NRC 2005-0051, Clarification to Information Regarding the Point Beach Nuclear Plant License Renewal Application
| ML051300355 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 04/29/2005 |
| From: | Koehl D Nuclear Management Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| NRC 2005-0051, TAC MC2099, TAC MC2100 | |
| Download: ML051300355 (26) | |
Text
Committed to Nuclear Excellen Point Beach Nuclear Plant Operated by Nuclear Management Company, LLC April 29, 2005 NRC 2005-0051 10 CFR 54 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Point Beach Nuclear Plant, Units 1 and 2 Dockets 50-266 and 50-301 License Nos. DPR-24 and DPR-27 Clarification to Information Regarding the Point Beach Nuclear Plant License Renewal Application (TAC Nos. MC2099 and MC2100)
By letter dated February 25, 2004, Nuclear Management Company, LLC (NMC),
submitted the Point Beach Nuclear Plant (PBNP) Units 1 and 2 License Renewal Application (LRA). On November 16, 2004, the Nuclear Regulatory Commission (NRC) requested additional information regarding 10 CFR 54.4(a)(2), non-safety affecting safety scoping clarifications (Section 2.1 of the LRA). NMC letter to the NRC dated January 31, 2005, provided a response to that request. The Nuclear Regulatory Commission (NRC) staff requested clarification of information regarding previous responses to NRC requests for additional information on the 10 CFR 54.4(a)(2) scoping methodology revision. NMC presented preliminary information with regard to this change in scoping methodology at a February 15, 2005, meeting with the NRC staff.
NMC letter to the NRC dated March 15, 2005, acknowledged that NMC would need to change the methodology for 10 CFR 54.4(a)(2) scoping to the "spaces" approach. The details of the NMC 10 CFR 54.4(a)(2) methodology, including specific exceptions to that methodology for special cases and impact of results on the LRA, are provided in the enclosure to this letter. These clarifications also contain information on results of the scoping of systems, structures and components (SSCs) in accordance with 10 CFR 54.4(a)(2) as well as the results of the Integrated Plant Assessment of those SSCs.
Should you have any questions concerning this submittal, please contact Mr. James E. Knorr at (920) 755-6863.
AC 6590 Nuclear Road
- Two Rivers, Wisconsin 54241 Telephone: 920.755.2321
Document Control Desk Page 2 This letter contains no new commitments and no revisions to existing commitments.
I declare under penalty of perjury that the forgoing is true and correct. Executed on April 29, 2005.
Dennis L. Koehl Site Vice-President, Point Beach Nuclear Plant Nuclear Management Company, LLC Enclosure cc:
Administrator, Region Ill, USNRC Project Manager, Point Beach Nuclear Plant, USNRC Resident Inspector, Point Beach Nuclear Plant, USNRC PSCW
ENCLOSURE CLARIFICATION TO INFORMATION REGARDING POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 LICENSE RENEWAL APPLICATION The following information provides the details of the NMC 10 CFR 54.4(a)(2) methodology, including specific exceptions to that methodology for special cases and impact of results on the Point Beach Nuclear Plant (PBNP) License Renewal Application (LRA). These clarifications also contain information on results of the scoping of systems, structures and components (SSCs) in accordance with 10 CFR 54.4(a)(2) as well as the results of the Integrated Plant Assessment of those SSCs.
The following provides additional information regarding the PBNP LRA.
10 CFR 54.4(a)(2) Scoping Methodology Changes LRA Section 2.1.2.1.2 Non-Safety Related Criteria Pursuant to 10 CFR 54.4(a)(2)
(Criterion 2):
The original scoping process at PBNP for 10 CFR 54.4(a)(2) included evaluating potential effect on vulnerable safety related (SR) components, assuming a finite spray/leakage duration from a failed non-safety related (NSR) system or component (SC). The spray/leakage duration assumed that the spray/leak would be identified by normal work activities within the plant (walkdowns, system parameter changes, sump alarms and trends, etc.). Based on feedback from the staff, NMC is changing the scoping methodology to remove the assumption of leakage duration and to eliminate the limitation of vulnerable targets to only electrical components.
The revised methodology invokes a plant "spaces" approach that assumes a spatial interaction can potentially occur if SR and NSR SCs are located within the same space.
For the purposes of this process, a space is defined by the room in which the SR and NSR components are located. Physical barriers (e.g., walls, ceilings, and floors) enclose the space. This revised methodology evaluates the effect of sprays and leaks on mechanical as well as electrical SR SCs, with no limitation on the duration of the sprays/leaks. NMC considers all liquid or steam bearing NSR SCs to be in the scope of the criterion 10 CFR 54.4(a)(2), provided the NSR SCs are located in the same space as a SR SC and the NSR SCs are in proximity where spray or leakage from the NSR SCs could contact a SR SC.
NMC has re-evaluated the SC at PBNP using the revised 10 CFR 54.4(a)(2) methodology. A number of configurations have been identified where the failure of NSR SCs would not result in the loss of intended function of the SR SCs in the "space."
Page 1 of 24
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The exceptions to the revised methodology follow:
Exceptions
- 1. NSR SCs in containment were not re-evaluated. SR SCs within containment are already evaluated for post-accident environments including spray and/or steam.
As such, the existing current licensing basis (CLB) has addressed the bounding environmental conditions for SR SCs within containment.
- 2. NSR components in rooms or cubicles where there are no SR components do not need to be in-scope. These rooms or cubicles have also been evaluated to ensure that SR piping does not run through them. The following cubicles or rooms have no SR equipment in them, and therefore NSR components in these cubicles or rooms are not in-scope:
- Demineralizer Cubicles and Demineralizer Valve Gallery
- Sump Tank Cubicle
- Gas Stripper Building
- Blowdown Evaporator Building
- Drumming Area
- PAB Truck Bay
- "B" and "C" Hold Up Tank (HUT) Cubicles (See note on "A" HUT in Exception 5)
- Laundry Tank Room
- 3. Only NSR SCs containing liquid or steam are considered to pose any potential for spatial interaction. NSR SCs containing gases (e.g., plant air systems, ventilation systems) pose no potential for aging effects on SR SCs due to leakage of air or gas.
- NSR portions of plant air systems (instrument air, service air) are not in-scope per this exception.
