part of the Explain how to apply the one-time inspection program to this item and categorize this item as RCPB and have an incorrect environment assigned. They should 09/13/2004 small-bore piping have an AIR environment resulting in no AERMs. The AMR and the LRA need to be revised to correct this error.

LR Contact Petras NRC Tracking Number 3.1.1.A-07H1 Assigned Department/ License Renewal Individual Petras Date Closed 09/17/2004 Table 3.1.2.A-3 LRA Section 72 Hsu Page 3.1-65 (flow elements) These are the FEs that are in the main RR piping. They are 28 in What are the sizes of flow elements? The BWR SCC handles 4 in. or larger pipe only. Pleas diameter. They are covered by NMP-ISI-003 (Ten-Year Inservice 09/13/2004 provide this item in ISI plan. Inspection Plan and inspected using UT procedures.(NDEP-UT-6.24)

LR Contact Petras NRC Tracking Number 3.1.1.A-29H2 Assigned Department/ License Renewal Individual Petras Date Closed 09/17/2004 Table 3.1.2.A-4 LRA Section Thursday, March 03, 2005 Page 45 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 74 Hsu Page 3.1-72 (filters) These components are part of the NMP1 CRD system and form part Please identify this item in applicants ISI plan of the RCPB. They are <4 in diameter and therefore subject to the 09/13/2004 Inservice Pressure Testing Plan, NMP1-PT-003. This is controlled administratively by the NMP procedure NIP-IIT-01 which controls all ASME Section XI activities.

LR Contact Petras NRC Tracking Number 3.1.1.A-07H1 Assigned Department/ License Renewal Individual Petras Date Closed 09/17/2004 Table 3.1.2.A-5 LRA Section 76 Hsu Page 3.1-78 (Bottom head, nozzles, nozzle safe ends), 3.1-83 (top head leak detection lines, See response to Issue 1 vessel shell) 09/13/2004 How to manage the cracking by using Fatigue monitoring program LR Contact Petras NRC Tracking Number 3.1.1.B-1H1 Assigned Department/ License Renewal Individual Petras Date Closed 09/16/2004 Table 3.1.2.B-1 LRA Section Thursday, March 03, 2005 Page 46 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 77 Hsu Page 3.1-78 (nozzles, nozzle safe ends) See response to Issues 1 and 4 How to manage the cast iron material which is not defined by GALL 09/13/2004 LR Contact Petras NRC Tracking Number 3.1.1.B-1H2 Assigned Department/ License Renewal Individual Petras Date Closed 09/16/2004 Table 3.1.2.B-1 LRA Section 81 Hsu Page 3.1-82, 83,84,85 (support skirt, top head and nozzles, top head leak detection lines, See the response to Issue 1 vessel welds) 09/13/2004 How to manage cracking for cast iron component? Explain GALL consistency LR Contact Petras NRC Tracking Number 3.1.1.B-1H3 Assigned Department/ License Renewal Individual Petras Date Closed 09/16/2004 Table 3.1.2.B-1 LRA Section Thursday, March 03, 2005 Page 47 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 82 Hsu Page 3.1-83 (Top head leak detection lines) No, there is only one There is a vessel flange leak detection line. Are there any other detection lines at the Top hea 09/10/2004 LR Contact Petras NRC Tracking Number 3.1.1B-8H1 Assigned Department/ License Renewal Individual Petras Date Closed 09/21/2004 Table 3.1.2.B-1 LRA Section 103 Wen Page 3.4-34 Q1: No, this item does not contain components made of cast iron.

Material: GALLs material item does not apply to components of Cast Iron. Does this item See Issue #4. Q2: See Issue #1.

09/13/2004 contain components made of cast iron?

Aging Effect: GALL identified the aging effect as cumulative fatigue damage. Deviating from GALLs description, NMP states the aging effect as "cracking." Since cracking could be the result of several different aging mechanisms, how NMPs fatigue monitoring program manage this aging effect of cracking?

LR Contact Hoppe NRC Tracking Number 3.4.1.A-01 W1 Assigned Department/ License Renewal Individual Hoppe Date Closed 09/16/2004 Table 3.4.2.A-2 LRA Section Thursday, March 03, 2005 Page 48 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 104 Wen Page 3.4-25 No, this item does not contain components made of cast iron. See Material: GALLs material item does not apply to components of Cast Iron. Does this item Issue #4.

09/13/2004 contain components made of cast iron?

Note: Discuss detection of aging effect.

LR Contact Hoppe NRC Tracking Number 3.4.1.A-02 W1 Assigned Department/ License Renewal Individual Hoppe Date Closed 09/16/2004 Table 3.4.2.A-1 LRA Section 105 Wen Page 3.4-28 No, this item does not contain components made of cast iron. See Material: GALLs material item does not apply to components of Cast Iron. Does this item Issue #4.

09/13/2004 contain components made of cast iron?

Note: Discuss plant-specific aging management program.

LR Contact Hoppe NRC Tracking Number 3.4.1.A-05 W1 Assigned Department/ License Renewal Individual Hoppe Date Closed 09/16/2004 Table 3.4.2.A-1 LRA Section Thursday, March 03, 2005 Page 49 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 106 Wen Page 3.4-34 No, this item does not contain components made of cast iron. See Material: GALLs material item does not apply to components of Cast Iron. Does this item Issue #4.

09/13/2004 contain components made of cast iron?

LR Contact Hoppe NRC Tracking Number 3.4.1.A-06 W1 Assigned Department/ License Renewal Individual Hoppe Date Closed 09/16/2004 Table 3.4.2.A-2 LRA Section 107 Wen Page 3.4-48 No, this item does not contain components made of cast iron. See Material: GALLs material item does not apply to components of Cast Iron. Does this item Issue #4.

09/13/2004 contain components made of cast iron?

LR Contact Hoppe NRC Tracking Number 3.4.1.B-02 W1 Assigned Department/ License Renewal Individual Hoppe Date Closed 09/17/2004 Table 3.4.2.B-2 LRA Section Thursday, March 03, 2005 Page 50 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 108 Wen Page 3.4-51 No, this item does not contain components made of cast iron. See Material: GALLs material item does not apply to components of Cast Iron. Does this item Issue #4.

09/13/2004 contain components made of cast iron?

Environment: Is this item subject to steam environment?

LR Contact Hoppe NRC Tracking Number 3.4.1.B-06 W1 Assigned Department/ License Renewal Individual Hoppe Date Closed 09/18/2004 Table 3.4.2.B-3 LRA Section 109 Wen Page 3.4-56 No, this item does not contain components made of cast iron. See Material: GALLs material item does not apply to components of Cast Iron. Does this item Issue #4.

09/13/2004 contain components made of cast iron?

Environment: Is this item subject to treated water environment?

LR Contact Hoppe NRC Tracking Number 3.4.1.B-07 W1 Assigned Department/ License Renewal Individual Hoppe Date Closed 09/15/2004 Table 3.4.2.B-4 LRA Section Thursday, March 03, 2005 Page 51 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 110 Saba NMP unit 1 credits fatigue monitoring program to manage cracking aging effect for Carbon or a) Gall Item IV.C1.3-d includes carbon steel, cast austenitic Low Alloy Steel (Yield Strength < 100 Ksi) and Ductile/Malleable Cast Iron, CASS, and WASS stainless steel, and stainless steel. As noted in the comment, Table 09/13/2004 valves and orifices in treated water or steam, temperature 482 F (Tables 3.3.2.A-17 and 20 3.3.2.A-17 and 20 of the LRA state that NMP Unit 1 is consistent Pages 3.3-164, 165, 167, 168, 178, and 180. NMP listed Not A (for valves) and Note C (for with the GALL. The NMP Unit 1 materials associated with the orifices) which denote that the above combination of material, environment, aging effect and corresponding LRA sections are Carbon Steel or Low Alloy Steel AMP are consistent with GALL items IV.C1.3d. (yield strength < 100ksi) and Ductile or Malleable Cast Iron (pg 164) a) GALL material is carbon steel. Explain how the same aging effect applies to the low alloy CASS (pgs. 165 and 180), and WASS (pgs. 167 and 178).

steel and cast iron components. Regarding Ductile or Malleable Cast Iron, consistent with the b) GALL treated water temperature is limited to 550 F Clarify whether NMP treated water response to Item 4, the LRA table will be revised to remove temperature is below this limit. If not, justify Ductile/Malleable Cast Iron in cases where the ductile cast iron is no c) How use of Fatigue Monitoring Program is consistent with TLAA that is recommended by present. There is no cast iron present in the subject systems. The GALL? remaining materials identified in the corresponding sections of the d) GALLs aging effect is Cumulative Fatigue Damage, where as NMP identified cracking LRA are consistent with the materials in GALL Item IV.C1.3-d; as an aging effect to be managed. Explain how these are consistent. Explain and provide therefore, the aging effects that apply to the applicable components documentation to show how cracking is managed by CFM program. (Note that aging effect in are also consistent.

LRA Table 3.1.1 for Item 1 is also cumulative fatigue damage.)

e) Explain what is the effect of low flow environment on the components aging effect. b) The <550°F environment identified in the corresponding GALL section does not actually represent a limit, it represents an upper temperature below which all nuclear plant treated water systems would fit. For treated water systems at NMP, we identify the highest temperature range as being >482°F for the specific AERMs associated with some materials that occur over that value. There ar no treated water systems at NMP that exceed the 550°F GALL parameter. This is, therefore, consistent with the <550°F provision i the GALL.

c) The Fatigue Monitoring Program is a TLAA Aging Management Program (See LRA Section B3.2 and GALL Program X.M1) d) See response to Issue 1. Cracking due to Fatigue will be replaced by Cumulative Fatigue Damage.

e) Low flow environment groups have been established to address the aging effects that may occur as a function of fluid flow of treated water through system piping. The specific aging effect resulting is loss of material. For carbon and low alloy steel exposed to treated water, loss of material due to flow accelerated corrosion (FAC) may occur in non-low flow environments. Loss of material due to genera corrosion may also occur in non-low flow treated water environments however, FAC is the predominant aging effect, therefore, in situation where both FAC and general corrosion may exist; the FAC program is assigned for managing loss of material for both FAC and general corrosion. For low flow treated water environments, FAC will not occur, but general corrosion may exist in carbon and low alloy steel.

An inspection (e.g. one time inspection) is credited with managing general corrosion in those cases. Flow rate does not have an effect Thursday, March 03, 2005 Page 52 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified on the potential aging effects for stainless steel in treated water. Th effect of low flow environment on the component aging effect is addressed in greater detail in the Material-Environment Group Technical Paper.

LR Contact Nold NRC Tracking Number 3.1.1.A-01s1 Assigned Department/ License Renewal Individual Nold Date Closed 10/08/2004 Tables 3.3.2.A-17 LRA Section Thursday, March 03, 2005 Page 53 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 111 Saba NMP unit 1 credits ASME Section XI ISI, One-time inspection, and water chemistry control a) Parameters monitored/inspected and detection of aging effects programs to manage cracking aging effect for Carbon or Low Alloy Steel (Yield Strength < 10 are two of the ten program attributes described in the Program 09/13/2004 Ksi) and Ductile/Malleable Cast Iron, CASS, and WASS piping and fittings and valves in Attribute Assessment documents provided for each credited program treated water or steam, temperature 482 F (Tables 3.3.2.A-10, 17 and 18, Pages 3.3-141, in the LRA. Please refer to the Program Attribute Assessment 142, 143, 164, 166, 167, 168, and 172) documents for each of the subject programs:

a) Provide documentation to show parameters monitored/inspected, and explain how aging ASME Section XI ISI, effect is detected. One-time inspection, b) Explain how the same aging effect applies to the low alloy steel and cast iron components and water chemistry control programs c) GALL treated water temperature is limited to 550 F Clarify whether NMP treated water for a description of the parameters monitored/inspected and temperature is below this limit. If not, justify detection of aging effects. These documents are available for review d) Explain what is the effect of low flow environment on the components aging effect. at Constellations License Renewal offices.

b) GALL Item IV.C1.1-I addresses small bore stainless steel and carbon steel reactor coolant pressure boundary components. As noted in the comment, Tables 3.3.2.A-10, 17 and 18 of the LRA stat that NMP Unit 1 is consistent with the GALL. The NMP Unit 1 materials associated with the corresponding LRA sections are Carbon Steel or Low Alloy Steel (yield strength < 100ksi) and Ductile or Malleable Cast Iron (pg. 164), CASS (pgs. 142 and 166), and WASS (pgs. 141, 143, 167, 168, and 172). Regarding Ductile or Malleable Cast Iron, consistent with the response to Item 4, the LRA table will be revised to remove Ductile/Malleable Cast Iron in cases where the ductile cast iron is not present. Table 3.3.2.A-17 will be revised to remove the cast iron wording. Regarding WASS, carbon steel and low alloy steel, these materials are consistent with the materials in GALL Item IV.C1.1-I; therefore, the aging effects that apply to the applicable components are also consistent. Regarding CASS, although all small bore components are included under the same program, the components with CASS materials are not consistent with GALL Item IV.C1.1-I; therefore, the LRA table will be revised accordingly.

c) The <550°F environment identified in the corresponding GALL section does not actually represent a limit, it represents an upper temperature below which all nuclear plant treated water systems would fit. For treated water systems at NMP, we identify the highest temperature range as being >482°F for the specific AERMs associated with some materials that occur over that value. There ar no treated water systems at NMP that exceed the 550°F GALL parameter. This is, therefore, consistent with the <550°F provision i the GALL.

d) Low flow environment groups have been established to address the aging effects that may occur as a function of fluid flow of treated water through system piping. The specific aging effect resulting is loss of material. For carbon and low alloy steel exposed to treated Thursday, March 03, 2005 Page 54 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified water, loss of material due to flow accelerated corrosion (FAC) may occur in non-low flow environments. Loss of material due to genera corrosion may also occur in non-low flow treated water environments however, FAC is the predominant aging effect, therefore, in situation where both FAC and general corrosion may exist; the FAC program is assigned for managing loss of material for both FAC and general corrosion. For low flow treated water environments, FAC will not occur, but general corrosion may exist in carbon and low alloy steel.

An inspection (e.g. one time inspection) is credited with managing general corrosion in those cases. Flow rate does not have an effect on the potential aging effects for stainless steel in treated water. Th effect of low flow environment on the component aging effect is addressed in greater detail in the Material-Environment Group Technical Paper.

LR Contact Nold NRC Tracking Number 3.1.1.A-07s1 Assigned Department/ License Renewal Individual Nold Date Closed 10/08/2004 Tables 3.3.2.A-10 LRA Section Thursday, March 03, 2005 Page 55 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 112 Saba Table 3.3.2.A-17, page 3.3-164 indicates that the combination of valve - carbon steel- treated a) Concur with the comment. The GALL Item should be IV.C1.3-a water -loss of material- and flow accelerated corrosion program is consistent with GALL item instead of IV.C1.3-c. The LRA will be changed to address this 09/13/2004 IV.C1.3c. GALL item IV.C1.3c is for valve- CASS- treated water- cracking- and BWR stress comment.

corrosion cracking and water chemistry. This appears to be a typing error (IV.C1.3a instead).

Clarify. b) Loss of material is the aging effect that is managed by the Flow GALL item IV.C1.1c listed wall thinning as the aging effect that requires to be managed. Accelerated Corrosion (FAC) Program. Wall thinning due to FAC is Clarify that loss of material aging effect listed in table 2s for this item applies to wall thinning bounded by the loss of material aging effect. Therefore, the loss of due to flow accelerated corrosion material aging effect for this item applies to wall thinning due to FAC LR Contact Nold NRC Tracking Number 3.1.1.A-25s1 Assigned Department/ License Renewal Individual Nold Date Closed 10/08/2004 Tables 3.3.2.A-17 LRA Section Thursday, March 03, 2005 Page 56 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 113 Saba NMP unit 2 credits fatigue monitoring program to manage cracking aging effect for Carbon or a) Gall Items IV.C1.1.h and IV.C1.3-d include carbon steel, cast Low Alloy Steel (Yield Strength < 100 Ksi) and Ductile/Malleable Cast Iron piping and fitting austenitic stainless steel, and stainless steel. As noted in the 09/13/2004 and valves in treated water or steam, temperature 482 F (Table 3.3.2.B-24, Pages 248, 249 comment, Table 3.3.2.B-24 of the LRA states that NMP Unit 2 is and 253). NMP listed Not A which indicates that the above combination of components, consistent with the GALL. The NMP Unit 2 materials associated wit material, environment, aging effect and AMP are consistent with GALL items IV C1.1h (for the corresponding LRA sections is Carbon Steel or Low Alloy Steel piping and fittings) and IV.C1.3d (for valves). (yield strength < 100ksi) and Ductile or Malleable Cast Iron.

a) GALL material is carbon steel. Explain how the same aging effect applies to the low alloy Regarding Ductile or Malleable Cast Iron, consistent with the steel and cast iron components. response to Item 4, the LRA table will be revised to remove b) GALL treated water temperature is limited to 550 F Clarify whether NMP treated water Ductile/Malleable Cast Iron in cases where the ductile cast iron is no temperature is below this limit. If not, justify present. Carbon Steel or Low Alloy Steel (yield strength < 100ksi) c) How use of Fatigue Monitoring Program is consistent with TLAA that is recommended by identified in the corresponding sections of the LRA are consistent GALL? with the materials in Gall Items IV.C1.1.h and IV.C1.3-d; therefore, d) GALLs aging effect is Cumulative Fatigue Damage, where as NMP identified cracking the aging effects that apply to the applicable components are also as an aging effect to be managed. Explain how these are consistent. Explain and provide consistent. There are no cast iron components identified in the documentation to show how cracking is managed by CFM program. (Note that aging effect in corresponding sections of the LRA.

LRA Table 3.1.1 B for Item 1 is also cumulative fatigue damage.)

e) Explain what is the effect of low flow environment on the components aging effect. b) The <550°F environment identified in the corresponding GALL section does not actually represent a limit, it represents an upper temperature below which all nuclear plant treated water systems would fit. For treated water systems at NMP, we identify the highest temperature range as being >482°F for the specific AERMs associated with some materials that occur over that value. There ar no treated water systems at NMP that exceed the 550°F GALL parameter. This is, therefore, consistent with the <550°F provision i the GALL.

c) The Fatigue Monitoring Program is a TLAA Aging Management Program. (See LRA Section B3.2 and GALL Program X.M1) d) See response to Issue 1. Cracking due to Fatigue will be replaced by Cumulative Fatigue Damage.

e) Low flow environment groups have been established to address the aging effects that may occur as a function of fluid flow of treated water through system piping. The specific aging effect resulting is loss of material. For carbon and low alloy steel exposed to treated water, loss of material due to flow accelerated corrosion (FAC) may occur in non-low flow environments. Loss of material due to genera corrosion may also occur in non-low flow treated water environments however, FAC is the predominant aging effect, therefore, in situation where both FAC and general corrosion may exist; the FAC program is assigned for managing loss of material for both FAC and general corrosion. For low flow treated water environments, FAC will not occur, but general corrosion may exist in carbon and low alloy steel.

An inspection (e.g. one time inspection) is credited with managing general corrosion in those cases. Flow rate does not have an effect Thursday, March 03, 2005 Page 57 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified on the potential aging effects for stainless steel in treated water. Th effect of low flow environment on the component aging effect is addressed in greater detail in the Material-Environment Group Technical Paper.

LR Contact Nold NRC Tracking Number 3.1.1.B-01s1 Assigned Department/ License Renewal Individual Nold Date Closed 10/08/2004 Table 3.3.2.B-24 LRA Section Thursday, March 03, 2005 Page 58 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 114 Saba NMP unit 2 credits ASME Section XI ISI, One-time inspection, and water chemistry control a) Parameters monitored/inspected and detection of aging effects programs to manage cracking aging effect for Carbon or Low Alloy Steel (Yield Strength < 10 are two of the ten program attributes described in the Program 09/13/2004 Ksi) and Ductile/Malleable Cast Iron, CASS, and WASS piping and fittings, flow elements, Attribute Assessment documents provided for each credited program orifices, and valves in treated water or steam, temperature 482 F (Tables 3.3.2.B-24 and 30 in the LRA. For a description of the parameters monitored/inspected Pages 3.3-246, 248, 249, 250, 251, 252, 253, 255, 274, and 276) and detection of aging effects, please refer to the Program Attribute a) Provide documentation to show parameters monitored/inspected, and explain how aging Assessment documents for each of the subject programs:

effect is detected. ASME Section XI ISI, b) Explain how the same aging effect applies to the low alloy steel and cast iron components One-time inspection, c) GALL treated water temperature is limited to 550 F Clarify whether NMP treated water and water chemistry control programs temperature is below this limit. If not, justify These documents are available for review at Constellations License d) Explain what is the effect of low flow environment on the components aging effect. Renewal offices.

b) GALL Item IV.C1.1-I addresses small bore stainless steel and carbon steel reactor coolant pressure boundary components. As noted in the comment, Tables 3.3.2.B-24 and 30 of the LRA state that NMP Unit 2 is consistent with the GALL. The NMP Unit 2 materials associated with the corresponding LRA sections are Carbon Steel or Low Alloy Steel (yield strength < 100ksi) and Ductile or Malleable Cast Iron (pgs. 246, 248, 249, 252, and 253) and WASS (pgs. 250, 251, 255, 274 and 275). Regarding Ductile or Malleable Cast Iron, consistent with the response to Item 4, the LRA table will be revised to remove Ductile/Malleable Cast Iron in cases where the ductile cast iron is not present. It will be removed from Table 3.3.2.B-24. Regarding WASS, carbon steel and low alloy steel, these materials are consistent with the materials in GALL Item IV.C1.1-I; therefore, the aging effects that apply to the applicable components are also consistent. There is no CASS identified in the corresponding sections of the LRA.

c) The <550°F environment identified in the corresponding GALL section does not actually represent a limit, it represents an upper temperature below which all nuclear plant treated water systems would fit. For treated water systems at NMP, we identify the highest temperature range as being >482°F for the specific AERMs associated with some materials that occur over that value. There ar no treated water systems at NMP that exceed the 550°F GALL parameter. This is, therefore, consistent with the <550°F provision i the GALL.

d) Low flow environment groups have been established to address the aging effects that may occur as a function of fluid flow of treated water through system piping. The specific aging effect resulting is loss of material. For carbon and low alloy steel exposed to treated water, loss of material due to flow accelerated corrosion (FAC) may occur in non-low flow environments. Loss of material due to genera corrosion may also occur in non-low flow treated water environments Thursday, March 03, 2005 Page 59 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified however, FAC is the predominant aging effect, therefore, in situation where both FAC and general corrosion may exist; the FAC program is assigned for managing loss of material for both FAC and general corrosion. For low flow treated water environments, FAC will not occur, but general corrosion may exist in carbon and low alloy steel.

An inspection (e.g. one time inspection) is credited with managing general corrosion in those cases. Flow rate does not have an effect on the potential aging effects for stainless steel in treated water. Th effect of low flow environment on the component aging effect is addressed in greater detail in the Material-Environment Group Technical Paper.

LR Contact Nold NRC Tracking Number 3.1.1.B-07s1 Assigned Department/ License Renewal Individual Nold Date Closed 10/08/2004 Table 3.3.2.B-24 LRA Section Thursday, March 03, 2005 Page 60 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 115 Saba NMP unit 2 refer to GALL items IV.C1.1c and IV.C1.3a for piping and fitting and valves with th This comment applies to the NMP2 Feedwater System piping and Table 1 item number. GALL items IV.C1.1c and listed wall thinning as the aging effect that fittings and valves in LRA Table 3.4.2.B-3. As noted in Section 2.1.1 09/13/2004 requires to be managed. Clarify that loss of material aging effect listed in table 2s for this ite of the Material Environment White Paper, "Loss of material is define applies to wall thinning due to flow accelerated corrosion. as a generalized loss of material distributed relatively evenly over th surface of a component. Synonyms for loss of material include loss of thickness, loss of section, wall thinning, weight loss, and ligament cracking. (bold and italics added for emphasis). Thus, the flow accelerated corrosion program is adequate for this aging effect."

LR Contact Petras NRC Tracking Number 3.1.1.B-25s1 Assigned Department/ License Renewal Individual Petras Date Closed 10/06/2004 Table 3.1.1.B LRA Section Thursday, March 03, 2005 Page 61 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 116 Saba Table 1 Item 3.3.1.A-1: The third paragraph of Section 2.1.1.2 of the CNS technical paper NMP in LRA Table 3.3.1.A states that: Not applicable for the NMP1 Spent Fuel Pool Filtering entitled "Technical Basis for Material-Environment Group Inputs To 09/13/2004 and Cooling System for the following reasons: The ConRad Database" (Revision 6) reads:

Stainless steel piping and flow elements in this system have no aging effects Stainless steel heat exchanger components either have no aging effects or have a differen "Type 316 stainless steel has a reduced tendency for pitting aging effect (loss of heat transfer) compared to Type 304 as a result of its higher molybdenum content Valves in this system either consist of a different material or have no aging effects however, this difference is only significant in higher chloride Pumps in this system are evaluated in rows 3.3.1.A-15 and 3.3.1.A-29. environments such as are found in seawater. At a pH between 4 and However, GALL Section VII.A4 identifies loss of material/pitting and crevice corrosion for the 8, pitting is possible but unlikely at 100 ppm chloride and will not stainless steel components in the spent fuel cooling and cleanup system. occur at 10 ppm chloride or below [6]. The tendency for pitting is als Provide additional justification to show why this item is not applicable to NMP (No aging effect increased with increasing oxygen concentration in the environment for stainless steel piping and fitting in this systems. Compare the NMP application with the and by sensitization of austenitic stainless steels [6]. At halogen discussion provided in the SRP further evaluation and GALL Volume 2 Tables. levels below 150 ppb pitting will not occur regardless of dissolved Further, how aging effects for piping and fitting within this system is different from pump casin oxygen content. A halogen concentration of 150 ppb is far higher than would be permitted by FOLLOW-UP QUESTIONS SENT ON 10/8: chemistry control programs for most water environments such as treated water. The system chemistry would have to be significantly

1) GALL items VII.A4.1-a, A4.2-a, A4.3-a, A4.4-b recommend using XI.M2 augmented with off normal for pitting to occur in any BWR or PWR system with XI.M32 program for managing loss of material for stainless steel and carbon steel component treated water."

in the chemically treated oxygenated water up to 125 F or demineralized oxygenated water.

Explain how the environment in the NMP Unit 1 spent fuel pool cooling and cleanup system An excerpt from the second paragraph of Section 2.1.1.3 of the CNS differs from the GALLs environment for this system. technical paper reads "Crevice corrosion affects stainless steels,

2) What are the concentrations of chloride, sulfate, and dissolved oxygen in the Unit 1 and nickel-based alloys, carbon and low alloy steels, cast irons, copper Unit 2 spent fuel pool cooling and cleanup system? alloys, and aluminum alloys under the same environmental condition

3) How treated water chemistry in the Unit 1 spent fuel pool cooling and cleanup system is that cause pitting."

managed?

Section 4.1.1.21 of the CNS technical paper for Treated Water, Temperature < 140ºF (TWL) reads:

"The water source is demineralized water that is chemically treated t remove oxygen. Corrosion inhibitors may be added to the water.

Administrative limits are placed on dissolved oxygen and contaminants, and in some cases suspended solids. The concentration of contaminants is generally controlled by filtration, ion exchangers, or both, but other methods such as feed-and bleed (dilution) may be used to meet administrative limits. The maximum normal operating dissolved oxygen concentration is 200 ppb or less and the maximum chloride, fluoride and sulfate concentrations durin normal operation are 1000 ppb."

From Attachment 1 "Material-Environment Group Analyses" of the CNS technical paper, the table analysis entitled "Wrought Austenitic Stainless Steel In Treated Water or Steam, Temperature < 140ºF" indicates that there are insufficient halogens in this treated water environment for pitting or crevice corrosion to occur.

Thursday, March 03, 2005 Page 62 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified These passages from the CNS technical paper form the basis of wh the Loss of Material mechanisms of pitting and crevice corrosion are not applicable to the wrought austenitic stainless steel "Piping and Fittings" component types of Table 3.32.A-21 (page 3.3-183) and why Table 3.3.1.A, Item 3.3.1.A-01 reads that "Stainless steel piping and flow elements in this system have no aging effects".

(b) As indicated in the "Spent Fuel Pool Filtering and Cooling System (FP) Aging Management Review for NMP1" (Revision 1) and in Table 3.3.2.A-21 (page 3.3-184) , the Fuel Pool - Circulating Pumps 11 & 12 casings are made of Gray Cast Iron. Hence the AERMs would be different that those expected for the wrought austenitic stainless steel piping and fittings of part (a).

FOLLOW-UP RESPONSE:

1) With respect to temperature, Section 2.1 Operating Procedure N1-OP-6 "Fuel Pool Filtering and Cooling System" specifies a Targe Band of <105º for normal operation with an upper limit of 140ºF.

Therefore the "norm" for the water in the Spent Fuel Pool is consistent with temperature limit specified in GALL items VII.A4.1-a, A4.2-a and A4.3-a. There is no temperature limit specified in the GALL for Item VII.A4.4-b (i.e. Demineralized Oxygenated Water).

Since the Unit 1 and Unit 2 fuel pools are open to building atmosphere, the water is considered as "oxygenated." There is no treatment of the water with chemicals to remove oxygen or to inhibit corrosion on either Unit. Based on these facts, further evaluation of the Spent Fuel Pool Filtering and Cooling System (FP) Aging Management Review for NMP1, and further evaluation of GALL items VII.A4.1-a, A4.2-a, A4.3-a, A4.4-b has led to the conclusion to revise the AMR and LRA Table 3.3.2.A-21 to make the AERMs and AMPs consistent with GALL Section VII.A4. More specifically, the Water Chemistry Control Program and the One-Time Inspection Program will be invoked as the AMP to manage pitting and crevice corrosion for all component types that are Wrought Austenitic Stainless Steel and/or Cast Austenitic Stainless Steel in an environment of Treated Water, temperature < 140ºF.

2) The concentrations of chlorides and sulfates in the Spent Fuel Cleanup Systems are limited to less than 100 ppb by plant chemistry procedure. For both NMP1 and NMP2, procedure S-CTP-V666 "Auxiliary System Chemistry" is used to control these concentrations Conductivity is also maintained to less than 2.0 µS/cm per this procedure while dissolved oxygen is not monitored. Monitoring the dissolved oxygen in the treated water would be meaningless since both Unit 1 & 2 pools are open to atmosphere and the demineralized water is not chemically treated to remove dissolved oxygen. Note:

Thursday, March 03, 2005 Page 63 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified The Aging Management Review Details Report of the Spent Fuel Pool Filtering and Cooling System (FP) Aging Management Review for NMP1 (Revision 1) invokes activity N1-CTP-V601 (without enhancements) as the plant procedure to use to monitor the FP water parameters under the Chemistry Control Program (X1.M2).

This procedure is not the optimum choice for an activity and should be changed in the AMR to S-CTP-V666.

3) Treated water chemistry in the Unit 1 spent fuel pool and cleanu system is managed with in-line demineralizers/filters maintenance (i.e. regeneration). Demineralizer regeneration frequency is based o differential pressure across the demineralizer. In the event of chlorid or sulfate concentrations exceeding the parameters specified in and monitored by procedure S-CTP-V666, a note is placed in the Chemistry Log and a DER is initiated. Treated water chemistry in the Unit 2 Spent Fuel Pool and Cleanup system is managed with in-line demineralizers/filters maintenance (i.e. regeneration). Demineralizer regeneration frequency is based on Plant Chemistrys monitoring of the filter/demineralized beds. In the event of chloride or sulfate concentrations exceeding the parameters specified in and monitored by procedure S-CTP-V666, a note is placed in the Chemistry Log and a DER is initiated.

LR Contact Nold NRC Tracking Number 3.3.1.A-01s1 Assigned Department/ License Renewal Individual Nold Date Closed 10/27/2004 Table 3.3.1.A LRA Section Thursday, March 03, 2005 Page 64 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 121 Saba SRP Section 3.3.2.2.5, Loss of Material due to General, Microbiologically Influenced, Pitting, a) Different programs are used to manage the same combination of and material, environment, and aging effect based on GALL guidance.

09/13/2004 Crevice Corrosion, states that: The Aging Management Program (AMP) chosen to manage loss of Loss of material due to general, pitting, and crevice corrosion could occur in the piping and filt material of various Carbon or Low Alloy Steel (Yield Strength < 100 housing and supports in the control room area, the auxiliary and radwaste area, the primary Ksi) and Ductile/Malleable Cast Iron (CLASL) components subject containment heating and ventilation systems, in the piping of the diesel generator building to aging management review was determined by the system specific ventilation system, in the aboveground piping and fittings, valves, and pumps in the diesel fue tables contained in NUREG-1801Volume 2, Generic Aging Lessons oil system and in the diesel engine starting air, combustion air intake, and combustion air Learned (GALL) Report - Tabulation of Results. Where deviations exhaust subsystems in the emergency diesel generator system. Loss of material due to gener exist from the GALL for the AMP chosen to manage the AERM (e.g.

pitting, crevice, and microbiologically influenced corrosion (MIC) could occur in the duct fitting loss of material), the LRA Summary of Management Aging Table access doors, and closure bolts, equipment frames and housing of the duct, due to pitting and column entitled Table 1 Item documents a link to the LRA Table 1 crevice corrosion could occur in the heating/cooling coils of the air handler heating/cooling, an that captures the exception taken to the GALL AMP.

due to general corrosion could occur on the external surfaces of all carbon steel structures an components, including bolting exposed to operating temperatures less than 212°F in the Beyond the GALL driven AMPs for managing the loss of CLASL ventilation systems. The GALL report recommends further evaluation to ensure that these agi material, the environment (e.g. external or internal air), the system, effects are adequately managed. the component type and the aging mechanism also factor into the NMP1 credits B2.1.11 (Closed-Cycle Cooling Water Program), B2.1.17 (Fire Water System decision of which Aging Management Program was chosen Program), B2.1.20 (One-Time Inspection Program), B2.1.26 (10 CFR 50 Appendix J Program managing the AERM of loss of (CLASL) material.

B2.1.32 (Preventive Maintenance Program), and B2.1.33 (Systems Walkdown Program) for managing loss of material of loss of material of Carbon or Low Alloy Steel (Yield Strength < The particular mechanism for the loss of material AERM for a 100 Ksi) and Ductile/Malleable Cast Iron components (piping and fittings, valves, heat particular component made of "Carbon or Low Alloy Steel (Yield exchangers, blowers, ducting, filters/strainers, tanks/air reservoirs, mufflers, valves and Strength < 100 Ksi) and Ductile/Malleable Cast Iron" (CLASL) can dampers, temperature elements, orifices, silencers, and bolting in many systems. be found in the "Aging Management Review Details Report" section a) Explain how aging effect of loss of material is different for these items. Why different of each systems Aging Management Review Package. Section 2.1.

programs are used to manage the same combination of material, environment, and aging effe of the "Technical Basis For Material-Environment Group Inputs To b) Clarify where air environment is outdoor or indoor, and where air is external or internal. The ConRad Database" white paper defines the mechanisms contained in the AMR. Section 2.1.1 indicates that the Loss of Material AERM has eleven possible aging mechanisms: General Corrosion (GC), Pitting Corrosion (PIC), Crevice Corrosion (CRC),

Galvanic Corrosion (GAC), Boric Acid Corrosion (BAC),

Microbiologically Influenced Corrosion (MIC), Wear/Fretting (WR),

Flow Accelerated Corrosion (FAC), Erosion (ER), Selective Leachin (SL) and Erosion-Corrosion. After consideration of the environment, the system (i. e. safety related, non-safety related etc), the component type and the aging mechanism(s) at work, the decision was made to credit (for instance) the B2.1.11 (Closed-Cycle Cooling Water Program), the B2.1.17 (Fire Water System Program), the B2.1.20 (One-Time Inspection Program), the B2.1.26 (10 CFR 50 Appendix J Program), the B2.1.32 (Preventive Maintenance Program), or the B2.1.33 (Systems Walkdown Program) for managing loss of CLASL material.

B) The potential various environments of air are defined in LRA Tab 3.0-1 "Environments" as being External, Internal or both (i.e.

potentially).

Thursday, March 03, 2005 Page 65 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified For those cases where an environment could be either external, internal or both, a review of:

-- the component type,

-- the systems internal environments

-- and the aging management program (AMP) is used to make the determination.

For example, for bolting in an environment of "Air, Moisture or Wetting, temperature < 140°F", the environment is external. A component type with an assigned AMP of "Systems Walkdown Program" dictates an external environment. If still in doubt, the Systems Aging Management Review package for the subject system can be used to confirm whether the environment is internal or external.

