ML063050613

Email: (PA-LR) Questions and Answers of Pilgrim LRA Aging Management Reviews

ML063050613
Person / Time
Site:	Pilgrim
Issue date:	06/30/2006
From:	Ellis D Entergy Corp
To:	Jennifer Davis, Subbaratnam R Division of Regulatory Improvement Programs
References
%dam200612, TAC MD2296
Download: ML063050613 (79)

Text

1IKent Howard - Questions and Answers of Pilgrim LRA Aging Management Reviews Page 1 1 I

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From: "Ellis, Douglas" <dellisl @entergy.com>

To: "James Davis" <JAD @nrc.gov>, <erachp@comcast.net>, <duh @nrc.gov>,

<rxs2 @ nrc.gov>, <david.lewis @pillsburylaw.com>

Date: 6/30/2006 1:44:57 PM

Subject:

Questions and Answers of Pilgrim LRA Aging Management Reviews Jim - as you requested, including cc:s. Doug Ellis, Pilgrim Licensing.

CC: "Ellis, Douglas" <dellisl @entergy.com>, "Ford, Bryan" <BFord@entergy.com>

c:\temp\GWJOOOOl .TMP Pagie 1 ii Mail Envelope Properties (44A5630F.CE2: 18 : 64738)

Subject:

Questions and Answers of Pilgrim LRA Aging Management Reviews Creation Date 6/30/2006 1:44:24 PM From: "Ellis, Douglas" <dellisl @entergy.com>

Created By: dellis 1 @entergy.com Recipients nrc.gov OWGWPOO3.HQGWDOO1 JAD (James Davis) nrc.gov TWGWPO02.HQGWDOO1 -

RXS2 (Ram Subbaratnam) entergy.com BFord CC (Bryan Ford) pillsburylaw.com david.lewis nrc.gov NRCWIA01.NRCWDOO1 "duh @nrc.gov"

1 NRC LRA AMR Audit of PNPS Number Status Request Response NRC PNPS Lead 341 Accepted In Table 4.1-1 of the LRA, the applicant did not identify a The license renewal rule, in 10 CFR 54.3, defines a TLAA as a Patel, Erach Finnin, Ron crane load cycle limit as a TLAA for the cranes within the licensee calculation or analysis that, among other things, involves scope of license renewal. Normally, based on the design time-limited assumptions defined by the current operating term. For code of the crane, a load cycle limit is specified at rated cranes, there is no calculation or analysis related to crane load capacity over the crane's projected life. Therefore, it is cycles. In addition, the number of cycles is NOT based on the generally necessary to perform a TLAA relating to crane load current operating term. CMAA-70 specifies an allowable stress cycles estimated to occur up to the end of the extended range based on joint category and service class. Service class is period of operation. Please explain why the crane load cycle based on load class (mean effective load factor) and number of limit was not included as a TLAA. cycles. The projected cycles for the PNPS reactor building crane are well below any of the cycle ranges given in CMAA-70.

The discussion column of Item 3.3.1-1 of Table 3.3.1 will be clarified to read as follows: "No PNPS calculation or analysis related to cumulative fatigue damage for steel cranes met the definition of TLAA in 10 CFR 54.3. The projected cycles for the PNPS reactor building crane are well below the cycle ranges given in CMAA-70. Steel cranes are evaluated as structural components in Section 3.5."

This requires an amendment to the LRA.

342 Accepted In Table 4.3-1, Maximum CUFs for Class I Components, note The transients on the RPV main steam, vent and instrument nozzles Patel, Erach Finnin, Ron 2 addresses exclusion rules for ASME Code. Please explain are mild and stresses remain below the endurance limit. The what these rules are. original CE (Combustion Engineering) vessel analysis demonstrates that the requirements of ASME Section III-1965 with summer 1966 Addenda (Original Construction Code), Paragraph N-415.1 Vessels Not Requiring Analysis for Cyclic Operation, were met. This was later confirmed to be the case in the Altran analysis.

A mistake exists in Table 4.3-1 of the LRA. The recirculation outlet nozzle usage factor does not meet the criteria of paragraph N-415.1.

LRA Table 4.3-1 will be revised to add the appropriate usage factor for the recirculation outlet nozzle. Note 2 will no longer be applied to the recirculation outlet nozzle. Note 2 will be revised to read as follows.

Detailed fatigue analysis is not required since component meets the requirements of ASME Section Il -1965 with summer 1966 Addenda (Original Construction Code), Paragraph N-415.1 Vessels Not Requiring Analysis for Cyclic Operation.