- NSR portions of ventilation systems are not in-scope per this exception.
- NSR portions of systems that are normally vented or connected to the vent header are not in-scope per this exception.
Page 2 of 24
- 4. Abandoned or manually isolated and drained NSR SCs are not considered to pose any potential for aging effects on SR SCs, and therefore do not need to be in-scope.
- NSR glycol drain tank in G-03/G-04 Emergency Diesel Generator Rooms is manually isolated, vented and drained when the engine is operational, and therefore is not in-scope per this exception.
- NSR portions of the Heating Steam system that are isolated and control tagged as abandoned are not in-scope per this exception.
- 5. Spray is not postulated from unpressurized systems, however leakage still is a potential. Leakage can only affect SR SCs that are physically below the unpressurized NSR components. If SR components are above or beside the unpressurized NSR components, the NSR components would not need to be in-scope.
- NSR chemical addition pots in the auxiliary feedwater pump rooms are normally vented and isolated and are mounted near the floor where they cannot leak on any SR equipment; therefore, these chemical addition pots are not in-scope.
- "A" HUT Cubicle has some SR piping that passes through this cubicle and exits the ceiling to supply SR components in a cubicle above. NSR piping that is above or adjacent to this SR piping has been included in-scope, but the HUT tank itself is at very low pressure (normally 2.5 psig) and as such it could not spray on the SR piping, and therefore the "A" HUT is not in scope.
- 6. NSR SCs in large open areas (e.g., turbine building, facade) are eliminated from scope if it can be shown that there is no possible effect on the SR SCs.
- The NSR Reactor Makeup Water (RMW) Tank is on the 6.5' elevation of the facade. This tank is not pressurized. This tank is about 1/3 the size of the Refueling Water Storage Tank (RWST), and therefore is bounded by the flooding analysis that assumed the RWST would fail. There are also two short runs of pressurized pipe (- 5' long) where the pipe exits the adjacent RMW pump room and crosses into the Primary Auxiliary Building (PAB). Intervening structures exist between these pipes and any SR equipment (nearest would be the containment penetrations on 26' elevation). Failure of any of these RMW components on the 6.5' elevation could not affect any SR equipment, and therefore these NSR components are not in-scope.
Page 3 of 24
- SR Crossover Steam Dump components are located within the 66' fan room. SR equipment in the 66' fan room includes SG pressure transmitters and the main steam lines themselves (in the overhead). The transmitters are environmental qualification (EQ) qualified for harsh environment based on main steam line break potential, and this bounds the energy level of the crossover steam dump system by a significant margin. The crossover steam dump components are a minimum of 50' away from SR equipment and failure of these NSR components will not affect the function of these SR components. Therefore, the NSR crossover steam dump components would not be in-scope.
- The SR Main Feedwater Regulating Valves (MFRVs), bypass valves, and associated solenoid operated valves (SOVs), are located on the 26' elevation of the Unit 1/Unit 2 Turbine Building. The safety function is for the MFRVs and bypass valves to close. The SOVs are EQ qualified for harsh environments. The piping on either end of these valves is NSR.
All other equipment on this elevation of the turbine building is NSR.
The only potential failure that could cause a failure of the safety function of these components, would be a flow accelerated corrosion (FAC) failure where a pipe-whip impact could bend the actuator stem and prevent the valve from closing. Simple leakage or spray would not affect the safety function of these valves, as external aging effects would only create fail-safe failures of the SR valves (through-wall leakage would divert flow from SGs which is the fail-safe direction). Therefore, NSR high energy piping sections that pose the potential for pipe-whip on these valves and/or SOVs are included in-scope. Portions of high energy piping that cannot physically reach, or are shielded from, the SR components by structures or other larger piping, are not included in-scope. Major components such as feedwater heaters and the condenser are anchored and do not have the potential for pipe-whip, and therefore are also not included in-scope.
Impact on LRA Results This revised methodology was applied to re-evaluate NSR SCs that are within the scope of the rule. This has led to the expansion of scope for some systems and also to the addition of line items to several tables in the LRA. New tables are required for one additional system (Plant Sampling). This system was already considered to be in-scope and described in LRA Section 2.3.3.14, but the previously identified in-scope SCs were addressed within other systems; therefore new tables in Section 2 and Section 3 were required.
Page 4 of 24
Note that the results of the use of the revised methodology discovered no new aging effects/mechanisms. Aging management program assignments are consistent with those previously identified in the LRA.
The following table provides the results of the scoping evaluation conducted based upon the 10 CFR 54.4(a)(2) methodology previously described:
Table 1: Impact of 10 CFR 54.4(a)(2) Scoping Methodology Changes on LRA Results Results in Results in Results in PBNP LR System Increase in Change to Change to In-Scope Section 2 Section 3 SCs Safety Injection System Yes Yes Yes Containment Spray System Yes Yes Yes Residual Heat Removal System Yes No No Chemical and Volume Control Yes Yes Yes System (CVCS)
Component Cooling Water System Yes No Yes Spent Fuel Pool Cooling System Yes Yes Yes Waste Disposal System Yes Yes Yes Service Water System Yes No No Emergency Power System Yes No No Essential Ventilation System Yes No No Circulating Water System Yes No No Treated Water System Yes Yes Yes Plant Sampling System Yes New table New table Heating Steam System Yes No No Main and Auxiliary Steam System Yes Yes Yes Feedwater and Condensate System Yes Yes Yes For each of these systems, a discussion of the impact of the 10 CFR 54.4(a)(2) scoping methodology changes on the LRA results follows. Only new information is included in the following tables.
Residual Heat Removal Svstem. Service Water Svstem. Emeraencv Power Svstem, Essential Ventilation System, Circulating Water System, and Heating Steam System Based on the scoping methodology previously described, NMC identified NSR components associated with these six systems that are located in the same space as SR SSCs, which are now considered in-scope.- The component types do not change from the component types listed in LRA Tables 2.3.2-3, 2.3.3-5, 2.3.3-7, 2.3.3-8, 2.3.3-1 0, and 2.3.3-12. In addition, there are no changes or additions to the aging management review results presented in LRA Tables 3.2.2-3, 3.3.2-5, 3.3.2-7, 3.3.2-9, 3.3.2-13, and 3.3.2-15.