LR Contact Nold NRC Tracking Number 3.3.1.A-05s1 Assigned Department/ License Renewal Individual Nold Date Closed 10/08/2004 Table 3.3.1.A LRA Section Thursday, March 03, 2005 Page 66 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 122 Saba NMP1 credits closed cycle cooling water system program for managing loss of material of The wrought austenitic stainless steel sub-components of the wrought stainless steel and heat exchangers in air, moisture or wetting, temperature 140 Drywell Cooler Heat Exchangers (HTX-201-01 through HTX-201-06 09/13/2004 (Table 3.3.2.A-4, NMP1 containment system, page 3.3-115). Explain how CCWS program consist of the unit cooler housings. As documented in the manages this aging effect. Provide documentation that shows how aging effect is detected, Containment Systems (CTN) Aging Management Review for NMP1, prevented, and monitored by this program. the Closed-Cycle Cooling Water System program is used to manage the loss of material aging effect with Activity (and plant procedure)

N1-MPM-201-550. Managing the loss of material AERM with the Closed-Cycle Cooling Water System program, is the wrong program to invoke. Managing the AERM of Loss of Material from the housing of the Drywell Cooler Heat Exchangers should be done under the Preventive Maintenance Program (PMP). Plant procedure N1-MPM 201-550 is still the correct procedure to perform this task. This procedure needs to be enhanced to detect, to prevent and to monito for the aging effects of loss of material due to crevice corrosion and pitting corrosion of the housing. In addition, the procedure needs to be enhanced to detect, to prevent and to monitor for the aging effect of cracking due to stress corrosion cracking. Since the procedure needs to be enhanced to capture these aging mechanisms, there is no historical information available to provide.

The Containment Systems (CTN) Aging Management Review for NMP1 will be revised to invoke the Preventive Maintenance Program for managing the AERMs of Cracking and Loss of Material. The PMP will specify Activity N1-MPM-201-550 with enhancements (ARC = Yes) for both AERMs.

In addition, LRA Table 3.3.2.A-4 (page 3.3-115) will be revised to specify that the Preventive Maintenance Program will manage the AERMs of Cracking and Loss of Material in Heat Exchangers made of Wrought Austenitic Stainless Steel in an environment of Air, Moisture or Wetting, temperature 140ºF.

Further review of LRA Table 3.3.2.A-4, revealed that the Loss of Heat Transfer function associated with the outside surfaces [Copper Alloys (Zinc 15%) in Air, Moisture or Wetting, temperature 140ºF]

of the tubes of the Drywell Cooler Heat Exchangers is also being managed with the Closed-Cycle Cooling Water System program.

This program will be changed on page 3.3-114 of the LRA table from the Closed-Cycle Cooling Water System program to the Preventive Maintenance Program. In addition, Containment Systems (CTN)

Aging Management Review for NMP1 will be revised to reflect this finding. More specifically, for the six components HTX-201-01-TUBE OD through HTX-201-06-TUBE-OD, the AMP will be changed from the Closed-Cycle Cooling Water System program to the Preventive Maintenance Program with Activity N1-MPM-201-550 (no enhancements needed i.e. ARC = NO).

Thursday, March 03, 2005 Page 67 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified A review of the Appendices A & B to the LRA, with respect to the above changes to Tables in the LRA, did not reveal any need for revision to these Appendices.

Section 1.2 (page 3) of the Unit 1 & 2 Preventive Maintenance Program Attribute Assessment needs to be revised to list the NMP1 Containment Systems as a system requiring an enhanced PM activity.

LR Contact Nold NRC Tracking Number 3.3.1.A-05s2 Assigned Department/ License Renewal Individual Nold Date Closed 10/13/2004 Table 3.3.2.A-4 LRA Section Thursday, March 03, 2005 Page 68 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 123 Saba NMP1 credits 10 CFR 50 Appendix J program for managing loss of material of Carbon or Low The Appendix J Program is focused on finding valve seat leakage Alloy Steel (Yield Strength < 100 Ksi) and Ductile/Malleable Cast Iron valves in air, in (Table potentially due to loss of material to the valve seat and/or plug/gate.

09/13/2004 3.3.2.A-4, NMP1 containment system, page 3.3-115). Explain how CCWS program manages The Appendix J activities performed under this program will serve as this aging effect. Provide documentation that shows how aging effect is detected, prevented, an indicator of overall valve integrity with respect to the valve body and monitored by this program. and the associated lines. These activities will prompt a valve inspection should the valve fail its Appendix J seat leakage rate test FOLLOW-UP QUESTION SENT ON 10/8: Since the valve internal components are typically not as robust as th valve body wall or associated piping walls, loss of material of those (Table 3.3.2.A-4, Page 3.3-116). components resulting in the failure of a leak test would occur before Provide justification that show how loss of material aging effect is detected, prevented, and the intended function of the valve body and associated lines pressur monitored by the Appendix J program. boundary would be challenged. Since these tests are performed on periodic basis, they are a more effective means of assuring maintenance of the LR intended function of the valve and associated lines than the One Time Inspection Program alone would be; however, the One Time Inspection Program will also be credited.

Therefore, the Appendix J Program alone is adequate to manage loss of material of the internal surfaces of these valves. If inspection results from a failed Appendix J test indicated that a loss of material is occurring, a DER would be initiated to evaluate the anomaly and develop a resolution to address the issue.

Providing historical documentation from Appendix J Program activity NMP-APPJ-001 would not show how the loss of material aging effec is detected, prevented, and monitored by the Appendix J Program.

These historical documents would provide leakage rates through valves and whether the valve passed or failed the leakage rate test.

the case of a failed test, a DER would be generated and a work orde executed in the plant that would capture both the condition of the valve internals with respect to loss of material and the corrective actions performed.

Supplemental Response 11/5/04:

The One Time Inspection Program will be added as to the Appendix J Program for AM of these penetration components as well as other where only the Appendix J Program is credited.

LR Contact Nold NRC Tracking Number 3.3.1.A-05s3 Assigned Department/ License Renewal Individual Nold Date Closed 11/05/2004 Thursday, March 03, 2005 Page 69 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified Table 3.3.2.A-4 LRA Section Thursday, March 03, 2005 Page 70 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 124 Saba NMP1 credits closed cycle cooling water system program for managing loss of material of a) For two of the heat exchangers (HTX-210-49 & HTX-210-50), the Carbon or Low Alloy Steel (Yield Strength < 100 Ksi) and Ductile/Malleable Cast Iron heat Carbon or Low Alloy Steel (Yield Strength < 100 Ksi) and 09/13/2004 exchangers in air, (Table 3.3.2.A-5, NMP1 control room HVAC system, page 3.3-119). Ductile/Malleable Cast Iron heat exchangers in air a) Explain how CCWS program manages this aging effect. Provide documentation that show material/environment refers to the heat exchanger housing. As how aging effect is detected, prevented, and monitored by this program. documented in the Control Room HVAC Aging Management Review b) Table 3.3.2.A-5 shows HT as the heat exchanger intended function to be maintained. for NMP1, the Closed-Cycle Cooling Water System Program Clarify whether loss of heat transfer is an aging effect for the heat exchanger to be managed (CCCW) monitors for the loss of material with the use of plant If so, explain how Loss of HT is managed by CCCW program. procedure and activity N1-MPM-070-409. From further review of the CCCW program and activity N1-MPM-070-409, it has been determined that neither are the optimum choice for program or activity for managing the loss of material on the air side of the heat exchanger. The Preventive Maintenance Program (PMP) will be invoked in lieu of the CCCW program in this row of the LRA Table 3.3.2.A-5. A new activity will be created against the PMP in place of using N1-MPM-070-409. The Preventive Maintenance Program and a new activity will be assigned to this Loss of Material AERM in a revision of the Control Room HVAC Aging Management Review for NMP1.

In addition, further review of LRA Table 3.3.2.A-5 (page 3.3-120) indicates that CCCW program is used to manage Loss of Heat Transfer function for the Air side of the Copper Alloy (Zinc 15%)

tubes. The heat exchangers that relate to this LRA row are HTX-210 49, HTX-210-50, HTX-210.1-119, HTX-210.1-120 and HTX-211-17.

Again, activity N1-MPM-070-409 is listed as the plant procedure to manage the AERM of LOHT in the Control Room HVAC Aging Management Review for NMP1. Consistent with the above, the Preventive Maintenance Program (PMP) will be invoked in lieu of the CCCW program for this row in the LRA Table. A new activity will be created against the PMP in place of using N1-MPM-070-409. The Preventive Maintenance Program and a new activity will be assigned to this Loss of Heat Transfer AERM in a revision of the Control Room HVAC Aging Management Review for NMP1.

For the other two heat exchangers (HTX-210.1-119 & HTX-210.1-120) the air environment is in error for the internal environment of th shell. The internal environment within the shell is demineralized untreated water. Therefore, the Control Room HVAC Aging Management Review for NMP1 needs to be revised as well LRA table 3.3.2.A-5.

b) As documented in the Control Room HVAC Aging Management Review for NMP1, five of the six CRAC heat exchangers have heat transfer intended functions in addition to pressure boundary intende functions. The CCCW Program activity used to prevent the loss of heat transfer function on the demineralized untreated water side of these five heat exchangers is new CCCW program Activity N1-Thursday, March 03, 2005 Page 71 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified CCCP-01. This activity has yet to be formalized and approved for plant use.

As documented in the Control Room HVAC Aging Management Review for NMP1 (and in part "a)" of this Resolution), managing the Loss of Heat transfer function of the air side of the heat exchanger tubes was to be done under the Closed-Cycle Cooling Water System Program (CCCW) with Activity N1-MPM-070-409. However, from further review of the CCCW program and activity N1-MPM-070-409, it has been determined that neither are the optimum choice of program or activity for managing the loss of heat transfer function on the air side of the heat exchanger tubes. The Preventive Maintenanc Program (PMP) will be invoked in lieu of the CCCW program in the Copper Alloy (Zinc 15%) / Air row of the LRA Table 3.3.2.A-5 (page 3.3-120). A new activity will be created against the PMP in place of using N1-MPM-070-409. The Preventive Maintenance Program and a new activity will be assigned for the Loss of Heat Transfer AERM for each of the five heat exchangers in a revision of the Control Roo HVAC Aging Management Review for NMP1.

A review of the Appendices A & B to the LRA, with respect to the above changes to Tables in the LRA, did not reveal any need for revision to these Appendices.

Section 1.2 (page 3) of the Unit 1 & 2 Preventive Maintenance Program Attribute Assessment needs to be revised to list the NMP1 Control Room HVAC System as a system requiring an enhanced PM activity.

LR Contact Nold NRC Tracking Number 3.3.1.A-05s4 Assigned Department/ License Renewal Individual Nold Date Closed 10/13/2004 Table 3.3.2.A-5 LRA Section Thursday, March 03, 2005 Page 72 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 125 Saba NMP1 credits one-time inspection program for managing loss of material of Carbon or Low (a) The LRA Programs Section (Appendix B) contains an overview o Alloy Steel (Yield Strength < 100 Ksi) and Ductile/Malleable Cast Iron filters/strainers in air, how the respective NMP program meets the ten program attributes 09/13/2004 (Table 3.3.2.A-5, NMP1 control room HVAC system, page 3.3-118). contained in the GALL. The Program Attribute Assessment (PAA) a) Clarify that loss of material aging effect of the above components in air is included in the for the One Time Inspection Program states "The structures and scope of OTI program. Because LRA Section B2.1.20, OTI program description does not components that will be inspected as part of the OTI Program are include any discussion on managing loss of material of these components in air. identified in the Aging Management Reports (AMRs) and will be b) Table 3.3.2.A-5 shows FLT as the filters/strainers intended function to be maintained. included as part of this program package. " Revision 0 of the AMR Clarify whether clogging (buildup of deposits) is an aging effect for these components to be for the Control Room HVAC System (CRAC) contains four "Carbon managed. If so, explain how it is managed by OTI program. or Low Alloy Steel (Yield Strength < 100 Ksi) and Ductile/Malleable Cast Iron" filter components in air. This is how the OTI program captures the management of loss of material in air for these filter components.

As noted in the PAA, the One-Time Inspection Program is a new program that will verify the effectiveness of other AMPs, or verify an AMP is not required, by confirming that unacceptable degradation is not occurring and the intended function of a component will be maintained during the extended period of operation. The program is used to confirm that either an aging effect is not occurring, or the aging effect is occurring very slowly as not to affect the component o structure intended function. The One-Time Inspection Program will be developed to be consistent with the Generic Aging Lessons Learned (GALL) Report,Section XI.M32 "One-Time Inspection Program". When evidence of an aging effect is revealed by a one-time inspection, the evaluation of the inspection results will identify appropriate corrective actions (b) The FLT intended function only applies to the filters/strainers for the CRAC ventilation system. The only aging effect for the filter components in air, of the CRAC system, is loss of material. The One-time Inspection program will ensure the overall integrity of the filter or strainer for the period of extended plant operations. Clogging is not an aging effect for the filter/strainers and, therefore, is not being managed by the OTI program for these components. Cleaning of clogged filters is a maintenance function (i.e. outside the scope of License Renewal).

LR Contact Nold NRC Tracking Number 3.3.1.A-05s5 Assigned Department/ License Renewal Individual Nold Date Closed 10/08/2004 Thursday, March 03, 2005 Page 73 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified Table 3.3.2.A-5 LRA Section Thursday, March 03, 2005 Page 74 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 126 Saba NMP1 credits preventive maintenance program for managing loss of material of Carbon or Lo An enhanced Preventative Maintenance Program will provide Loss o Alloy Steel (Yield Strength < 100 Ksi) and Ductile/Malleable Cast Iron components in air, Material inspections for the following NMP1 systems that have 09/13/2004 (various components in various systems). Provide examples of how PM program has been Carbon or Low Alloy Steel (Yield Strength < 100 Ksi) and effective in managing loss of material aging effect without failure of the components intended Ductile/Malleable Cast Iron (CLASL) components in air:

function. Containment (CTN)Systems; Emergency Diesel Generator (DG)

System; Diesel Generator Building Ventilation (DGAC) System; Fire Detection And Protection (FDP) System; Reactor Building HVAC (RBAC) System; Radioactive Waste Disposal Building HVAC (RWAC) System And Turbine Building HVAC (TBAC) System. The plant specific OE review for these systems/components did not identify any cases of a loss of intended function due to aging degradation.

For the CTN system, activities N1-MMP-GEN-200 and GAP-HSC-02 will monitor for the Loss of Material of CLASL components in air.

Since these activities are being enhanced monitor for LOM there are no examples to provide of how PM program has been effective in managing loss of material aging effect without failure of the components intended function (Reference Containment Systems (CTN) Aging Management Review for NMP1, Revision 1).

For the DG system, new activity N-N1PMP-011 will monitor for the Loss of Material of CLASL components in air. Since the activity is new (i.e. yet to be formalized and approved) there are no examples provide of how PM program has been effective in managing loss of material aging effect without failure of the components intended function (Reference Emergency Diesel Generator System (DG)

Aging Management Review for NMP1, Revision 1).

For the DGAC system, new activity N-N1PMP-003 will monitor for the Loss of Material of CLASL components in air. Since the activity i new (i.e. yet to be formalized and approved) there are no examples provide of how PM program has been effective in managing loss of material aging effect without failure of the components intended function (Reference Diesel Generator Building Ventilation (DGAC)

Aging Management Review for NMP1, Revision 0).

For the FDP system, new activity N-N1PMP-012 will monitor for the Loss of Material of CLASL components in air. Since the activity is new (i.e. yet to be formalized and approved) there are no examples provide of how PM program has been effective in managing loss of material aging effect without failure of the components intended function (Reference Fire Detection and Protection System (FDP)

Aging Management Review for NMP1, Revision 1).

Thursday, March 03, 2005 Page 75 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified For the RBAC system, existing activities N1-MPM-GEN-551 and N1 TSP-202-001 need to be revised to monitor for the Loss of Material of CLASL components in air. Since these activities need enhancement, there are no examples to provide of how the PM program activities have been effective in managing loss of material aging effect without failure of the components intended function.

(Reference Reactor Building HVAC System (RBAC) Aging Management Review for NMP1, Revision 0)

For the RWAC system, new activity N-N1PMP-02 will monitor for the Loss of Material of CLASL components in air. Since the activity is new (i.e. yet to be formalized and approved) there are no examples provide of how PM program has been effective in managing loss of material aging effect without failure of the components intended function (Reference Radwaste Building HVAC System (RWAC)

Aging Management Review for NMP1, Revision 1).

For the TBAC system, existing activity N1-MPM-GEN-558 needs to be revised to monitor for the Loss of Material of CLASL components in air. Since this activity needs enhancement, there are no examples to provide of how the PM program activity has been effective in managing loss of material aging effect without failure of the components intended function. (Reference Turbine Building HVAC System (TBAC) Aging Management Review for NMP1, Revision 1)

LR Contact Nold NRC Tracking Number 3.3.1.A-05s6 Assigned Department/ License Renewal Individual Nold Date Closed 10/08/2004 Table 3.3.1.A LRA Section Thursday, March 03, 2005 Page 76 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 127 Saba Justify using water chemistry and one time inspection program for managing cracking aging The use of the One-time Inspection Program (detection) in effect of wrought stainless steel piping and fittings in treated water temperature 482 (Table conjunction with the Water Chemistry Control program (mitigation) is 09/13/2004 3.3.2.A, Page 171). justified in the fact that the stainless steel sample lines of the NMP1 Sampling System see mostly no flow and see low flow when in use.

Per the first two sentences of the 1st paragraph of the Program Description for GALL XI.M32, "The program includes measures to verify the effectiveness of an aging management program (AMP) an confirm the absence of an aging effect. For example, for structures and components that rely on an AMP, such as water chemistry control, this program verifies the effectiveness of the AMP by confirming that unacceptable degradation is not occurring and the intended function of a component will be maintained during the extended period of operation."

The "Program Description - Nine Mile Point Units 1 & 2" Section of the "Unit 1 & 2 One Time Inspection Program Attribute Assessment", Revision 1 reads "The One-time Inspection Program will institute one-time inspections of components to verify that: a) an aging effect requiring management (AERM) is not expected to occur but there is insufficient data to completely rule it out, and b) the agin effect on a component is occurring very slowly as not to affect the component or structure function. For example, the OTI Program will be used to verify the effectiveness of the Water Chemistry Program by inspection of selected components in low flow and stagnant areas."

Therefore, the AERM of cracking in the small bore stainless steel sample lines is effectively mitigated through the Water Chemistry Control Program during the current licensed period of power operations. The One Time Inspection Program will provide confirmation that the AERM of cracking is not occurring and will provide reasonable assurance that the intended function of the stainless steel sample lines will be maintained during the extended period of operation.

LR Contact Nold NRC Tracking Number 3.3.1.A-26s1 Assigned Department/ License Renewal Individual Nold Date Closed 10/08/2004 Table 3.3.2.A-18 LRA Section Thursday, March 03, 2005 Page 77 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified Thursday, March 03, 2005 Page 78 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 129 Saba SRP Section 3.3.2.2.5, Loss of Material due to General, Microbiologically Influenced, Pitting, a) Different programs are used to manage the same combination of and material, environment, and aging effect based on GALL guidance.

09/13/2004 Crevice Corrosion, states that: The Aging Management Program (AMP) chosen to manage loss of Loss of material due to general, pitting, and crevice corrosion could occur in the piping and filt material of various "Carbon or Low Alloy Steel (Yield Strength < 100 housing and supports in the control room area, the auxiliary and radwaste area, the primary Ksi) and Ductile/Malleable Cast Iron" (CLASL) components subject containment heating and ventilation systems, in the piping of the diesel generator building to aging management review was determined by the system specific ventilation system, in the aboveground piping and fittings, valves, and pumps in the diesel fue tables contained in NUREG-1801Volume 2, "Generic Aging Lessons oil system and in the diesel engine starting air, combustion air intake, and combustion air Learned (GALL) Report - Tabulation of Results". Where deviations exhaust subsystems in the emergency diesel generator system. Loss of material due to gener exist from the GALL for the AMP chosen to manage the AERM (e.g.

pitting, crevice, and microbiologically influenced corrosion (MIC) could occur in the duct fitting loss of material), the LRA "Summary of Management Aging Table" access doors, and closure bolts, equipment frames and housing of the duct, due to pitting and column entitled "Table 1 Item" documents a link to the LRA Table 1 crevice corrosion could occur in the heating/cooling coils of the air handler heating/cooling, an that captures the exception taken to the GALL AMP.

due to general corrosion could occur on the external surfaces of all carbon steel structures an components, including bolting exposed to operating temperatures less than 212°F in the Beyond the GALL driven AMPs for managing the loss of CLASL ventilation systems. The GALL report recommends further evaluation to ensure that these agi material, the environment (e.g. external or internal air), the system, effects are adequately managed. the component type and the aging mechanism also factor into the NMP2 credits Appendix B2.1.17 (Fire Water System Program), B2.1.20 (One-Time Inspection decision of which Aging Management Program was chosen Program), B2.1.32 (Preventive Maintenance Program), and B2.1.33 (Systems Walkdown managing the AERM of loss of (CLASL) material.

Program) for managing loss of material of Carbon or Low Alloy Steel (Yield Strength < 100 K and Ductile/Malleable Cast Iron, copper alloys, and WASS components (filters/strainers, The particular mechanism for the loss of material AERM for a mufflers, piping and fittings, tanks, valves, fire dampers, air handling units, blowers, ducting, particular component made of "Carbon or Low Alloy Steel (Yield heat exchangers, unit coolers, debris screens, flow elements, diesel engine air start motors, Strength < 100 Ksi) and Ductile/Malleable Cast Iron" (CLASL) can starting air lubricator, air separators, and bolting in many systems. be found in the "Aging Management Review Details Report" section c) Explain how aging effect of loss of material is different for these items. Why different of each systems Aging Management Review Package. Section 2.1.

programs are used to manage the same combination of material, environment, and aging effe of the "Technical Basis For Material-Environment Group Inputs To d) Clarify where air environment is outdoor or indoor, and where air is external or internal. The ConRad Database" white paper defines the mechanisms contained in the AMR. Section 2.1.1 indicates that the Loss of Material AERM has eleven possible aging mechanisms: General Corrosion (GC), Pitting Corrosion (PIC), Crevice Corrosion (CRC),

Galvanic Corrosion (GAC), Boric Acid Corrosion (BAC),

Microbiologically Influenced Corrosion (MIC), Wear/Fretting (WR),

Flow Accelerated Corrosion (FAC), Erosion (ER), Selective Leachin (SL) and Erosion-Corrosion. After consideration of the environment, the system (i. e. safety related, non-safety related etc), the component type and the aging mechanism(s) at work, the decision was made to credit (for instance) the B2.1.11 (Closed-Cycle Cooling Water Program), the B2.1.17 (Fire Water System Program), the B2.1.20 (One-Time Inspection Program), the B2.1.26 (10 CFR 50 Appendix J Program), the B2.1.32 (Preventive Maintenance Program), or the B2.1.33 (Systems Walkdown Program) for managing loss of CLASL material.

B) The potential various environments of air are defined in LRA Tab 3.0-1 "Environments" as being External, Internal or both (i.e.

potentially).

Thursday, March 03, 2005 Page 79 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified For those cases where an environment could be either external, internal or both, a review of:

-- the component type,

-- the systems internal environments

-- and the aging management program (AMP) is used to make the determination.

For example, for bolting in an environment of "Air, Moisture or Wetting, temperature < 140°F", the environment is external. A component type with an assigned AMP of "Systems Walkdown Program" dictates an external environment. If still in doubt, the Systems Aging Management Review package for the subject system can be used to confirm whether the environment is internal or external.

LR Contact Nold NRC Tracking Number 3.3.1.B-05s1 Assigned Department/ License Renewal Individual Nold Date Closed 10/08/2004 Table 3.3.1.B LRA Section Thursday, March 03, 2005 Page 80 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 130 Saba NMP credits fire protection program for managing loss of material of Carbon or Low Alloy Ste As noted in Table 3.3.2.B-23 of the LRA (page 3.3-244), the Fire (Yield Strength < 100 Ksi) and Ductile/Malleable Cast Iron valve and dampers in air, (Table Protection Program is being applied only to the fire dampers (Note 09/13/2004 3.3.2.B-23, page 3.3-244). Explain how CCWS program manages this aging effect. Provide 30). Both the GALL (XI.M26) and the Program Attribute Assessmen documentation that shows how aging effect is detected, prevented, and monitored by this (PAA) for the Units 1 and 2 Fire Protection Program under the program. section titled Parameters Monitored/Inspected include inspections of fire dampers. Specifically, Section 3.2 of the PAA states Once each operating cycle, the accessible surfaces of fire area barriers (floors, ceilings, and walls) required by each units safe shutdown analysis are visually inspected for degradation, cracks, and obvious penetration that affect their functional rating. These inspections include the seals surrounding fire doors and dampers. (italics added for emphasis)

LR Contact Nold NRC Tracking Number 3.3.1.B-05s2 Assigned Department/ License Renewal Individual Nold Date Closed 09/22/2004 Table 3.3.2.B-23 LRA Section Thursday, March 03, 2005 Page 81 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 131 Saba NMP credits one-time inspection program for managing loss of material of copper alloy heat (a) The Program Attribute Assessment for the One Time Inspection exchangers in moist air or wetted environment, (Table 3.3.2.B-9, pages 3.3-208 Program states The structures and components that will be 09/13/2004 a) Clarify that loss of material aging effect of the above components in air is included in the inspected as part of the OTI Program are identified in the Aging scope of OTI program. Because LRA Section B2.1.20, OTI program description does not Management Reports (AMRs) and will be included as part of this include any discussion on managing loss of material of this components in air. program package. Examples include: a) small bore piping, b) b) Tables 3.3.2.B-9 shows HT an intended function to be maintained for this heat exchanger components in low flow areas or stagnant areas, c) ventilation Clarify whether clogging (buildup of deposits) is an aging effect for this component to be systems. Thus, these components are adequately managed by the managed. If so, explain how it is managed by OTI program. OTI Program.

(b) The only aging effects for the heat exchanger components that have a HT intended function are loss of material and loss of heat transfer. For the air side of the Heat Exchanger the coils are inspected and cleaned (if necessary) per Preventive Maintenance Program Activity procedure N2-MPM-HVC-V554 (section 7.4.7 &

Appendix B). For the water side, internal deposits to the coils are prevented from occurring per the guidance of the Closed-cycle Cooling Water Program. Thus the heat transfer function will be maintained for these heat exchangers during the period of extended operations. The One-time inspection program does not manage the Loss of Heat Transfer AERM. The One-time inspection program ensures that Loss of Material has not occurred to the coils and provides reasonable assurance that the coils can serve their pressure boundary function during the period of extended operations LR Contact Nold NRC Tracking Number 3.3.1.B-05s3 Assigned Department/ License Renewal Individual Nold Date Closed 10/27/2004 Table 3.3.2.B-9 LRA Section Thursday, March 03, 2005 Page 82 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 132 Saba NMP credits preventive maintenance program for managing loss of material of copper alloy un (a) Your comment addresses LRA Table 3.3.2.B-31 which is the coolers in air, (Table 3.3.2.B-31, pages 3.3-278 NMP2 Yard Structures Ventilation System. As noted on page B-58 09/13/2004 a) Clarify that loss of material aging effect of the above components in air is included in the of the LRA, the scope of the Preventive Maintenance Program scope of PM program. includes heat exchangers, (which includes coolers). Furthermore, a b) Tables 3.3.2.B-31 shows HT an intended function to be maintained for this heat exchange noted on page B-61, the PM program will be enhanced to include th Clarify whether clogging (buildup of deposits) is an aging effect for this component to be aging effects detected. As noted in the Program Attribute managed. If so, explain how it is managed by PM program. Assessment for the PM program, the NMP2 Yard Structures Ventilation System is one of the systems that will require enhanced or new PM activities to manage the aging effects in the LRA.

(b) The only aging effects for the heat exchanger components that have a HT intended function are loss of material and loss of heat transfer. For the air side of the Heat Exchanger the coils are inspected and cleaned (if necessary) per NMP2 Preventative Maintenance Program procedure N2-EPM-GEN-V781. The water side heat transfer surfaces of the Yard Structures Ventilation Unit Coolers is monitored and maintained per NMP2 Open-Cycle Cooling Water System Program procedure N2-MPM-GEN-V571.

LR Contact Nold NRC Tracking Number 3.3.1.B-05s4 Assigned Department/ License Renewal Individual Nold Date Closed 09/22/2004 Table 3.3.2.B-31 LRA Section Thursday, March 03, 2005 Page 83 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 133 Saba NMP credits one-time inspection program for managing loss of material of Carbon or Low All (a) The LRA Programs Section (Appendix B) contains an overview o Steel (Yield Strength < 100 Ksi) and Ductile/Malleable Cast Iron filters/strainers and WASS how the respective NMP program meets the ten program attributes 09/13/2004 debris screens in air, (Tables 3.3.2.B-9 and 20, NMP2, pages 3.3-208 and 236). contained in the GALL. The Program Attribute Assessment (PAA) a) Clarify that loss of material aging effect of the above components in air is included in the for the One Time Inspection Program states "The structures and scope of OTI program. Because LRA Section B2.1.20, OTI program description does not components that will be inspected as part of the OTI Program are include any discussion on managing loss of material of these components in air. identified in the Aging Management Reports (AMRs) and will be b) Tables 3.3.2.B-9 and 20 show FLT as these components intended function to be included as part of this program package." Revision 0 of the AMR fo maintained. Clarify whether clogging (buildup of deposits) is an aging effect for these the NMP2 Primary Containment Purge System (CPS) contains six components to be managed. If so, explain how it is managed by OTI program. "Wrought Austenitic Stainless Steel" filter components in air.

Revision 1 of the AMR for the Control Building HVAC System (HVC) contains seven "Carbon or Low Alloy Steel (Yield Strength < 100 Ks and Ductile/Malleable Cast Iron" filter components in air. This is how the OTI program captures the management of loss of material in air for these filter components.

As noted in the PAA, the One-Time Inspection Program is a new program that will verify the effectiveness of other AMPs, or verify an AMP is not required, by confirming that unacceptable degradation is not occurring and the intended function of a component will be maintained during the extended period of operation. The program is used to confirm that either an aging effect is not occurring, or the aging effect is occurring very slowly as not to affect the component o structure intended function. The One-Time Inspection Program will be developed to be consistent with the Generic Aging Lessons Learned (GALL) Report,Section XI.M32 "One-Time Inspection Program". When evidence of an aging effect is revealed by a one-time inspection, the evaluation of the inspection results will identify appropriate corrective actions.

(b) The FLT intended function only applies to the filters/strainers for this ventilation system. The only aging effect for these components is loss of material. The One-time Inspection program will ensure the overall integrity of the filter or strainer for the period of extended plan operations. Clogging is not an aging effect for the filter/strainers and therefore, is not being managed by the OTI program for these components. Cleaning of clogged filters is a maintenance function (i.e. outside the scope of License Renewal).

LR Contact Nold NRC Tracking Number 3.3.1.B-05s5 Assigned Department/ License Renewal Individual Nold Date Closed 10/08/2004 Thursday, March 03, 2005 Page 84 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified (Tables 3.3.2.B-9 an LRA Section d 20 Thursday, March 03, 2005 Page 85 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 134 Saba NMP credits preventive maintenance program for managing loss of material of Carbon or Low An enhanced Preventative Maintenance Program will provide Loss o Alloy Steel (Yield Strength < 100 Ksi) and Ductile/Malleable Cast Iron components in air, Material inspections for the following NMP2 systems that have 09/13/2004 (various components in various systems). Provide examples of how PM program has been Carbon or Low Alloy Steel (Yield Strength < 100 Ksi) and effective in managing loss of material aging effect without failure of the components intended Ductile/Malleable Cast Iron (CLASL) components in air: Air Startup function. Standby Diesel Generator (EGA) System; Standby Diesel Generato Fuel Oil (EGF) System; Control Building HVAC (HVC) System; Diesel Generator Building Ventilation (HVP) System; and Yard Structures Ventilation (HVY) System. The plant specific OE review for these systems/components did not identify any cases of a loss of intended function due to aging degradation.

For the EGA system, new activity N-N2PMP-010 will monitor for the Loss of Material of CLASL components in air. Since the activity is new (i.e. yet to be formalized and approved) there are no examples provide of how PM program has been effective in managing loss of material aging effect without failure of the components intended function (Reference Air Start-Up Emergency Diesel Generator (EGA) Aging Management Review for NMP2).

For the EGF system, new activity N-ACST-02 will monitor the external surfaces of CLASL Tank components in air for the Loss of Material. Since the activity is new (i.e. yet to be formalized and approved) there are no examples to provide of how PM program has been effective in managing loss of material aging effect without failure of the components intended function. (Reference Emergency Diesel Generator (EGF) System Aging Management Review for NMP2, Revision 1).

For the HVC system, new activity N-N2PMP-001 will monitor for the Loss of Material of the CLASL component in air. Since the activity is new (i.e. yet to be formalized and approved) there are no examples provide of how PM program has been effective in managing loss of material aging effect without failure of the components intended function (Reference Control Building HVAC System (HVC) Aging Management Review for NMP2, Revision 1).

For the HVP system, existing activities N2-EPM-GEN-V781and N2-EPM-GEN-V786 need to be revised to monitor for the Loss of Material of CLASL components in air. Since these activities need enhancement, there are no examples to provide of how the PM program activities have been effective in managing loss of material aging effect without failure of the components intended function.

(Reference Diesel Generator Building Ventilation System (HVP)

Aging Management Review for NMP2, Revision 1)

For the HVY system, existing activity N2-EPM-GEN-V781 needs to Thursday, March 03, 2005 Page 86 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified be revised to monitor for the Loss of Material of CLASL components in air. Since this activity needs enhancement, there are no examples to provide of how the PM program activity has been effective in managing loss of material aging effect without failure of the components intended function. (Reference Yard Structures Ventilation System (HVY) Aging Management Review for NMP2, Revision 1)

Note: The Unit 1 and 2 Preventative Maintenance Program Attribute Assesssment (PAA), Revision 0 does not contain the Emergency Diesel Generator (EGF) System in the Section 1.2 Unit 2 Systems list of systems that require enhancement. Therefore, this PAA will require revision.

LR Contact Nold NRC Tracking Number 3.3.1.B-05s6 Assigned Department/ License Renewal Individual Nold Date Closed 10/08/2004 Table 3.3.1.B LRA Section Thursday, March 03, 2005 Page 87 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 135 Saba Provide documentation to show how loss of material aging effect of the carbon steel tanks in LRA Section B2.1.20 reads The One-Time Inspection Program is a fuel oil environment, Tables 3.3.2-12 and 28, pages 214 and 267. new program that manages aging effects with potentially long 09/13/2004 incubation periods for susceptible components WSLR. Program activities include visual, volumetric, and other established inspection techniques consistent with industry practice to provide a means of verifying that an aging effect is either (1) not occurring, or (2) progressing so slowly that it has a negligible effect on the intended function of the structure or component. The program also provides measures for verifying the effectiveness of existing AMPs. If a one-time inspection reveals an aging effect requiring management, an evaluation is required to determine the ability of the affected component to perform its intended function(s) during the period of extended operation and any appropriate corrective action.

Since the One-time Inspection Program is new, documentation with respect to loss of material is not currently available. This loss of material information will be obtained during the actual one-time inspection of the fuel oil tanks. The One-time Inspection of the fuel o tanks will be driven by activities N-OTI-025 and N-OTI-027 as documented respectively in the NMP2 Engine-Driven Fire Pump Fue Oil System AMR and the NMP2 Standby Diesel Generator Fuel Oil System AMR.

Currently, the existing aging management programs for both the NMP2 Standby Diesel Generator Fuel Oil System and the NMP2 Engine-Driven Fire Pump Fuel Oil System consist of activities (i.e.

procedures N2-CSP-EDG-M500 and N2-CTP-FPW-Q502) in the Fuel Oil Chemistry Program. These activities ensure that water and particulates within the fuel oil are kept below minimum threshold levels during plant operations thereby minimizing the possibility of loss of material in the fuel oil tanks. The One-time Inspection Program will provide the measure for verifying the effectiveness of the Fuel Oil Chemistry Program.

LR Contact Nold NRC Tracking Number 3.3.1.B-07s1 Assigned Department/ License Renewal Individual Nold Date Closed 10/27/2004 Tables 3.3.2-12 and LRA Section 28 Thursday, March 03, 2005 Page 88 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 136 Saba Justify using preventive maintenance program in lieu of aboveground carbon steel tanks for For the Tanks of Table 3.3.2.B-28, page 267 the environment (i.e.

managing loss of material aging effect of carbon steel tanks in air environment (assumed to b air) to which these carbon steel tanks are exposed is not outside air 09/13/2004 outdoor/external), Table 3.3.2.B-28 Page 267.