Page 5 of 24
Safety Injection System NMC identified NSR components within the Safety Injection system that are now considered in-scope for 10 CFR 54.4(a)(2). These components included the normally isolated full flow test'line, which includes level gauges. The piping, pipe components, and valves are already listed in LRA Table 2.3.2-1 and Table 3.3.2-1; however, the level gauges are not. The additions to the LRA Section 2 and Section 3 tables are as follows:
Table 2.3.2-1 Safety Injection System Component Group l
Intended Function LEVEL GAUGES PRESSURE BOUNDARY Table 3.2.2-1 Engineered Safety Features - Safety Injection System - Summary of Aging Management Evaluation NUREG
-1801 Aging Effect Aging Volume Component Intended Requiring Management 2 Line Table Type Function Material Environment Management Programs Item 1 Item Notes Level Gauges Pressure Stainless Indoor-No Air None None Required J
Boundary Steel Conditioning (External)
Treated Water-Loss of Material One-Time V.D1.1-a 3.2.1-15 H, 3 Borated, T<1400F Inspection (Internal)
Program Water Chemistry V.D1.1-a 3.2.1-15 H. 3 Control Program Glass Indoor - No Air None None Required J
Conditioning (External)
Treated Water -
None None Required J
Borated, T<1400F (Internal)
Containment Spray System NMC identified NSR components within the Containment Spray System that are now considered in-scope for 10 CFR 54.4(a)(2). These components included the normally isolated full flow test line, which includes a level gauge. The piping, pipe components, and valves are already listed in LRA Table 2.3.2-2 and Table 3.3.2-2; however, the level gauges are not. The additions to the LRA Section 2 and Section 3 tables are as follows:
Table 2.3.2-2 Containment Spray System Component Group l
Intended Function LEVEL GAUGES PRESSURE BOUNDARY Page 6 of 24
Table 3.2.2-2 Engineered Safety Features - Containment Spray System - Summary of Aging Management Evaluation NUREG
-1801 Aging Effect Aging Volume Component Intended Requiring Management 2 Line Table Type Function Material Environment Management Programs Item 1 Item Notes Level Gauges Pressure Stainless Indoor-No Air None None Required J
Boundary Steel Conditioning (External)
Treated Water -
Loss of Material One-Time V.A.1-a 3.2.1-15 H, 3 Borated, T<1 400F Inspection (Internal)
Program Water Chemistry V.A.1-a 3.2.1-15 H, 3 Control Program Glass Indoor - No Air None None Required J
Conditioning (Extemal)
Treated Water -
None None Required J
Borated, T<1 400F (Intemal)
Chemical and Volume Control System Numerous NSR components within the Chemical and Volume Control System that are located in the general areas of the PAB, namely the Boric Acid Storage Tanks, the Volume Control Tank, and various piping and valves associated with these tanks and other components, are now considered in-scope for 10 CFR 54.4(a)(2). Many of these component types are already listed in LRA Table 2.3.3-1 and Table 3.3.2-1; however, the level gauges are not. Additionally, some new materiaVenvironment combinations were also identified. The additions to the LRA Section 2 and Section 3 tables are as follows:
Table 2.3.3-1 Chemical and Volume Control System Component Group.
Intended Function LEVEL GAUGES PRESSURE BOUNDARY Page 7 of 24
Table 3.3.2-1 Auxiliary Systems - Chemical and Volume Control System - Summary of Aging Management Evaluation NUREG
-1801 Aging Effect Aging Volume Component Intended Requiring Management 2 Line Table Type Function Material Environment Management Programs Item 1 Item Notes Filters/
Pressure Stainless Treated Water-Cracking due to One-Time (V.D1.1-a)
(3.2.1-35, B. 3 Strainers Boundary Steel Borated, T1 400F SCC Inspection 15)
(Internal)
Program Water Chemistry (V.D1.1-a)
(3.2.1-35, B. 3 Control Program 15)
Loss of Material One-Time (V.D1.1-a)
(3.2.1-35, H, 3 Inspection 15)
Program Water Chemistry (V.D1.1-a)
(3.2.1-35, H. 3 Control Program 15)
Level Gauges Pressure Stainless Indoor-No Air None None Required J
Boundary Steel Conditioning (External)
Treated Water -
Loss of Material One-Time (V.D1.1-a)
(3.2.1-35, H. 3 Borated, T<140'F Inspection 15)
(Internal)
Program Water Chemistry (V.D1.1-a)
(3.2.1-35, H. 3 Control Program 15)
Glass Indoor-No Air None None Required J
Conditioning (External)
Treated Water-None None Required J
Borated, Tc1 40'F (Internal)
Pump Casing Pressure Stainless Treated Water -
Loss of Material One-Time J, 5 Boundary Steel Other (Internal)
Inspection Program Water Chemistry J, 5 Control Program Tanks Pressure Carbon/
Indoor-No Air Loss of Material Systems (VII.l.1-b)
(3.3.1-F, 4 Boundary Low Alloy Conditioning Monitoring 05)
Steel (External)
Program Treated Water -
Loss of Material One-Time J, 5 Other (Internal)
Inspection Program Water Chemistry J. 5 Control Program Component Cooling Water System Some NSR components within the Component Cooling Water system that are located in the PAB and facade, namely piping and valves to and from the letdown gas stripper and blowdown evaporator buildings, are now considered in-scope for 10 CFR 54.4(a)(2).
Page 8 of 24
All of the these component types are already listed in LRA Table 2.3.3-2 and Table 3.3.2-2, however a new material/environment combination was identified.