The three 7-day fuel oil storage tanks for the two Standby Diesel Generators and the HPCS Diesel Generator, are encased (i.e.

buried) in concrete below the diesel generator building. There are three diesel fuel oil day tanks, one for each diesel engine. Each day tank is located in the day tank room above the engine generator control panel room of its associated diesel generator. Thus, none of these six tanks external surfaces are exposed to outside air.

Accordingly, none of these fuel oil tanks fit the intended scope of AMP XI.M29 Aboveground Carbon Steel Tanks as defined in Chapter XI of NUREG-1801.

Section 1.2 Scope of the Unit 1 & 2 Preventative Maintenance Program Attribute Assessment and LRA Section B2.1.32 Preventative Maintenance Program reads that the scope of the program includes tanks. Therefore, the use of the Preventative Maintenance Program is justified.

LR Contact Nold NRC Tracking Number 3.3.1.B-23s1 Assigned Department/ License Renewal Individual Nold Date Closed 09/22/2004 Table 3.3.2-28 LRA Section Thursday, March 03, 2005 Page 89 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 137 Patterson Page 3.2-52, -53 Cracking of wrought austenitic stainless steel heat exchangers in the Revised Response on 11/5/04:

emergency cooling system is managed by the PM program. Please provide documentation th 09/13/2004 demonstrates that this program provides for detection of this aging effect that is equivalent to Table 3.2.2.A-3 (p 3.2-52 & 53) for the NMP1 Emergency Cooling ASME Code Section XI IWB/IWC/IWD. System Heat Exchangers is incorrect in its omission of the ASME Section XI (GALL XI.M1) program for managing the aging effect of cracking. These components are ASME Class 2 on the tube side and Class 3 on the shell side. As such, they are part of the NMP1 ISI program. The Aging Management Program column in this table will be revised to include the ASME Section XI program. In addition Note E is replaced with Note B and Note 16 will either be removed o revised to provide clarifying information. The Preventive Maintenance program will continue to be credited as this activity represents the temperature monitoring performed on the Emergency Cooling System, including the heat exchangers.

LR Contact Petras NRC Tracking Number 3.1.1.A-3 1 1 A 09P1 Assigned Department/ License Renewal Individual Petras Date Closed 11/05/2004 Table 3.2.2.A-3 LRA Section Thursday, March 03, 2005 Page 90 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 138 Patterson Page 3.2-57 Cracking of wrought austenitic stainless steel piping and fittings in the emergenc There are no components on referenced page that credit the NMP1 cooling system is managed by the PM program. Please confirm that these components are PMP for aging management. Nor are there any Piping and Fittings 09/13/2004 small bore or provide documentation that demonstrates that this program provides for components on any page that credit the NMP1 PMP for aging detection of this aging effect that is equivalent to ASME Code Section XI IWB/IWC/IWD. management. Most of the piping in the NMP1 EC system is not "small-bore" see LRA drawings LR-18017-C_001 and LR-18048-C_000 for clarification of pipe sizes.

LR Contact Petras NRC Tracking Number 3.1.1.A-29P1 Assigned Department/ License Renewal Individual Petras Date Closed 10/15/2004 Table 3.2.2.A-3 LRA Section 140 Patterson GALL Item V.D2.1-b refers to piping and fittings of the HPCI system. Please justify its Discussed with auditor.

application (under Note A) to piping and fittings of the ECS.

09/13/2004 LR Contact Petras NRC Tracking Number 3.2.1A-01P2 Assigned Department/ License Renewal Individual Petras Date Closed 10/27/2004 Table 3.2.1-A LRA Section Thursday, March 03, 2005 Page 91 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 141 Patterson Page 3.2-41 GALL Item V.D2.2-a refers to pumps of the ECC systems. Please justify its Same as 140 application (under Note B) to pumps of the CSS.

09/13/2004 LR Contact Petras NRC Tracking Number 3.2.1.A-02P1 Assigned Department/ License Renewal Individual Petras Date Closed 09/24/2004 Table 3.2.2.A-1 LRA Section 142 Patterson Page 3.2-41 GALL Item V.D2.2-a refers to pumps of the ECC systems. Please justify its Reviewed and discussed with auditor.

application (under Note B) to pumps of the CSS.

09/13/2004 LR Contact Petras NRC Tracking Number 3.2.1.A-04P1 Assigned Department/ License Renewal Individual Petras Date Closed 09/21/2004 Table 3.2.2.A-1 LRA Section Thursday, March 03, 2005 Page 92 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 143 Patterson Page 3.2-39 GALL Item V.D2.1-e refers to piping and fittings of the automatic depressurizatio GALL row VD2.1-e specifies a plant-specific AMP. The One Time system. For heat exchangers, it is not clear how the proposed AMPs will address the intended Inspection program will be replaced by the PM Program. Procedure 09/13/2004 function of heat transfer. The GALL report suggests performance monitoring for such N1-MPM-080-410 provides a complete inspection of these heat components. Please identify the AMP that will manage aging effects that can compromise this exchangers every 2 years for degradation of any kind. Any sign of function. fouling during those inspections would result in a DER to correct the immediate problem and provide for preventive actions.

LR Contact Petras NRC Tracking Number 3.2.1.A-03P1 Assigned Department/ License Renewal Individual Petras Date Closed 10/12/2004 Table 3.2.2.A-1 LRA Section 144 Patterson Page 3.2-36, -38 In Table 3.2.2.A-1 (core spray system), the LRA indicates that filters/strainer Reviewed and discussed with auditor. (Also, note that this question and flow orifices are to be managed using the open-cycle cooling water system program. Tab refers to the NMP1 Containment Spray system, not the Core Spray 09/13/2004 3.2.1.A, Item 3.2.1.A-12, states that heat exchangers for the NMP1 ESF Systems are not System as written above.)

serviced by open cycle cooling system. The GALL Report states that the OCCW system is defined as a system or systems that transfer heat from safety-related systems, structures, and components (SSC) to the ultimate heat sink (UHS).

Please clarify the distinction being drawn between the open-cycle cooling system and the raw water supplied to the containment spray heat exchangers.

LR Contact Petras NRC Tracking Number 3.2.1.A-03P2 Assigned Department/ License Renewal Individual Petras Date Closed 09/21/2004 Table 3.2.2.A-1 LRA Section Thursday, March 03, 2005 Page 93 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 145 Patterson Page 3.2-36, -38 In Table 3.2.2.A-1 (core spray system), the LRA indicates that filters/strainer Reviewed and discussed with auditor. (Also, note that this question and flow orifices are to be managed using three different methods: the open-cycle cooling wat refers to the NMP1 Containment Spray system, not the Core Spray 09/13/2004 system program (only), ISI program (only), and ISI with on-time inspection. Please explain System as written above.)

which components are managed in which fashion, and why.

LR Contact Petras NRC Tracking Number 3.2.1.A-03P3 Assigned Department/ License Renewal Individual Petras Date Closed 09/21/2004 Table 3.2.2.A-1 LRA Section 146 Patterson Page 3.2-36, -38 In Table 3.2.2.A-1 (core spray system), the LRA indicates that filters/strainer Reviewed and discussed with auditor and flow orifices are to be managed using the open-cycle cooling water system program. Tab 09/13/2004 3.2.1.A, Item 3.2.1.A-12, states that heat exchangers for the NMP1 ESF Systems are not serviced by open cycle cooling system. The GALL Report states that the OCCW system is defined as a system or systems that transfer heat from safety-related systems, structures, and components (SSC) to the ultimate heat sink (UHS).

Please clarify the distinction being drawn between the open-cycle cooling system and the raw water supplied to the containment spray heat exchangers, and resolve the apparent discrepan LR Contact Petras NRC Tracking Number 3.2.1.A-05P1 Assigned Department/ License Renewal Individual Petras Date Closed 09/21/2004 Table 3.2.2.A-1 LRA Section Thursday, March 03, 2005 Page 94 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 147 Patterson Page 3.2-46, -49 Please provide the basis for the conclusion that the ISI program is an All activities of the BWR SCC program are encompassed at NMP by acceptable substitute for the BWR SCC program for stainless steel piping and fittings as well the XI.M1 and XI.M2 as described in the NMP LRA Appendix B2.1.6 09/13/2004 as valves in the core spray system. B2.1.1, and B2.1.2.

From the BWR SCC Program Attribute Assessment:

PROGRAM DESCRIPTION GALL Section XI.M7 -- BWR Stress Corrosion Cracking GALL The program to manage intergranular stress corrosion cracking (IGSCC) in boiling water reactor (BWR) coolant pressure boundary piping made of stainless steel (SS) is delineated in NUREG-0313, Rev. 2, and Nuclear Regulatory Commission (NRC) Generic Letter (GL) 88-01 and its Supplement 1. The program includes (a) preventive measures to mitigate IGSCC, and (b) inspection and flaw evaluation to monitor IGSCC and its effects. The staff-approved boiling water reactor vessel and internals project (BWRVIP-75) report allows for modifications of inspection scope in the GL 88-01 program.

NINE MILE POINT The ISI program includes periodic visual, surface, and/or volumetric examination and system pressure tests of all Class 1, 2, and 3 pressure-retaining components and their integral attachments. The program includes inspection of the reactor coolant pressure boundary piping made of stainless steel (SS) as delineated in NUREG-0313, Rev. 2, and Nuclear Regulatory Commission (NRC)

Generic Letter (GL) 88-01 and its Supplement 1. (Ref. 15 and 16)

Additional measures to mitigate intergranular stress corrosion cracking (IGSCC) in the reactor vessel internals and in the reactor recirculation piping system have been implemented by hydrogen water chemistry (HWC). (Ref. 26 & 35) In addition, the noble metal chemical application (NMCA) (Ref. 25 & 36), which injects platinum and rhodium into the recirculation loops and reactor vessel, has bee implemented to increase the effectiveness of the HWC by acting as a surface catalyst providing additional recombination of hydrogen an oxidants on the surface of the piping and reactor vessel. This process has been proven effective in reducing the growth of IGSCC in the reactor vessel and the reactor coolant components. The Water Chemistry Control Program establishes system goals, operating limits, and corrective actions for SSCs that are included Thursday, March 03, 2005 Page 95 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified under the BWRVIP. (Refs. 27, 28, and 37) Refer to the Program Attribute Assessment for the Water Chemistry Control Program associated with GALL Program XI.M2 Water Chemistry for details.

The current licensing basis for NMP is based on the 1989 Edition with no Addenda, whereas the GALL Report covers the 1995 Edition with the 1996 Addenda. This was found acceptable by the NRC in SERs dated October 5, 2000 (Enclosure to Reference 40) and March 3, 2000 (Enclosure to Reference 41), respectively. This is an exception to the GALL program elements.

LR Contact Petras NRC Tracking Number 3.2.1A-16P1 Assigned Department/ License Renewal Individual Petras Date Closed 10/12/2004 Table 3.2.2.A-2 LRA Section Thursday, March 03, 2005 Page 96 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 148 Patterson Page 3.2-57, -63, -64, -65 Please provide the basis for the conclusion that the ISI program is All activities of the BWR SCC program are encompassed at NMP by acceptable substitute for the BWR SCC program for stainless steel piping and fittings as well the XI.M1 and XI.M2 as described in the NMP LRA Appendix B2.1.6 09/13/2004 as valves in the emergency cooling system. B2.1.1, and B2.1.2.

From the BWR SCC Program Attribute Assessment:

PROGRAM DESCRIPTION GALL Section XI.M7 - BWR Stress Corrosion Cracking GALL The program to manage intergranular stress corrosion cracking (IGSCC) in boiling water reactor (BWR) coolant pressure boundary piping made of stainless steel (SS) is delineated in NUREG-0313, Rev. 2, and Nuclear Regulatory Commission (NRC) Generic Letter (GL) 88-01 and its Supplement 1. The program includes (a) preventive measures to mitigate IGSCC, and (b) inspection and flaw evaluation to monitor IGSCC and its effects. The staff-approved boiling water reactor vessel and internals project (BWRVIP-75) report allows for modifications of inspection scope in the GL 88-01 program.

NINE MILE POINT The ISI program includes periodic visual, surface, and/or volumetric examination and system pressure tests of all Class 1, 2, and 3 pressure-retaining components and their integral attachments. The program includes inspection of the reactor coolant pressure boundary piping made of stainless steel (SS) as delineated in NUREG-0313, Rev. 2, and Nuclear Regulatory Commission (NRC)

Generic Letter (GL) 88-01 and its Supplement 1. (Ref. 15 and 16)

Additional measures to mitigate intergranular stress corrosion cracking (IGSCC) in the reactor vessel internals and in the reactor recirculation piping system have been implemented by hydrogen water chemistry (HWC). (Ref. 26 & 35) In addition, the noble metal chemical application (NMCA) (Ref. 25 & 36), which injects platinum and rhodium into the recirculation loops and reactor vessel, has bee implemented to increase the effectiveness of the HWC by acting as a surface catalyst providing additional recombination of hydrogen an oxidants on the surface of the piping and reactor vessel. This process has been proven effective in reducing the growth of IGSCC in the reactor vessel and the reactor coolant components. The Water Chemistry Control Program establishes system goals, operating limits, and corrective actions for SSCs that are included Thursday, March 03, 2005 Page 97 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified under the BWRVIP. (Refs. 27, 28, and 37) Refer to the Program Attribute Assessment for the Water Chemistry Control Program associated with GALL Program XI.M2 Water Chemistry for details.

The current licensing basis for NMP is based on the 1989 Edition with no Addenda, whereas the GALL Report covers the 1995 Edition with the 1996 Addenda. This was found acceptable by the NRC in SERs dated October 5, 2000 (Enclosure to Reference 40) and March 3, 2000 (Enclosure to Reference 41), respectively. This is an exception to the GALL program elements.

LR Contact Petras NRC Tracking Number 3.2.1A-16P2 Assigned Department/ License Renewal Individual Petras Date Closed 10/12/2004 Table 3.2.2.A-3 LRA Section 149 Patterson Page 3.2-50 Certain valves of the LPCS are associated with GALL Item V.D2.3-c, which All of these components are small bore per the discussion in Table recommends the use of a BWR SCC program consistent with XI.M7 and water chemistry 3.2.1.A.

09/13/2004 consistent with XI.M2. Please confirm that all of these components are small bore per the discussion in Table 3.2.1.A.

LR Contact Petras NRC Tracking Number 3.2.1A-16P3 Assigned Department/ License Renewal Individual Petras Date Closed 09/21/2004 Table 3.2.2.A-2 LRA Section Thursday, March 03, 2005 Page 98 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 150 Patterson Page 3.3-141 Loss of material from piping and fittings in the liquid poison system is associate See response to Issue 4 with GALL Item V.D2.1 a, but the GALL item does not apply to components of cast iron.

09/13/2004 LR Contact Hoppe NRC Tracking Number 3.2.1.A-02K1 Assigned Department/ License Renewa Individual Hoppe Date Closed 09/17/2004 Table 3.3.2.A-10 LRA Section 151 Patterson Page 3.3-164 Loss of material from valves in the reactor water cleanup system is associated See response to # 4:

with GALL Item V.D2.3 b, but the GALL item does not apply to components of cast iron.

09/13/2004 There are no cast iron components in this system.

(b) The Material column in the tables in section 3 of the NMP 1 an NMP 2 LRA identifies generic material types as evaluated in the Material & Environment White Paper. This type is identified in the AMR as CLASL: Carbon or Low Alloy Steel (Yield< 100ksi) or Ductile/Malleable Cast Iron The LRA table will be revised to remove Ductile/Malleable Cast Iron the ductile cast iron is not present.

LR Contact Hoppe NRC Tracking Number 3.2.1.A-02K2 Assigned Department/ License Renewal Individual Hoppe Date Closed 10/04/2004 Table 3.3.2.A-17 LRA Section Thursday, March 03, 2005 Page 99 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 152 Patterson Page 3.3-148 Loss of material from containment isolation components of the radwaste system See response to #4 is associated with GALL item V.C.1-a. Please confirm that there are no cast iron components 09/13/2004 this type at NMP Unit 1 and clarify how the preventive maintenance program will be used to There are no cast iron components in this system.

manage internal loss of material.

(b) The "Material" column in the tables in section 3 of the NMP 1 Follow-up Question on 10/4/2004: and NMP 2 LRA identifies generic material types as evaluated in the Is the inspection described in the proposed resolution among the enhancements of the PM Material & Environment "White Paper". This type is identified in the program mentioned in Appendix B of the LRA? What is the basis for determining that a AMR as CLASL: "Carbon or Low Alloy Steel (Yield< 100ksi) or sufficient sample is inspected under the PM program? (For example, are all affected Ductile/Malleable Cast Iron" components inspected within a 5-year interval? or is there a sufficiently large sample within a specified interval at the end of the current period of licensed operation for the particular MEA t The LRA table will be revised to remove Ductile/Malleable Cast Iron establish statistical confidence that the aging effect is adequately managed? If the latter, plea the ductile cast iron is not present.

provide a copy of the analysis at the next visit to CNS offices.)

Although routine maintenance is largely preventive in nature, only th condition monitoring aspects of PM Program activities are credited for license renewal. For example, when a piping system is opened t conduct preventive maintenance on a valve, a visual inspection of th valve body and/or piping may be specified. Such activities do not prevent aging effects from occurring, but will identify degraded conditions that would affect the ability of the component to perform i intended function.

Response to Follow-Up Question on 10/4/2004:

Yes, the enhancements to the existing PM program as described in LRA Appendix B include the inspections for the containment isolatio components of the NMP1 Radwaste System. This information is in the Unit 1 Radwaste AMR under components IV-83.1-09, 10, 11 &

12.

The existing Preventive Maintenance Program provides for performance of various maintenance activities on a specified frequency based on vendor recommendations and operating experience. This is an existing maintenance program on plant components that is credited for license renewal. Enhancements are to ensure the applicable aging effects are discovered and evaluated The sample size, frequency and statistics are not associated with th PM program. These are factors associated with the One-Time Inspection Program.

LR Contact Hoppe NRC Tracking Number 3.2.1.A-03K1 Assigned Department/ License Renewal Individual Hoppe Thursday, March 03, 2005 Page 100 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified Date Closed 10/15/2004 Table 3.3.2.A-14 LRA Section 153 Patterson Page 3.3-161 Blowers, bolting, ducting, piping and fittings, valves and dampers of carbon stee See response to #4:

are associated with GALL item V.B.1-a. Please clarify the use of cast iron for these componen There are no cast iron components in this system.

09/13/2004 types in the reactor building HVAC system.

(b) The Material column in the tables in section 3 of the NMP 1 an NMP 2 LRA identifies generic material types as evaluated in the Material & Environment White Paper. This type is identified in the AMR as CLASL: Carbon or Low Alloy Steel (Yield< 100ksi) or Ductile/Malleable Cast Iron The LRA table will be revised to remove Ductile/Malleable Cast Iron the ductile cast iron is not present.

LR Contact Hoppe NRC Tracking Number 3.2.1.A-03K2 Assigned Department/ License Renewal Individual Hoppe Date Closed 10/04/2004 Table 3.3.2.A-16 LRA Section Thursday, March 03, 2005 Page 101 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 154 Patterson Page 3.3-161 Valves and dampers are associated with GALL item V.B.1-a, which addresses Reviewed and explained with the auditor equipment frames and housing but not the equipment itself. Please clarify the basis for the No 09/13/2004 assigned.

LR Contact Wells NRC Tracking Number 3.2.1.A-03K3 Assigned Department/ License Renewal Individual Wells Date Closed 09/15/2004 Table 3.3.2.A-16 LRA Section 155 Patterson Pages 3.3-147, -148, -149, components of the radwaste system (piping and fittings, tanks, an The LRA will be revised to change this row to Note G (different valves) are exposed to untreated demineralized water. This environment is not addressed in environment) 09/13/2004 GALL report. Please clarify the assignment of Notes for these items .

(Same comment for tracking numbers 3.2.1.A-05K1 and 3.2.1.A-06K1)

LR Contact Wells NRC Tracking Number 3.2.1.A-03K4 3 2 1 A 05K1 Assigned Department/ License Renewal Individual Wells Date Closed 09/17/2004 Table 3.3.2.A-14 LRA Section Thursday, March 03, 2005 Page 102 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 156 Patterson Pages 3.3-147, -149 It is unclear why piping, fittings, and valves of the radwaste system are n The Radwaste System carbon steel piping, fittings, and valves that considered subject to pitting and crevice corrosion (reference to GALL item 3.2.1.A-03 and are in a raw water environment are subject to pitting and crevice 09/13/2004 sometimes -06, but not -05. corrosion. The Radwaste System carbon steel piping, fittings, and valves that are in a demineralized untreated water, low flow Additional Follow-up clarification requested on 10/4/2004 (see mark-up of response form to se environment are subject to general corrosion, galvanic corrosion, an the context of the questions): MIC. This is consistent with section 4.1.3 of the Material-Environment White Paper which states Galvanic corrosion of

1) At issue is pitting. The mechanism of pitting and crevice corrosion is a galvanic process, bu carbon/low alloy steel will be an aging mechanism; but flow the substitution of terms is not helpful. Please address pitting and crevice corrosion. accelerated corrosion is not an aging mechanism for carbon/low allo steel. Although MIC was not found, the bacteria levels were high

2) Not true. FAC is not an aging mechanism if flow rates are lowbut FAC does affect C/l.a. enough for MIC to occur and there is nothing to prevent MIC in steel. Why is this mentioned here at all? The aging mechanisms of concern are general, pittin systems with demineralized untreated water. Therefore, MIC is

& crevice, and MI corrosion--NOT FAC. identified by ConRAD for components subject to low-flow demineralized untreated water. Low flow or stagnant areas are the

3) Is there some reason for the NRC to take cognizance of ConRAD? most likely locations.

4) ConRAD may choose to avoid repetitive determination, but its not clear that any technica The Radwaste System carbon steel piping, fittings, and valves that basis for this position exists. Please identify the guidance of the SRP-LR or the GALL that are in air or treated water, temperature > 140 degrees F, but <212 suggests that an aging mechanism need not be identified wherever it applies to a component degrees F, low flow are only subject to general corrosion. As noted subject to aging management or revise the LRA to do so. in Section 2.1.1 of the Material-Environment White Paper, General corrosion is the predominant aging mechanism for carbon steels and

5) This is because the aging effects are identified to a significant degree by the particular line cast irons in treated water under low flow conditions and in air.

item in Table 1 that is referenced in Table 2. Failing to make that reference is omitting Pitting and crevice corrosion also will occur under these conditions.

information that is expected. To avoid repetitive determination of these mechanisms, ConRAD only identifies general corrosion as an aging mechanism for carbon steels in low-flow treated water and air because all three mechanisms will be managed by the AMPs that manage general corrosion. For materials other than carbon steel, ConRAD will determine that pitting and crevice corrosion will occur independently of general corrosion.

Finally, in accordance with NEI 95-10, the Standard LRA format doe not identify the aging mechanisms, just the aging effects.

LR Contact Petras NRC Tracking Number 3.2.1.A-05K2 Assigned Department/ License Renewal Individual Petras Date Closed 10/25/2004 Table 3.3.2.A-14 LRA Section Thursday, March 03, 2005 Page 103 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 157 Patterson Page 3.3-159 Please provide a copy of the implementing procedure for the preventive Section 1.2 of the "Unit 1 and 2 Preventative Maintenance Program maintenance program used to monitor the aging effects of cracking, hardening, shrinkage, an Attribute Assessment" lists the NMP1 Reactor Building HVAC 09/13/2004 loss of strength for polymers in the reactor building HVAC system. (RBAC) System as a system requiring enhanced or new PM activities.

The Reactor Building HVAC System (RBAC) Aging Management Review for NMP1 (Revision 0) lists the internal and external surface of the expansion joints for the two RBAC Blowers as the component (FN-202-33, FN-202-33-EJ-Ext, FN-202-53, FN-202-53-EJ-Ext) that are made up from polymers (i.e. neoprene). This AMR also indicate that Section 7.2 of Activity N1-MPM-GEN-551 of the NMP1 Preventive Maintenance (PM) Program will be enhanced to inspect the neoprene expansion joints for the AERMs of cracking, hardening

& shrinkage and loss of strength.

Plant procedure N1-MPM-GEN-551 has yet to be revised and approved for use in the plant to inspect the neoprene expansion join for the AERMs of cracking, hardening & shrinkage and loss of strength. This procedure will be revised and implemented before the period of extended plant operations.

LR Contact Nold NRC Tracking Number 3.2.1.A-07K1 Assigned Department/ License Renewal Individual Nold Date Closed 10/12/2004 Table 3.3.2.A-16 LRA Section Thursday, March 03, 2005 Page 104 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 158 Patterson Page 3.3-147 Please clarify the basis for assignment of the Note letter for bolting. Note C was assigned because GALL item V.E.2-a only applies to high pressure or high temperature systems. Thus, this component 09/13/2004 was aligned with GALL item V.E.1-b which does not address bolting and given Note C (different component than that addressed in the GALL)

LR Contact Wells NRC Tracking Number 3.2.1.A-10K1 Assigned Department/ License Renewal Individual Wells Date Closed 09/16/2004 Table 3.3.2.A-14 LRA Section 159 Patterson Page 3.3-167 Please confirm that the valves managed using just two programs (one-time The components for which the one-time inspection and water inspection and water chemistry control) are small bore components. chemistry control programs are credited with managing cracking of 09/13/2004 austenitic stainless steel are small bore components only. This line item corresponds to only one valve, VLV-33-110.

LR Contact Brown NRC Tracking Number 3.2.1.A-16K1 Assigned Department/ License Renewal Individual Brown Date Closed 10/12/2004 Table 3.3.2.A-17 LRA Section Thursday, March 03, 2005 Page 105 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 160 Patterson Page 3.2-101 Loss of material from heat exchangers of the ECC system is associated with There are no cast iron components in this system.

GALL Item V.D2.4-a, which does not apply to components of cast iron. For steel heat 09/13/2004 exchanger components, the GALL Report recommends an open-cycle cooling water program (b) The Material column in the tables in section 3 of the NMP 1 an consistent with XI.M20. For other components subject to selective leaching, a program NMP 2 LRA identifies generic material types as evaluated in the consistent with GALL AMP XI.M33 is usually recommended. Please confirm that these Material & Environment White Paper. This type is identified in the components are made of carbon steel or explain how selective leaching will be addressed for AMR as CLASL: Carbon or Low Alloy Steel (Yield< 100ksi) or this component type. Ductile/Malleable Cast Iron The LRA table will be revised to remove Ductile/Malleable Cast Iron the ductile cast iron is not present.

LR Contact Hoppe NRC Tracking Number 3.2.1.B-12P2 Assigned Department/ License Renewal Individual Hoppe Date Closed 10/12/2004 Table 3.2.2.B-5 LRA Section 161 Patterson Pages 3.2-74 Certain piping and fittings of the HPCS are associated with GALL Item V.D2.1-c All of these components are small bore per the discussion in Table which recommends the use of a BWR SCC program consistent with XI.M7 and water 3.2.1.A.

09/13/2004 chemistry consistent with XI.M2. Please confirm that all of these components are small bore per the discussion in Table 3.2.1.A.

LR Contact Petras NRC Tracking Number 3.2.1.B-16P1 Assigned Department/ License Renewal Individual Petras Date Closed 09/21/2004 Table 3.2.2.B-2 LRA Section Thursday, March 03, 2005 Page 106 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 162 Patterson Pages 3.2-90, -92, -93 Certain piping and fittings of the RCIC are associated with GALL Item All of these components are small bore per the discussion in Table V.D2.1-c, which recommends the use of a BWR SCC program consistent with XI.M7. Please 3.2.1.A.

09/13/2004 confirm that all of these components are small bore per the discussion in Table 3.2.1.A.

LR Contact Petras NRC Tracking Number 3.2.1.B-16P2 Assigned Department/ License Renewal Individual Petras Date Closed 09/21/2004 Table 3.2.2.B-4 LRA Section 163 Patterson Pages 3.2-76 Certain valves of the HPCS are associated with GALL Item V.D2.3-c, which All of these components are small bore per the discussion in Table recommends the use of a BWR SCC program consistent with XI.M7 and water chemistry 3.2.1.A.

09/13/2004 consistent with XI.M2. Please confirm that all of these components are small bore per the discussion in Table 3.2.1.A.

LR Contact Petras NRC Tracking Number 3.2.1.B-16P3 Assigned Department/ License Renewal Individual Petras Date Closed 09/24/2004 Table 3.2.2.B-2 LRA Section Thursday, March 03, 2005 Page 107 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 164 Patterson Pages 3.2-84 Certain valves of the LPCS are associated with GALL Item V.D2.3-c, which All of these components are small bore per the discussion in Table recommends the use of a BWR SCC program consistent with XI.M7 and water chemistry 3.2.1.A.

09/13/2004 consistent with XI.M2. Please confirm that all of these components are small bore per the discussion in Table 3.2.1.A.

LR Contact Petras NRC Tracking Number 3.2.1.B-16P4 Assigned Department/ License Renewal Individual Petras Date Closed 09/24/2004 Table 3.2.2.B-3 LRA Section 165 Patterson Pages 3.2-96, -97 Certain valves of the RCIC are managed using one-time inspections and All of these components are small bore per the discussion in Table water chemistry control but are associated with GALL Item V.D2.3-c, which recommends the 3.2.1.A.

09/13/2004 use of a BWR SCC program consistent with XI.M7 and water chemistry consistent with XI.M2 Please confirm that all of these components are small bore per the discussion in Table 3.2.1.A.

LR Contact Petras NRC Tracking Number 3.2.1B-16P5 Assigned Department/ License Renewal Individual Petras Date Closed 09/24/2004 Table 3.2.2.B-4 LRA Section Thursday, March 03, 2005 Page 108 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 166 Patterson Pages 3.2-106 Certain valves of the RHR are managed using one-time inspections and water All of these components are small bore per the discussion in Table chemistry control but are associated with GALL Item V.D2.3-c, which recommends the use of 3.2.1.A.

09/13/2004 BWR SCC program consistent with XI.M7 and water chemistry consistent with XI.M2. Please confirm that all of these components are small bore per the discussion in Table 3.2.1.A.

LR Contact Petras NRC Tracking Number 3.2.1.B-16P6 Assigned Department/ License Renewal Individual Petras Date Closed 09/24/2004 Table 3.2.2.B-5 LRA Section Thursday, March 03, 2005 Page 109 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 167 Patterson Page 3.2-92 Please provide the basis for the conclusion (found in the discussion of item All activities of the BWR SCC program are encompassed at NMP by 3.2.1.B-16 in Table 1) that the ISI program is an acceptable substitue for the BWR SCC the XI.M1 and XI.M2 as described in the NMP LRA Appendix B2.1.6 09/13/2004 program for stainless steel piping and fittings in the RCIC. B2.1.1, and B2.1.2.

From the BWR SCC Program Attribute Assessment:

PROGRAM DESCRIPTION GALL Section XI.M7 -- BWR Stress Corrosion Cracking GALL The program to manage intergranular stress corrosion cracking (IGSCC) in boiling water reactor (BWR) coolant pressure boundary piping made of stainless steel (SS) is delineated in NUREG-0313, Rev. 2, and Nuclear Regulatory Commission (NRC) Generic Letter (GL) 88-01 and its Supplement 1. The program includes (a) preventive measures to mitigate IGSCC, and (b) inspection and flaw evaluation to monitor IGSCC and its effects. The staff-approved boiling water reactor vessel and internals project (BWRVIP-75) report allows for modifications of inspection scope in the GL 88-01 program.

NINE MILE POINT The ISI program includes periodic visual, surface, and/or volumetric examination and system pressure tests of all Class 1, 2, and 3 pressure-retaining components and their integral attachments. The program includes inspection of the reactor coolant pressure boundary piping made of stainless steel (SS) as delineated in NUREG-0313, Rev. 2, and Nuclear Regulatory Commission (NRC)

Generic Letter (GL) 88-01 and its Supplement 1. (Ref. 15 and 16)

Additional measures to mitigate intergranular stress corrosion cracking (IGSCC) in the reactor vessel internals and in the reactor recirculation piping system have been implemented by hydrogen water chemistry (HWC). (Ref. 26 & 35) In addition, the noble metal chemical application (NMCA) (Ref. 25 & 36), which injects platinum and rhodium into the recirculation loops and reactor vessel, has bee implemented to increase the effectiveness of the HWC by acting as a surface catalyst providing additional recombination of hydrogen an oxidants on the surface of the piping and reactor vessel. This process has been proven effective in reducing the growth of IGSCC in the reactor vessel and the reactor coolant components. The Water Chemistry Control Program establishes system goals, operating limits, and corrective actions for SSCs that are included Thursday, March 03, 2005 Page 110 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified under the BWRVIP. (Refs. 27, 28, and 37) Refer to the Program Attribute Assessment for the Water Chemistry Control Program associated with GALL Program XI.M2 Water Chemistry for details.

The current licensing basis for NMP is based on the 1989 Edition with no Addenda, whereas the GALL Report covers the 1995 Edition with the 1996 Addenda. This was found acceptable by the NRC in SERs dated October 5, 2000 (Enclosure to Reference 40) and March 3, 2000 (Enclosure to Reference 41), respectively. This is an exception to the GALL program elements.

LR Contact Petras NRC Tracking Number 3.2.1.B-16P7 Assigned Department/ License Renewal Individual Petras Date Closed 10/12/2004 Table 3.2.2.B-4 LRA Section Thursday, March 03, 2005 Page 111 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 168 Patterson Page 3.2-103 Please provide the basis for the conclusion that the ISI program is an acceptab All activities of the BWR SCC program are encompassed at NMP by substitute for the BWR SCC program for stainless steel piping and fittings in the RHR system the XI.M1 and XI.M2 as described in the NMP LRA Appendix B2.1.6 09/13/2004 B2.1.1, and B2.1.2.

From the BWR SCC Program Attribute Assessment:

PROGRAM DESCRIPTION GALL Section XI.M7 -- BWR Stress Corrosion Cracking GALL The program to manage intergranular stress corrosion cracking (IGSCC) in boiling water reactor (BWR) coolant pressure boundary piping made of stainless steel (SS) is delineated in NUREG-0313, Rev. 2, and Nuclear Regulatory Commission (NRC) Generic Letter (GL) 88-01 and its Supplement 1. The program includes (a) preventive measures to mitigate IGSCC, and (b) inspection and flaw evaluation to monitor IGSCC and its effects. The staff-approved boiling water reactor vessel and internals project (BWRVIP-75) report allows for modifications of inspection scope in the GL 88-01 program.

NINE MILE POINT The ISI program includes periodic visual, surface, and/or volumetric examination and system pressure tests of all Class 1, 2, and 3 pressure-retaining components and their integral attachments. The program includes inspection of the reactor coolant pressure boundary piping made of stainless steel (SS) as delineated in NUREG-0313, Rev. 2, and Nuclear Regulatory Commission (NRC)

Generic Letter (GL) 88-01 and its Supplement 1. (Ref. 15 and 16)

Additional measures to mitigate intergranular stress corrosion cracking (IGSCC) in the reactor vessel internals and in the reactor recirculation piping system have been implemented by hydrogen water chemistry (HWC). (Ref. 26 & 35) In addition, the noble metal chemical application (NMCA) (Ref. 25 & 36), which injects platinum and rhodium into the recirculation loops and reactor vessel, has bee implemented to increase the effectiveness of the HWC by acting as a surface catalyst providing additional recombination of hydrogen an oxidants on the surface of the piping and reactor vessel. This process has been proven effective in reducing the growth of IGSCC in the reactor vessel and the reactor coolant components. The Water Chemistry Control Program establishes system goals, operating limits, and corrective actions for SSCs that are included Thursday, March 03, 2005 Page 112 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified under the BWRVIP. (Refs. 27, 28, and 37) Refer to the Program Attribute Assessment for the Water Chemistry Control Program associated with GALL Program XI.M2 Water Chemistry for details.

The current licensing basis for NMP is based on the 1989 Edition with no Addenda, whereas the GALL Report covers the 1995 Edition with the 1996 Addenda. This was found acceptable by the NRC in SERs dated October 5, 2000 (Enclosure to Reference 40) and March 3, 2000 (Enclosure to Reference 41), respectively. This is an exception to the GALL program elements.

LR Contact Petras NRC Tracking Number 3.2.1.B-16P8 Assigned Department/ License Renewal Individual Petras Date Closed 10/12/2004 Table 3.2.2.B-5 LRA Section 169 Patterson Page 3.3-263 GALL Item V.D2.1-a refers to piping and fittings of several ECC systems (for Reviewed and explained with the auditor which cast iron is not a material identified in the GALL report) but does not apear to include 09/13/2004 those of the spent fuel pool cooling and cleanup system. Please identify which GALL item number (V.D2.1.1-7) applies or clarify the basis for the Note (A-E) assigned.

LR Contact Wells NRC Tracking Number 3.2.1.B-02K1 Assigned Department/ License Renewal Individual Wells Date Closed 09/16/2004 Table 3.3.2.B-27 LRA Section Thursday, March 03, 2005 Page 113 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 170 Patterson Page 3.3-264 GALL Item V.D2.3-b refers to valves of the ECC systems (for which cast iron is Reviewed and explained with the auditor not a material identified in the GALL report) but does not apear to include those of the spent fu 09/13/2004 pool cooling and cleanup system. Please clarify the basis for the Note (A-E) assigned.

LR Contact Wells NRC Tracking Number 3.2.1.B-02K2 Assigned Department/ License Renewal Individual Wells Date Closed 09/16/2004 Table 3.3.2.B-27 LRA Section 171 Patterson Page 3.3-263 GALL Item V.D2.1-e refers to piping and fittings of the ECC systems but does Reviewed and explained with the auditor not apear to include those of the spent fuel pool cooling and cleanup system. Please clarify th 09/13/2004 basis for the Note (A-E) assigned.

LR Contact Wells NRC Tracking Number 3.2.1.B-03K1 Assigned Department/ License Renewal Individual Wells Date Closed 09/16/2004 Table 3.3.2.B-27 LRA Section Thursday, March 03, 2005 Page 114 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 172 Patterson GALL Item V.D2.1-e refers to piping and fittings that are exposed to moist containment As noted in Table 3.0-1 of the LRA the term air is defined as Air atmosphere. Other components that refer to this item identify the environment as moist air . . includes indoor and outdoor, air-conditioned and non air-conditioned 09/13/2004 but the environment for this component is identified as simply air. Please explain why this is atmospheres. Air is assumed to contain some humidity; however, appropriate for the spent fuel pool cooling and cleanup system. significant amounts of condensation, pooling of water, or alternate wetting and drying do not occur.

LR Contact Wells NRC Tracking Number 3.2.1.B-03K2 Assigned Department/ License Renewal Individual Wells Date Closed 09/16/2004 Table 3.3.2.B-27 LRA Section 173 Patterson GALL Item V.C1.1-b calls for a plant-specific program to manage pitting, crevice, and The subject components are floor and equipment drain system pipin microbiologically influenced corrosion of stainless steel valve bodies and bonnets and pipe. between the containment isolation valves. The Appendix J Program 09/13/2004 Please explain how the Appendix J Program will identify such corrosion prior to failure of the is focused on finding valve seat leakage, although it would find containment boundary, or identify an alternative AMP that will do so. leakage (other than very minor leakage that could be categorized as acceptable valve seat leakage) of the piping or valve pressure (This also is identified as 3.2.1.B-06K1) boundary. Therefore, the Appendix J program alone is not adequate to manage pitting, crevice corrosion and MIC. The One-Time Inspection Program should be assigned to these components. If warranted by the initial One-Time Inspection program results, a plan specific program could be initiated to perform periodic inspections of these components.

LR Contact Brown NRC Tracking Number 3.2.1.B-05K1 3 2 1 B 05K1 Assigned Department/ License Renewal Individual Brown Date Closed 10/12/2004 Table 3.2.1.B LRA Section Thursday, March 03, 2005 Page 115 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 174 Patterson Page 3.3-184 For loss of material from pump casings of the SFP filtering and cooling system, In general for the Spent Fuel Pool Cooling and Cleanup System the GALL report recommends using a closed-cycle cooling water system program consistent (BWR), the GALL (Section VII.C.A4) specifies the Water Chemistry 09/13/2004 with XI.M21, which specifies an extent and schedule of inspections and testing in accordance Program in combination with the One-Time Inspection Program to with EPRI TR-107396, [to] assure detection of corrosion before the loss of intended function o manage loss of material of the components, except for components the component. It also recommends performance and functional testing in accordance with on the closed-cycle cooling water side of the heat exchangers. The EPRI TR-107396, [to ensure] acceptable functioning of the CCCW system or components subject pump casings were aligned with GALL VII.C.2.3-a because serviced by the CCCW system. Please provide the basis for concluding that the water the material (cast iron) did not match the pump material in GALL Item chemistry program provides comparable management of this aging effect. VII.A4.6-a.

NMP1 controls Spent Fuel Pool chemistry in accordance with procedure S-CTP-V666, "Auxiliary Systems Chemistry," which provides action levels for spent fuel pool water chemistry parameters. The action levels are in accordance with the recommendations found in Appendix B of EPRI TR-103515-R2, "BWR Water Chemistry Guidelines - 2000 Revision," and as such, fall within the scope of the Water Chemistry Control Program for NMP.

The pump casing material is gray cast iron and the environment is "Treated water, Temperature <140°F." No operating experience indicating degradation of this material-environment combination was found during the Operation Experience review for the NMP license renewal application. Therefore, use of the one-time inspection program to detect loss of material due to corrosion of the pump casings is appropriate to verify the absence of a significant aging effect. If significant loss of material were found during the initial inspection under the One-Time Inspection Program, the One-Time Inspection Program requires a periodic inspection activity to be initiated. Use of the One-Time Inspection Program in conjunction with Water Chemistry is therefore appropriate and is consistent with the programs recommended by GALL for BWR Spent Fuel Pool Cooling systems.

LR Contact Brown NRC Tracking Number 3.3.1A-15K1 Assigned Department/ License Renewal Individual Brown Date Closed 10/14/2004 Table 3.3.2.A-21 LRA Section Thursday, March 03, 2005 Page 116 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 175 Patterson Page 3.3-174 Loss of material from piping and fittings in the service water system is associate See response to #4:

with GALL Item VII.C1.1-a, but the GALL item does not apply to components of cast iron. There are no cast iron components in this system.

09/13/2004 Additionally, cast iron is susceptible to selective leaching in a raw water environment, and a selective leaching program consistent with GALL AMP XI.M33 is recommended for componen (b) The Material column in the tables in section 3 of the NMP 1 an types made of materials associated with VII.C1.1-a and subject to this aging mechanism. NMP 2 LRA identifies generic material types as evaluated in the Material & Environment White Paper. This type is identified in the AMR as CLASL: Carbon or Low Alloy Steel (Yield< 100ksi) or Ductile/Malleable Cast Iron The LRA table will be revised to remove Ductile/Malleable Cast Iron the ductile cast iron is not present.

LR Contact Hoppe NRC Tracking Number 3.3.1A-17K1 Assigned Department/ License Renewal Individual Hoppe Date Closed 10/12/2004 Table 3.3.2.A-19 LRA Section 176 Patterson Page 3.3-175 Loss of material from valves in the service water system is associated with GAL See response to # 4. There is no cast iron in the service water Item VII.C1.2-a, but the GALL item does not apply to components of cast iron. Additionally, ca system.

09/13/2004 iron is susceptible to selective leaching in a raw water environment, and a selective leaching program consistent with GALL AMP XI.M33 is recommended for component types made of materials associated with VII.C1.2-a and subject to this aging mechanism.

LR Contact Hoppe NRC Tracking Number 3.3.1A-17K2 Assigned Department/ License Renewal Individual Hoppe Date Closed 10/12/2004 Table 3.3.2.A-19 LRA Section Thursday, March 03, 2005 Page 117 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 177 Patterson Page 3.3-174 Loss of material from pumps in the service water system is associated with GAL There are no cast iron components in this system.

Item VII.C1.5-a, but the GALL item does not apply to components of cast iron. Additionally, ca 09/13/2004 iron is susceptible to selective leaching in a raw water environment, and a selective leaching (b) The Material column in the tables in section 3 of the NMP 1 an program consistent with GALL AMP XI.M33 is recommended for component types made of NMP 2 LRA identifies generic material types as evaluated in the materials associated with VII.C1.5-a and subject to this aging mechanism. Material & Environment White Paper. This type is identified in the AMR as CLASSL: Carbon or Low Alloy Steel (Yield< 100ksi) or Ductile/Malleable Cast Iron The LRA table will be revised to remove Ductile/Malleable Cast Iron the ductile cast iron is not present.

LR Contact Hoppe NRC Tracking Number 3.3.1A-17K3 Assigned Department/ License Renewal Individual Hoppe Date Closed 10/12/2004 Table 3.3.2.A-19 LRA Section Thursday, March 03, 2005 Page 118 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 178 Patterson Page 3.3-102 Loss of material from circulating water gates, traveling screens, and rakes in the See response to # 4. There are no cast iron components in this circulating water system is associated with GALL Item VII.C1.6-a, but the GALL item does not system.

09/13/2004 apply to components of cast iron. Additionally, cast iron is susceptible to selective leaching in raw water environment, and a selective leaching program consistent with GALL AMP XI.M33 (b) The Material column in the tables in section 3 of the NMP 1 an recommended for component types made of materials associated with VII.C1.6-a and subject NMP 2 LRA identifies generic material types as evaluated in the this aging mechanism. Material & Environment White Paper. This type is identified in the AMR as CLASSL: Carbon or Low Alloy Steel (Yield< 100ksi) or Ductile/Malleable Cast Iron The LRA table will be revised to remove Ductile/Malleable Cast Iron the ductile cast iron is not present.

LR Contact Hoppe NRC Tracking Number 3.3.1A-17K4 Assigned Department/ License Renewal Individual Hoppe Date Closed 10/12/2004 Table 3.3.2.A-1 LRA Section Thursday, March 03, 2005 Page 119 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 179 Patterson Page 3.3-194 Loss of material from piping and fittings in the alternate DHR system is See response to # 4. There are no cast iron components in this associated with GALL Item VII.C3.1-a, but the GALL item does not apply to components of ca system.

09/13/2004 iron. Additionally, cast iron is susceptible to selective leaching in a raw water environment, an a selective leaching program consistent with GALL AMP XI.M33 is recommended for (b) The Material column in the tables in section 3 of the NMP 1 an component types made of materials associated with VII.C3.1-a and subject to this aging NMP 2 LRA identifies generic material types as evaluated in the mechanism. Please explain the basis for assigning Note A to this AMR item. Material & Environment White Paper. This type is identified in the AMR as CLASL: Carbon or Low Alloy Steel (Yield< 100ksi) or Ductile/Malleable Cast Iron The LRA table will be revised to remove Ductile/Malleable Cast Iron the ductile cast iron is not present.

LR Contact Hoppe NRC Tracking Number 3.3.1.B-17K1 Assigned Department/ License Renewal Individual Hoppe Date Closed 10/12/2004 Table 3.3.2.B-2 LRA Section Thursday, March 03, 2005 Page 120 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 180 Patterson Page 3.3-194 Loss of material from valves in the alternate DHR system is associated with See response to # 4. There are no cast iron components in this GALL Item VII.C3.2-a, but the GALL item does not apply to components of cast iron. system.

09/13/2004 Additionally, cast iron is susceptible to selective leaching in a raw water environment, and a selective leaching program consistent with GALL AMP XI.M33 is recommended for componen (b) The Material column in the tables in section 3 of the NMP 1 an types made of materials associated with VII.C3.2-a and subject to this aging mechanism. NMP 2 LRA identifies generic material types as evaluated in the Material & Environment White Paper. This type is identified in the AMR as CLASSL: Carbon or Low Alloy Steel (Yield< 100ksi) or Ductile/Malleable Cast Iron The LRA table will be revised to remove Ductile/Malleable Cast Iron the ductile cast iron is not present.

LR Contact Hoppe NRC Tracking Number 3.3.1.B-17K2 Assigned Department/ License Renewal Individual Hoppe Date Closed 10/12/2004 Table 3.3.2.B-2 LRA Section Thursday, March 03, 2005 Page 121 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 181 Patterson Page 3.3-203 Loss of material from chillers of the control building chilled water system is See response to # 4. There are no cast iron components in this associated with GALL Item VII.C1.3-a, which does not apply to components of cast iron. system.

09/13/2004 Additionally, cast iron is susceptible to selective leaching in a raw water environment, and a selective leaching program consistent with GALL AMP XI.M33 is recommended for componen (b) The Material column in the tables in section 3 of the NMP 1 an types made of materials associated with VII.C1.3-a and subject to this aging mechanism. NMP 2 LRA identifies generic material types as evaluated in the Material & Environment White Paper. This type is identified in the AMR as CLASL: Carbon or Low Alloy Steel (Yield< 100ksi) or Ductile/Malleable Cast Iron The LRA table will be revised to remove Ductile/Malleable Cast Iron the ductile cast iron is not present.

LR Contact Hoppe NRC Tracking Number 3.3.1.B-17K3 Assigned Department/ License Renewal Individual Hoppe Date Closed 10/12/2004 Table 3.3.2.B-8 LRA Section Thursday, March 03, 2005 Page 122 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 182 Patterson Page 3.3-243 and -244 Loss of material from unit coolers of the reactor building HVAC system See response to # 4. There are no cast iron components in this is associated with GALL Item VII.C1.3-a, which does not apply to components of cast iron. system.

09/13/2004 Additionally, cast iron and copper alloys are susceptible to selective leaching in a raw water environment, and a selective leaching program consistent with GALL AMP XI.M33 is (b) The Material column in the tables in section 3 of the NMP 1 an recommended for component types made of materials associated with VII.C1.3-a and subject NMP 2 LRA identifies generic material types as evaluated in the this aging mechanism. Material & Environment White Paper. This type is identified in the AMR as CLASSL: Carbon or Low Alloy Steel (Yield< 100ksi) or Ductile/Malleable Cast Iron The LRA table will be revised to remove Ductile/Malleable Cast Iron the ductile cast iron is not present.

LR Contact Hoppe NRC Tracking Number 3.3.1.B-17K4 Assigned Department/ License Renewal Individual Hoppe Date Closed 10/12/2004 Table 3.3.2.B-23 LRA Section Thursday, March 03, 2005 Page 123 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 183 Patterson Page 3.3-257 and -244 Loss of material from filters/strainers of the service water system is See response to # 4. There are no cast iron components in this associated with GALL Item VII.C1.6-a, which does not apply to components of cast iron. system.

09/13/2004 Additionally, cast iron is susceptible to selective leaching in a raw water environment, which should be addressed if the component is made of this material. (b) The Material column in the tables in section 3 of the NMP 1 an NMP 2 LRA identifies generic material types as evaluated in the Material & Environment White Paper. This type is identified in the AMR as CLASL: Carbon or Low Alloy Steel (Yield< 100ksi) or Ductile/Malleable Cast Iron The LRA table will be revised to remove Ductile/Malleable Cast Iron the ductile cast iron is not present.

LR Contact Hoppe NRC Tracking Number 3.3.1.B-17K5 Assigned Department/ License Renewal Individual Hoppe Date Closed 10/12/2004 Table 3.3.2.B-26 LRA Section Thursday, March 03, 2005 Page 124 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 184 Patterson Page 3.3-258 Loss of material from piping and fittings of the service water system is associate See response to # 4. There are no cast iron components in this with GALL Item VII.C1.1-a, which does not apply to components of cast iron. Additionally, cas system.

09/13/2004 iron is susceptible to selective leaching in a raw water environment, and a selective leaching program consistent with GALL AMP XI.M33 is recommended for component types made of (b) The Material column in the tables in section 3 of the NMP 1 an materials associated with VII.C1.1-a and subject to this aging mechanism. NMP 2 LRA identifies generic material types as evaluated in the Material & Environment White Paper. This type is identified in the AMR as CLASL: Carbon or Low Alloy Steel (Yield< 100ksi) or Ductile/Malleable Cast Iron The LRA table will be revised to remove Ductile/Malleable Cast Iron the ductile cast iron is not present.

LR Contact Hoppe NRC Tracking Number 3.3.1.B-17K6 Assigned Department/ License Renewal Individual Hoppe Date Closed 10/12/2004 Table 3.3.2.B-26 LRA Section Thursday, March 03, 2005 Page 125 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 185 Patterson Page 3.3-260 Loss of material from valves of the service water system is associated with GAL There are no cast iron components in this system.

Item VII.C1.2-a, which does not apply to components of cast iron. Additionally, cast iron is 09/13/2004 susceptible to selective leaching in a raw water environment, and a selective leaching program (b) The "Material" column in the tables in section 3 of the NMP 1 consistent with GALL AMP XI.M33 is recommended for component types made of materials and NMP 2 LRA identifies generic material types as evaluated in the associated with VII.C1.2-a and subject to this aging mechanism. Material & Environment "White Paper". This type is identified in the AMR as CLASL: "Carbon or Low Alloy Steel (Yield< 100ksi) or Ductile/Malleable Cast Iron."

The LRA table will be revised to remove Ductile/Malleable Cast Iron the ductile cast iron is not present.

LR Contact Hoppe NRC Tracking Number 3.3.1.B-17K7 Assigned Department/ License Renewal Individual Hoppe Date Closed 10/12/2004 Table 3.3.2.B-26 LRA Section Thursday, March 03, 2005 Page 126 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 186 Patterson Page 3.3-259 Loss of material from pump casings of the service water system is associated There are no cast iron components in this system.

with GALL Item VII.C1.5-a, which does not apply to components of cast iron. Additionally, cas 09/13/2004 iron is susceptible to selective leaching in a raw water environment, and a selective leaching (b) The "Material" column in the tables in section 3 of the NMP 1 program consistent with GALL AMP XI.M33 is recommended for component types made of and NMP 2 LRA identifies generic material types as evaluated in the materials associated with VII.C1.5-a and subject to this aging mechanism. Material & Environment "White Paper". This type is identified in the AMR as CLASSL: "Carbon or Low Alloy Steel (Yield< 100ksi) or Ductile/Malleable Cast Iron."

The LRA table will be revised to remove Ductile/Malleable Cast Iron the ductile cast iron is not present.

LR Contact Hoppe NRC Tracking Number 3.3.1.B-17K8 Assigned Department/ License Renewal Individual Hoppe Date Closed 10/12/2004 Table 3.3.2.B-26 LRA Section Thursday, March 03, 2005 Page 127 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 187 Patterson Page 3.3-205 Loss of material from pump casings of the control building chilled water system There are no cast iron components in this system.

associated with GALL Item VII.C2.3-a. A selective leaching program consistent with GALL 09/13/2004 AMP XI.M33 is recommended for cast iron component types associated with VII.C2.3-a. (b) The "Material" column in the tables in section 3 of the NMP 1 and NMP 2 LRA identifies generic material types as evaluated in the Material & Environment "White Paper." This type is identified in the AMR as CLASL: "Carbon or Low Alloy Steel (Yield< 100ksi) or Ductile/Malleable Cast Iron."

The LRA table will be revised to remove Ductile/Malleable Cast Iron the ductile cast iron is not present.

LR Contact Hoppe NRC Tracking Number 3.3.1B-15K1 Assigned Department/ License Renewal Individual Hoppe Date Closed 10/12/2004 Table 3.3.2.B-8 LRA Section Thursday, March 03, 2005 Page 128 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 188 Patterson Page 3.3-203 Loss of material from chillers of the control building chilled water system is There are no cast iron components in this system.

associated with GALL Item VII.C2.4-a, which does not apply to components of cast iron.

09/13/2004 Additionally, cast iron is susceptible to selective leaching in a treated water environment, and (b) The "Material" column in the tables in section 3 of the NMP 1 selective leaching program consistent with GALL AMP XI.M33 is recommended for and NMP 2 LRA identifies generic material types as evaluated in the components of closed-cycle cooling water systems subject to this aging mechanism. Material & Environment "White Paper." This type is identified in the AMR as CLASL: "Carbon or Low Alloy Steel (Yield< 100ksi) or Ductile/Malleable Cast Iron."

The LRA table will be revised to remove Ductile/Malleable Cast Iron the ductile cast iron is not present.

LR Contact Hoppe NRC Tracking Number 3.3.1B-15K2 Assigned Department/ License Renewal Individual Hoppe Date Closed 10/12/2004 Table 3.3.2.B-8 LRA Section Thursday, March 03, 2005 Page 129 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 189 Patterson Page 3.3-205 Please confirm that no cast iron is associated with this component, a tank in the There are no cast iron components in this system.

control building chilled water system.

09/13/2004 (b) The "Material" column in the tables in section 3 of the NMP 1 and NMP 2 LRA identifies generic material types as evaluated in the Material & Environment "White Paper." This type is identified in the AMR as CLASL: "Carbon or Low Alloy Steel (Yield< 100ksi) or Ductile/Malleable Cast Iron."

The LRA table will be revised to remove Ductile/Malleable Cast Iron the ductile cast iron is not present.

LR Contact Hoppe NRC Tracking Number 3.3.1B-15K3 Assigned Department/ License Renewal Individual Hoppe Date Closed 10/12/2004 Table 3.3.2.B-8 LRA Section 190 Patterson Page 3.3-259 Loss of material from stainless steel pump casings in the service water system As discussed with the auditor, stainless steel is not a material addressed in GALL Item VII.C1.5-a. Please clarify the basis for associating this component identified in the Selective Leaching Program in the GALL 09/13/2004 type with VII.C1.4-a, and address the need to apply a selective leaching AMP.

LR Contact Wells NRC Tracking Number 3.3.1B-17K9 Assigned Department/ License Renewal Individual Wells Date Closed 09/16/2004 Table 3.3.2.B-26 LRA Section Thursday, March 03, 2005 Page 130 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 191 Patterson Page 3.3-257 Please confirm that no cast iron is associated with this component, a flow There are no cast iron components in this system.

element in the service water system.

09/13/2004 (b) The Material column in the tables in section 3 of the NMP 1 an NMP 2 LRA identifies generic material types as evaluated in the Material & Environment White Paper. This type is identified in the AMR as CLASSL: Carbon or Low Alloy Steel (Yield< 100ksi) or Ductile/Malleable Cast Iron The LRA table will be revised to remove Ductile/Malleable Cast Iron the ductile cast iron is not present.

LR Contact Hoppe NRC Tracking Number 3.3.1B-17K10 Assigned Department/ License Renewa Individual Hoppe Date Closed 10/12/2004 Table 3.3.2.B-26 LRA Section 192 Patterson Page 3.3-260 Please confirm that no cast iron is associated with this component, a temperatu There are no cast iron components in this system.

element in the service water system.

09/13/2004 (b) The Material column in the tables in section 3 of the NMP 1 an NMP 2 LRA identifies generic material types as evaluated in the Material & Environment White Paper. This type is identified in the AMR as CLASSL: Carbon or Low Alloy Steel (Yield< 100ksi) or Ductile/Malleable Cast Iron The LRA table will be revised to remove Ductile/Malleable Cast Iron the ductile cast iron is not present.

LR Contact Hoppe NRC Tracking Number 3.3.1B-17K11 Assigned Department/ License Renewal Individual Hoppe Date Closed 10/12/2004 Table 3.3.2.B-26 LRA Section Thursday, March 03, 2005 Page 131 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 193 Patterson Page 3.3-197 Please clarify the basis for reliance on the Appendix J program for managemen The Appendix J Program is focused on finding valve seat leakage, of loss of material from piping, fittings, and valves of the compressed air system. although it would find leakage (other than very minor leakage that 09/13/2004 could be categorized as acceptable valve seat leakage) of the piping or valve pressure boundary. Therefore, the Appendix J program alone is not adequate to manage loss of material of the internal surfaces of piping, valves, and fittings. NMP2 does not have a Compressed Air Monitoring Program, which GALL recommends for this item. The One-Time Inspection Program should be assigned to manage loss of material in the components corresponding to GALL Item No. VII.D.1-a. If initial inspection results warrant, a plant-specific program with periodic inspections would be developed.

LR Contact Brown NRC Tracking Number 3.3.1B-19K1 Assigned Department/ License Renewal Individual Brown Date Closed 10/12/2004 Table 3.3.2.B-5 LRA Section Thursday, March 03, 2005 Page 132 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 194 Patterson Page 3.3-209 Loss of material from piping and fittings of the control building HVAC system is There are no cast iron components in this system.

associated with GALL Item VII.C1.1-a, which does not apply to components of cast iron. The 09/13/2004 GALL Report recommends an open-cycle cooling water program consistent with XI.M20 (b) The "Material" column in the tables in section 3 of the NMP 1 supplemented with a selective leaching program consistent with GALL AMP XI.M33 for and NMP 2 LRA identifies generic material types as evaluated in the components subject to this aging mechanism. Please identify the implementing procedure tha Material & Environment "White Paper." This type is identified in the will be used to manage this aging effect and explain how it addresses the concerns related to AMR as CLASL: "Carbon or Low Alloy Steel (Yield< 100ksi) or GL 89-13 and selective leaching. Ductile/Malleable Cast Iron."

The LRA table will be revised to remove Ductile/Malleable Cast Iron the ductile cast iron is not present.

LR Contact Hoppe NRC Tracking Number 3.3.1B-17K12 Assigned Department/ License Renewal Individual Hoppe Date Closed 10/12/2004 Table 3.3.2.B-9 LRA Section Thursday, March 03, 2005 Page 133 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 195 Patterson Page 3.3-210 Loss of material from valves and dampers of the control building HVAC system There are no cast iron components in this system.

associated with GALL Item VII.C3.2-a, which does not apply to components of cast iron. For 09/13/2004 these components, the GALL Report recommends an open-cycle cooling water program (b) The "Material" column in the tables in section 3 of the NMP 1 consistent with XI.M20 (supplemented with a selective leaching program consistent with GALL and NMP 2 LRA identifies generic material types as evaluated in the AMP XI.M33 for components subject to this aging mechanism). Please explain how a single Material & Environment "White Paper." This type is identified in the inspection of these components will adequately manage loss of material, even assuming that AMR as CLASL: "Carbon or Low Alloy Steel (Yield< 100ksi) or selective leaching is addressed/implemented by AMP B2.1.21/B2.1.20. Ductile/Malleable Cast Iron."

The LRA table will be revised to remove Ductile/Malleable Cast Iron the ductile cast iron is not present.

LR Contact Hoppe NRC Tracking Number 3.3.1B-17K13 Assigned Department/ License Renewal Individual Hoppe Date Closed 10/12/2004 Table 3.3.2.B-9 LRA Section Thursday, March 03, 2005 Page 134 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 196 Patterson Page 3.3-224 Loss of material from flow elements of the floor and equipment drains system is The environment for floor drains was conservatively categorized as associated with GALL Item VII.C1.4-a. The GALL Report recommends an open-cycle cooling raw water due to the relatively uncontrolled nature of the fluid to 09/13/2004 water program consistent with XI.M20. Please explain how a single inspection of these which floor drains may be exposed. Floor drains are exposed components will adequately manage this aging effect. periodically to water that is oxygenated and may contain impurities i excess the concentrations allowable in treated water. However, floo drains have not had a history of degradation due to pitting corrosion crevice corrosion, and microbiologically influenced corrosion, that have been experienced in open-cycle cooling water systems.

Therefore, One-Time Inspection is appropriate to determine if loss o material is significant in floor drain components. If the initial inspections conducted under the One-Time Inspection Program find that loss of material is significant, a periodic plant-specific inspection program would be established.

LR Contact Brown NRC Tracking Number 3.3.1B-17K14 Assigned Department/ License Renewal Individual Brown Date Closed 10/12/2004 Table 3.3.2.B-14 LRA Section Thursday, March 03, 2005 Page 135 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 197 Patterson Page 3.3-225 Loss of material from piping and fittings as well as valves of the floor and There are no cast iron components in this system.

equipment drains system is associated with GALL Item VII.C1.1-a, which does not apply to 09/13/2004 components of cast iron. The GALL Report recommends an open-cycle cooling water program (b) The "Material" column in the tables in section 3 of the NMP 1 consistent with XI.M20 supplemented with a selective leaching program consistent with GALL and NMP 2 LRA identifies generic material types as evaluated in the AMP XI.M33 for components subject to this aging mechanism. Please explain how a single Material & Environment "White Paper." This type is identified in the inspection of these components will adequately manage loss of material, even assuming that AMR as CLASL: "Carbon or Low Alloy Steel (Yield< 100ksi) or selective leaching is addressed/implemented by AMP B2.1.21/B2.1.20. Ductile/Malleable Cast Iron."

The LRA table will be revised to remove Ductile/Malleable Cast Iron the ductile cast iron is not present.

LR Contact Hoppe NRC Tracking Number 3.3.1B-17K15 Assigned Department/ License Renewal Individual Hoppe Date Closed 10/12/2004 Table 3.3.2.B-14 LRA Section Thursday, March 03, 2005 Page 136 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 198 Wen Page 3.4-46 [GALL Consistency Level: E] The subject valves are small diameter valves in instrumentation or To manage the aging effect of crack initiation and growth due to SCC for the subject valves, drain piping of the main steam system. The BWR Stress Corrosion 09/13/2004 GALL recommends using XI.M7, BWR Stress Corrosion Cracking and XI, M2, Water Cracking Program is described in the GALL as applicable to piping 4 Chemistry. The applicant indicates that it would use One-Time Inspection Program and inches and larger nominal diameter and also valve bodies, and also Water Chemistry Control Program. Please provide the basis for concluding that the One- pump casings, valve bodies and reactor vessel attachments and Time Inspection Program could substitute the BWR Stress Corrosion Program and provide appurtenances, such as head spray and vent components.

comparable management of this aging effect. (presumably valves associated with smaller diameter piping are also excluded) Therefore, these valves are outside the scope of the BW Stress Corrosion Cracking Program. These valves would be difficult or impossible to inspect volumetrically, as required by the guidelines of GALL Program X1.M7, "BWR Stress Corrosion Cracking."

FOLLOW UP on 11/3/04:

What was not addressed here is that this piping is not RCS pressure boundary piping. It is small bore SS instrument piping off of the turbine steam chest and off of the flow venturi. It is not, therefore, subject to Section XI pressure testing. As described above, these valves were originally aligned to GALL Section IV since this was the best material/environment match; however, the GALL Item cited and the Table 3.1.1.A item cited were not the best choices for these valves. The two Table 3.4.2.B-1 table items for WASS valves (one for normal flow and one for low flow) on P. 3.4-46 will be realigned to GALL Item IV.C1.1-i and Table 1 Item 3.1.1.A-07. The last paragraph in the note for Item 3.1.1.A-07 applies to these valves and will be changed to read, Additionally, for small bore piping, fittings, and valves in the NMP1 CRD and Main Steam Systems that are not part of the Inservice Inspection Testing Program, NMP1 only credits the Water Chemistry and One-Time Inspection Programs.

Additionally, in the Draft GALL revision, Item VII.B2 (Item S-38),

stainless steel in a steam environment applies to this issue and the Water Chemistry and One Time Inspection AMPs are credited for cracking. We are, therefore, in conformance with the proposed guidance in the draft of the new GALL.

The valves were matched with GALL Item IV.C1.3-c because portions of the main steam system are part of the reactor coolant pressure boundary, and the some of the components and aging effects identified in the AMR have no GALL match in the Main Steam System (GALL VIII.B2) Table. For instance, GALL VIII.B2 has no item for stainless steel valves.

The program description for GALL Program X1.M32, One-Time Inspection indicates the program addresses concerns regarding (a) an aging effect is not expected to occur but there is insufficient data Thursday, March 03, 2005 Page 137 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified to completely rule it out, or (b) an aging effect is expected to progres very slowly. Stress corrosion cracking of wrought austenitic stainless steel fits this description because, although SCC could occur, it is unlikely because of the dry steam environment in the mai steam system. For small bore piping and fittings the One-Time inspection program will use either NDE methods with demonstrated capability to detect cracking of the inside surfaces of the piping.

Destructive testing of a sample of piping and fittings permanently removed may also be used where practical. Therefore, the One-Time Inspection Program is appropriate for managing cracking for the subject valves.

FOLLOW-UP:

As described above, these valves were originally aligned to section since this was the best material/environment match. However, in th Draft GALL revision, in Section VII B2 the stainless steel/steam combination exists. These valves are already managed per this dra guidance. The valves will be re-aligned to GALL row VIII B2.2b.

LR Contact Poehler NRC Tracking Number 3.1.1.A-29 W1 Assigned Department/ License Renewal Individual Poehler Date Closed 10/04/2004 Table 3.4.2.A-4 LRA Section Thursday, March 03, 2005 Page 138 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 199 Wen Page 3.4-45 Q1:No, this item does not contain components made of cast iron.

Material: GALLs material item does not apply to components of Cast Iron. Does this item See Issue #4.

09/13/2004 contain components made of cast iron? Q2: These components represent external surfaces. Q3: Yes, they Where are the locations of these components? Are they accessible for system walkdown? are accessible for system walkdown.

LR Contact Reed NRC Tracking Number 3.2.1.A-10 W1 Assigned Department/ License Renewal Individual Reed Date Closed 09/16/2004 Table 3.4.2.A-4 LRA Section 200 Wen Page 3.4-42 Q1:No, this item does not contain components made of cast iron.

Material: GALLs material item does not apply to components of Cast Iron. Does this item See Issue #4.

09/13/2004 contain components made of cast iron? Q2: These components represent external surfaces. Q3: Yes, they Where are the locations of these components? Are they accessible for system walkdown? are accessible for system walkdown.

LR Contact Reed NRC Tracking Number 3.2.1.A-10 W1 Assigned Department/ License Renewal Individual Reed Date Closed 09/16/2004 Table 3.4.2.A-3 LRA Section Thursday, March 03, 2005 Page 139 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 201 Wen Page 3.4-42 Q1: No, this item does not contain components made of cast iron.

Material: GALLs material item does not apply to components of Cast Iron. Does this item See Issue #4. Q2: These components represent external surfaces.

09/13/2004 contain components made of cast iron? Q3:Yes, they are accessible for system walkdown. Q4: Per Where are the locations of these components? Are they accessible for system walkdown? Appendix B, Aging Management Programs and Activities (B.2.0),

Why there is no Bolting Integrity Program? NMP-1 does not have a Bolting Integrity Program. However, aging effects are managed by System Walkdown (low pressure, low temperature)

LR Contact Reed NRC Tracking Number 3.3.1.A-05 W1 Assigned Department/ License Renewal Individual Reed Date Closed 09/16/2004 Table 3.4.2.A-3 LRA Section 202 Wen Page 3.4-42 Q1:No, this item does not contain components made of cast iron.

Material: GALLs material item does not apply to components of Cast Iron. Does this item See Issue #4.

09/13/2004 contain components made of cast iron? Q2: These components represent external surfaces. Q3: Yes, they Where are the locations of these components? Are they accessible for system walkdown? are accessible for system walkdown.

LR Contact Reed NRC Tracking Number 3.3.1.A-05 W2 Assigned Department/ License Renewal Individual Reed Date Closed 09/16/2004 Table 3.4.2.A-3 LRA Section Thursday, March 03, 2005 Page 140 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 203 Woodfield In LRA table 3.5.2.A-9 (table 2) on page 3.5-89 for component block wall in air, one of the See response to # 42 which states that:

intended functions listed is RS. The definition of the acronym can not be found in the LRA.

09/13/2004 The staff believes this to mean radiation shielding, which is shown as acronym RD in table 2.0 RS Intended Function is Radiation Shielding. RD in LRA Table 2.0-1 of the LRA. The applicant is asked to verify the meaning of RS and correct any discrepancy will be revised to RS.

between RD and RS in the LRA.

LR Contact Hoppe NRC Tracking Number 3.5.1.A-24W3 Assigned Department/ License Renewal Individual Hoppe Date Closed 09/30/2004 Table 3.5.2.A-9 LRA Section 204 Merzke What is the aging effect of Zinc, and does the Fire Water System Program mitigate the aging There are no pure zinc components requiring aging management.

effect? The listing of zinc in Table 3.3.2.B-13 is to distinguish the zinc 09/14/2004 contents of two separate copper alloys, rather than to identify zinc a a separate material with distinct aging effects. The FWS Program does manage the aging of the copper alloy, though.

LR Contact Brown NRC Tracking Number 3.3.1.B-21M1 Assigned Department/ License Renewal Individual Brown Date Closed 10/08/2004 Table 3.3.1.B LRA Section Thursday, March 03, 2005 Page 141 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 205 Merzke Where in the Fire Protection Program does it discuss, piping and fittings? It primarily (Note: comment was addressed to piping and fittings in air that cred discusses fire barriers. the fire protection program on p. 3.3-218. These components are 09/14/2004 part of the Fire Protection Halon (FPG) system piping so never contain water)

Section B2.1.16 of the LRA and the Fire Protection System PAA will be revised to explicitly discuss that the program addresses aging management of piping and fittings in a non water environment.

LR Contact Brown NRC Tracking Number 3.3.1.B-19M1 Assigned Department/ License Renewal Individual Brown Date Closed 10/08/2004 Table 3.3.1.B LRA Section Thursday, March 03, 2005 Page 142 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 206 Saba For NMP1 Reactor Water Cleanup System - Heat Exchangers for the The above Issue concerning Cumulative Fatigue Damage and the material/environment combination Wrought Austentic Stainless Steel/ Fatigue Monitoring Program is a generic issue for the LRA (see 09/14/2004 Treated Water or Steam, temperature 212ºF, but > 482ºF Table License Renewal Inspection Open Issue #1).