The additions to the LRA Section 3 table are as follows:
Table 3.3.2-2 Auxiliary Systems - Component Cooling Water System - Summary of Aging Management Evaluation NUREG
-1801 Aging Effect Aging Volume Component Intended Requiring Management 2 Line Table Type Function Material Environment Management Programs Item 1 Item Notes Valve Bodies Pressure Copper Indoor - No Air None None Required J
Boundary Alloy (Zn Conditioning
< 15%)
(External)
Treated Water-Loss of Material Closed-Cycle Vll.C2.2-3.3.1-15 F, 5 Other (Velocity)
Cooling Water a
(Internal)
System Surveillance Program One-Time VII.C2.2-3.3.1-15 F. 5 Inspection a
Program Spent Fuel Pool Coolinc Svstem Numerous NSR components within the Spent Fuel Pool Cooling system that are located in the general areas of the PAB, namely piping and valves to/from the spent fuel pool demineralizer and the skimmer pump sub-system, are now considered in-scope for 10 CFR 54.4(a)(2). Many of these component types are already listed in LRA Table 2.3.3-3 and Table 3.3.2-3; however, tanks are not. Additionally, a new materiaVenvironment combination was identified. The additions to the LRA Section 2 and Section 3 tables are as follows:
Table 2.3.3-3 Spent Fuel Cooling System Component Group Intended Function FILTERS/STRAINERS PRESSURE BOUNDARY TANKS PRESSURE BOUNDARY Page 9 of 24
Table 3.3.2-3 Auxiliary Systems - Spent Fuel Cooling System - Summary of Aging Management Evaluation NUREG
-1801 Aging Effect Aging Volume Component Intended Requiring Management 2 Line Table Type Function Material Environment Management Programs Item 1 Item Notes Filters/
Pressure Stainless Indoor - No Air None None Required J
Strainers Boundary Steel Conditioning (External)
Treated Water-Loss of Material One-Time (V.D1.1-(3.2.1-35, H, 3 Borated, T<14 0°F Inspection a) 15)
(Internal)
Program Water Chemistry (V.D1.1-(3.2.1-35, H, 3 Control Program a) 15)
Pump Casing Pressure Stainless Indoor - No Air None None Required J
Boundary Steel Conditioning (External)
Treated Water -
Loss of Material One-Time (V.A.3-a, (3.2.1-35, H, 3 Borated, T<1 40'F Inspection V.D1.2-a) 15)
(Internal)
Program Water Chemistry (V.A.3-a, (3.2.1-35, H, 3 Control Program V.D1.2-a) 15)
Tanks Pressure Stainless Indoor - No Air None None Required J
Boundary Steel Conditioning (External)
Treated Water -
Loss of Material One-Time (V.D1.7-(3.2.1-35, H, 3 Borated, T<14 0'F Inspection b) 15)
(Internal)
Program Water Chemistry (V.D1.7-(3.2.1-35, H, 3 Control Program b) 15)
Waste Disposal System Numerous NSR components within the Waste Disposal system that are located in the general areas of the PAB, namely piping, valves, components associated with the waste liquid portion of this system and the seal water portion of the waste gas compressors, are now considered in-scope for 10 CFR 54.4(a)(2). Many of these component types are already listed in LRA Table 2.3.3-1 and Table 3.3.2-1; however, numerous component types are not. Additionally, some new material/environment combinations were identified. The additions to the LRA Section 2 and Section 3 tables are as follows:
Table 2.3.3-4 Waste Disposal System Component Group Intended Function I
COMPRESSOR CASING PRESSURE BOUNDARY DRAIN TRAPS PRESSURE BOUNDARY FILTERS/STRAINERS PRESSURE BOUNDARY Page 10 of 24
Table 2.3.3-4 Waste Disposal System Component Group Intended Function LEVEL GAUGES PRESSURE BOUNDARY PUMP CASING PRESSURE BOUNDARY RESTRICTING ORIFICES PRESSURE BOUNDARY SIGHT GLASS PRESSURE BOUNDARY TANKS PRESSURE BOUNDARY Table 3.3.2-4 Auxiliary Systems - Waste Disposal System - Summary of Aging Management Evaluation NUREG
-1801 Aging Effect Aging Volume Component Intended Requiring Management 2 Line Table Type Function Material Environment Management Programs Item 1 Item Notes Compressor Pressure Cast Iron Indoor-No Air Loss of Material Systems VI1.1.1-b 3.3.1-05 F, 4 Casing Boundary Conditioning Monitoring (External)
Program Treated Water -
Loss of Material Water Chemistry J, 5 Other (Internal)
Control Program One-Time J, 5 Inspection Program Drain Trap Pressure Stainless Indoor - No Air None None Required J
Boundary Steel Conditioning (External)
Treated Water -
Loss of Material Water Chemistry J, 5 Other (Internal)
Control Program One-Time J, 5 Inspection Program Filters/
Pressure Carbon/
Indoor-No Air Loss of Material Systems VI1.1.1-b 3.3.1-05 4 Strainers Boundary Low Conditioning Monitoring Alloy (External)
X Program Steel Treated Water -
Loss of Material Water Chemistry J, 5 Other (Internal)
Control Program One-Time J, 5 Inspection Program Stainless Indoor - No Air None None Required J
Steel Conditioning (External)
Treated Water-Loss of Material One-Time (V.D1.1-(3.2.1-35, H, 3 Borated, T<1400F Inspection a) 15)
(Internal)
Program Water Chemistry (V.D1.1-(3.2.1-35, H, 3 Control Program a) 15)
Page 11 of 24
Table 3.3.2-4 Auxiliary Systems - Waste Disposal System - Summary of Aging Management Evaluation NUREG
-1801 Aging Effect Aging Volume Component Intended Requiring Management 2 Line Table Type Function Material Environment Management Programs Item 1 Item Notes Flow Pressure Stainless TreatedWater-Loss of Material One-Time J, 5 Indicators Boundary Steel Other (Internal)
Inspection Program Water Chemistry J, 5 Control Program Level Gauges Pressure Carbon!
Indoor-No Air Loss of Material Systems V1I.I.1-b 3.3.1-05 4 Boundary Low Conditioning Monitoring Alloy (External)
Program Steel Treated Water -
Loss of Material Water Chemistry J, 5 Other (Internal)
Control Program One-Time J. 5 Inspection Program Copper Indoor-No Air None None Required J
Alloy (Zn Conditioning
< 15%)
(External)
Treated Water -
Loss of Material Water Chemistry J, 5 Other (Internal)
Control Program One-Time J, 5 Inspection Program Glass Indoor - No Air
. None.