3.3.2.A-17 displays Cracking for the AERM and Fatigue Monitoring Program as the AMP. Cumulative Fatigue Damage With respect to the question above and LRA Table 3.3.2.A-17, the should be listed as the AERM with the Fatigue Monitoring Program AMP Fatigue Monitoring Program will be deleted from the table sinc listed as the AMP. Cracking should be listed separately as an AERM the aging effect does not apply to Heat Exchangers as indicated in with the Preventative Maintenance Program and Water Chemistry Table VII.E3 of the GALL. The AERM Cracking for the Heat Programs listed as the AMPs. In addition, the GALL does not list Exchangers will be managed by the Preventative Maintenance Cumulative Fatigue Damage as an AERM and the Fatigue Monitoring Program and the Water Chemistry Control Program as already listed Program as the AMP to manage it for this material/environment in Table 3.3.2.A-17, Page 3.3-162.

combination. Explain why this aging effect applies to the NMP1 Heat Exchangers and how this aging effect is managed by FMP. Additional Finding: LRA Table 3.3.2.A-17 (page 3.3.162) lists VII.e3.3-d as the NUREG-1801 Volume 2 Item for Heat Exchangers with Wrought Austentic Stainless Steel and Treated Water or Steam Temperature 212ºF, but <482ºF. This Item is for Regenerative Heat Exchangers as listed in the GALL. Drawing LR-18009-C, sheet 1 displays Heat Exchanger HTX-33.1-22 as a Non-Regenerative Heat Exchanger. The Reactor Water Cleanup System (CU) Aging Management Review for NMP1 Revision 1 displays the correct Items (VII.E3.4.2 & VII.E3.4.3, respectively) for the Non-Regenerative Heat Exchanger Tubesheet and Tube-ID. Therefore, the NUREG-1801 Volume 2 Item listed in the Table should be changed to VII.E3-4-a in this LRA Table for this row.

LR Contact Nold NRC Tracking Number 3.3.1.a-03s2 Assigned Department/ License Renewal Individual Nold Date Closed 10/27/2004 Table 3.3.2.A-17 LRA Section Thursday, March 03, 2005 Page 143 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 207 Merzke How can you credit the Fire Water System Program for this component? The AMP specifies (Note: Comment pertains to piping and fittings on LRA p. 3.3-136, components containing water. Table 3.3.2.A-8, per C. Browne. Specifically, the component is the 09/15/2004 exhaust piping for the diesel fire pump)

The AMP for these components will be changed to the Fire Protection Program. Section B2.1.16 of the LRA and the PAA will b revised to include these components within the scope of the program LR Contact Brown NRC Tracking Number 3.3.1.A-05M1 Assigned Department/ License Renewal Individual Brown Date Closed 10/08/2004 Table 3.3.1.A LRA Section 208 Merzke How can you credit the Fire Water System Program for this component? The AMP specifies (LRA page 3.3-219, item description Silencer) components containing water, while the Silencer is exposed to an exhaust environment.

09/15/2004 The AMP for these components will be changed to the Fire Protection Program.

The program description in Section B2.1.16 and the Fire Protection Program Attribute Assessment will be revised appropriately.

LR Contact Brown NRC Tracking Number 3.3.1.A-05M2 Assigned Department/ License Renewal Individual Brown Date Closed 10/08/2004 Table 3.3.1.A LRA Section Thursday, March 03, 2005 Page 144 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 209 Merzke According to Technical Basis for Material-Environment Group Inputs to the Conrad Database The actual value used as a threshold was 5x1020 n/cm2. The value (White Paper), a neutron fluence of 1 x 1020 n/cm2 is considered an effective threshold for of 1x1020 n/cm2 listed in the White Paper Section 2.1.2.1 is 09/15/2004 neutron embrittlement of wrought austenitic stainless steel (WASS), because below this incorrect. The use for 5x1020 n/cm2 as an effective threshold for amount of fluence, the changes in mechanical properties of WASS are considered neutron embrittlement of wrought austenitic stainless steel was insignificant. What is the technical basis for this assertion? based on several industry studies. These studies defined varying thresholds for when neutron embrittlement becomes significant. The table below contains several references and the thresholds reported for the onset of neutron embrittlement. 5x1020 n/cm2 is roughly the average of these values. The most recent review of radiation embrittlement of stainless steel in light water reactors (MRP-79) supports the use of this threshold. It is difficult to define a true threshold for the onset of loss of fracture toughness since loss of fracture toughness is continuous from the beginning of neutron irradiation. The AMR results for the NMP reactor vessel internals ar consistent with the GALL and BWRVIP guidance which does not identify loss of fracture toughness as an aging effect requiring management (even for components with fluence exceeding 5x1020 n/cm2) for wrought austenitic stainless steel components. The fluence threshold for loss of fracture toughness applies only to PWRs. Therefore, cracking, whether due to SCC or IASCC or both, is the relevant aging effect requiring management.

However, the Technical Basis for Material-Environment Group Input to the Conrad Database (White Paper) Section 2.1.2.1 will be revise to support a threshold of 5x1020 n/cm2 which was used to define environments in which loss of fracture toughness could occur.

Industry Studies Defining Fluence Thresholds Reference Threshold Comment TR-103839, BWR Reactor Vessel 1x1020 n/cm2 (~0.2 dpa) (E>1 MeV)

WCAP-14577-1A, License Renewal Evaluation: Aging Managemen for Reactor Internals, March 2001, Westinghouse Electric Co.

LLC 1x1021 n/cm2 (E>0.1MeV). Correlates approximately with a fluence of 5x1020 n/cm2 (E>1 MeV) NRC disagreed with this threshold in Safety Evaluation for the WCAP.

BWR Core Shroud Inspection and Flaw Evaluation Guideline (BWRVIP-76), EPRI TR-114232, November 1999 3x1020 n/cm2-5x1020 n/cm2 (E>1MeV) Significant changes in ductility begin to occur in this fluence range. 5x1020 n/cm2, is considered an upper bound by BWRVIP for use of limit load fracture mechanics techniques for assessment of core shroud cracking.

Evaluation of BWR Top-Guide Integrity, EPRI NP-4767, Final Report, November 1986 Toughness properties of stainless steel Thursday, March 03, 2005 Page 145 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified irradiated to 1x1021 n/cm2 are quite high.

Materials Reliability Program - A Review of Radiation Embrittlement for Stainless Steels (MRP-79)-Revision 1, 1008204, Topical Report, September 2004 A graph of toughness (KJC) versus dpa for all light water reactors (LWR) is provided. The graph shows that the LWR data appears to conform to trend lines for a graph of fast reactor toughness versus dpa. (Fast reactor data are more abundant, there is limited data for LWR) The threshold for the beginning of measurable losses in toughness in fast reactors is between 0.5-2 dpa (3.3x1020 n/cm2 - 1.3x1021 n/cm2) with significant changes not occurring until 1 dpa (6.7x1020n/cm2).

LR Contact Poehler NRC Tracking Number Assigned Department/ License Renewal Individual Poehler Date Closed 09/21/2004 General LRA Section Thursday, March 03, 2005 Page 146 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 210 Saba The GALL report recommends further evaluation of programs to manage loss of material due (A) With respect to the NMP1 Spent Fuel Pool Filtering and Cleanup pitting and crevice corrosion of the piping, filter housing, valve bodies, and shell and nozzles o System, there is no ion heat exchanger in the system. The Aging 09/15/2004 the ion exchanger in the spent fuel pool cooling and cleanup system (BWR) and of the piping Effect/Mechanism of Loss of Material/Pitting and Crevice Corrosion and pump casing in the shutdown cooling system (older BWR) to verify the effectiveness of th identified for water chemistry program. a) Stainless Steel Piping (GALL Item # A4.1-a) b) Stainless Steel Filter (GALL Item # A4.2-a)

Also, GALL items VII E4.1a and b identify cumulative fatigue aging damage and loss of mater c) Stainless Steel Valves (GALL Item # A4.3-a),

as aging effects for carbon steel and stainless steel piping and fittings that required to be managed. with an environment of Chemically treated oxygenated water up to 50ºF (125º) does not apply based on water chemistry. More NMP LRA Table 3.3.1.A-03 states that the NMP1 SDC piping and fittings do not have this specifically, the NMP1 environment of Treated Water, temperature aging effect/mechanism. Justify why NMP1 SDC piping and fittings do not have the above 140ºF is not considered to be Oxygenated. The water source is aging effects. demineralized water that is chemically treated to remove oxygen. Th maximum normal operating dissolved oxygen concentration is 200 ppb or less. (Reference Section 4.1.1.21 of the white paper Technical Basis For Material-Environment Group Inputs to the ConRad Database)

(B)The justification of why (per LRA Table 3.3.1.A-03) the SDC piping and fittings do not have the aging effects of cumulative fatigue aging damage and loss of material are as follows:

a) For GALL Item E4.1-b the Aging Effect/Mechanism of Cumulative Fatigue Damage/Fatigue is not relevant to the Wrought Austentic Stainless Steel component type (i.e. Piping and Fittings) identified in Table 3.3.2.A-20 based on temperature. More specifically, the environment of Treated Water, temperature 140ºFis below the threshold temperature 220ºF at which thermal cycle fatigue is an acknowledged AERM. Furthermore, low cycle fatigue is not an AERM since the Shutdown Cooling System is not subject to frequen cycles of use or nonuse, nor is it frequently tested. (Reference Section 2.1.3.1 the white paper Technical Basis For Material-Environment Group Inputs to the ConRad Database) b) For GALL Item E4.1-a the Aging Effect/Mechanism of Loss of Material/Pitting Crevice Corrosion is not relevant to the Wrought Austentic Stainless Steel component type (i.e. Piping and Fittings) identified in Table 3.3.2.A-20 based on water chemistry. More specifically, the environment of Treated Water, temperature 140ºF is not considered to be Oxygenated. The water source is demineralized water that is chemically treated to remove oxygen. Th maximum normal operating dissolved oxygen concentration is 200 ppb or less. (Reference Section 4.1.1.21 of the white paper Technical Basis For Material-Environment Group Inputs to the ConRad Database)

Thursday, March 03, 2005 Page 147 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified LR Contact Nold NRC Tracking Number 3.3.1.A-03s3 Assigned Department/ License Renewal Individual Nold Date Closed 10/27/2004 Table 3.3.1.A LRA Section 211 Hsu Page 3.1-22, what is the basis for the conclusion in the 2nd paragraph for GALL rows 3.1.1.A- The LRA will be revised to provide further clarification.

01?

09/15/2004 LR Contact Wells NRC Tracking Number Assigned Department/ License Renewal Individual Wells Date Closed 09/17/2004 Table 3.1.1.A LRA Section 212 Hsu Page 3.1-26, justify the 2nd sentence in the discussion column for GALL row 3.1.1.A-08? The sentence will be deleted from the LRA 09/15/2004 LR Contact Wells NRC Tracking Number Assigned Department/ License Renewal Individual Wells Date Closed 09/17/2004 Table 3.1.1.A LRA Section Thursday, March 03, 2005 Page 148 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 213 Hsu Page 3.1-29, revise the 2nd paragraph to address why FAC is not applicable for GALL row The LRA will be revised.

3.1.1.A-25. (same comment also applies to 3.1.1.B-25) 09/15/2004 LR Contact Wells NRC Tracking Number Assigned Department/ License Renewal Individual Wells Date Closed 09/17/2004 Table 3.1.1.A and Ta LRA Section ble 3 1 1 B 216 Hsu Page 3.1-31, provide further clarification as to why the BWR SCC program does not apply for The LRA will be revised to clarify that for small bore valves, NMP GALL row 3.1.1.A-29. (same comment also applies to 3.1.1.B-29) credits One -Time Inspection and Water Chemistry rather than 09/15/2004 BWR SCC and Water Chemistry.

LR Contact Wells NRC Tracking Number Assigned Department/ License Renewal Individual Wells Date Closed 09/17/2004 Table 3.1.1.A and Ta LRA Section ble 3 1 1 B Thursday, March 03, 2005 Page 149 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 218 Wen Page 3.4-20 FOLLOW-UP RESPONSE REPLACES PREVIOUS RESPONSE:

09/16/2004 GALL indicates that carbon steel piping (VIII B2.1-a) and valve bodies (VIII B2.2-b) are subjec The Discussion in Table 1 Item 3.4.1.A-07 is incorrect. It was to aging effect of loss of material due to general, pitting, and crevice corrosion, why NMP1 LR intended that it be consistent with the Discussion in Table 1 Item does not consider this aging effect? 3.4.1.B-07. The Discussion column for Table 1 Item 3.4.1.A-07 will be changed to read, "Consistent with NUREG-1801 with exceptions (see Appendix B2.1.2). NMP1 also credits the One-Time Inspection Program (Appendix B2.1.20), in addition to the Water Chemistry Program, for small bore piping and valves in a treated water environment."

LR Contact Reed NRC Tracking Number 3.4.1.A-07 W1 Assigned Department/ License Renewal Individual Reed Date Closed 10/04/2004 Table 3.4.1.A LRA Section 219 Wen 3.4.1.B-10 W1: Page 3.4-23 Per NMP-2 Circulating Water System and Condensate System Scoping and Screening documents , the condenser and the cooling 09/16/2004 The circulating water flowing through the tube side of NMP2 condenser is considered as close tower (GALL Item VIII E-4e (condensate coolers/ condensers cycle cooling water system. What AMP will be used to manage the aging effect of loss of (serviced by closed- cycle cooling water), tubes, tubesheet, channel material due to general, pitting, and crevice corrosion for the condenser (GALL Item VIII E -4e head, and shell)) are not within the scope of license renewal.

Therefore, these items are not subject to aging management review LR Contact Reed NRC Tracking Number 3.4.1.B-10 W1 Assigned Department/ License Renewal Individual Reed Date Closed 10/18/2004 Table 3.4.1.B LRA Section Thursday, March 03, 2005 Page 150 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 220 Saba This question is for B2.1.15, Table 3.3.1.A-26, and Table 3.3.2.A-17. (a) The Aging Management Review Details Report of the "Reactor LRA Table 3.3.1.A-26 states that this item is consistent with GALL with exceptions [reactor Water Cleanup System (CU) Aging Management Review for NMP1" 09/16/2004 water cleanup system inspection with exceptions]. Additionally, NMP1 credits the One-time (Revision 1) identifies two components (CU-PIPE-CS & CU-PIPE-Inspections and water chemistry program for small bore piping in the NMP1 sampling system. SS) whose AERMs of "Cracking" or "Loss of Material" are managed a) GALL XI.M25 scope of program states that based on the NRC letter on the screening for aging by the BWR Reactor Water Cleanup System Program.

criteria related to inspection guidelines for RWCU piping welds outboard of the second isolatio These two components represent all the stainless steel and carbon valve. . . identify the RWCU piping that are within the scope of this program (refer to the steel CU piping subject to AMR. This AMR wrongly invokes the location of the piping on P&ID). BWR Reactor Water Cleanup System Program for managing the b) LRA Table 3.3.2.A-17, page 3.3-167 credits BWR reactor water cleanup program for LOM of carbon steel piping within the CU system. The Unit 1 ISI managing loss of material of piping and fittings component type in treated water, temperature Programs are ASME Section XI programs and in the case of piping,

<140 F. Explain how RWCU program manages this combination of component type, materia the primary purpose is weld inspection (cracking), not material loss.

environment and aging effect. Also add this combination to the program description and There are no specific requirements to perform thickness readings fo elements, if applicable. material loss on any piping. The program only monitors for IGSCC o c) Similar to b for NSR piping, fittings, and equipment in Table 3.3.2.A-17, page 3.3-16 SCC in stainless steel pipe. Therefore, the "Reactor Water Cleanup System (CU) Aging Management Review for NMP1" needs to be revised. In addition, Table 3.3.2.A-17 (page 3.3-163) needs to be revised with the Water Chemistry Control Program and with the One time Inspection Program to manage the Loss of Material for component type "Piping and Fittings" made of "Carbon or Low Alloy Steel (Yield Strength < 100 Ksi) and Ductile/Malleable Iron".

The following License Renewal drawings identified in the Scoping Report (page 1) of the "Reactor Water Cleanup System (CU)

Scoping and Screening for NMP1" (Revision 2) identify the boundaries for CU piping subject to AMP "Reactor Water Cleanup System (CU) Aging Management Review for NMP1". More specifically, the stainless steel CU piping is identified on drawings LR-18002-C, Sheet 1 (coordinate D-2), LR-18006-C, Sheet 1 (coordinates 1-G & 6-G), LR-18006-C, Sheet 2 (coordinate E-4) and LR-18009-C, Sheet 1 (coordinates A-1, A-2, B-1, B-2, C-1, & C-2)

Note: Two Boundary Flag errors were discovered on drawing LR-18006-C, Sheet 1 at coordinate 1-G and F-2. (1) The boundary flag at arrow "LR-18014-C SHT. 2 "R.B.S.S. #1" should not be highlighted with red nor indicate LR-CU (both directions). A boundar flag labeled LR-SS should be at valve IV-110-128 consistent with drawing LR-18041-C, SHT. 2 (coordinate F-4). (2) There is no LR-FW / LR-CU boundary flag on the inboard side of valve IV-33-01R.

(b) Note: The material of piping and fittings component type in treated water, temperature <140°F is found on LRA page 3.3-163; not page 3.3.167.

As indicated on page 3 of the Aging Management Review Details Report of the "Reactor Water Cleanup System (CU) Aging Management Review for NMP1" (Revision 1), the BWR Reactor Thursday, March 03, 2005 Page 151 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified Water Cleanup System Program will manage the AERM of Loss of Material with the use of program Activity NMP1-ISI-003 "Nine Mile Point Nuclear Power Station - Third Inservice Inspection Interval -

Inservice Inspection Program Plan" (Revision 2). As noted in the resolution to (a) above, the AMR wrongly invokes the BWR Reactor Water Cleanup System Program for managing the LOM of carbon steel piping within the CU system. The Unit 1 ISI Programs that comprise the BWR Reactor Water Cleanup System Program are ASME Section XI programs and in the case of piping, the primary purpose is weld inspection (cracking), not material loss. There are n specific requirements to perform thickness readings for material loss on any piping. Based on this finding, there is no need to add this material/environment/AERM combination to the program description and elements. Therefore, the "Reactor Water Cleanup System (CU)

Aging Management Review for NMP1" needs to be revised. In addition, LRA Table 3.3.2.A-17 (page 3.3-163) needs to be revised with the Water Chemistry Control Program and with the One-time Inspection Program to manage the Loss of Material for component type "Piping and Fittings" made of "Carbon or Low Alloy Steel (Yield Strength < 100 Ksi) and Ductile/Malleable Iron".

C) The BWR Reactor Water Cleanup System Program should not be invoked on page 3.3-163 of LRA Table 3.3.2.A-17 for component type "NSR piping, fittings, and equipment" since the material type is "Any" and this program pertains to the welds of stainless steel piping Instead, the Water Chemistry Control Program and the One-time Inspection Program should be invoked for the component type of "NSR piping, fittings, and equipment". Page 3.3-163 of LRA Table 3.3.2.A-17 will be revised to replace the BWR Reactor Water Cleanup System Program with the Water Chemistry Control Program and with the One-time Inspection Program for the component type o "NSR piping, fittings, and equipment". In addition, the "Nine Mile Point Unit 1 Scoping & Screening Aging Management Review NSR Piping" should be revised to reflect this revision for the CU system.

LR Contact Nold NRC Tracking Number 3.3.1.A-26s2 Assigned Department/ License Renewal Individual Nold Date Closed 10/08/2004 Table 3.3.2.A-17 LRA Section Thursday, March 03, 2005 Page 152 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified Thursday, March 03, 2005 Page 153 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 221 Saba This question is for B2.1.15, Table 3.3.1.B-26, and Table 3.3.2.A-24. a) The Aging Management Review Details Report of the "Reactor LRA Table 3.3.1.B-26 states that this item is not applicable for the NMP2 RWCU system Water Cleanup System (WCS) Aging Management Review for 09/16/2004 because the only components with this aging effect/mechanism are piping and fittings that pa NMP2" (Revision 1) identifies two components (2-WCS-025-4-1 and of the reactor coolant pressure boundary and are evaluated in row 3.1.1.B-07. 2WCS*V41) whose AERM of "Loss of Material" is managed for a) GALL XI.M25 scope of program states that based on the NRC letter on the screening aging by the BWR Reactor Water Cleanup System Program. This criteria related to inspection guidelines for RWCU piping welds outboard of the second isolatio AMR wrongly invokes the BWR Reactor Water Cleanup System valve. . .Clarify that there is no piping and fittings in this system that is required to be manage Program for managing the LOM for these two components within the by this RWCU program (both large bore piping and small bore piping). WCS. The Unit 2 ISI Programs that comprise the BWR Reactor b) LRA Table 3.3.2.B-24 page 3.3-250 credits BWR reactor water cleanup program for Water Cleanup System Program are ASME Section XI programs an managing loss of material of piping and fittings component type in treated water or steam, in the case of piping, the primary purpose is weld inspection temperature 482 F, low flow. Explain how RWCU program manages this combination of (cracking), not material loss. There are no specific requirements to component type, material, environment and aging effect. Also add this combination to the perform thickness readings for material loss on any piping or valves program description and elements, if applicable. The program only monitors for IGSCC or SCC in stainless steel pipe c) Similar to b for NSR piping, fittings, and equipment in Table 3.3.2.B-24, pages 3.3-246 and Therefore, the "Reactor Water Cleanup System (WCS) Aging 247 Management Review for NMP2" needs to be revised. In addition, Table 3.3.2.B-24 (page 3.3-250) needs to be revised to delete the BWR Reactor Water Cleanup System Program to manage the Loss of Material for component type "Piping and Fittings" made of "Carbo or Low Alloy Steel (Yield Strength < 100 Ksi) and Ductile/Malleable Iron" with a environment of "Treated Water or Steam, temperature 482ºF, Low Flow".

The BWR Reactor Water Cleanup System Program is not invoked for any of the other "Piping and Fittings" component types or other component types within the "Reactor Water Cleanup System (WCS)

Aging Management Review for NMP2".

B) As documented in the Resolution to (a) above, for managing the loss of material from component type piping and fittings in treated water or steam (temperature 482ºF, low flow) the BWR Reactor Water Cleanup System Program will not be invoked. The Unit 2 ISI Programs that comprise the BWR Reactor Water Cleanup System Program are ASME Section XI programs and in the case of piping, the primary purpose is weld inspection (cracking), not material loss.

There are no specific requirements to perform thickness readings fo material loss on any piping or valves. Based on this, there is no nee to add this material/environment/AERM combination to the program description and elements. Table 3.3.2.B-24 (page 3.3-250) will be revised to delete the BWR Reactor Water Cleanup System Program to manage the Loss of Material for component type "Piping and Fittings" made of "Carbon or Low Alloy Steel (Yield Strength < 100 Ksi) and Ductile/Malleable Iron" with a environment of "Treated Water or Steam, temperature 482ºF, Low Flow".

C) The BWR Reactor Water Cleanup System Program should not be invoked on pages 3.3-246 and 3.3-247 of LRA Table 3.3.2.B-24 Thursday, March 03, 2005 Page 154 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified for component type "NSR piping, fittings, and equipment" since the material type is "Any" and this program pertains to the welds of stainless steel piping. Instead, the Water Chemistry Program and th One-time Inspection Program should be invoked for the component type of "NSR piping, fittings, and equipment". Pages 3.3-246 and 3.3 247 of LRA Table 3.3.2.B-24 will be revised to replace the BWR Reactor Water Cleanup System Program with the Water Chemistry Control Program and the One-Time Inspection Program for the component type of "NSR piping, fittings, and equipment". In addition, the "Nine Mile Point Unit 2 Scoping & Screening Aging Management Review NSR Piping" for WCS will be revised to reflect this change.

LR Contact Nold NRC Tracking Number 3.3.1.B-26s1 Assigned Department/ License Renewal Individual Nold Date Closed 10/08/2004 Table 3.3.1.B-26 LRA Section Thursday, March 03, 2005 Page 155 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 225 Patterson What is the predicted neutron fluence at the LPCI nozzle (Unit 2) at the end of the period of The fluence is projected to be 7.22x1017 n/cm2 at the end of the extended operation? period of extended operation.

09/16/2004 The projection was performed as follows:

The bottom of the RHR/LPCI (N6) nozzle is located approximately 6 inches above the core midplane (Reference 1, 2). (Reference 3 give the core midplane elevation as 295.313 inches above the vessel 0.0 reference, the lowest point of the bottom head. Reference 1 and 2 shows the LPCI nozzle centerline elevation as 372.50 inches above vessel 0 reference, with the bottommost portion of the nozzle at approximately 360 inches.) The most recent surveillance capsule report for NMP2 includes a graph of fluence at the end of cycle 7 versus azimuthal positions and also axial distance from the core midplane (Reference 3). Projecting this fluence to the end of the period of extended operations is done as follows:

End of Cycle 7 = 8.72 EFPY Projected EFPY at end of extended license = (54 EFPY based on 60 years)(90% capacity factor)

Peak flux rate from 8.72 EFPY from Reference 3 = 8.78x108 n/cm2-s (E>1 MeV)

There is both an axial and azimuthal variation in fluence as shown b Figures 3-2 and 3-3 of Reference 3.

The ratio of the 8.72 EFPY fluences for +65 inches to the peak fluence location= 1.1x1017 n/cm2/1.95x1017 n/cm2 = 0.56 The azimuthal variation was modeled for one octant; however, the variation repeats in each octant. The LPCI nozzles are located at 45 135, and 315 degrees, each of which corresponds to the 45 degree location the first octant. The ratio of the fluence at the 45 degree location to the peak azimuthal location is 1.32x1017 n/cm2/1.95x1017n/cm2=0.68 Flux for 8.72 to 54 EFPY at the LPCI nozzle locations= (peak flux)(axial ratio)(azimuthal ratio)

=(8.78x108 n/cm2-s)(0.56)(0.68)=3.34x108n/cm2-s Fluence at LPCI nozzle location at 8.72 EFPY = (peak fluence)(axia ratio)(azimuthal ratio)

Thursday, March 03, 2005 Page 156 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified

=(1.95x1017 n/cm2)(0.56)(0.68)=7.43x1016 n/cm2 Number of seconds/EFPY = 365x24x60x60=3.1536x107 Projected fluence = (flux)( time (s)) + (fluence at 8.72 EFPY)

= (3.34x108 n/cm2-s)(54EFPY-8.72EFPY)(3.1536x107s/EFPY)+

7.43x1016 n/cm2 = 5.51x1017 n/cm2 As noted in Reference 4, there is considerable uncertainty in the calculated flux and fluence at the end of cycle 7. The vessel inner radius fluence uncertainty (1) is 15.5%. In addition the axial and azimuthal flux profiles can shift based on core and fuel designs. To account for the large time span of this projection, and the fluence calculation uncertainty a +- 2 factor is added to the projection.

Therefore the fluence based on 2 sigma is projected to be between (7.22x1017 n/cm2 and 3.8x1017 )

[plus 2 sigma 5.51x1017 n/cm2 +(2)(0.155)(5.51x1017 n/cm2) =

7.22x1017 n/cm2

[minus 2 sigma 5.51x1017 n/cm2 -(2)(0.155)(5.51x1017 n/cm2) =

3.8x1017 n/cm2 It is noted that the RHR/LPCI nozzle body was assigned to the environment group Treated Water or Steam, High Temperature -

BWR Reactor Vessel (TWHV), which does not have neutron embrittlement as an aging effect requiring management. However, based on the projection detailed above, the nozzle should have bee assigned to the environment group Treated Water or Steam, High Temperature, Neutron Fluence greater than or equal to 1x1017 n/cm2- BWR Reactor Pressure Vessel (TWHV17), which has loss of fracture toughness due to neutron embrittlement as an aging effec requiring management. The Reactor Surveillance Program will be assigned to manage loss of fracture toughness. This issue also applies to one water level nozzle (N13) located at 366 above the vessel 00 elevation.

LR Contact Poehler NRC Tracking Number 3.1.1.B-04P1 Assigned Department/ License Renewal Individual Poehler Date Closed 10/12/2004 Thursday, March 03, 2005 Page 157 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified Table 3.1.1.B LRA Section Thursday, March 03, 2005 Page 158 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified 228 Hsu P. 3.1-23 and 3.1-26 Revised Response on 11/5/04:

Please justify the statement "...Isolation Condenser that have this aging effect/mechanism are 10/18/2004 exposed to a different environment (air). See row 3.1.1.A-09 for further clarification." The discussion in rows 3.1.1.A-03 and 3.1.1.A-09 will be revised to The GALL Item IV.C1.4-b recommends XI.M1 and XI.M2. Per this item, XI.M1 is to be indicate that the Isolation Condensers are managed with the augmented to detect cracking due to SCC or loss of material due to pitting and crevice Inservice Inspection program (XI.M1), water chemistry control corrosion, and verification of the effectiveness of the program is required to ensure that program (XI.M2), temperature monitoring and radiological significant degradation is not occurring. An acceptable verification program is to include monitoring. An exception to GALL Item IV.C1.4-a is taken with temperature and radioactivity monitoring of the shell side water and eddy current testing of the respect to eddy current testing of the tubes since the Isolation tubes. Please explain how the PM Program manages this item. Condenser end bells are welded and access covers are not present to allow access to the tube sheet and tubes.

The Isolation Condensers are classified as ASME Section XI Class for the tube side and Class 3 for the shell side. As such, they are examined in accordance with the requirements of the ASME Section XI code. The tube and shell side receive an inservice pressure test conducted by procedure N1-IST-GEN-INS, ASME Class 2 and Class 3 Systems Inservice Pressure Test, Rev 3, dated 3/15/2001.

Water chemistry for the Isolation Condensers is managed in accordance with the GALL XI.M2 program for the tube side (per procedure N1-CSP-D100, Reactor Coolant Chemistry, Rev 4, dated 7/7/2003) and NMP1 Technical Specifications for the shell side (per procedure N1-CSP-M370, Emergency Condenser Shell Sampling and Analysis, Rev 1, dated 11/7/2002).

Temperature monitoring of the Isolation Condensers is performed per procedure N1-TTP-EC-SA001, Emergency Cooling System Temperature Trending, Rev 0, dated 1/30/2004. The shell side vents are monitored continuously for radioactivity with indicators in the Ma Control Room.

It is not possible to eddy-current test the Isolation Condenser tubes due to welded construction and no access covers on the end bells.

(Ref. Foster Wheeler Corp assembly drawing M-655-25, Rev F, dated 6/7/66). The above testing and monitoring activities provide adequate assurance that the Isolation Condensers will perform their Intended Functions.

LR Contact Petras NRC Tracking Number Assigned Department/ License Renewal Individual Petras Date Closed 11/05/2004 Thursday, March 03, 2005 Page 159 of 160

GCA AMR Issues (9/13-17) - Closed Issue ID NRC Issue Description Actions Taken / Issue Resolution Date Inspector Identified Table 3.1.1A LRA Section 229 Wen GALL indicates that carbon steel closure bolting in high-pressure or high-temperature systems It is acknowledged that an assumed no leakage bolted closure is is subject to aging effect of loss of material and crack initiation and growth (GALLVIII H.2-a an inconsistent with and unrealistic for GALL Items VIII.H2-a and 10/13/2004 H.2-b). The applicant indicated that those aging effects need not be considered because VIII.H2-b. Table Items 3.4.1.A-08 and 3.4.1.B-08 and subject Gall "leakage" is not assumed in its bolting assessment. item numbers are for closure bolting of the Steam and Power Conversion System. To remove this inconsistency, the LRA will be However, the bolting aging effect of crack initiation and growth due to cyclic loading and /or revised to indicate that the environment for these bolts in the Steam SCC has nothing to do with "leakage." Also, carbon steel components exposed to air, moistu and Power Conversion System is "Closure Bolting for Non-Borated and humidity would cause general corrosion without "leaking fluid." Please clarify the Water Systems With Operating Temperatures 212oF, With discussion column of Items 3.4.1.A-08 (Page 3.4-20) and 3.4.1.B-08 (Page 3.4-23) that those Leaking Fluid." In this environment, the material assigned to the aging effects need not be considered. closure studs, "Carbon/Low Alloy Steel, Yield Strengths > 100 ksi" will have the aging effect of cracking initiation and growth due to stress corrosion cracking, in addition to crack initiation and growth due to fatigue (i.e. cyclic loading) and loss of material due to genera corrosion. Therefore, NMP will be consistent with the GALL item since we identify SCC as an aging mechanism. The Discussion section for Items 3.4.1.A-08 and 3.4.1.B-08 will be revised accordingly.

FOLLOW-UP INFORMATION ON 11/3/04:

Additionally, the Section 3.4 Table 2s will be corrected, as appropriate, to include the Loss of Material AERM for bolting.

LR Contact Nold NRC Tracking Number Assigned Department/ License Renewal Individual Nold Date Closed 11/04/2004 Items 3.4.1.A-08 & B LRA Section 08 Thursday, March 03, 2005 Page 160 of 160

GCA AMR Issues (9/13-17) - Open Issue ID NRC Issue Description Actions Taken Date Inspector Identified 7 Hsu Page 3.1-62, component: closure bolting. This is a new response to this Issue.

09/10/2004 QUESTION 3.1.1A-26H1: GALL identifies Bolting integrity AMP to manage the aging of loss of The GALL report indicates loss of preload caused by the material. Bolting integrity program contains following 3 elements: 1) the use of lubricants and seala mechanism of stress relaxation is an aging effect for closure boltin

2) torguing activities 3) detection of aging effect with ASME Section XI. Provide justification to associated with the reactor vessel, reactor vessel internals, and th address first 2 elements or any other means were used to address the other 2 elements. Why doe reactor coolant pressure boundary. The GALL describes the applicant not consider the loss of preload aging effect for this item? environment for these bolts as "Air With a Metal Temperature Up t 288°C (550°F)". NMP does not identify loss of preload due to stress relaxation, or any other mechanism, as an aging effect requiring management for the corresponding components (i.e.,

reactor vessel, internals, or reactor coolant pressure boundary bolting).

NMP found that loss of preload due to stress relaxation is not an aging effect that requires management except for reactor internals that are exposed to high neutron fluence. The primary reasons for this judgment are as follows:

1) While the preload in a bolted joint does decrease after the initia torquing of the bolt, this is primarily a short-term effect. Long term stress relaxation due to creep is not a significant aging effect for bolts at primary system temperatures.

2) Compilations of industry experience with bolting failures find few or no incidents of bolt leakage attributed to loss of preload due to stress relaxation. Also a search of NMP plant-specific experience found no incidents of bolted joint leakage attributable to loss of preload due to stress relaxation.

3) Loss of preload of a bolted joint would cause leakage, resulting general corrosion of the fastener and/or cracking due to fatigue.

Both loss of material due to general corrosion and crack initiation and growth due to fatigue are aging effects that are managed for the closure bolting components at NMP. Stress corrosion cracking caused by improper lubricants or any other cause would be detected by the ASME Section XI Inservice Inspection Program, which applies to all the subject bolting.

4) Specification of proper preload and proper lubricants for a bolted joint is a design issue. Proper joint design and maintenance practices during torquing should ensure that the probability of loss of preload is minimized.

5) Any design deficiency of bolted joints in RV internals applications with low neutron fluence values will be detected during ten-year ISIs. Any loss of preload due improper design considerations would be addressed at that time Thursday, March 03, 2005 Page 1 of 62

GCA AMR Issues (9/13-17) - Open Issue ID NRC Issue Description Actions Taken Date Inspector Identified Supporting information for these points is provided below.

1) While the preload in a bolted joint does decrease after the initia torquing of the bolt, this is primarily a short-term effect. Long term stress relaxation due to creep is not a significant aging effect for bolts at primary system temperatures.

Creep in metallic materials typically is insignificant below one-third to one-half the melting temperature ' of the alloy. For low alloy steels, the elevated temperature regime, in which creep becomes significant, begins at around 0.36 Tm or 700°F, and 0.49 Tm (1000°F) for austenitic iron-base high temperature alloys (Reference 1). By contrast, the maximum temperature NMP primary systems closures bolting could be exposed to is about 550°F. A study of stress relaxation in Type 304 bolting described in Reference 2 found that stress relaxation essentially saturates after 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> in bolted joints exposed to temperatures of 900°F and below. The maximum amount of stress relaxation was 8%.

This type of stress relaxation is accounted for in the design of bolted joints.