None Required J
Conditioning (External)
Treated Water-None None Required J
Borated, T<1400F (Internal)
Treated Water-None None Required J
Other (Internal)
Stainless Indoor-No Air None None Required J
Steel Conditioning (External)
Treated Water-Loss of Material One-Time (V.D1.1-(3.2.1-35, H, 3 Borated, Tc1400F Inspection a) 15)
(Intemal)
Program Water Chemistry (V.D1.1-(3.2.1-35, H, 3 Control Program a) 15)
Pipe and Pressure Carbon/
Treated Water -
Loss of Material Water Chemistry J, 5 Fittings Boundary Low Other (Internal)
Control Program Alloy One-Time J. 5 Steel Inspection Program Stainless Treated Water-Loss of Material Water Chemistry J 5 Steel Other (Interal)
Control Program Page 12 of 24
Table 3.3.2-4 Auxiliary Systems - Waste Management Evaluation Disposal System - Summary of Aging NUREG
-1801 Aging Effect Aging Volume Component Intended Requiring Management 2 Line Table Type Function Material Environment Management Programs Item 1 Item Notes Pipe and Pressure Stainless Treated Water -
Loss of Material One-Time J, 5 Fittings Boundary Steel Other (Internal)
Inspection Program Pump Casing Pressure Cast Iron Indoor-No Air Loss of Material Systems (VII.l.1-b)
(3.3.1-F, 4 Boundary Conditioning Monitoring 05)
(External)
Program Treated Water -
Loss of Material Water Chemistry J, 5 Other (Internal)
Control Program One-Time J. 5 Inspection Program Stainless Indoor - No Air None None Required J
Steel Conditioning (External)
Treated Water -
Loss of Material One-Time (V.D1.2-(3.2.1-35, H, 3 Borated,T<1400F Inspection a) 15)
(Internal)
Program Water Chemistry (V.D1.2-(3.2.1-35, H, 3 Control Program a) 15)
Treated Water -
Loss of Material Water Chemistry J, 5 Other (Internal)
Control Program One-Time J, 5 Inspection Program Radiation Pressure Stainless Treated Water -
Loss of Material Water Chemistry J, 5 Monitor Boundary Steel Other (Internal)
Control Program One-Time J, 5 Inspection Program Restricting Pressure Copper Indoor - No Air None None Required J
Orifices Boundary Alloy (Zn Conditioning
> 15%)
(External)
Treated Water -
Loss of Material Water Chemistry J, 5 Other (Internal)
Control Program One-Time J, 5 Inspection Program Stainless Indoor-No Air None None Required J
Steel Conditioning (External)
Treated Water -
Loss of Material Water Chemistry J. 5 Other (Internal)
Control Program One-Time J, 5 Inspection P ro g ram Page 13 of 24
Table 3.3.2-4 Auxiliary Systems - Waste Disposal System - Summary of Aging Management Evaluation NUREG
-1801 Aging Effect Aging Volume Component Intended Requiring Management 2 Line Table Type Function Material Environment Management Programs Item 1 Item Notes Sight Glass Pressure Stainless Indoor - No Air None None Required J
Boundary Steel Conditioning (External)
Treated Water-Loss of Material One-Time (V.D1.1-(3.2.1-35, H, 3 Borated, T<1 400F Inspection a) 15)
(Internal)
Program Water Chemistry (V.D1.1-(3.2.1-35, H, 3 Control Program a) 15)
Glass Indoor - No Air None None Required J
Conditioning (External)
Treated Water -
None None Required J
Borated, T<1 400F (Internal)
Tanks Pressure Carbon/
Indoor-No Air Loss of Material Systems VI1.1.1-b 3.3.1-05 4 Boundary Low Conditioning Monitoring Alloy (External)
Program Steel Treated Water -
Loss of Material Water Chemistry J, 5 Other (internal)
Control Program One-Time J, 5 Inspection Program Plastic Indoor - No Air None None Required J
Pipe Conditioning (PVC)
(External)
Treated Water -
None None Required J
lOther (Internal)
Stainless Indoor-No Air None None Required J
Steel Conditioning (External)
Treated Water -
Loss of Material One-Time (V.D1.7-(3.2.1-35, H, 3 Borated, T<1400F Inspection b) 15)
(Internal)
Program Water Chemistry (V.11.7-(3.2.1-35, H, 3 Control Program b) 15)
Valve Bodies Pressure Carbon/
Treated Water-Loss of Material Water Chemistry J, 5 Boundary Low Other (Internal)
Control Program Alloy One-Time J, 5 Steel Inspection Program Cast Treated Water -
Loss of Material One-Time J, 5 Austenitic Other (Internal)
Inspection Stainless Program Steel__
Water Chemistry J, 5 Control Program Page 14 of 24
Table 3.3.2-4 Auxiliary Systems - Waste Disposal System - Summary of Aging Management Evaluation NUREG
-1801 Aging Effect Aging Volume Component Intended Requiring Management 2 Line Table Type Function Material Environment Management Programs Item 1 Item Notes Valve Bodies Pressure Stainless Treated Water -
Loss of Material Water Chemistry J, 5 Boundary Steel Other (Internal)
Control Program One-Time J. 5 Inspection Program Treated Water System Numerous NSR components within the Treated Water system that are located in the general areas of the PAB, namely the demineralized water and reactor makeup water headers and valves, and portions of the potable water sub-system located in the PAB, are now considered in-scope for 10 CFR 54.4(a)(2). Many of these component types are already listed in LRA Table 2.3.3-11 and Table 3.3.2-14; however, some are not.