EPRI TR-104213, "Bolted Joint Maintenance and Application Guide, (Reference 3)" indicates relaxation of fastener gasket and flange stress, which occurs throughout the joint life, is a possible cause of leaks. However, the detailed discussion of relaxation effects indicates permanent set of the gasket is the primary cause for relaxation of the joint. Gaskets are not considered long-lived components for license renewal purposes. Long-term, ongoing stress relaxation therefore not due to the long-lived passive components of the joint, such as the bolt. Relaxation due to permanent set of the gasket is likely to be much more significant than relaxation due to the small, insignificant amount of creep to be expected in the bolt.

2) Compilations of industry experience with bolting failures find few or no incidents of bolt leakage attributed to loss of preload due to stress relaxation. Also a search of NMP plant-specific experience found no incidents of bolted joint leakage attributable to loss of preload due to stress relaxation.

Table 1-1, Volume 1, EPRI NP-5769, "Degradation and Failure of Bolting in Nuclear Power Plants (Reference 4)," provides a summary of bolting failures. Loss of preload was not a contributing factor to the failures of reactor coolant pressure boundary bolting.

The majority of reactor coolant pressure boundary failures were du Thursday, March 03, 2005 Page 2 of 62

GCA AMR Issues (9/13-17) - Open Issue ID NRC Issue Description Actions Taken Date Inspector Identified to boric acid corrosion, with a few due to stress corrosion cracking The same reference also provides details on the contributing factors to these failures. For boric acid corrosion failures, gasket leakage was the primary contributing factor to most of the failures.

Boric acid leakage is not a concern for the reactor coolant pressure boundary at NMP, because reactor water is not borated. However bolted joint leakage could contribute to general corrosion. For the stress corrosion cracking failures, excessive preload, improper lubricants, or improper heat treatment of the material were contributing factors. The only fatigue failures documented were in reactor internals bolting; improper torque (which could lead to loss of preload) was implicated in only one of three failures. NMP does consider loss of preload for reactor internals bolting exceeding 5x1020 n/cm2 an aging effect requiring management.

NUREG-1339, "Resolution of Generic Safety Issue 29: Bolting Degradation or Failure in Nuclear Power Plants," summarized the NRCs examination of bolting failures from 1964 through the early 1980s. Common characteristics included high sustained tensile stresses, out-of specification pretorquing, an aqueous environmen caused by high humidity, primary and borated water leakage, and materials that were overly hard and out of specification. The most frequently observed failure mode for the structural bolting was SCC. Pressure retaining bolting failed due to corrosion wastage.

3) Loss of preload of a bolted joint would cause leakage, resulting in general corrosion of the fastener and/or cracking due to fatigue.

Both loss of material due to general corrosion and crack initiation and growth due to fatigue are aging effects that are managed for the closure bolting components at NMP. Stress corrosion cracking caused by improper lubricants or any other cause would be detected by the ASME Section XI Inservice Inspection Program, which covers all the subject bolting.

The subject bolts fall into three different material groups: 1) Carbon or Low Alloy Steel, yield Strength 100ksi (CLASG) 2) Martensitic Precipitation Hardening, and Superferritic Stainless Steels (MPS),

and 3) Wrought Austenitic Stainless Steels (WASS). The environment group assigned to all of the subject bolts is "Closure bolting in Non-Borated Water Systems with Operating Temperatures 212°F." This environment does not assume joint leakage is occurring, thus the bolts are not exposed to a wetted environment. Therefore, stress corrosion cracking (SCC) is not an aging effect requiring management for the material group CLASG, although this material could suffer SCC if exposed to high-temperature fluid. General corrosion is managed by the ASME Section XI inservice Inspection (Subsections IWB, IWC, and IWD)

Thursday, March 03, 2005 Page 3 of 62

GCA AMR Issues (9/13-17) - Open Issue ID NRC Issue Description Actions Taken Date Inspector Identified Program for CLASG bolts; the other material groups are not susceptible to general corrosion. Although the assigned environment group assumes general corrosion is caused by the humidity present in normal air, the ASME Section XI program woul detect general corrosion caused by a leaking joint. Although not credited in the LRA for managing cracking of closure bolting in the CLASG material group, the ASME Section XI inservice Inspection (Subsections IWB, IWC, and IWD) Program also requires volumetric examination of bolting greater than 2 inches in diamete which would detect cracking due to any cause (fatigue, SCC, etc.)

ASME Section XI requires a visual VT-1 examination on bolting 2 inches and less in diameter which would also detect cracking.

MPS bolts are considered particularly susceptible to SCC and therefore can experience SCC in high temperature moist environments without the presence of aggressive contaminants.

Therefore, the ASME Section XI inservice Inspection (Subsections IWB, IWC, and IWD) Program is credited with managing SCC for MPS bolts. For all three material groups, crack initiation and growth is considered an AERM that is managed by the Fatigue Monitoring Program (FMP). For the WASS bolts, cracking due to the mechanism of fatigue is the only aging effect requiring management. Generally, the bolts and the bolted connection woul not be the bounding component with respect to fatigue usage in th overall components (for example, the reactor vessel). Since loss o preload could result in higher alternating stress on the bolts, actua fatigue usage for the bolts could increase. For this reason, the bolting components should credit the ASME Section XI inservice Inspection (Subsections IWB, IWC, and IWD) Program in addition to the FMP for management of cracking.

Although only the Fatigue Management Program is credited in the LRA with managing cracking, these bolts also are inspected under ASME Section XI Inservice Inspection (Subsections IWB, IWC, and IWD) Program which would detect cracking due to any cause (SCC, fatigue, etc.).

Therefore, the significant aging effects that would result from loss of preload, crack initiation and growth due to fatigue, and loss of material due to general corrosion, are managed for the subject bolting.

4) Specification of proper preload and lubricants for a bolted joint is a design issue. Proper joint design and maintenance practices during torquing should ensure that the probability of loss of preload is minimized.

Standard Design Specification SDS-006, "Bolt Torque Thursday, March 03, 2005 Page 4 of 62

GCA AMR Issues (9/13-17) - Open Issue ID NRC Issue Description Actions Taken Date Inspector Identified Requirements (Reference 6)," provides guidelines for determining bolt torques, which control preloads. This specification is referenced by mechanical maintenance procedures at NMP1 and NMP2. Mechanical maintenance procedures at NMP specify approved lubricants to be used on fasteners.

Existing programs that are credited with managing aging are adequate for managing the significant aging effects that could result from loss of preload of bolted joints. Loss of preload would be detected and corrected if joint leakage or cracking were found.

References

1) "Elevated Temperature Failures," p. 263-297 in ASM Handbook, Volume 11 - Failure Analysis and Prevention, 1986, ASM International, Metals Park Ohio

2) "Materials Reliability Program Technical Basis Document Concerning Irradiation-Induced Stress Relaxation and Void Swelling in Pressurized Water Reactor Vessel Internals," MRP-50; 1000970, Interim Report, October 2001, Electric Power Research Institute, Palo Alto, CA

3) EPRI TR-104213, "Bolted Joint Maintenance and Application Guide," Final Report, December 1995, Electric Power Research Institute, Palo Alto, CA

4) NUREG-1339, "Resolution of Generic Safety Issue 29: Bolting Degradation or Failure in Nuclear Power Plant," June 1990, USNR

5) EPRI NP-5769, "Degradation and Failure of Bolting in Nuclear Power Plants," Volumes 1 and 2, April 1988, Electric Power Research Institute, Palo Alto, CA

6) Nine Mile Point Nuclear Station Standard Design Specification SDS-006, "Bolt-Torque Requirements for Unit 1 and Unit 2,"

Revision 2 Issued 2/20/2004 LR Contact Poehler NRC Tracking Numbe 3.1.1A-26H1 Assigned Department/ License Renewal Individual Poehler Issue Status Waiting for NRC

Response

Thursday, March 03, 2005 Page 5 of 62

GCA AMR Issues (9/13-17) - Open Issue ID NRC Issue Description Actions Taken Date Inspector Identified LRA Section Table 3.1.2.A-3 8 Hsu Page 3.1-65, component: closure bolting. See issue 7 response.

09/10/2004 QUESTION 3.1.1A-26H1: GALL identifies Bolting integrity AMP to manage the aging of loss of material. Bolting integrity program contains following 3 elements: 1) the use of lubricants and seala

2) torguing activities 3) detection of aging effect with ASME Section XI. Provide justification to address first 2 elements or any other means were used to address the other 2 elements. Why doe applicant not consider the loss of preload aging effect for this item?

LR Contact Petras NRC Tracking Numbe 3.1.1A-26H1 Assigned Department/ License Renewal Individual Petras Issue Status Waiting for NRC

Response

LRA Section Table 3.1.2.A-4 Thursday, March 03, 2005 Page 6 of 62

GCA AMR Issues (9/13-17) - Open Issue ID NRC Issue Description Actions Taken Date Inspector Identified 10 Woodfield The applicant states in the discussion for table 3.5.1.A item number 3.5.1.A-02 that cracking from Penetration sleeves, penetration bellows, and dissimilar metal cyclic loading and crack initiation and growth from SCC is not applicable for penetration sleeves, welds at NMP1 are not subjected to conditions that cause cracking 09/10/2004 penetration bellows, and dissimilar metal welds at NMP Unit 1. The applicant then gives reasons w due to cyclic loading and crack growth due to stress corrosion it believes these aging effects are not applicable. The GALL report specifies the Containment cracking. Three reasons are stated as to why NMP1 does not Inservice Inspection (IWE) and containment leak rate test (Appendix J) aging management program consider cracking for cyclic loading & crack initiation and growth to manage the cracking of these components. However, Containment ISI and Leak rate testing may from SCC an applicable aging effect/mechanism:

not be sufficient to detect cracks and therefore, the GALL recommends further evaluation of these programs to manage cracking of penetrations due to cyclic loading or SCC. The project team believ 1. Maximum Operating Temperature is insufficient to allow the that an aging management evaluation should be provided in table 3.5.2.A (table 2) for these magnitude of thermal cycles necessary for cracking due to cyclic components and the table 1 line item 3.5.1.A-02 discussion should state consistent with GALL with loading (fatigue).

exception. The discussion provided is applicable as an evaluation of the two programs ability and The liner reinforcement at all penetrations meets the requirements need to detect the aging effect of cracking from cyclic loading and SCC. Explain how extensive the of the ASME Boiler and Pressure Vessel Code,Section III, Class B use of penetration bellows is for the primary containment structure and the different materials used f vessels. Penetration design and materials conform to the these bellows. Provide the environment (temperature, pressure, humidity, presence of aggressive requirements of the ASME Boiler and Pressure Vessel Code, agents) to which penetration sleeves, penetration bellows, and dissimilar metal welds are exposed, Section III, Nuclear Vessels. The piping is anchored at the both on a continuing basis and on a periodic or intermittent basis. penetration sleeves, and the anchorage restraint forces and moments were included in the design of the sleeve anchorage. Th temperature of the penetration sleeve at its attachment weld to the liner does not exceed 150 deg F under operating conditions. Sleev radiation fins, thermal sleeves, and pipe insulation were employed to maintain this temperature requirement.

2. Drywell and suppression pool penetration sleeves with the exception of the Control Rod Drive penetrations are low strength carbon/low alloy steel, which is not susceptible to SCC in the drywell or suppression pool environment.

The Primary Containment Aging Management Review verifies that the primary containment penetrations are fabricated out of low strength carbon and low alloy steel.

3. The CRD penetration sleeves are not exposed to a moist environment, which is required for SCC.

The Primary Containment Aging Management Review verifies that the primary containment CRD penetrations are located in an air environment.

Additionally, Table 1 item number 3.5.1.A-02 is not referenced in any Table 2 for NMP1.

LR Contact Hoppe NRC Tracking Numbe 3.5.1.A-02W1 Assigned Department/ License Renewal Individual Hoppe Issue Status Waiting for NRC

Response

Thursday, March 03, 2005 Page 7 of 62

GCA AMR Issues (9/13-17) - Open Issue ID NRC Issue Description Actions Taken Date Inspector Identified LRA Section Table 3.5.1.A Thursday, March 03, 2005 Page 8 of 62

GCA AMR Issues (9/13-17) - Open Issue ID NRC Issue Description Actions Taken Date Inspector Identified 17 Woodfield The applicant states in the discussion for table 3.5.1.A item number 3.5.1.A-17 that cracking from Vent line bellows, vent line headers and downcomers at NMP1 are cyclic loading and crack initiation and growth from SCC is not applicable for steel elements: vent line not subjected to conditions that cause cracking due to cyclic 09/10/2004 bellows, vent headers, and downcomers at NMP Unit 1. The applicant then gives reasons why it loading and crack growth due to stress corrosion cracking. Three believes these aging effects are not applicable. The GALL report specifies the Containment Inservic reasons are stated as to why NMP1 does not consider cracking fo Inspection (IWE) and containment leak rate test (Appendix J) aging management programs to cyclic loading & crack initiation and growth from SCC an applicable manage the cracking of these components. However, Containment ISI and Leak rate testing may n aging effect/mechanism:

be sufficient to detect cracks and therefore, the GALL recommends further evaluation of these programs to manage cracking of components due to cyclic loading or SCC. The project team believ 1. Maximum Operating Temperature is insufficient to allow the that an aging management evaluation should be provided in table 3.5.2.A (table 2) for these magnitude of thermal cycles necessary for cracking due to cyclic components and the table 1 line item 3.5.1.A-17 discussion should state consistent with GALL with loading (fatigue).

exception. The discussion provided is applicable as an evaluation of the two programs ability and The liner reinforcement at all penetrations meets the requirements need to detect the aging effect of cracking from cyclic loading and SCC. Explain how extensive the of the ASME Boiler and Pressure Vessel Code,Section III, Class B use of vent line bellows is for the primary containment structure and the different materials used for vessels. Penetration design and materials conform to the these bellows. Provide the environment (temperature, pressure, humidity, presence of aggressive requirements of the ASME Boiler and Pressure Vessel Code, agents) to which vent line bellows, vent headers and downcommers are exposed, both on a continu Section III, Nuclear Vessels. The piping is anchored at the basis and on a periodic or intermittent basis. penetration sleeves, and the anchorage restraint forces and moments were included in the design of the sleeve anchorage. Th temperature of the penetration sleeve at its attachment weld to the liner does not exceed 150 deg F under operating conditions. Sleev radiation fins, thermal sleeves, and pipe insulation were employed to maintain this temperature requirement.

2. Vent line bellows are not normally wetted, so they are not susceptible to SCC.

The Primary Containment Aging Management Review verifies that the primary containment vent line bellows are in an air environmen which would preclude them from SCC

3. Other components are low strength carbon/low alloy steel, whic is not susceptible to SCC in the drywell or suppression pool environment.

The Primary Containment Aging Management Review verifies that the primary containment vent line headers and downcomers are lo strength carbon/low alloy steel, which is not susceptible to SCC.

Additionally, Table 1 item number 3.5.1.A-17 is not referenced in any Table 2 for NMP1.

LR Contact Hoppe NRC Tracking Numbe 3.5.1.A-17W1 Assigned Department/ License Renewal Individual Hoppe Issue Status Waiting for NRC

Response

LRA Section Table 3.5.1.A Thursday, March 03, 2005 Page 9 of 62

GCA AMR Issues (9/13-17) - Open Issue ID NRC Issue Description Actions Taken Date Inspector Identified Thursday, March 03, 2005 Page 10 of 62

GCA AMR Issues (9/13-17) - Open Issue ID NRC Issue Description Actions Taken Date Inspector Identified 32 Nguyen NMP credits plant specific Preventive Maintenance Program with enhancements for managing the Table 3.3.1.A, Item Number 3.3.1.A-05 pertains to the external aging effects of certain systems, structures, and components (SCCs) of emergency diesel generato surfaces of carbon steel components of the diesel fuel oil system 09/10/2004 EDGs) . Describe how the enhanced AMP is used to detect aging effects/mechanism of EDG and emergency diesel generator systems. The aging management SSCs. Provide a sample of preventive maintenance procedure for EDGs SSCs to demonstrate how of these diesel generator components is addressed with the the preventive maintenance program is used for managing the aging effects of EDGs SSCs aging. Emergency Diesel Generator System Aging Management Review for NMP1.

As noted in LRA Section B2.1.32 and the Program Attribute Assessment reads "The Preventive Maintenance (PM) Program is an existing plant-specific program which consists of the ten aging management program elements described in Appendix A of NUREG-1800, "Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants" after program enhancement (italicized for emphasis). The PM program encompasses maintenance activities to ensure that SCCs important to safety and reliability are maintained at the quality required to perform their intended functions. The type and frequency of PM tasks are in accordance with vendor recommendations and OE. (Ref. 2)."

Furthermore, as noted in LRA Section B2.1.32, the PM program will be enhanced to "expand the PM Program to encompass activities for certain additional components, identified in the LR AMRs. Explicitly define the aging management attributes, including the systems and the component types/commodities included in the program."

For the NMP1 Emergency Diesel Generator Components (i.e.

carbon steel mufflers, air intakes, piping, exhausts and silencers) that invoke the Preventative Maintenance Program to manage the AERMs of LOM, Activity N-N1PMP-011 is specified. Activity N-N1PMP-011 was created to enhance the program for License Renewal and has yet to be formalized or approved. Therefore, a sample procedure is unavailable at this point in time. The enhanced AMP will detect the aging effects of concern "...by visua inspection and examination of component surfaces for evidence of defects and age-related degradation" (from LRA Section B2.1.32).

LR Contact Nold NRC Tracking Numbe 3.3.1.A-05.DN 1 Assigned Department/ License Renewal Individual Nold Issue Status Waiting for NRC

Response

Thursday, March 03, 2005 Page 11 of 62

GCA AMR Issues (9/13-17) - Open Issue ID NRC Issue Description Actions Taken Date Inspector Identified LRA Section Table 3.3.1.A Thursday, March 03, 2005 Page 12 of 62

GCA AMR Issues (9/13-17) - Open Issue ID NRC Issue Description Actions Taken Date Inspector Identified 40 Woodfield The applicant states in the discussion for table 3.5.1.B item number 3.5.1.B-02 that cracking from Penetration sleeves, penetration bellows, and dissimilar metal cyclic loading and crack initiation and growth from SCC is not applicable for penetration sleeves, welds at NMP2 are not subjected to conditions that cause cracking 09/13/2004 penetration bellows, and dissimilar metal welds at NMP Unit 2. The applicant then gives reasons w due to cyclic loading and crack growth due to stress corrosion it believes these aging effects are not applicable. The GALL report specifies the Containment cracking. Three reasons are stated as to why NMP2 does not Inservice Inspection (IWE) and containment leak rate test (Appendix J) aging management program consider cracking for cyclic loading & crack initiation and growth to manage the cracking of these components. However, Containment ISI and Leak rate testing may from SCC an applicable aging effect/mechanism:

not be sufficient to detect cracks and therefore, the GALL recommends further evaluation of these programs to manage cracking of penetrations due to cyclic loading or SCC. The project team believ 1. Maximum Operating Temperature is insufficient to allow the that an aging management evaluation should be provided in table 3.5.2.B (table 2) for these magnitude of thermal cycles necessary for cracking due to cyclic components and the table 1 line item 3.5.1.B-02 discussion should state consistent with GALL with loading (fatigue).

exception. The discussion provided is applicable as an evaluation of the two programs ability and Penetration design and materials conform to the requirements of need to detect the aging effect of cracking from cyclic loading and SCC. Explain how extensive the the ASME Boiler and Pressure Vessel Code,Section III, Division 2 use of penetration bellows is for the primary containment structure and the different materials used f The piping is anchored at the penetration sleeves, and the these bellows. Provide the environment (temperature, pressure, humidity, presence of aggressive anchorage restraint forces and moments were included in the agents) to which penetration sleeves, penetration bellows, and dissimilar metal welds are exposed, design of the sleeve anchorage. The temperature of the penetratio both on a continuing basis and on a periodic or intermittent basis. sleeve at its attachment weld to the liner does not exceed 200 deg F under operating conditions. Sleeve radiation fins, thermal sleeves, and pipe insulation were employed to maintain this temperature requirement.

2. Stress corrosion cracking requires a moist environment.

Stainless steel penetrations in the drywell are not exposed to significant moisture. Stainless steel penetrations in the suppression pool may be wetted, but are at a lower temperature

(<110 deg F).

The Primary Containment Aging Management Review verifies that the drywell penetrations are exposed to air, and that the suppression pool penetrations are exposed to low temperature demineralized untreated water.

3. SCC is not an aging effect for stainless steel in treated or demineralized water < 140 deg F.

The Material-Environment White paper details our position that SCC is not an aging effect for stainless steel in treated or demineralized water < 140 deg F.

Additionally, Table 1 item number 3.5.1.B-02 is not referenced in any Table 2 for NMP2.

LR Contact Hoppe NRC Tracking Numbe 3.5.1.B-02W1 Assigned Department/ License Renewal Individual Hoppe Issue Status Waiting for NRC

Response

Thursday, March 03, 2005 Page 13 of 62

GCA AMR Issues (9/13-17) - Open Issue ID NRC Issue Description Actions Taken Date Inspector Identified LRA Section Table 3.5.1.B Thursday, March 03, 2005 Page 14 of 62

GCA AMR Issues (9/13-17) - Open Issue ID NRC Issue Description Actions Taken Date Inspector Identified 47 Woodfield The applicant states in the discussion for table 3.5.1.B item number 3.5.1.B-17 that cracking from Vent line bellows, vent line headers and downcomers at NMP2 are cyclic loading and crack initiation and growth from SCC is not applicable for steel elements: vent line not subjected to conditions that cause cracking due to cyclic 09/13/2004 bellows, vent headers, and downcomers at NMP Unit 2. The applicant then gives reasons why it loading and crack growth due to stress corrosion cracking. Three believes these aging effects are not applicable. The GALL report specifies the Containment Inservic reasons are stated as to why NMP2 does not consider cracking fo Inspection (IWE) and containment leak rate test (Appendix J) aging management programs to cyclic loading & crack initiation and growth from SCC an applicable manage the cracking of these components. However, Containment ISI and Leak rate testing may n aging effect/mechanism:

be sufficient to detect cracks and therefore, the GALL recommends further evaluation of these programs to manage cracking of components due to cyclic loading or SCC. The project team believ 1. Maximum Operating Temperature is insufficient to allow the that an aging management evaluation should be provided in table 3.5.2.B (table 2) for these magnitude of thermal cycles necessary for cracking due to cyclic components and the table 1 line item 3.5.1.B-17 discussion should state consistent with GALL with loading (fatigue).

exception. The discussion provided is applicable as an evaluation of the two programs ability and Penetration design and materials conform to the requirements of need to detect the aging effect of cracking from cyclic loading and SCC. Provide the environment the ASME Boiler and Pressure Vessel Code,Section III, Division 2 (temperature, pressure, humidity, presence of aggressive agents) to which downcommers are The piping is anchored at the penetration sleeves, and the exposed, both on a continuing basis and on a periodic or intermittent basis. anchorage restraint forces and moments were included in the design of the sleeve anchorage. The temperature of the penetratio sleeve at its attachment weld to the liner does not exceed 200 deg F under operating conditions. Sleeve radiation fins, thermal sleeves, and pipe insulation were employed to maintain this temperature requirement.

2. SCC is not considered an aging effect for wrought austenitic stainless steel at temperatures < 140 deg F. Portions of the downcomers that are wetted are < 140 deg F. Other parts of the downcomers are not wetted so are not susceptible to SCC.

The Primary Containment Aging Management Review verifies the environments to which the downcomers are exposed. The Materia Environment White paper details our position that SCC is not an aging effect for stainless steel that is exposed to air.

3. NMP2 does not have vent lines or vent headers.

These components do not exist because NMP2 is a Mark II containment design as stated in the NMP2 USAR.

Additionally, Table 1 item number 3.5.1.A-17 is not referenced in any Table 2 for NMP2.

LR Contact Hoppe NRC Tracking Numbe 3.5.1.B-17W1 Assigned Department/ License Renewal Individual Hoppe Issue Status Waiting for NRC

Response

LRA Section Table 3.5.1.B Thursday, March 03, 2005 Page 15 of 62

GCA AMR Issues (9/13-17) - Open Issue ID NRC Issue Description Actions Taken Date Inspector Identified 62 Hsu Page 3.1-47, 48 Information provided to auditor regarding materials, AMP, and Component: Penetrations environment. No, not all these penetrations are 4 in diameter.

09/13/2004 Please clarify which penetration is carbon or low alloy steel and which penetration is nickel based (The various instrument penetrations and the core dp/liquid poison alloys and which one is WASS. penetration are < 4.) Per p. XI M-24 for NUREG-1801 under the Please clarify which AMP & environment are applied to which penetration. Scope of Program section for the XI.M7 program: The program The BWR SCC program is applicable to all BWR austenitic SS piping that is 4 in. or larger. Are also applies to pump casings, valve bodies and reactor vessel these penetrations 4 in. or larger? attachments and appurtenances, based on this, XI.M7 was applie to these components.

LR Contact Petras NRC Tracking Numbe 3.1.1A-29H1 Assigned Department/ License Renewal Individual Petras Issue Status Waiting for NRC

Response

LRA Section Table 3.1.2.A-1 63 Hsu Page 3.1-50 See attached list. None of the components listed are in a steam Component: thermal sleeves environment.

09/13/2004 GALL IV.A1.4-a identifies high-purity water environment. The applicant identifies treated water or steam environment.

Clarify whether the steam environment applies for this component or not.

LR Contact Petras NRC Tracking Numbe 3.1.1A-32H1 Assigned Department/ License Renewal Individual Petras Issue Status Waiting for NRC

Response

LRA Section Table 3.1.2.A-1 Thursday, March 03, 2005 Page 16 of 62

GCA AMR Issues (9/13-17) - Open Issue ID NRC Issue Description Actions Taken Date Inspector Identified 69 Hsu Page 3.1-58 Information supplied to auditor (GALL spreadsheet). No there is n Component: core shroud support structures cracking in the core support structures.

09/13/2004 Clarify which parts are made from nickel-based alloy and which parts are made of WASS. Is there any existing cracking experience for this plant's core shroud support structures? Steam environme LR Contact Petras NRC Tracking Numbe 3.1.1.A-31H2 Assigned Department/ License Renewal Individual Petras Issue Status Waiting for NRC

Response

LRA Section Table 3.1.2.A-2 Thursday, March 03, 2005 Page 17 of 62

GCA AMR Issues (9/13-17) - Open Issue ID NRC Issue Description Actions Taken Date Inspector Identified 73 Hsu Page 3.1-67 (pumps) Yes, this line refers to pump casings. The NMP1 pump casings do The proper component name is pump casing. The pump casing contains weld, or not? If yes, use not contain welds for other than their interfaces with the suction an 09/13/2004 Code Case N-481 as alternative examination, or not? How to apply BWR SCC to CASS pump casin discharge piping.

Additional Information Required: Response to Request for Additional Information:

Please explain how to apply to BWR SCC to pump casing The NMP1 recirc pump casings are welded to the suction and discharge piping and these welds are part of the BWRSCC program since they are Category A welds under the GL 88-01 requirements.

The pump casings have an aging mechanism of stress corrosion cracking. As noted in LRA section B2.1.6, "The BWR Stress Corrosion Cracking (SCC) Program is an existing program that mitigates intergranular SCC (IGSCC) in stainless steel reactor coolant pressure boundary components." Crediting this program for recirculation pump casings is consistent with GALL item IV.C1.2-b. The "Pumps" Component Type on Page 3.1-67 is, therefore, consistent with this GALL line item as well as Items IV.C1.2-a and IV.C1.2-c. Since NMP is consistent with the GALL Report for aging management of these pumps, this should not be an issue.

Since the BWR SCC Program inspects welds and the only welds associated with these pumps are the welds to the system piping, the ISI Program, which already inspects these pumps, will be added as an AMP.

LR Contact Petras NRC Tracking Numbe 3.1.1.A-23H1 Assigned Department/ License Renewal Individual Petras Issue Status Waiting for NRC

Response

LRA Section Table 3.1.2.A-4 Thursday, March 03, 2005 Page 18 of 62

GCA AMR Issues (9/13-17) - Open Issue ID NRC Issue Description Actions Taken Date Inspector Identified 75 Hsu Page 3.1-75,77 (valves, CASS& WASS, one-time + water chemistry control) NOT of the CRD systems varies by component location.

Provide the normal operating temperature (NOT) information (<212F) for the control rod drive system Temperatures are shown on NMP1 drawing 237E990 CRD 09/13/2004 What is the basis for considering the one-time inspection program manages the cracking for this item Hydraulic System Flow Diagram. Per LRA section B2.1.20 Program activities include visual, volumetric, and other establishe FOLLOW-UP QUESTION RECEIVED ON 10/15: inspection techniques consistent with industry practice to provide a means of verifying that an aging effect is either (1) not occurring, o Page 3.1-103 (valves, cracking, WASS), 3.1-110,111,112,120 (valves), 3.1-118,119 (piping, fitting, (2) progressing so slowly that it has a negligible effect on the pumps) 3.1-74, 75, 77 (valves, cass) intended function of the structure or component. The program also provides measures for verifying the effectiveness of existing AMPs The GALL requires Inservice inspection, water chemistry, and one-time inspection program to If a one-time inspection reveals an aging effect requiring manage these components. management, an evaluation is required to determine the ability of the affected component to perform its intended function(s) during

1) Does applicant actually inspect these components at the time of one-time inspection? If not, the the period of extended operation and any appropriate corrective components do not have any inspection for life and extended period. action.

2) Does applicant have any other means to manage the cracking?

3) Do these components belong to the items of 3.1.1.B-7 (small bore cracking due to IGSCC)? FOLLOW-UP RESPONSE:

4) What is the safety consequence due to the cracking of these components?

5) What is the operating experience? 1) All components in the program will be subject to inspections on a sampling basis as described in the OTI Program PAA, which meets the requirements of GALL Program XI.M32.

2) These components are part of the non-ASME Class portions o the U1 CRD, U2 RVI, U2 Recirc and U2 CRD systems and are specifically excluded from the ISI Program. Therefore, they will be managed per the OTI and Water Chemistry Programs. In the corresponding LRA Table 2 line items, Note 24 is included and specifically states that these components are not included in the IS program.

3) For the U1 CRD components, the corresponding LRA Table 1 line item in 3.1.1.A-07; for U2 RVI and Recirc it is 3.1.1.B-29 and for U2 CRD it is 3.1.1.B-07. In the Discussion column for each of these line items, there are statements addressing these small bore piping and valves and indicate why the OTI program is credited

4) The safety consequences due to cracking in these components are none since these components are part of the non-ASME Class portion of the corresponding systems.

5) Since the One-Time Inspection Program is a new program, there is no associated operating experience. Moreover, since the purpose of the program is simply to confirm that potentially plausible degradation is not occurring, past plant operating experience is not germane.

LR Contact Petras NRC Tracking Numbe 3.1.1.A-29H3 Thursday, March 03, 2005 Page 19 of 62

GCA AMR Issues (9/13-17) - Open Issue ID NRC Issue Description Actions Taken Date Inspector Identified Assigned Department/ License Renewal Individual Petras Issue Status Waiting for NRC

Response

LRA Section Table 3.1.2.A-5 Thursday, March 03, 2005 Page 20 of 62

GCA AMR Issues (9/13-17) - Open Issue ID NRC Issue Description Actions Taken Date Inspector Identified 78 Hsu Page 3.1-79 (nozzle safe ends) Name Number OD ID Environment Provide identification of nozzle safe end and nozzle safe end size GALL IV.A1.4-a identifies reacto CRD Return N10 3 3/4 2.692 Water 09/13/2004 coolant water environment. Explain steam environment is for which nozzle. Explain why not apply RHR/LPCI N6 13 1/4 11 1/2 Water BWR SCC program instead of ASME XI ISI (IWB/C/D) for WASS nozzle safe ends Core Spray N5 & N16 11 3/8 9 5/8 Water Feedwater N4 13 1/4 11.507 Water Follow-up Question Recwived on 10-7: Steam N3 26 7/8 23.647 Steam Recirc Inlet N2 14 1/2 12 Water The applicant responded that all activities of the BWRSCC program are implemented by the XI.M1 Recirc Outlet N1 25 3/8 22 1/16 Water and XI.M2 program at NMPNS as described in Appendix B2.1.6. Core d/p N11 2.454 1.938 Water The draft response of the AMP question 141 states that all the activities of the BWR SCC program Instrument N14 3 1/8 1.938 Water are implemented through NRC GL 88-01 instead of ISI plan. NRC GL 88-01 inspect requirement is not the same as AMP B2.1.1 (ASME Section XI, IWB/C/D program). The NMP AMP B2.1.1 is All activities of the BWR SCC program are implemented by the implemented with RI-ISI. Please clarify this issue with BWR SCC AMP program owner. XI.M1 and XI.M2 program at NMPNS as described in LRA Appendix B2.1.6. The components in question are currently managed by the XI.M1 program so that was assigned.

FOLLOW-UP RESPONSE:

PROGRAM DESCRIPTION from the GALL Report:

GALL Section XI.M7 - BWR Stress Corrosion Cracking "The program to manage intergranular stress corrosion cracking (IGSCC) in boiling water reactor (BWR) coolant pressure boundary piping made of stainless steel (SS) is delineated in NUREG-0313, Rev. 2, and Nuclear Regulatory Commission (NRC) Generic Letter (GL) 88-01 and its Supplement 1. The program includes (a) preventive measures to mitigate IGSCC, and (b) inspection and flaw evaluation to monitor IGSCC and its effects. The staff-approved boiling water reactor vessel and internals project (BWRVIP-75) report allows for modifications of inspection scope in the GL 88-01 program."

Nine Mile Point meets the requirements of the GALL Report for implementation of the BWR SCC Program. The requirements at NMP are maintained within the ISI Program documentation.

At NMP2 the following nozzles are inspected using the GL 88-01 (BWR SCC) requirements: N1, N2, N4, N5, N6, N9 and N16. They are all Category D welds under the GL definition except one N4 weld which is a Category E weld due to a weld overlay repair. The N10 nozzle is not inspected under the GL 88-01 requirements since that line has been cut and capped. The remainder of the nozzles are covered by the ASME code examinations of XI.M1.

LR Contact Petras NRC Tracking Numbe 3.1.1.B-29H1 Thursday, March 03, 2005 Page 21 of 62

GCA AMR Issues (9/13-17) - Open Issue ID NRC Issue Description Actions Taken Date Inspector Identified Assigned Department/ License Renewal Individual Petras Issue Status Waiting for NRC

Response

LRA Section Table 3.1.2.B-1 Thursday, March 03, 2005 Page 22 of 62

GCA AMR Issues (9/13-17) - Open Issue ID NRC Issue Description Actions Taken Date Inspector Identified 79 Hsu Page 3.1-80 (nozzle thermal sleeves) Material information supplied to auditor (via spreadsheet.) All Explain how to apply BWR SCC to the nozzle thermal sleeves. Thermal sleeve is a pipe inside a inspections directed by the BWR SCC program are performed by 09/13/2004 pipe. How to apply UT to thermal sleeves? Provide thermal sleeves identification for different mate the XI.M1 program. These inspections follow all guidelines of the types ASME Section XI code for these components.

FOLLOW-UP QUESTION RECEIVED ON 10/15: According to NER-2M-074 the thermal sleeve welds are inaccessible and engineering evaluation will be requried if any The response states that the thermal sleeve welds are inaccessible and engineering evaluation will indications are found on other (similar) welds.

required if any indications are founds on other similar welds. The response indicates that BWRSCC program can not manage the degradation. Please provide the anticipated plan that should include Feedwater nozzle thermal sleeves are also inaccessible inspection method, frequency. or what type engineering evaluations to address this issue.

FOLLOW-UP RESPONSE:

There are thermal sleeves for the following components: Jet Pumps, Core Spray nozzle, LPCI nozzle, Feedwater nozzle, RHR nozzle, and the CRD Return nozzle.

For the Feedwater nozzle thermal sleeves, no inspections are necessary since the design of this nozzle has been changed per the NUREG-0619 requirements. The nozzle is inspected per the XI.M1 Program.

For the CRD Return nozzle, this line has been cut and capped; therefore, no inspections of the thermal sleeve are necessary, the nozzle is inspected per the XI.M1 program.

Jet pump thermal sleeves are inspected following the BWRVIP-41 guidelines.

For the Core Spray nozzle thermal sleeves inspections follow guidance of BWRVIP-18.

For the LPCI thermal sleeves, guidance of BWRVIP-42 is followed For the RHR and RCS Thermal sleeves, XI.M1 guidance is followed.

LR Contact Petras NRC Tracking Numbe 3.1.1.B-29H2:

Assigned Department/ License Renewal Individual Petras Issue Status Waiting for NRC

Response

Thursday, March 03, 2005 Page 23 of 62

GCA AMR Issues (9/13-17) - Open Issue ID NRC Issue Description Actions Taken Date Inspector Identified LRA Section Table 3.1.2.B-1 80 Hsu Page 3.1-81 (penetrations) Information supplied to auditor about penetration material types.

Provide penetrations identification for different material types. How to manage the cracking for cast There is no cast iron in the RCS system, see response to issue 4.

09/13/2004 iron component by fatigue monitoring program? Explain GALL consistency LR Contact Petras NRC Tracking Numbe 3.1.1.B-31H1 Assigned Department/ License Renewal Individual Petras Issue Status Waiting for NRC

Response

LRA Section Table 3.1.2.B-1 83 Hsu Page 3.1-84,85 (vessel welds (including attachment welds)) Information provided to auditor. See issue number four regarding Provide weld identification for different material types. How to manage cracking for cast iron cast iron. There is no Cast Iron in the RCS.

09/13/2004 component which is not a GALL RCS material? Explain GALL consistency.

LR Contact Hoppe NRC Tracking Numbe 3.1.1B28H1 Assigned Department/ License Renewal Individual Petras Issue Status Waiting for NRC

Response

LRA Section Table 3.1.2.B-1 Thursday, March 03, 2005 Page 24 of 62

GCA AMR Issues (9/13-17) - Open Issue ID NRC Issue Description Actions Taken Date Inspector Identified 84 Hsu Page 3.1-87 (access hole covers) Material information provided to auditor.

Provide access hole cover id for different material types. Describe which part of the BWR VIP 09/10/2004 manages this item and how to manage this item. Why does applicant not consider GALL item IV.B1 From NER-2M-078: "When the BWRVIP originally determined the e (Core shroud and core plate alloy 600 Access hole cover) instead of B1.1-f scope of BWRVIP-38, BWR Shroud Support Inspection and Flaw Evaluation Guidelines, Access Hole Cover inspections were not FOLLOW-UP QUESTION RECEIVED ON 10/15: part of the guidelines. On March 2001, however, GE issued SIL 462, Rev.1. This revision changed the recommended inspection The follow-up question is not applied to AMR. The follow-up question applied to AMP (B2.1.8) and intervals for the examinations and recommended UT inspection fo has been sent previously to applicant. The staff expects to see a BWRVIP program and UT plants with NMCA for all configurations except those plants that commitment included in the required program to manage access hole cover. The BWRVIP program have a bolted repair installed. Additionally, while Revision 1 to SIL to manage steam dryer will be implemented prior to extended period of operation. 462 recognizes four separate configurations of AHC design and acknowledges that the susceptibility to IGSCC is different for each configuration, its guidance does not recognize this variance of susceptibility with the exception of allowance for bolted repairs (NMP2, which has a Top Hat design, eliminates crevice conditions and is less susceptible to cracking). Therefore, the industry requested the BWRVIP Assessment Committee to develop inspection and evaluation guidelines for AHCs. The outcome of the October 7-9, 2002 BWRVIP Assessment Committee meeting in San Jose, CA. was:

a. GE was tasked with developing a report that would determine susceptibility of different AHC designs to IGSCC and identify inspection guidelines. Review of crack growth would take into consideration BWRVIP-59 (Crack growth in nickel based alloys) and BWRVIP-60 (Crack growth in low alloy steels). The report prepared by GE for the BWROG (GE-NE-523-107-0892, BWR Access Hole Cover Radial Cracking Evaluation) will be used as a guidance document.

B. EPRI will develop and qualify UT inspection techniques for inspection of the Access Hole covers.

C. A separate document for AHC Inspection and Flaw Evaluation will be prepared by the BWRVIP.

Table 1 of Attachment 1 identifies inspection requirements for the Access Hole Covers. Attachment 2 provides sketches of the Access Hole Covers. Visual inspection (EVT-1) of the Access Hole Covers was performed during RF08. No anomalous conditions were noted. It is recommended that future inspections be performed using the UT method. BWRVIP guidance shall be utilized as and when it becomes available."

These components are managed at NMP by the XI.M9 program; therefore, they were assigned to GALL row IV.B1.1-f.

Thursday, March 03, 2005 Page 25 of 62

GCA AMR Issues (9/13-17) - Open Issue ID NRC Issue Description Actions Taken Date Inspector Identified FOLLOW-UP RESPONSE:

NMP will continue to follow the preliminary industry guidelines described above until the aging of the access hole covers has bee formally addressed by the BWRVIP Committee. At that time, NMP intends to incorporate such guidance into the BWRVIP program and follow the recommended NDT procedures.

LR Contact Petras NRC Tracking Numbe 3.1.1B-31H1 Assigned Department/ License Renewal Individual Petras Issue Status Waiting for NRC

Response

LRA Section Table 3.1.2.B-2 85 Hsu Page 3.1-87 (CRD assembly) Page 3.1-88 (core plate & bolts, and supports)3.1-89 (core shroud)3. In general all of those components are in a treated water 91(core spray lines & spargers),3.1-93,94,95 (jet pump assemblies, LPCI couplings, orificed fuel environment. The inside of the BWR vessel is a saturated system 09/13/2004 supports) and there may be areas where a steam/water mixture exists. Per GALL identifies high purity water environment. The applicant identifies treated water or steam. the Material/Environment White paper there is no difference in Clarify whether the steam environment applies for this component or not AERMs between water and steam for the TWH (Treated Water or Steam, Temperature Greater Than Or Equal To 482 deg F) or TWHI (Treated Water or Steam, High Temperature, Neutron Fluence Less Than 5E20 n/sq. cm - BWR Reactor Vessel Internals) environment.

LR Contact Petras NRC Tracking Numbe 3.1.1.B-31H2 Assigned Department/ License Renewal Individual Petras Issue Status Waiting for NRC

Response

LRA Section Table 3.1.2.B-2 Thursday, March 03, 2005 Page 26 of 62

GCA AMR Issues (9/13-17) - Open Issue ID NRC Issue Description Actions Taken Date Inspector Identified 86 Hsu Page 3.1-88 (control rod guide tube) 3.1-93 (jet pump assemblies GALL item IV.B1.4-c), 3.1-95 ( Per the guidance of BWRVIP-47 neutron embrittlement is not an orificed fuel supports GALL item IV.B1.5-a) AERM for the OFS or CRGT. (Section 2.2.3). The same is true 09/10/2004 CASS material exposed to high temperature & radiation should consider loss of fracture due to for the Jet Pump assemblies (per section 2.2.3 of BWRVIP-41.)

thermal aging & neutron irradiation embrittlement. Why does applicant not address this issue?

FOLLOW-UP RESPONSE:

FOLLOW-UP QUESTION RECEIVED ON 10/13:

The BWRVIP action item requirements will be addressed in a The applicant has to complete the action items described in the LR FSER to rely on this BWRVIP. separate LRA Supplemental Letter. For BWRVIP LR plant specific Please provide the information described in the LR FSER. The paragraph from the LR SER is listed actions that each applicant has to implement prior to entry into the below: PEO, these actions have not yet been developed but will be developed and submitted to the NRC prior to entry into the PEO.

Neutron Embrittlement and/or Thermal Embrittlement SUPPLEMENTAL RESPONSE 11/5/04:

The BWRVIP-41 report does not recommend an inspection of cast stainless steel (CASS) jet pump assembly components, stating that CASS components are not susceptible to IGSCC and that the Any developments/improvements by the industry in the neutron fluence in the annulus region is not large enough to cause neutron embrittlement and/or implementation of BWRVIP-41 and/or -47 relative to CASS aging thermal embrittlement. However, the BWRVIP-41 report does not contain any data to indicate the management of the jet pump subcomponents and the orificed fuel threshold for neutron embrittlement and/or thermal embrittlement of CASS and does not identify the supports will be adopted by NMP.

neutron fluence levels the CASS jet pump assembly components are subjected to. The staff notes that neutron embrittlement and/or thermal embrittlement of CASS components becomes a concern The Discussion column of Table 1 Item 3.1.1.A-33 will be revised only if cracks are present in the components. Therefore, if the individual applicant can show that to read, "NMP1 does not have jet pumps. Aging management of cracks have not occurred in the CASS components, then the staff can conclude that loss of fracture the orificed fuel supports is conducted in accordance with toughness resulting from neutron embrittlement and/or thermal embrittlement will not be a significan BWRVIP-47 of the BWR Vessel Internals Program, XI.M9, which aging effect. does not recognize loss of fracture toughness as an aging effect requiring management for the orificed fuel supports."

Further, the BWRVIP and the NRC's Office of Nuclear Regulatory Research (RES) is engaged in a joint confirmatory research program to determine the effects of high levels of neutron fluence on BW The Discussion column of Table 1 Item 3.1.1.B-33 will be revised internals. The results of the joint BWRVIPIRES program into the effects of neutron fluence on BWR to read, "The jet pumps and this aging effect are managed by internals should be considered by the applicant in evaluating the need for additional inspections of BWRVIP-41 of the BWR Vessel Internals Program, XI.M9. Aging CASS jet pump assemblies in the renewal period. This determination by the applicant will allow the management of the orificed fuel supports is conducted in staff to conclude that the applicant has an adequate aging management program for the CASS jet accordance with BWRVIP-47 of the BWR Vessel Internals pump assemblies. Program, XI.M9, which does not recognize loss of fracture toughness as an aging effect requiring management for the orificed It should also be noted that the BWRVIP has stated it intends to revise Section 3.0 of the BWRVIP-4 fuel supports."

report to state that, if a meaningful inspection of components, such as the hidden thermal sleeve welds, can not be obtained after a feasibility study on the development of inspection tooling, the licensee will notify the BWRVIP with sufficient details to support development of alternative actions, such as a flaw tolerance evaluation, and the BWRVIP will notify the NRC.

LR Contact Petras NRC Tracking Numbe 3.1.1.BXXH1 Assigned Department/ License Renewal Individual Petras Issue Status Waiting for NRC

Response

Thursday, March 03, 2005 Page 27 of 62

GCA AMR Issues (9/13-17) - Open Issue ID NRC Issue Description Actions Taken Date Inspector Identified LRA Section Table 3.1.2.B-2 Thursday, March 03, 2005 Page 28 of 62

GCA AMR Issues (9/13-17) - Open Issue ID NRC Issue Description Actions Taken Date Inspector Identified 87 Hsu Page 3.1-89 (core shroud head bolts) The reason different programs are used is that there are actually Describe how to manage the core shroud head bolts with BWRVIP programs. The applicant two different aging mechanisms being managed. One is Cracking 09/10/2004 proposes different program to manage same aging effect for different material type. Please explain due to Fatigue; the other is Stress Corrosion Cracking (Refer to the why applicant used Fatigue monitoring program to manage nickel based alloy and BWRVIP & water response to AMR Issue 1 relative to Cracking due to Fatigue).

chemistry program to manage WASS material type. NBA is not susceptible to SCC. NMPNS implementation of the BWRVIP is described in LRA Appendix B2.1.8.

FOLLOW-UP QUESTIONS SENT ON 10/8:

FOLLOW-UP RESPONSE:

1. BWRVIP-76 does not mention how to manage the core shroud head bolts. Please clarify how to manage core shroud head bolts in detail. Inspection of the shroud head bolts is not required per the

2. Cracking due to fatigue will not be addressed by the fatigue monitoring as agreed in AMR issue BWRVIP I & E Guidelines. Failure consequence is discussed in Please address cracking in locations where crevices are involved for Alloy 600 shroud head bolts an BWRVIP-06-A, Section 3.2.2.

provide aging management program for ALLOY 600 bolts.

GE SIL 433 and SIL 433, Supplement 1, identified industry cracking in shroud head bolts due to crevice-induced IGSCC. The SIL recommended that utilities periodically UT their shroud head bolts. The primary location of cracking in the industry has been jus above the connecting weld of the collar to the shaft, within the crevice formed between the SHB collar and the SHB shaft.

The NMP2 bolts were modified prior to commercial operation to eliminate the creviced weld and add 1/4 inch flow holes in the sleeve to promote water circulation and reduce oxygen concentration. For this reason the NMP-2 bolts are considered resistant to IGSCC and, therefore, the bolts are not ultrasonically examined consistent with the SIL and Cracking is not an AERM fo these components.

Shroud head bolt ultrasonic examinations are not recommended based on the IGSCC resistant features incorporated in the existing installed bolts. However, shroud head bolt visual inspections are performed each refueling outage.

LR Contact Petras NRC Tracking Numbe 3.1.1.B-31H3 Assigned Department/ License Renewal Individual Petras Issue Status Waiting for NRC

Response

LRA Section Table 3.1.2.B-2 Thursday, March 03, 2005 Page 29 of 62

GCA AMR Issues (9/13-17) - Open Issue ID NRC Issue Description Actions Taken Date Inspector Identified 88 Hsu Page 3.1-90 (core shroud support structures) Material/Environment Information provided to auditor. None of the Please identify the subcomponents material types. Provide Environment identification. Which part Core Shroud support components are exposed to steam. Per 09/10/2004 does expose to steam? Describe how to manage WASS material type structures by BWRVIP for GALL row IV.B1.3-a the BWRVIP program is shown as adequate core spray internals (GALL item IV.B1.3-a). to manage SCC in WASS. The BWRVIP program at NMP is described in LRA Appendix B2.1.8.

FOLLOW-UP QUESTION ON 10/14/04:

FOLLOW-UP RESPONSE:

Is the core shroud support structure inspected under BWRVIP-38 or BWRVIP for core spray internals? What is correct vol. 2 item? Yes, the Core Shroud supports are inspected under the BWRVIP-38 as described in NER-2M-075.

The Vol. 2 item for the Core Shroud Supports themselves is IV.B1.1-f for the components that are nickel-based alloys. There are CS components in NMP2 core support structures that have no corresponding GALL Report line item.

LR Contact Petras NRC Tracking Numbe 3.1.1.B-31H4 Assigned Department/ License Renewal Individual Petras Issue Status Waiting for NRC

Response

LRA Section Table 3.1.2.B-2 Thursday, March 03, 2005 Page 30 of 62

GCA AMR Issues (9/13-17) - Open Issue ID NRC Issue Description Actions Taken Date Inspector Identified 89 Hsu Page 3.1-91(differential pressure liquid control line) Augmented UT inspection of the Core DP and Liquid Control (N-Provide this item in applicants ISI plan and describe how to manage this item by the BWRVIP for th 11) nozzle-to-safe end weld 2RPV-KB34 was performed during 09/10/2004 core spray internals. RF08, based on SIL-571 and NMP2 ISI Program plan requirements. A VT-2 examination of nozzle N11 is performed in FOLLOW-UP QUESTION 10/14/04: accordance with procedure N2-OSP-RPV@002, "Reactor Pressure Vessel and all class 1 systems leakage test," during Is the above component inspected under BWRVIP-27 or BWRVIP for core spray internals? What is refueling outages.

correct vol. 2 item?

FOLLOW-UP RESPONSE:

Since NMP2 injects liquid poison through the HPCS line, the only inspection required by the BWRVIP is the ASME Code inspection of the N-11 vessel nozzle assembly. This is the VT-2 inspection referred to above and is performed as part of the RCPB Pressure test under the XI.M1 program.

The GALL item number for the core spray spargers is IV.B1.3.3.

There is no specific GALL Item number for the core plate p/liquid control line.

LR Contact Petras NRC Tracking Numbe 3.1.1.B-31H5 Assigned Department/ License Renewal Individual Petras Issue Status Waiting for NRC

Response

LRA Section Table 3.1.2.B-2 Thursday, March 03, 2005 Page 31 of 62

GCA AMR Issues (9/13-17) - Open Issue ID NRC Issue Description Actions Taken Date Inspector Identified 90 Hsu Page 3.1-92 (flanges) This component does not refer to the core shroud. This line refers Provide this item in applicants ISI plan and describe how to manage this item by the BWRVIP for th to LPCI Coupling support flanges. Per GALL Row IVB1.1-a the 09/10/2004 core shroud. BWRVIP program is adequate to manage the AERM of SCC.

NMP implementation of the BWRVIP program is described in LRA FOLLOW-UP QUESTION RECEIVED ON 10/13: Appendix B2.1.8.

Where are the other components of the LPCI coupling in NMP LRA? In BWRVIP-42 (page A-5) FOLLOW-UP RESPONSE:

states that the following LPCI coupling components/welds need to be addressed with a plant-specifi inspection strategy for license renewal: The AMR of the LPCI Couplings is specifically addressed in Table

• Shroud attachment ring to shroud weld 3.1.2.B-2 on Page 3.1-96 and the line item includes all

• Clamp/bolt assembly subcomponents that make up the LPCI Coupling assembly with th

• Clamp eye bolt to clamp weld exception of the coupling flanges. For some reason, these

• Eye bolt nut to clamp weld coupling subcomponents were identified separately in the NMP2 Please describe how to manage the above items. Master Equipment List (MEL) so they were addressed separately i the AMR and the LRA; therefore, the Component Type identified a "Flanges" on Page 3.1-92 of the LRA applies only to these LPCI Coupling Flanges. To make this clear the Component Type will be changed from "Flanges" to "LPCI Coupling Flanges" and the GALL Volume 2 Item will be changed from "IV.B1.1-a" to "IV.B1.1-g."

Additionally, the bulleted item in the Discussion column of Table 1 Item 3.1.1.B-31 that says "Flanges" will be changed to "LPCI Coupling Flanges." These flanges are addressed in the BWRVIP-42 Program as addressed in NER-2M-083.

The LR-related plant specific requirements of the BWRVIP-42 SER will be addressed in the LRA Supplemental Letter that NMP will be issuing to specifically address all credited BWRVIP LR requirements.

LR Contact Petras NRC Tracking Numbe 3.1.1.B-31H6 Assigned Department/ License Renewal Individual Petras Issue Status Waiting for NRC

Response

LRA Section Table 3.1.2.B-2 Thursday, March 03, 2005 Page 32 of 62

GCA AMR Issues (9/13-17) - Open Issue ID NRC Issue Description Actions Taken Date Inspector Identified 91 Hsu Page 3.1-96 (spray nozzles) There are no Cast Iron materials in the RCS. See Issue 4 Explain GALL consistency for cast iron material in RCS response.

09/13/2004 LR Contact Petras NRC Tracking Numbe 3.1.1.B1-H3 Assigned Department/ License Renewal Individual Petras Issue Status Waiting for NRC

Response

LRA Section Table 3.1.2.B-2 92 Hsu Page 3.1.-96 (peripheral fuel supports) The NMP BWRVIP program is described in LRA Appendix Provide this item in applicants ISI plan and describe how to manage this item by the BWRVIP for B2.1.8. NMPNS has implemented all 09/13/2004 lower plenum. relevant BWRVIP-required inspections as augmented examination through the Inservice Inspection Program (refer to Section B2.1.1)

There are no scheduled inspections for these components per BWRVIP 25 and BWRVIP 47. Engineering review of components required to be inspected per BWRVIP-25 indicated that the Peripheral Fuel Support-to-core plate weld was exempt from inspections (See BWRVIP-25, Table 3-2 and Section 2.2).

LR Contact Petras NRC Tracking Numbe 3.1.1.B-31H7 Assigned Department/ License Renewal Individual Petras Issue Status Waiting for NRC

Response

LRA Section Table 3.1.2.B-2 Thursday, March 03, 2005 Page 33 of 62

GCA AMR Issues (9/13-17) - Open Issue ID NRC Issue Description Actions Taken Date Inspector Identified 93 Hsu Page 3.1-97 (steam dryer) This GALL row was used, per Note D, since the Identify this item in applicants ISI plan and describe how to manage this item by the BWRVIP for co material/environment/AERM and AMP are consistent with that 09/13/2004 shroud(IV.B1.1-a). GALL row. The Steam Dryers are identified in section three (augmented examinations) of the NMP2 ISI program plan. NMP FOLLOW-UP QUESTION RECEIVED ON 10/15: implementation of the BWRVIP program is described in LRA Appendix B2.1.8.

The follow-up question is not applied to AMR. The follow-up question applied to AMP (B2.1.8) and has been sent previously to applicant. The staff expects to see a BWRVIP program and UT FOLLOW-UP RESPONSE:

commitment included in the required program to manage access hole cover. The BWRVIP program to manage steam dryer will be implemented prior to extended period of operation. The answer regarding the access hole cover is given in Issue 84.

While the steam dryer is not currently addressed in any BWRVIP documents, NMP2 has examined the steam dryer to address SIL 474, SIL 644, and its supplement. NMP2 continues to inspect the steam dryer in accordance with these SILs and under the ISI Program Plan for ASME Section XI examination, Category B-N-1.

NMP2 plans to commit to the industry resolution for managing the aging of the steam dryer through the BWRVIP Program, once it is approved by the NRC. The LRA, AMR, and PAA will be revised accordingly.

LR Contact Petras NRC Tracking Numbe 3.1.1.B-31H8 Assigned Department/ License Renewal Individual Petras Issue Status Waiting for NRC

Response

LRA Section Table 3.1.2.B-2 Thursday, March 03, 2005 Page 34 of 62

GCA AMR Issues (9/13-17) - Open Issue ID NRC Issue Description Actions Taken Date Inspector Identified 94 Hsu Page 3.1-98 , 3.1-104(closure bolting) The GALL report indicates loss of preload caused by the GALL identifies Bolting integrity AMP to manage the aging of loss of material. Bolting integrity mechanism of stress relaxation is an aging effect for closure boltin 09/13/2004 program contains following 3 elements: 1) the use of lubricants and sealants 2) torque activities 3) associated with the reactor vessel, reactor vessel internals, and th detection of aging effect with ASME Section XI. Provide justification to address first 2 elements or reactor coolant pressure boundary. The GALL describes the any other means were used to address the other 2 elements. Why does applicant not consider the environment for these bolts as "Air With a Metal Temperature Up t loss of preload aging effect for this item? 288°C (550°F)". NMP does not identify loss of preload due to stress relaxation, or any other mechanism, as an aging effect requiring management for the corresponding components (i.e.,

reactor vessel, internals, or reactor coolant pressure boundary bolting).

NMP found that loss of preload due to stress relaxation is not an aging effect that requires management except for reactor internals that are exposed to high neutron fluence. The primary reasons for this judgment are as follows:

1) While the preload in a bolted joint does decrease after the initia torquing of the bolt, this is primarily a short-term effect. Long term stress relaxation due to creep is not a significant aging effect for bolts at primary system temperatures.

2) Compilations of industry experience with bolting failures find few or no incidents of bolt leakage attributed to loss of preload due to stress relaxation. Also a search of NMP plant-specific experience found no incidents of bolted joint leakage attributable to loss of preload due to stress relaxation.

3) Loss of preload of a bolted joint would cause leakage, resulting general corrosion of the fastener and/or cracking due to fatigue.

Both loss of material due to general corrosion and crack initiation and growth due to fatigue are aging effects that are managed for the closure bolting components at NMP. Stress corrosion cracking caused by improper lubricants or any other cause would be detected by the ASME Section XI Inservice Inspection Program, which applies to all the subject bolting.

4) Specification of proper preload and proper lubricants for a bolted joint is a design issue. Proper joint design and maintenance practices during torquing should ensure that the probability of loss of preload is minimized.

5) Any design deficiency of bolted joints in RV internals applications with low neutron fluence values will be detected during ten-year ISIs. Any loss of preload due improper design considerations would be addressed at that time Thursday, March 03, 2005 Page 35 of 62

GCA AMR Issues (9/13-17) - Open Issue ID NRC Issue Description Actions Taken Date Inspector Identified Supporting information for these points is provided below.

1) While the preload in a bolted joint does decrease after the initia torquing of the bolt, this is primarily a short-term effect. Long term stress relaxation due to creep is not a significant aging effect for bolts at primary system temperatures.

Creep in metallic materials typically is insignificant below one-third to one-half the melting temperature ' of the alloy. For low alloy steels, the elevated temperature regime, in which creep becomes significant, begins at around 0.36 Tm or 700°F, and 0.49 Tm (1000°F) for austenitic iron-base high temperature alloys (Reference 1). By contrast, the maximum temperature NMP primary systems closures bolting could be exposed to is about 550°F. A study of stress relaxation in Type 304 bolting described in Reference 2 found that stress relaxation essentially saturates after 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> in bolted joints exposed to temperatures of 900°F and below. The maximum amount of stress relaxation was 8%.

This type of stress relaxation is accounted for in the design of bolted joints.

EPRI TR-104213, "Bolted Joint Maintenance and Application Guide, (Reference 3)" indicates relaxation of fastener gasket and flange stress, which occurs throughout the joint life, is a possible cause of leaks. However, the detailed discussion of relaxation effects indicates permanent set of the gasket is the primary cause for relaxation of the joint. Gaskets are not considered long-lived components for license renewal purposes. Long-term, ongoing stress relaxation therefore not due to the long-lived passive components of the joint, such as the bolt. Relaxation due to permanent set of the gasket is likely to be much more significant than relaxation due to the small, insignificant amount of creep to be expected in the bolt.

2) Compilations of industry experience with bolting failures find few or no incidents of bolt leakage attributed to loss of preload due to stress relaxation. Also a search of NMP plant-specific experience found no incidents of bolted joint leakage attributable to loss of preload due to stress relaxation.

Table 1-1, Volume 1, EPRI NP-5769, "Degradation and Failure of Bolting in Nuclear Power Plants (Reference 4)," provides a summary of bolting failures. Loss of preload was not a contributing factor to the failures of reactor coolant pressure boundary bolting.

The majority of reactor coolant pressure boundary failures were du to boric acid corrosion, with a few due to stress corrosion cracking The same reference also provides details on the contributing Thursday, March 03, 2005 Page 36 of 62

GCA AMR Issues (9/13-17) - Open Issue ID NRC Issue Description Actions Taken Date Inspector Identified factors to these failures. For boric acid corrosion failures, gasket leakage was the primary contributing factor to most of the failures.

Boric acid leakage is not a concern for the reactor coolant pressure boundary at NMP, because reactor water is not borated. However bolted joint leakage could contribute to general corrosion. For the stress corrosion cracking failures, excessive preload, improper lubricants, or improper heat treatment of the material were contributing factors. The only fatigue failures documented were in reactor internals bolting; improper torque (which could lead to loss of preload) was implicated in only one of three failures. NMP does consider loss of preload for reactor internals bolting exceeding 5x1020 n/cm2 an aging effect requiring management.

NUREG-1339, "Resolution of Generic Safety Issue 29: Bolting Degradation or Failure in Nuclear Power Plants," summarized the NRCs examination of bolting failures from 1964 through the early 1980s. Common characteristics included high sustained tensile stresses, out-of specification pretorquing, an aqueous environmen caused by high humidity, primary and borated water leakage, and materials that were overly hard and out of specification. The most frequently observed failure mode for the structural bolting was SCC. Pressure retaining bolting failed due to corrosion wastage.

3) Loss of preload of a bolted joint would cause leakage, resulting in general corrosion of the fastener and/or cracking due to fatigue.

Both loss of material due to general corrosion and crack initiation and growth due to fatigue are aging effects that are managed for the closure bolting components at NMP. Stress corrosion cracking caused by improper lubricants or any other cause would be detected by the ASME Section XI Inservice Inspection Program, which covers all the subject bolting.

The subject bolts fall into three different material groups: 1) Carbon or Low Alloy Steel, yield Strength 100ksi (CLASG) 2) Martensitic Precipitation Hardening, and Superferritic Stainless Steels (MPS),

and 3) Wrought Austenitic Stainless Steels (WASS). The environment group assigned to all of the subject bolts is "Closure bolting in Non-Borated Water Systems with Operating Temperatures 212°F." This environment does not assume joint leakage is occurring, thus the bolts are not exposed to a wetted environment. Therefore, stress corrosion cracking (SCC) is not an aging effect requiring management for the material group CLASG, although this material could suffer SCC if exposed to high-temperature fluid. General corrosion is managed by the ASME Section XI inservice Inspection (Subsections IWB, IWC, and IWD)

Program for CLASG bolts; the other material groups are not susceptible to general corrosion. Although the assigned Thursday, March 03, 2005 Page 37 of 62

GCA AMR Issues (9/13-17) - Open Issue ID NRC Issue Description Actions Taken Date Inspector Identified environment group assumes general corrosion is caused by the humidity present in normal air, the ASME Section XI program woul detect general corrosion caused by a leaking joint. Although not credited in the LRA for managing cracking of closure bolting in the CLASG material group, the ASME Section XI inservice Inspection (Subsections IWB, IWC, and IWD) Program also requires volumetric examination of bolting greater than 2 inches in diamete which would detect cracking due to any cause (fatigue, SCC, etc.)

ASME Section XI requires a visual VT-1 examination on bolting 2 inches and less in diameter which would also detect cracking.

MPS bolts are considered particularly susceptible to SCC and therefore can experience SCC in high temperature moist environments without the presence of aggressive contaminants.

Therefore, the ASME Section XI inservice Inspection (Subsections IWB, IWC, and IWD) Program is credited with managing SCC for MPS bolts. For all three material groups, crack initiation and growth is considered an AERM that is managed by the Fatigue Monitoring Program (FMP). For the WASS bolts, cracking due to the mechanism of fatigue is the only aging effect requiring management. Generally, the bolts and the bolted connection woul not be the bounding component with respect to fatigue usage in th overall components (for example, the reactor vessel). Since loss o preload could result in higher alternating stress on the bolts, actua fatigue usage for the bolts could increase. For this reason, the bolting components should credit the ASME Section XI inservice Inspection (Subsections IWB, IWC, and IWD) Program in addition to the FMP for management of cracking.

Although only the Fatigue Management Program is credited in the LRA with managing cracking, these bolts also are inspected under ASME Section XI Inservice Inspection (Subsections IWB, IWC, and IWD) Program which would detect cracking due to any cause (SCC, fatigue, etc.).

Therefore, the significant aging effects that would result from loss of preload, crack initiation and growth due to fatigue, and loss of material due to general corrosion, are managed for the subject bolting.

4) Specification of proper preload and lubricants for a bolted joint is a design issue. Proper joint design and maintenance practices during torquing should ensure that the probability of loss of preload is minimized.

Standard Design Specification SDS-006, "Bolt Torque Requirements (Reference 6)," provides guidelines for determining bolt torques, which control preloads. This specification is Thursday, March 03, 2005 Page 38 of 62

GCA AMR Issues (9/13-17) - Open Issue ID NRC Issue Description Actions Taken Date Inspector Identified referenced by mechanical maintenance procedures at NMP1 and NMP2. Mechanical maintenance procedures at NMP specify approved lubricants to be used on fasteners.

Existing programs that are credited with managing aging are adequate for managing the significant aging effects that could result from loss of preload of bolted joints. Loss of preload would be detected and corrected if joint leakage or cracking were found.

References

1) "Elevated Temperature Failures," p. 263-297 in ASM Handbook, Volume 11 - Failure Analysis and Prevention, 1986, ASM International, Metals Park Ohio

2) "Materials Reliability Program Technical Basis Document Concerning Irradiation-Induced Stress Relaxation and Void Swelling in Pressurized Water Reactor Vessel Internals," MRP-50; 1000970, Interim Report, October 2001, Electric Power Research Institute, Palo Alto, CA

3) EPRI TR-104213, "Bolted Joint Maintenance and Application Guide," Final Report, December 1995, Electric Power Research Institute, Palo Alto, CA

4) NUREG-1339, "Resolution of Generic Safety Issue 29: Bolting Degradation or Failure in Nuclear Power Plant," June 1990, USNR

5) EPRI NP-5769, "Degradation and Failure of Bolting in Nuclear Power Plants," Volumes 1 and 2, April 1988, Electric Power Research Institute, Palo Alto, CA

6) Nine Mile Point Nuclear Station Standard Design Specification SDS-006, "Bolt-Torque Requirements for Unit 1 and Unit 2,"

Revision 2 Issued 2/20/2004 LR Contact Petras NRC Tracking Numbe 3.1.1.B-26 Assigned Department/ License Renewal Individual Petras Issue Status Waiting for NRC

Response

LRA Section Table 3.1.2.B-3 Thursday, March 03, 2005 Page 39 of 62

GCA AMR Issues (9/13-17) - Open Issue ID NRC Issue Description Actions Taken Date Inspector Identified 95 Hsu Page 3.1-98 (condensing chambers) They are small bore and class one; therefore they are treated per Identify this item in applicants ISI plan. GALL row IVC1.1-i. They are tested as part of the ISI Pressure 09/13/2004 Testing program.

LR Contact Petras NRC Tracking Numbe 3.1.1.B-07H1 Assigned Department/ License Renewal Individual Petras Issue Status Waiting for NRC

Response

LRA Section Table 3.1.2.B-3 96 Hsu Page 3.1-99,118,119 (PIPING & FITTING),3.1-114 (accumulators), 3.1-115 (CRD hydraulic control See response to ID # 4:

units),

09/13/2004 Provide GALL consistency for cast iron in RCS. There are no cast iron components in this system.

(b) The Material column in the tables in section 3 of the NMP 1 and NMP 2 LRA identifies generic material types as evaluated in the Material & Environment White Paper. This type is identified i the AMR as CLASSL: Carbon or Low Alloy Steel (Yield< 100ksi) or Ductile/Malleable Cast Iron The LRA table will be revised to remove Ductile/Malleable Cast Iro if the ductile cast iron is not present.

LR Contact Hoppe NRC Tracking Numbe 3.1.1.B-07H2 Assigned Department/ License Renewal Individual Hoppe Issue Status Waiting for NRC

Response

LRA Section Table 3.1.2.B-3 Thursday, March 03, 2005 Page 40 of 62

GCA AMR Issues (9/13-17) - Open Issue ID NRC Issue Description Actions Taken Date Inspector Identified 97 Hsu Page 3.1-102, 109 (restriction orifice) These components can be found on LR-028_c, LR-029_b, and LR Please Identify this item in applicants ISI plan. Please provide geometry/configuration of this item. 029_c. They are small bore and Class one; therefore, they are 09/13/2004 treated per GALL row IV.C1.1-i. They are tested as part of the ISI Pressure Testing program.

LR Contact Petras NRC Tracking Numbe 3.1.1.B-07H3 Assigned Department/ License Renewal Individual Petras Issue Status Waiting for NRC

Response

LRA Section Table 3.1.2.B-3 Thursday, March 03, 2005 Page 41 of 62

GCA AMR Issues (9/13-17) - Open Issue ID NRC Issue Description Actions Taken Date Inspector Identified 98 Hsu Page 3.1-103 (valves, cracking, WASS) 3.1-110 , 3.1-111,112,120(valves), 3.1-118,119 (piping, The NMP XI.M32, One-Time Inspection Program, is described in fitting, pumps) LRA Appendix B2.1.20. These components are located in various 09/13/2004 Explain how the one-time inspection program is credited for this item. Identify this valves function & systems and all form parts of the RCPB. Additionally, these location components are small-bore (less than 4 inches). As noted in GAL Section XI.M32, the One-Time Inspection Program is adequate to FOLLOW-UP QUESTION RECEIVED ON 10/15: manage aging for these types of components.

Page 3.1-103 (valves, cracking, WASS), 3.1-110,111,112,120 (valves), 3.1-118,119 (piping, fitting, The various system boundary drawings included with the LRA pumps) 3.1-74, 75, 77 (valves, cass) show these components.

The GALL requires Inservice inspection, water chemistry, and one-time inspection program to FOLLOW-UP RESPONSE:

manage these components.

See response to Issue 75.

1) Does applicant actually inspect these components at the time of one-time inspection? If not, the components do not have any inspection for life and extended period.

2) Does applicant have any other means to manage the cracking?

3) Do these components belong to the items of 3.1.1.B-7 (small bore cracking due to IGSCC)?

4) What is the safety consequence due to the cracking of these components?

5) What is the operating experience?

LR Contact Petras NRC Tracking Numbe 3.1.1.B-29H1 Assigned Department/ License Renewal Individual Petras Issue Status Waiting for NRC

Response

LRA Section Table 3.1.2.B-3 Thursday, March 03, 2005 Page 42 of 62

GCA AMR Issues (9/13-17) - Open Issue ID NRC Issue Description Actions Taken Date Inspector Identified 99 Hsu Page 3.1-105 (NSR piping, fitting and equipment) The NSR piping, fittings, and equipment in question is all small Is BWR SCC program applicable to all S.S. pipe 4 in. or larger, regardless of code classification? bore; therefore, the BWR SCC Program would not apply for aging 09/13/2004 management.

LR Contact Petras NRC Tracking Numbe 3.1.1.B-XXH2 Assigned Department/ License Renewal Individual Petras Issue Status Waiting for NRC

Response

LRA Section Table 3.1.2.B-4 Thursday, March 03, 2005 Page 43 of 62

GCA AMR Issues (9/13-17) - Open Issue ID NRC Issue Description Actions Taken Date Inspector Identified 100 Hsu Page 3.1-107 (piping & fitting), 3.1-111, 112, 113(valves) At NMPNS, all activities of the BWR SCC program are managed Explain why applicant does not apply BWR SCC program instead of ASME XI, ISI(IWB/C/D). and performed under the ASME XI ISI and the Water Chemistry 09/13/2004 Programs. See LRA Appendix B2.1.6.