Additionally, some new materiaVenvironment combinations were identified. The additions to the LRA Section 2 and Section 3 tables are as follows:
Table 2.3.3-11 Treated Water System Component Group Intended Function FILTERS/STRAINERS PRESSURE BOUNDARY HEAT EXCHANGER PRESSURE BOUNDARY Table 3.3.2-14 Auxiliary Systems - Treated Water System - Summary of Aging Management Evaluation NUREG
-1801 Aging Effect Aging Volume Component Intended Requiring Management 2 Line Table Type Function Material Environment Management Programs Item 1 Item Notes Filters/
Pressure Stainless Indoor - No Air None None Required J
Strainers Boundary Steel Conditioning (External)
Treated Water -
Loss of Material One-Time J, 41 Other (Internal)
Inspection Program Heat Pressure Carbon/
Indoor-No Air Loss of Material Systems VII.I.1-b 3.3.1-05 4 Exchanger Boundary Low Conditioning Monitoring Alloy (External)
Program Steel Treated Water -
Loss of Material One-Time J, 41 Other (Internal)
Inspection P ro g ra m_
Page 15 of 24
Table 3.3.2-14 Auxiliary Systems - Treated Water System - Summary of Aging Management Evaluation NUREG
-1801 Aging Effect Aging Volume Component Intended Requiring Management 2 Line Table Type Function Material Environment Management Programs Item 1 Item Notes Valve Bodies Pressure Copper Indoor-No Air None None Required J
Boundary Alloy (Zn Conditioning
< 15%)
(External)
Raw Water Loss of Material One-Time J. 41 Drainage Inspection (Internal)
Program Treated Water -
Loss of Material One-Time J, 41 Other (Internal)
Inspection Program Stainless Raw Water Loss of Material One-Time J, 41 Steel Drainage Inspection (Internal)
Program Plant SamnDlina Svstem During the original scoping effort for PBNP, the Plant Sampling system was determined to be in-scope, but the few components that were in-scope were addressed in other systems (see LRA Section 2.3.3-10). Due to this fact, the tables in Section 2 and Section 3 for the Plant Sampling system were not required.
Based on the new methodology, many more components within this system are now considered in-scope per 10 CFR 54.4(a)(2). (NOTE: The items originally covered as in-scope in other interfacing systems were left in those other systems.) The newly identified components include the tubing runs and valves from containment isolation valves or various sample locations to the primary sample room. The inclusion of these components resulted in the creation of new tables for Section 2 and Section 3 for the Plant Sampling system. The additional LRA Section 2 and Section 3 tables are as follows:
Table 2.3.3-14 Plant Sampling System Component Group
.Intended Function FILTERS/STRAINERS PRESSURE BOUNDARY LEVEL GAUGES PRESSURE BOUNDARY PIPING AND FITTINGS PRESSURE BOUNDARY RESTRICTING ORIFICES PRESSURE BOUNDARY TANKS PRESSURE BOUNDARY VALVE BODIES PRESSURE BOUNDARY Page 16 of 24
Table 3.3.2-10 Auxiliary Systems - Plant Sampling System - Summary of Aging Management Evaluation NUREG
-1801 Aging Effect Aging Volume Component Intended Requiring Management 2 Line Table Type Function Material Environment Management Programs Item 1 Item Notes Filters/
Pressure Stainless Indoor-No Air None None Required J
Strainers Boundary Steel Conditioning (External)
Treated Water -
Loss of Material One-Time (VIII.B1.1 (3.4.1-35, F, 5 Secondary, Inspection
-a) 7)
T<1200F (Internal)
Program Water Chemistry (VIII.B1.1 (3.4.1-35, F, 5 Control Program
-a) 7)
Level Gauges Pressure Stainless Indoor - No Air None None Required J
Boundary Steel Conditioning (External)
Treated Water-Loss of Material One-Time (Vil.B1.1 (3.4.1-35, F, 5 Secondary, Inspection
-a) 7)
T<12 0°F (Internal)
Program Water Chemistry (VIII.B1.1 (3.4.1-35, F, 5 Control Program
-a) 7)
Glass Indoor-No Air None None Required J
Conditioning (External)
Treated Water-None None Required J
Secondary, T<1200F (Internal)
Piping and Pressure Stainless Indoor-No Air None None Required J
Fittings Boundary Steel Conditioning (External)
Treated Water-Loss of Material One-Time (V.D1.1-(3.2.1-35, H, 3 Borated, T<1400F Inspection a) 15)
(Internal)
Program Water Chemistry (V.D1.1-(3.2.1-35, H, 3 Control Program a) 15)
Treated Water-Cracking due to One-Time (V.D1.1-(3.2.1-35,34
- Primary, SCC Inspection a) 15) 1 400F<T<480 F Program (Internal)
Water Chemistry (V.D1.1-(3.2.1-35, B Control Program a) 15)
Loss of Material One-Time (V.D1.1-(3.2.1-35, H, 3 Inspection a) 15)
Program Water Chemistry (V.D1.1-(3.2.1-35, H, 3 Control Program a) 15)
Treated Water-Cracking due to One-Time (VIII.B1.1 (3.4.1-35, F. 5 Secondary, SCC Inspection
-a) 7)
T>12 0°F (Internal)
Program Water Chemistry (VIII.B1.1 (3.4.1-35, F, 5 Control Program
-a)
- 7)
Page 17 of 24
Table 3.3.2-10 Auxiliary Systems - Plant Sampling System - Summary of Aging Management Evaluation
.... L.;
-1801 Aging Effect Aging Volume Component Intended Requiring Management 2 Line Table.