FOLLOW-UP QUESTION RECEIVED ON 10/15:

FOLLOW-UP RESPONSE:

The applicant response indicates that at NMPNS, all activities of the BWR SCC program are managed and performed under the ASME XI ISI and the water chemistry program and refers to LRA PROGRAM DESCRIPTION from the GALL Report:

Appendix B2.1.6. However, according to the response for the AMP Issue 148, all activities of the BWR SCC program are managed and performed under the GL 88-01 instead of ASME XI ISI. GALL Section XI.M7 - BWR Stress Corrosion Cracking Please clarify which program is used to manage these components.

"The program to manage intergranular stress corrosion cracking (IGSCC) in boiling water reactor (BWR) coolant pressure boundary piping made of stainless steel (SS) is delineated in NUREG-0313, Rev. 2, and Nuclear Regulatory Commission (NRC) Generic Letter (GL) 88-01 and its Supplement 1. The program includes (a) preventive measures to mitigate IGSCC, and (b) inspection and flaw evaluation to monitor IGSCC and its effects. The staff-approved boiling water reactor vessel and internals project (BWRVIP-75) report allows for modifications of inspection scope in the GL 88-01 program."

Nine Mile Point meets the above requirements of the GALL Report for implementation of the BWR SCC Program. The requirements at NMP are maintained within the ISI Program documentation.

LR Contact Petras NRC Tracking Numbe 3.1.1.B-29H2 Assigned Department/ License Renewal Individual Petras Issue Status Waiting for NRC

Response

LRA Section Table 3.1.2.B-4 Thursday, March 03, 2005 Page 44 of 62

GCA AMR Issues (9/13-17) - Open Issue ID NRC Issue Description Actions Taken Date Inspector Identified 101 Hsu Page 3.1-108, 109(pumps) Pump material information provided to auditor. No, these pumps Did applicant apply Code Case N-481 for CASS pumps? Provide pumps identification for different are not exposed to a steam environment. No, Code Case N-481 is 09/13/2004 material types. Do these pumps expose internally to the steam environment? not applied to these pumps.

LR Contact Petras NRC Tracking Numbe 3.1.1.B-29H3 Assigned Department/ License Renewal Individual Petras Issue Status Waiting for NRC

Response

LRA Section Table 3.1.2.B-4 102 Hsu Page 3.1-120 (valves), 3.1.1-119 (piping 7 fitting) Per the Material-Environment White Paper, Low Flow is defined as How to define low flow? Why does applicant not consider FAC for carbon/low-alloy steel? flow 6 f/s. All components on these two pages are in Low Flow 09/13/2004 environments. As such, FAC is not an AERM.

LR Contact Petras NRC Tracking Numbe 3.1.1.B-XXH3 Assigned Department/ License Renewal Individual Petras Issue Status Waiting for NRC

Response

LRA Section Table 3.1.2.B-5 Thursday, March 03, 2005 Page 45 of 62

GCA AMR Issues (9/13-17) - Open Issue ID NRC Issue Description Actions Taken Date Inspector Identified 117 Saba Table 1 Item 3.3.1.A-2: The Issue has already been comprehensively answered for both a) Explain how preventive maintenance program detects hardening, shrinkage and loss of strength Units NMP1 and NMP2 with the Resolution of LR Inspection Open 09/13/2004 the polymer ducting material. Issue #128 -- Please refer to its Resolution.

b) Provide example(s) of previous detection/inspection performed on these component, material an environmental combination.

c) Explain if any corrective action was performed as a result of the above activities.

LR Contact Nold NRC Tracking Numbe 3.3.1.A-2s1 Assigned Department/ License Renewal Individual Nold Issue Status Waiting for NRC

Response

LRA Section Table 3.3.1.A 118 Saba NMP identifies cracking as an aging effect for the wrought austenitic stainless steel piping and See response to Issue 1 fittings, rupture disc, and heat exchangers. GALL identifies cumulative fatigue damage as the agin 09/13/2004 effect for components that are in the reactor water cleanup and shutdown cooling system. Although cracking initiation and growth occurs due to fatigue aging mechanism, cracking may be initiated by other aging mechanism (e.g., SCC, IGSCC).

a) Clarify that aging effect for these components is cracking due to fatigue.

b) Explain how FPM manages cracking due to fatigue for the above mentioned components.

LR Contact Nold NRC Tracking Numbe 3.3.1.A-03s1 Assigned Department/ License Renewal Individual Nold Issue Status Waiting for NRC

Response

LRA Section Table 3.3.1.A Thursday, March 03, 2005 Page 46 of 62

GCA AMR Issues (9/13-17) - Open Issue ID NRC Issue Description Actions Taken Date Inspector Identified 119 Saba NMP identifies cracking as an aging effect for the wrought austenitic stainless steel heat 1) As documented in the CNS white paper entitled Technical exchangers. This combination of component, material, and aging effect is items in question 3.3.1.A Basis For Material -Environment Group Inputs to the ConRad 09/13/2004 3s1. However, NMP identifies Table 3.3.1-4 item instead of Table 3.3.1-3 item. Explain how this row Database:

item differs from the above mentioned items.

"Stress corrosion cracking (SCC) is the initiation and growth of FOLLOW-UP CLARIFICATION SENT on 10/8: cracks in materials caused by the interaction of an aggressive environment, a susceptible material, and tensile stress.

In LRA Table 3.3.2.A-17, Page 3.3-162, the applicant refers to the Table 1 1.

Item 3.3.1.A-04 and credits fatigue monitoring program, preventive maintenance (PM) program, and 2. Corrosive Environment. SCC cracks initiate by corrosion of the water chemistry control (WCC) program for managing cracking aging effects. metal. The presence of halogens (> 0.15 ppm), oxygen (>0.2 ppm)

1. Explain how PM and WCC programs will manage cracking aging effect for the stainless steel hea or sulfates (> 50 ppb) increases the susceptibility nickel-based exchangers in the reactor water cleanup system. Provide documentation or preventive maintenance alloys to SCC. Typically, such concentrations of these aggressive procedures to address this item. species are not present in treated water, but have occasionally

2. In Table 3.3.1.A,, item 3.3.1.A-04, the second paragraph of discussion states that NMP1 RWCU been inadvertently introduced. Raw water typically has the heat exchanger components with an aging effect/mechanism of cracking due to fatigue are evaluate necessary impurities to cause SCC. Temperatures in excess of in row 3.3.1.A-03 and other heat exchanger components either consist of a different material or have 140°F are usually required to produce SCC.

no aging effect. Please provide justification for this paragraph. 3. "

Note: The fatigue TLAA does not perform fatigue crack growth evaluation. Explain the second sentence of this paragraph. As documented in the Aging Management Review Details Report o the Reactor Water Cleanup System (CU) Aging Management Review for NMP1, the Water Chemistry Control Program uses activity N1-CSP-D100 (i.e. plant procedure entitled "Reactor Coolant Chemistry") to prevent a corrosive environment by limiting conductivity, chlorides and sulfates of/in the reactor coolant to threshold values. Succinctly, activity N1-CSP-D100 is employed to mitigate the effect of a potentially corrosive environment.

As documented in the Aging Management Review Details Report o the Reactor Water Cleanup System (CU) Aging Management Review for NMP1, the Preventive Maintenance Program specifies new activity N-N1PMP-013. This activity has yet to be formalized, approved and incorporated into plant maintenance practices. Upon further evaluation it has been determined to change the AMP for the management of the stress corrosion cracking (SCC) for the Wrought Austenitic Stainless Steel (WASS) heat exchanger subcomponents. The One-Time Inspection Program and new activity N-OTI-032 will be used instead of the Preventative Maintenance Program and activity N-N1PMP-013. This new activit has yet to be formalized, approved and incorporated into plant maintenance practices. Therefore, no documentation of condition monitoring with respect to stress corrosion cracking (SCC) for the Wrought Austenitic Stainless Steel (WASS) heat exchangers of the Reactor Water Cleanup System can be provided at this time.

The Aging Management Review Details Report of the Reactor Water Cleanup System (CU) Aging Management Review for NMP will be revised to make this AMP change. Note: LRA Table 3.3.2.A 17 also identifies NUREG-1801 Volume II Item VII.E3.3-d as the Thursday, March 03, 2005 Page 47 of 62

GCA AMR Issues (9/13-17) - Open Issue ID NRC Issue Description Actions Taken Date Inspector Identified correct Item number for the Non-Regenerative Heat Exchangers.

This is wrong and will be changed to Item number VII.E3.4-a. Item VII.E3.3-d corresponds to the Regenerative Heat Exchangers.

2) Further review of the plant operating parameters (Reference N1 OP-3 ) for the reactor water side of NMP1 RWCU non-regenerative heat exchangers (versus regenerative as specified before) indicates that Treated Water, Temperature < 212°F But 140ºF (TWML) is a more precise match than Treated Water, Temperature < 482ºF But 212ºF (TWM) for the environment.

Therefore, the Reactor Water Cleanup System (CU) Aging Management Review for NMP1 will be revised to reflect this. With an environment of TWML, the aging effect of Cracking due to the aging mechanism of Fatigue is no longer relevant to this heat exchanger. Accordingly, LRA Table 3.3.2.A-17 will be revised to reflect the environment of Treated Water, Temperature < 212ºF But 140ºF LR Contact Nold NRC Tracking Numbe 3.3.1.A-04s1 Assigned Department/ License Renewal Individual Nold Issue Status Waiting for NRC

Response

LRA Section Table 3.3.1.A Thursday, March 03, 2005 Page 48 of 62

GCA AMR Issues (9/13-17) - Open Issue ID NRC Issue Description Actions Taken Date Inspector Identified 120 Saba NMP manages cracking of wrought stainless steel heat exchangers in the treated water environmen From Section 2.1.3.2 "Technical Basis For Material-Environment (Table 3.3.2.A-17, page 162) using water chemistry and preventive maintenance program. Provide Group Inputs to the ConRad Database":

09/13/2004 documentation to show how this aging effect is detected, mitigated, and/or monitored by these programs. "Stress corrosion cracking (SCC) is a common aging mechanism for wrought and cast austenitic stainless steels in treated water.

SCC of austenitic stainless steels in treated water may be transgranular (TGSCC) or intergranular. TGSCC typically affects austenitic stainless steels when the environment becomes contaminated with halogens, particularly chloride ions, and oxygen Chloride is usually present in insufficient concentration in both PWR and BWR reactor coolant to cause TGSCC. Action levels for chloride from EPRI guidelines during power operation are 10 ppb (0.01 ppm) for recirculating steam generators [20], 150 ppb (0.15 ppm) for PWR reactor coolant [23], and 200 ppb (0.2 ppm) or less in BWR reactor coolant [24]."

For the wrought austenitic stainless steel (WASS) sub-components of the NMP1 Reactor Water Cleanup System heat exchanger with an environment of "Treated Water or Steam, Temperature < 482ºF But 212ºF" (TWM), the Water Chemistry Control Program will maintain reactor coolant halogens (particularl chloride ions) below the above SCC initiation threshold limits per plant procedure (and Activity) N1-CSP-D100 thereby mitigating SCC. Dissolved oxygen in the reactor coolant is also monitored and maintained per this procedure.

The Preventative Maintenance Program (PMP) will direct inspections that manage the AERM of "Cracking." In particular, new PMP "Activity" N-N1PMP-013 will include inspections for the aging mechanism of stress corrosion cracking in the WASS heat exchanger subcomponents. Therefore, "Activity" N-N1PMP-013 will provide the aging management functions of detection and monitoring. Since this is a new activity yet to be formalized or approved, documentation of previous inspection results are not currently available.

LR Contact Nold NRC Tracking Numbe 3.3.1.A-04s2 Assigned Department/ License Renewal Individual Nold Issue Status Waiting for NRC

Response

LRA Section Table 3.3.2.A-17 Thursday, March 03, 2005 Page 49 of 62

GCA AMR Issues (9/13-17) - Open Issue ID NRC Issue Description Actions Taken Date Inspector Identified Thursday, March 03, 2005 Page 50 of 62

GCA AMR Issues (9/13-17) - Open Issue ID NRC Issue Description Actions Taken Date Inspector Identified 128 Saba a) Identify the type of polymers are used in NMP2 (Ploymers are divided into elastomers and a) The NMP1 ventilation systems subject to aging management plastics.) review include Reactor Building HVAC and Turbine Building 09/13/2004 b) Explain how preventive maintenance program detects hardening, shrinkage and loss of strength HVAC. The four polymer components/subcomponents of the the polymer ducting material. Reactor Building HVAC system are made of neoprene. The C) Provide example(s) of previous detection/inspection performed on these component, material an polymer component and its subcomponent of the Turbine Building environmental combination. HVAC system are made of fiberglass.

D) Explain if any corrective action was performed as a result of the above activities.

The NMP2 ventilation systems subject to aging management FOLLOW-UP QUESTIONS: review include Control Building HVAC and Reactor Building HVAC a) The one polymer component of the Control Building HVAC system

-Fiberglass is not an elastomer. Fiberglass is a man made fiber in which the fiber forming substance is made of neoprene. The ten polymer components of the Reactor is glass. NMP Technical Basis for Material Environment Inputs to the ConRad Database, Section 3. Building HVAC system are made of fiberglass.

states that fiber glass is the most familiar form of fiber-re-enforced plastic (FRP). Note that polymers B) Section 1.2 of the Unit 1 and 2 Preventative Maintenance (elastomers) are described in Section 3.25 of this document. Therefore, aging effects for fiberglass Program Attribute Assessment lists the NMP2 Reactor Building Ducting in air should be evaluated and added to the AMR where applicable for both units. This HVAC (RBAC) System as a system requiring enhanced or new PM combination is not consistent with Tables 3.3.1.A-2 and 3.3.2.B-2 items. activities. The Turbine Building HVAC (TBAC) needs to be added

-Polymer (Neoprene) blowers in the air environment in the NMP1 Reactor Building HVAC system to this list of Unit 1 Systems requiring enhanced or new PM (Table 3.3.2.a-16, Page 3.3-159) refers to Table3.2.1.A-7 as the Table 1 item, and also shows this activities based on below.

combination to be consistent with GALL item V.B.1-b. Explain why polymers in the reactor building HVAC are not evaluated against Table 3.3.1.A-2 Item. For the NMP1 Reactor Building HVAC (RBAC) System, Activity N1 B) MPM-GEN-551 of the NMP1 Preventive Maintenance (PM)

-For fiberglass components in both units, see comments in part (a). Program will be revised to monitor the neoprene expansion joints

-For elastomer components in the air with vibratory emotion in Unit 1, aging effects are loss of for degradation due the AERMs of Cracking, Loss of Strength material due to wear, cracking and hardening and loss of strength due to elastomer degradation and Hardening and Shrinkage. For the NMP1 Turbine Building and hardening and shrinkage due to weathering (Refer to Section 2.2 of the basis document). HVAC (TBAC) System, a new Activity N-N1PMP-016 for the

-For elastomer components in the air in Unit 2, aging effects cracking and hardening and loss of NMP1 Preventive Maintenance (PM) Program has been assigned strength due to elastomer degradation, and hardening and shrinkage due to weathering (Refer to for the development of a procedure that will monitor the fiberglass Section 2.2 of the basis document). expansion joint for degradation due the AERMs of Cracking,

-The above mentioned enhancements/new activities should be added as enhancements/commitmen Loss of Strength and Hardening and Shrinkage.

to LRA Section B2.1.32 and preventive maintenance program basis documents. Section 1.2 of the Unit 1 and 2 Preventative Maintenance Program

-Hardening, loss of strength, and shrinkage cannot be detected by visual inspection only. Describe Attribute Assessment lists both the NMP2 Control Building HVAC how these aging effects will be deterred and monitored by the commitment to the program. (What System (HVC) and the NMP2 Reactor Building HVAC (HVR) methods other than visual inspection e.g., hardness measurement, will be used?) System as systems requiring enhanced or new PM activities.

For the NMP2Control Building HVAC System (HVC), a new Activit N-N2PMP-007 for the NMP2 Preventive Maintenance (PM)

Program has been assigned for the development of a procedure that will monitor the neoprene expansion joint for degradation due the AERMs of Cracking, Loss of Strength and Hardening and Shrinkage. For the NMP2 Reactor Building HVAC (HVR) System a new Activity N-N2PMP-008 for the NMP2 Preventive Maintenance (PM) Program has been assigned for the development of a procedure that will monitor the fiberglass flexible connections for degradation due the AERMs of Cracking, Loss of Strength and Hardening and Shrinkage.

C) Since the plant procedure N1-MPM-GEN-551 needs to be revised and since Activities N-N1PMP-016, N-N2PMP-007 & N-Thursday, March 03, 2005 Page 51 of 62

GCA AMR Issues (9/13-17) - Open Issue ID NRC Issue Description Actions Taken Date Inspector Identified N2PMP-008 are new (i.e. not formalized and approved), it is not possible to provide example(s) of previous detection/inspections performed on these component, material and environmental combinations d) Since the plant procedure N1-MPM-GEN-551 needs to be revised and since Activities N-N1PMP-016, N-N2PMP-007 & N-N2PMP-008 are new (i.e. not formalized and approved), there wer no corrective actions performed as a result of previous monitoring activities.

A) The NMP1 ventilation systems subject to aging management review include Reactor Building HVAC and Turbine Building HVAC. The four polymer components/subcomponents of the Reactor Building HVAC system are made of neoprene. The polymer component and its subcomponent of the Turbine Building HVAC system are made of fiberglass.

The NMP2 ventilation systems subject to aging management review include Control Building HVAC and Reactor Building HVAC The one polymer component of the Control Building HVAC system is made of neoprene. The ten polymer components of the Reactor Building HVAC system are made of fiberglass.

RESOLUTIONS TO FOLLOW-UP QUESTIONS:

a) Fiberglass is a polymer consisting of glass strands in a polymeric base. Fiberglass in air is susceptible to the aging effects of Cracking and Loss of Strength from Section 3.35 and Attachment 1 of the NMP Technical Basis for Material Environmen Inputs to the ConRad Database. Polymers (i.e. elastomers) in air are susceptible to the aging effects of Cracking, Hardening and Loss of Strength and Hardening and Shrinkage. Since the aging effects are different for the same environment, polymers (i.e.

elastomers) and fiberglass will be broken into two separate materia categories in the LRA and in the respective AMR for each system that contains fiberglass. This change will cause of revision to the Turbine Building HVAC System (TBAC) Aging Management Review for NMP1 & LRA Table 3.3.2.A-23 and to the Reactor Building HVAC System (HVR) Aging Management Review for NMP2 & LRA Table 3.3.2.B-23. In addition fiberglass components/subcomponents are found in the NMP1 Circulating Water System and in the NMP2 Condensate System. Accordingly, the Circulating Water System Aging Management Review for NMP1 & LRA Table 3.3.2.A-1 and the Condensate System (CNM)

Aging Management Review for NMP2 & LRA Table 3.4.2.B-2 will also be revised to reflect this change. In addition, LRA Sections 3.3.2.A.1, 3.3.2.A.23, 3.3.2.B.23 and 3.4.2.B.2 will be revised to change Polymers to Fiberglass. With this new divisio Thursday, March 03, 2005 Page 52 of 62

GCA AMR Issues (9/13-17) - Open Issue ID NRC Issue Description Actions Taken Date Inspector Identified of material types, fiberglass (FRP) and polymers (POLY), there is no need to revise Tables 3.3.1.A-2 and 3.3.2.B-2 items.

B) As indicated in the Discussion section of Table Item 3.2.1.A-07, the NMP1 Reactor Building HVAC System performs similar functions to the Standby Gas Treatment System. This is in evidence with the third paragraph of Section 2.3.3.A.18 which reads as follows .

The Reactor Building Emergency Ventilation System removes air from areas where excessive heat concentration and potential airborne contamination exists, maintains a negative pressure in the Reactor Building relative to atmosphere, and removes and filters contaminated air during accident conditions. The Reactor Building Emergency Ventilation System is a standby system consisting of redundant filter trains, which operates in the event of an accident or normal ventilation failure. Emergency ventilation is accomplished by fans that exhaust air from the Reactor Building through a filter bank to the atmosphere through the stack. This system can also be used to process the drywell and torus atmospheres when venting.

These functions are typically associated with the Standby Gas Treatment System and explain why Table Item 3.2.1.A-07 of Table 3.2.1.A was chosen over Table Item 3.3.1.A-02 of Table 3.3.1.A.

Succinctly, it was a more accurate match based on the description of system function.

B) Section 1.2 of the Unit 1 and 2 Preventative Maintenance Program Attribute Assessment lists the NMP1 Reactor Building HVAC (RBAC) System as a system requiring enhanced or new PM activities. The Turbine Building HVAC (TBAC) needs to be added to this list of Unit 1 Systems requiring enhanced or new PM activities based on below.

For the NMP1 Reactor Building HVAC (RBAC) System, Activity N1 MPM-GEN-551 of the NMP1 Preventive Maintenance (PM)

Program will be revised to monitor the neoprene expansion joints for degradation due the AERMs of Cracking, Loss of Strength and Hardening and Shrinkage. For the NMP1 Turbine Building Thursday, March 03, 2005 Page 53 of 62

GCA AMR Issues (9/13-17) - Open Issue ID NRC Issue Description Actions Taken Date Inspector Identified HVAC (TBAC) System, a new Activity N-N1PMP-016 for the NMP1 Preventive Maintenance (PM) Program has been assigned for the development of a procedure that will monitor the fiberglass expansion joint for degradation due the AERMs of Cracking, Loss of Strength and Hardening and Shrinkage.

Section 1.2 of the Unit 1 and 2 Preventative Maintenance Program Attribute Assessment lists both the NMP2 Control Building HVAC System (HVC) and the NMP2 Reactor Building HVAC (HVR)

System as systems requiring enhanced or new PM activities.

For the NMP2Control Building HVAC System (HVC), a new Activit N-N2PMP-007 for the NMP2 Preventive Maintenance (PM)

Program has been assigned for the development of a procedure that will monitor the neoprene expansion joint for degradation due the AERMs of Cracking, Loss of Strength and Hardening and Shrinkage. For the NMP2 Reactor Building HVAC (HVR) System a new Activity N-N2PMP-008 for the NMP2 Preventive Maintenance (PM) Program has been assigned for the development of a procedure that will monitor the fiberglass flexible connections for degradation due the AERMs of Cracking, Loss of Strength and Hardening and Shrinkage.

RESOLUTIONS TO FOLLOW-UP QUESTIONS:

-Further evaluation of the fiberglass component types with respect to the environment invoked in the NMP1 Turbine Building HVAC system LRA Table 3.3.2.A-23 (page 3.3.189) and in the NMP2 Reactor Building HVAC system LRA Table 3.3.2.B-23 (page 3.3-242) warranted no changes to the environments chosen. As documented in the resolution to part a) follow-up questions, the material type will be changed from polymer to fiberglass as appropriate for the systems that contain fiber glass.

-Further review of the Design Investigation Report in the Reactor Building HVAC System (RBAC) Aging Management Review for NMP1 indicates that the neoprene elastomers are expansion joint associated with the Fans FN-202-33 and FN202-53. Therefore, an environment of Air with Vibratory Motion (i.e. AIRV) should have been assigned instead of Air. This AMR and LRA Table 3.3.2.A-16 will be revised to reflect this finding.

-For the neoprene elastomer component (i.e. expansion joint) of th NMP2 Control Building HVAC system, Table 3.3.2.B-9 reads accurately as found in the LRA and agrees with what is found in Attachment 1 Material-Environment Group Analyses of CNS Thursday, March 03, 2005 Page 54 of 62

GCA AMR Issues (9/13-17) - Open Issue ID NRC Issue Description Actions Taken Date Inspector Identified white paper Technical Basis for Material-Environment Group Inputs to the ConRad Database for the material/environment of POLY/AIR. No change is required.

-Since Section 1.2 of the Unit 1 and 2 Preventative Maintenance Program Attribute Assessment lists the NMP1 Reactor Building HVAC (RBAC) System as a system requiring enhanced or new PM activities there is no need to revised this document as a result of revising the RBACs AMR. Since no new component types are being added by the revision to the Reactor Building HVAC System (RBAC) Aging Management Review for NMP1 there is no need to update LRA Section B2.1.32.

• The method of detection of hardening, loss of strength and shrinkage of neoprene elastomers will be determined at the time o program/activity development. Typically in the industry this is performed via a visual inspection and touch test to establish possible hardening and shrinkage. Methodologies of detection other than visual inspections will be explored during activity development.

C) Since the plant procedure N1-MPM-GEN-551 needs to be revised and since Activities N-N1PMP-016, N-N2PMP-007 & N-N2PMP-008 are new (i.e. not formalized and approved), it is not possible to provide example(s) of previous detection/inspections performed on these component, material and environmental combinations d) Since the plant procedure N1-MPM-GEN-551 needs to be revised and since Activities N-N1PMP-016, N-N2PMP-007 & N-N2PMP-008 are new (i.e. not formalized and approved), there wer no corrective actions performed as a result of previous monitoring activities.

LR Contact Nold NRC Tracking Numbe 3.3.1.B-02s1 Assigned Department/ License Renewal Individual Nold Issue Status Waiting for NRC

Response

LRA Section Table 3.3.1.B Thursday, March 03, 2005 Page 55 of 62

GCA AMR Issues (9/13-17) - Open Issue ID NRC Issue Description Actions Taken Date Inspector Identified 139 Patterson Various For a large number of items where the aging mechanism of concern is fatigue, the applican See response to Issue 1 identifies the aging effect as cracking. This is misleading, as cracking maybe the result of several 09/13/2004 different aging mechanisms (e.g., SCC) and fatigue must be considered even in the absence of identified cracks.

LR Contact Hoppe NRC Tracking Numbe 3.2.1.A-01P1 Assigned Department/ License Renewal Individual Hoppe Issue Status Waiting for NRC

Response

LRA Section Table 3.2.1-A 214 Hsu Page 3.1-30, explain/justify the 2nd bullet for GALL row 3.1.1.A-26. (same comment also applies to The LRA will be revised to delete the 2nd bullet. For the 3rd bullet 3.1.1.B-26). Also provide justification for 3rd bullet (loss of preload) and 4th bullet. see issue 7 regarding the justification for not having the aging 09/15/2004 effect of loss of preload. The 4th bullet will be deleted.

Additonal Information Required:

Need to resolve issue 7 on loss of preload Response to Request for Additional Information:

The loss of preload issue will be addressed in response to issue 7 LR Contact Wells NRC Tracking Numbe Assigned Department/ License Renewal Individual Wells Issue Status Waiting for NRC

Response

LRA Section Table 3.1.1.A and Table 3.1.1.B Thursday, March 03, 2005 Page 56 of 62

GCA AMR Issues (9/13-17) - Open Issue ID NRC Issue Description Actions Taken Date Inspector Identified 215 Hsu Page 3.1-30, provide further clarification for GALL row 3.1.1.A-27. (same comment also applies to This comment applies to the NMP Feedwater and Control Rod 3.1.1.B-27) Drive Return Line Nozzles. As noted in BWRVIP-74-A SCC is not 09/15/2004 an AERM for these two components. Thus, the only AERM for FOLLOW-UP QUESTION on 10/14/04: these nozzles is fatigue. This additional information will be added to the discussion column of rows 3.1.1.A-27 and 3.1.1.B-27.

The discussion states that the AERM is not applicable because crack initiation and growth due to cyclic loading (other than fatigue, row 3.1.1.A-01) does not exist at NMP1. FOLLOW-UP RESPONSE:

The applicant responded that as noted in BWRVIP-74-A SCC is not an AERM for these two The NMP1 Feedwater and Control Rod Drive Return Line Nozzles components. Thus the only AERM for these nozzles is fatigue. are inspected under the ISI program as augmented examinations, in compliance with NUREG 0619 (as modified under plant specific The GALL recommended XI.M5, BWR Feedwater Nozzle and XI.M6, BWR CRD return line nozzle SERs for the CRDRLN), Generic Letter 81-11, I&E Bulletin 80-13, programs to manage the cracks. Explain how to use fatigue monitoring program to detection revision 1, Supplement 1 and GE-NE 523-A71-0594. The cracking. Please provide justification for not consider cracking as stated in NMP LRA. requirements of GALL programs XI.M5 and XI.M6 are included wit the NMP1 ISI Plan, and would detect such cracking. The LRA row 3.1.1.A-27 will be revised to clarify this point. NMP is consistent with the GALL Report Programs for these components.

Regarding NMP2, even though cracking of the NMP2 feedwater nozzles has been minimized due to redesign by GE, they are also inspected per the ASME Section XI Code. The potential CRD return line problem has been solved at NMP2 by removing the CR return line and capping the nozzle, thus eliminating temperature transients that caused cracking in other BWR facilities. The LRA row 3.1.1.B-27 will be revised to clarify this point. With the redesigns, NMP2 is still consistent with the requirements of the GALL XI.M5 and M6 Programs. As with NMP1, at NMP2, the GALL Report XI.M5 and M6 Program requirements are captured and addressed in the NMP2 ISI Plan.

LR Contact Wells NRC Tracking Numbe Assigned Department/ License Renewal Individual Wells Issue Status Waiting for NRC

Response

LRA Section Table 3.1.1.A and Table 3.1.1.B Thursday, March 03, 2005 Page 57 of 62

GCA AMR Issues (9/13-17) - Open Issue ID NRC Issue Description Actions Taken Date Inspector Identified 217 Hsu Address the orificed fuel support in the discussion column for GALL row 3.1.1.A-33 The LRA will be revised.

09/15/2004 FOLLOW-UP QUESTIONS SENT ON 10/8: FOLLOW-UP RESPONSE:

The CASS orificed fuel support is exposed under the environment of high temperature treated water NMP aging effect requiring management for reactor vessel or steam with neutron fluence < 5E20 n/cm^2. Clarify why aging of embrittlement due to neuron an internals are consistent with the BWRVIP reports. Specifically, thermal is not considered. BWRVIP-47 provides guidelines for lower plenum components Provide information on this component: including the orificed fuel support (OFS) (Reference 1). BWRVIP-(a) Information on type of casting (i.e; centrifugal or static) 47 has been accepted for referencing in license renewal (b) The composition of CASS (i.e; Molybdenum content and delta ferrite values) applications (Reference 2). Although loss of fracture toughness (c) Previous plant specific experience regarding the cracked components and type and extent of due to thermal plus neutron embrittlement of the OFS could occur, subsequent inspection of CASS components due to neutron and thermal embrittlement. The fluenc it is not an AERM because loss of fracture toughness is not values should be based on the end of the extended period of operation. significant unless a crack is present. Because cracking due to any mechanism is not an AERM for the OFS according to BWRVIP-47 loss of fracture toughness is also not an AERM for the OFS.

A) Material type identification of the NMP1 OFS for license renewal purposes was based on generic industry guidance (BWRVIP-47) (Reference 1). BWRVIP-47 does not indicate whether the OFS is statically or centrifugally cast. This type of casting (complex shape) is typically statically cast.

B) BWRVIP-47 indicates Type CF3 or CF8 are typically used for the OFS, which are low-molybdenum grades. Information on the delta ferrite content is unavailable.

C) NMP1 is following the BWRVIP guidelines which do not require any augmented inspections of the OFS. No cracking of the OFS has been identified during any inservice inspection of the RV References

1. "BWR Vessel and Internals Project, BWR Lower Plenum Inspection and Flaw Evaluation Guidelines (BWRVIP-47)," EPRI TR-108727, December 1997

2. Letter from C.I. Grimes, USNRC, to Carl Terry (BWRVIP Chairman) re: Acceptance for Referencing of Report, "BWR Vessel and Internals Project, BWR Lower Plenum Inspection and Flaw Evaluation Guidelines (BWRVIP-47)," For Compliance With the License Renewal Rule (10CFR Part 54) (TAC No. MA0790),

Dated December 7, 2000 LR Contact Wells NRC Tracking Numbe Assigned Department/ License Renewal Individual Wells Thursday, March 03, 2005 Page 58 of 62

GCA AMR Issues (9/13-17) - Open Issue ID NRC Issue Description Actions Taken Date Inspector Identified Issue Status Waiting for NRC

Response

LRA Section Table 3.1.1.A 222 Hsu Page 3.1-45, provide justification for why loss of material does not apply for GALL row 3.1.1.B-34. The LRA will be revised to provide clarification in the note. Our (Note: on BWR/5 all RPV nozzles except recirculation nozzles are unclad.) results are consistent with BWRVIP-74-A which does not assign 09/16/2004 LOMllGC, PIC, or CRC to the top head or nozzles. The BWRVIPs and their implementation for LR will be addressed in a separate LRA Supplemental Letter.

LR Contact Wells NRC Tracking Numbe Assigned Department/ License Renewal Individual Wells Issue Status Waiting for NRC

Response

LRA Section Table 3.1.1.B Thursday, March 03, 2005 Page 59 of 62

GCA AMR Issues (9/13-17) - Open Issue ID NRC Issue Description Actions Taken Date Inspector Identified 223 Hsu Page 3.1-38, provide justification 2nd paragraph for GALL row 3.1.1.B-08. (cracking applies to both Materials with high yield stress (> 100 Ksi) can exhibit SCC if carbon and stainless steel) combined with an aggressive environment, whereas low strength 09/16/2004 materials such as carbon steels and CLASL do not exhibit SCC because the yield strength of these materials is less than 100 Ksi.

Please also see the response to Issue 1. The LRA note for Item 3.1.1.B-08 will be revised and GALL alignment will be fixed to IV.A1.1-d.

LR Contact Wells NRC Tracking Numbe Assigned Department/ License Renewal Individual Wells Issue Status Waiting for NRC

Response

LRA Section Table 3.1.1.B Thursday, March 03, 2005 Page 60 of 62

GCA AMR Issues (9/13-17) - Open Issue ID NRC Issue Description Actions Taken Date Inspector Identified 224 Hsu Provide further justification for rows 3.1.1.A-22&B-22. The environment in GALL item IV.A.1.1-C The subject GALL item is for Reactor Vessel Closure Studs and identifies environment of air, leaking, BWR reactor coolant water, or steam at 288 degrees C. Nuts. The LRA will be revised to indicate that the environment for 09/16/2004 these bolts is "Closure Bolting for Non-Borated Water Systems With Operating Temperatures 212°F, With Leaking Fluid." In this environment, the material assigned to the closure studs, "Carbon/Low Alloy Steel, Yield Strengths > 100 ksi" will have the aging effect of cracking initiation and growth due to stress corrosion cracking, in addition to crack initiation and growth due to fatigue and loss of material due to general corrosion. Therefore, NMP will be consistent with the GALL item since we identify SCC as an aging mechanism. The "Reactor Head Closure Studs" program will be credited with managing SCC of the studs.

LR Contact Wells NRC Tracking Numbe Assigned Department/ License Renewal Individual Wells Issue Status Waiting for NRC

Response

LRA Section Table 3.1.1.A&B Thursday, March 03, 2005 Page 61 of 62

GCA AMR Issues (9/13-17) - Open Issue ID NRC Issue Description Actions Taken Date Inspector Identified 226 Hsu page 3.1-26 (flange leak detection line) No, RI-ISI has not eliminated this component. This component is page 3.1-52 (top head leak detection line) tested by the ISI pressure test since it is essentially a small-bore 09/17/2004 pipe. At NMP1, it will be part of the One Time Inspection (XI.M32)

Please describe the inspection method for this component. Did the RI-ISI program eliminate this program, too, since the component there is subject to SCC.

component? Did One-Time Inspection program examine this component?

LR Contact Petras NRC Tracking Numbe 3.1.1.A-08H1 Assigned Department/ License Renewal Individual Petras Issue Status Waiting for NRC

Response

LRA Section Table 3.1.A 227 Hsu page 3.1-38 (flange leak detection line) and page 3.1-83 Please provide the AMP information for The NMP Fatigue Monitoring Program is described in LRA managing this cracking. Describe the inspection method for this component. Appendix B3.2. Please also see response to Issue 1 regarding 09/17/2004 Cracking and Fatigue.

FOLLOW-UP QUESTION SENT ON 10/8:

FOLLOW-UP RESPONSE:

GALL recommends plant specific program to manage cracking. Fatigue monitoring program does n manage cracking. Please provide plant-specific program which can manage the aging effect of See response to Issue 223.

cracking and provide justification.

LR Contact Petras NRC Tracking Numbe 3.1.1.B-08H1 Assigned Department/ License Renewal Individual Petras Issue Status Waiting for NRC

Response

LRA Section Table 3.1.B Thursday, March 03, 2005 Page 62 of 62