Type Function Material Environment Management Programs Item 1 Item Notes Piping and Pressure Stainless Treated Water-Loss of Material One-Time (VIII.B1.1 (3.4.1-35, F, 5 Fittings Boundary Steel Secondary, Inspection
-a) 7)
T>1200F (Internal)
Program Water Chemistry (VI1I.B1.1 (3.4.1-35, F, 5 Control Program
-a) 7)
Treated Water -
Loss of Material One-Time (VIII.B1.1 (3.4.1-35, F. 5 Secondary, Inspection
-a) 7)
T<1200F (Internal)
Program Water Chemistry (VI1I.B1.1 (3.4.1-35, F, 5 Control Program
-a) 7)
Restricting Pressure Stainless Indoor - No Air None None Required J
Orifices Boundary Steel Conditioning (External)
Treated Water-Loss of Material One-Time (V.D1.1-(3.2.1-35, H. 3 Borated, T<1400F Inspection a) 15)
(Internal)
Program Water Chemistry (V.D1.1-(3.2.1-35, H, 3 Control Program a) 15)
Tanks Pressure Stainless Indoor-No Air None None Required J
Boundary Steel Conditioning (External)
Treated Water -
Loss of Material One-Time J. 5 Secondary, Inspection T<1200F (Intemal)
Program Water Chemistry J, 5 Control Program Valve Bodies Pressure Stainless Indoor - No Air None None Required J
Boundary Steel Conditioning (External)
Treated Water -
Loss of Material One-Time (V.D1.4-(3.2.1-35, H, 3 Borated, T<1400F Inspection b) 15)
(Internal)
Program Water Chemistry (V.D1.4-(3.2.1-35, H, 3 Control Program b) 15)
Treated Water-Cracking due to One-Time (V.D1.4-(3.2.1-35,34
- Primary, SCC Inspection b) 15) 1 400F<T<480 "F Program (Internal)
Water Chemistry (V.D1.4-(3.2.1-35, B Control Program b) 15)
Loss of Material One-Time (V.D1.4-(3.2.1-35, H, 3 Inspection b) 15)
P ro g ram Page 18 of 24
Table 3.3.2-10 Auxiliary Systems - Plant Sampling System - Summary of Aging Management Evaluation NUREG
-1801 Aging Effect Aging Volume Component Intended Requiring Management 2 Line Table Type Function Material Environment Management Programs Item 1 Item Notes Valve Bodies Pressure Stainless Treated Water-Loss of Material Water Chemistry (V.D1.4-(3.2.1-35, H, 3 Boundary Steel
- Primary, Control Program b) 15) 1400F<T<480 0F (Internal)
Treated Water-Cracking due to One-Time (Vili.B1.2 (3.4.1-35, F, Secondary, SCC Inspection
-a)
- 7)
H, 5 T>1200F (Internal)
Program Water Chemistry (Vil.B1.2 (3.4.1-35, F, Control Program
-a)
- 7)
H, 5 Loss of Material One-Time (Vli.B1.2 (3.4.1-35, F, 5 Inspection
-a) 7)
Program Water Chemistry (VIII.B1.2 (3.4.1-35, F, 5 Control Program
- a) 7)
Treated Water -
Loss of Material One-Time (VIlIl.B1.2 (3.4.1-35, F. 5 Secondary, Inspection
-a) 7)
T<1200F (Internal)
Program I
Water Chemistry (V1il.B1.2 (3.4.1-35, F, 5 Control Program
-a) 7)
Main and Auxiliary Steam System Numerous NSR components within the Main and Auxiliary Steam system that are located in the facade, namely the components of the steam generator blowdown sub-system, and high energy piping and valves in proximity to the Main Feedwater Regulating Valves, are now considered in-scope for 10 CFR 54.4(a)(2). Many of these component types are already listed in LRA Table 2.3.4-1 and Table 3.4.2-1; however, some are not. Additionally, some new material/environment combinations were identified. The additions to the LRA Section 2 and Section 3 tables are as follows:
Table 2.3.4-1 Main and Auxiliary Steam System Component Group Intended Function FILTERS/STRAINERS PRESSURE BOUNDARY HEAT EXCHANGERS PRESSURE BOUNDARY LEVEL GAUGES PRESSURE BOUNDARY PUMP CASING PRESSURE BOUNDARY TANKS PRESSURE BOUNDARY Page 19 of 24
Table 3.4.2-1 Steam and Power Conversion System - Main and Auxiliary Steam System -
Summary of Aging Management Evaluation NUREG
-1801 Aging Effect Aging Volume Component Intended Requiring Management 2 Line Table Type Function Material Environment Management Programs Item 1 Item Notes Filters/
Pressure Carbon/
Indoor-No Air Loss of Material Systems VIII.H.1-b 3.4.1-05 4 Strainers Boundary Low Conditioning Monitoring Alloy (External)
Program Steel Treated Water-Loss of Material One-Time VIII.F.1-b 3.4.1-02 D Secondary, Inspection T<12 0'F (Internal)
Program Water Chemistry VII.F.1-b 3.4.1-02 D Control Program Treated Water-Loss of Material One-Time VIII.F.1-b 3.4.1-02 D Secondary, Inspection T>1200F (Internal)
Program Water Chemistry VIII.F.1-b 3.4.1-02 D Control Program Loss of Material Flow Accelerated VIII.F.1-a 3.4.1-06 C due to Corrosion Program FAC/Erosion-Water Chemistry V1II.F.1-a 3.4.1-06 34 Corrosion Control Program V__-3.6 Cast Iron Indoor-No Air Loss of Material Systems (VIII.H.1-(3.4.1-F. 4 Conditioning Monitoring b) 05)
(External)
Program Treated Water-Loss of Material One-Time (VIII.F.1-(3.4.1-F, 5 Secondary, Inspection b) 02)
T>1200F (Internal)
Program Water Chemistry (VIII.F.1-(3.4.1-F, 5 Control Program b) 02)
Heat Pressure Carbon/
Indoor-No Air Loss of Material Systems ViII.H.1-b 3.4.1-05 4 Exchanger Boundary Low Conditioning Monitoring Alloy (External)
Program Steel Treated Water-Loss of Material One-Time VII.F.4-d 3.4.1-02 B Secondary, Inspection T>1200F (Internal)
Program Water Chemistry VIII.F.4-d 3.4.1-02 B Control Program Loss of Material Flow Accelerated VIII.F.1-a 3.4.1-06 C due to Corrosion Program ll FAC/Erosion-Water Chemistry ViII.F.1-a 3.4.1-06 34 Corrosion Control Program Raw Water Loss of Material Closed Cycle (VII.C1.3- (3.3.1-35, D (Internal)
Cooling Water a) 17)
Program Stainless Indoor-No Alr None None Required J
Steel Conditioning (External)
Page 20 of 24
Table 3.4.2-1 Steam and Power Conversion System - Main and Auxiliary Steam System -
Summary of Aging Management Evaluation NUREG
-1801 Aging Effect Aging Volume Component Intended Requiring Management 2 Line Table Type Function Material Environment Management Programs Item 1 Item Notes Heat Pressure Stainless Treated Water-Loss of Material One-Time (VIII.F.4-(3.4.1-F. 5 Exchanger Boundary Steel Secondary, Inspection d) 02)
T>1200F (Internal)
Program Water Chemistry (VIII.F.4.
(3.4.1-F, 5 Control Program d) 02)
Cracking due to One-Time H, 5 SCC Inspection Program Water Chemistry H, 5 Control Program Level Gauges Pressure Carbon/
Indoor-No Air Loss of Material Systems VIII.H.1-b 3.4.1-05 4 Boundary Low Conditioning Monitoring Alloy (External)
Program Steel Treated Water-Loss of Material One-Time VIII.F.1-b 3.4.1-02 D Secondary, Inspection T<120'F (Internal)
Program Water Chemistry VIII.F.1-b 3.4.1-02 D Control Program Glass Indoor-No Air None None Required J
Conditioning (External)
Treated Water -
None None Required J
Secondary, Tc1200F (Internal)
Pump Casing Pressure Cast Iron Indoor-No Air Loss of Material Systems (ViiI.H.1-(3.4.1-F, 4 Boundary Conditioning Monitoring b) 05)
(External)
Program Treated Water-Loss of Material Water Chemistry (VIII.F.3-(3.4.1-F, 4 Secondary, Control Program a) 02)
T<1200F (Internal)
One-Time (VIII.F.3-(3.4.1-F, 4 Inspection a) 02)
Program Steam Traps Pressure Cast Iron Indoor-No Air Loss of Material Systems (VIII.H.1-(3.4.1-F, 4 Boundary Conditioning Monitoring b) 05)
(External)
Program Treated Water-Loss of Material One-Time (VIII.F.1-(3.4.1-F, 5 Secondary, Inspection b) 02)
T>1200F (Internal)
Program Water Chemistry (VIII.F.1-(3.4.1-F, 5 Control Program b) 02)
Tanks Pressure Carbon/
Indoor-No Air Loss of Material Systems VIII.H.1-b 3.4.1-05 4 Boundary Low Alloy Conditioning Monitoring Steel (External)
Program Page 21 of 24
Table 3.4.2-1 Steam and Power Conversion System - Main and Auxiliary Steam System -
Summary of Aging Management Evaluation NUREG
-1801 Aging Effect Aging Volume Component Intended Requiring Management 2 Line Table Type Function Material Environment Management Programs Item 1 Item Notes Tanks Pressure Carbon/
Treated Water-Loss of Material One-Time VIII.F.1-b 3.4.1-02 D Boundary Low Alloy Secondary, Inspection Steel T>1200F (Internal)
Program Water Chemistry VIII.F.1-b 3.4.1-02 D Control Program Loss of Material Flow Accelerated VIII.F.1-a 3.4.1-06 C due to Corrosion Program FAC/Erosion-Water Chemistry VilI.F.1-a 3.4.1-06 34 Corrosion Control Program Valve Bodies Pressure Copper Treated Water-Loss of Material One-Time (VIII.F.2-(3.4.1-F, 5 Boundary Alloy (Zn Secondary, Inspection b) 02)
< 15%)
T>120'F (Internal)
Program Water Chemistry (VIII.F.2-(3.4.1-F, 5 Control Program b) 02)
Feedwater and Condensate System Numerous NSR components within the Feedwater and Condensate System that are located in the turbine building, namely high energy piping and valves in proximity to the Main Feedwater Regulating Valves, are now considered in-scope for 10 CFR 54.4(a)(2).
Many of these component types are already listed in LRA Table 2.3.4-2 and Table 3.4.2-2; however, some are not. Additionally, some new materiaVenvironment combinations were also identified. The additions to the LRA Section 2 and Section 3 tables are as follows:
Table 2.3.4-2 Feedwater and Condensate System Component Group Intended Function LEVEL GAUGES PRESSURE BOUNDARY PUMP CASING PRESSURE BOUNDARY STEAM TRAPS PRESSURE BOUNDARY TANKS PRESSURE BOUNDARY Page 22 of 24
Table 3.4.2-2 Steam and Power Conversion System - Feedwater and Condensate System
- Summary of Aging Management Evaluation NUREG
-1801 Aging Effect Aging Volume Component Intended Requiring Management 2 Line Table Type Function Material Environment Management Programs Item 1 Item Notes Level Gauges Pressure Carbon/
Indoor-No Air Loss of Material Systems VIII.H.1-b 3.4.1-05 4 Boundary Low Conditioning Monitoring Alloy (External)
Program Steel Treated Water -
Loss of Material One-Time VliI.D1.1-3.4.1-02 D Secondary, Inspection c
T<1200F (Internal)
Program Water Chemistry VIII.D1.1-3.4.1-02 D Control Program c
Glass Indoor - No Air None None Required J
Conditioning (External)
Treated Water -
None None Required J
Secondary, T<1200F (Internal)
Piping and Pressure Stainless Indoor - No Air None None Required J
Fittings Boundary Steel Conditioning (External)
Treated Water -
Cracking due to One-Time J. 5 Secondary, SCC Inspection T>1200F (Internal)
Program Water Chemistry J, 5 Control Program Loss of Material One-Time (VIII.D1.1 (3.4.1-F, 5 Inspection
-c) 02)
Program Water Chemistry (VIII.D1.1 (3.4.1-F, 5 Control Program
-c) 02)
Pump Casing Pressure Cast Iron Indoor-No Air Loss of Material Systems (VIII.H.1-(3.4.1-F. 4 Boundary Conditioning Monitoring b) 05)
(External)
Program Treated Water-Loss of Material Water Chemistry (VIl.D1.3- (3.4.1-F, 5 Secondary, Control Program a) 02)
T<1200F (Interal)
One-Time (VII.D1.3- (3.4.1-F, 5 Inspection a) 02)
Program Steam Traps Pressure Cast Iron Indoor-No Air Loss of Material Systems (VIII.H.1-(3.4.1-F, 4 Boundary Conditioning Monitoring b) 05)
(External)
Program Treated Water -
Loss of Material One-Time (Vill.D1.1 (3.4.1-F, 5 Secondary, Inspection
-c) 02)
T>1200F (Internal)
Program Water Chemistry VIII.D1.1-3.4.1-02 F, 5 Control Program c
Page 23 of 24
Table 3.4.2-2 Steam and Power Conversion System - Feedwater and Condensate System
- Summary of Aging Management Evaluation NUREG
-1801 Aging Effect Aging Volume Component Intended Requiring Management 2 Line Table Type Function Material Environment Management Programs Item 1 Item Notes Tanks Pressure Carbon/
Indoor-No Air Loss of Material Systems ViI.H.1-b 3.4.1-05 4 Boundary Low Conditioning Monitoring Alloy (External)
Program Steel Treated Water -
Loss of Material One-Time (Vlil.D1.1 (3.4.1-F. 5 Secondary, Inspection
-c) 02)
T<1200F (Internal)
Program Water Chemistry Vil.D1.1-3.4.1-02 F. 5 Control Program c
Page 24 of 24