This requires an amendment to the LRA.

Page 1 of 77

Number Status Request Response NRC PNPS Lead 343 Accepted Section 4.3.1.3, Class 1 piping and components states all Section 4.3.1.3 of the LRA is correct. PNPS has no site-specific Patel, Erach Finnin, Ron remaining RCS pressure boundary piping is designed and fatigue analysis for the feedwater piping. Section 4.3.3 of the LRA analyzed in accordance with ANSI B31.1. However, in is discussing the effects of the reactor coolant environment on section 4.3.3, on page 4.3-8, it implies that fatigue analysis fatigue. Entergy will remove the generic (NUREG-6260) values for exists for feedwater piping (which is part of the RCS pressure the core spray safe end, the RR outlet nozzle and the feedwater boundary piping designed and analyzed lAW B31.1.). piping from Table 4.3-3. There are no PNPS-specific analyses for Please clarify this discrepancy, since B31.1 does not require these locations.

a fatigue analysis calculation.

See the response to Question 346A below for the PNPS commitment for performing EAF (environmentally adjusted fatigue) analyses.

This requires an amendment to the LRA.

344 Accepted Section 4.3.1.3, Class I piping and components second PNPS will add the following sentence at the end of Section 4.3.1.3: Patel, Erach Finnin, Ron paragraph states that the design transients are tracked and "The effects of the reactor coolant environment on fatigue are evaluated to ensure that cycle limits are not exceeded, addressed in Section 4.3.3 of the LRA."

thereby assuring that CUFs do not exceed 1.0. It further states that continuation of this program, therefore, will The TLAA addressed by Section 4.3.1.3 is calculation of CUFs ensure that the allowed number of transient cycles is not without accounting for the effects of reactor coolant environment.

exceeded. Consequently, the TLAA (fatigue analyses) for This TLAA remains valid for the period of extended operation as Class 1 piping and components will remain valid for the long as the analyzed number of transients is not exceeded.

period of extended operation in accordance with 10 CFR 54.2 1 (c)(1)(i) or the effects of aging on the intended function(s) The calculation of CUFs accounting for the effects of the reactor will be adequately managed for the period of extended coolant environment does not exist, as the current licensing basis operation in accordance with 10 CFR 54.21 (c)(1 )(iii). This by does not require consideration of environmental fatigue factors.

itself could be a true statement, however, cycle counting Since 10 CFR 54.3 defines TLAAs as licensee calculations and does not address the effects of environmental fatigue, which analyses, there is not a TLAA that considers environmental fatigue is not included here. Acknowledging that section 4.3.3 factors.

addresses environmental fatigue, please clarify how that section is tied into the conclusion made in section 4.3.1.3. To remove the perceived implication that exceeding the allowable number of transients would cause the CUFs to exceed 1.0, the following changes will be made to the LRA.

LRA Section 4.3.1, page 4.3-4 will be modified as follows: "The PNPS Fatigue Monitoring Program ensures that the numbers of transient cycles experienced by the plant remain within the allowable numbers of cycles, and hence the component CUFs remain below their analyzed values."

LRA Section 4.3.1.3, Second sentence of the second paragraph will be changed as follows:

"The design transients are tracked and evaluated to ensure that cycle limits are not exceeded, thereby assuring that CUFs remain below their analyzed values."

This response requires an amendment to the LRA.

Page2of77

Number Status Request Response NRC PNPS Lead I 345 Accepted Section 4.3.1.4, Feedwater Nozzle Fatigue states that this The Thermal Power Optimization Task Report T0302 updated the Patel, Erach Finnin, Ron extrapolated usage factor for the feedwater nozzles, feedwater nozzle CUF to <1.0 based on the associated (1.5%) power considering both the currently analyzed system design uprate. The extrapolation in LRA section 4.3.1.4 is thus no longer transients and rapid cycling through the period of extended valid. PNPS will modify the LRA to delete this extrapolation. PNPS operation, is thus <0.899. This number is not correct. Please will perform a new feedwater nozzle fatigue analysis prior to the explain how this number was calculated. period of extended operation.

This commitment is Item 35 of the PNPS commitments for license renewal.

This requires an amendment to the LRA.

346 Open - Section 4.3.3, Effects of Reactor Water Environment on A. Further refinement of the ASME Class 1 fatigue analysis for the Patel, Erach Finnin, Ron NRC Fatigue Life. RPV and nozzle locations will be performed considering the Please provide more details on your implementation plan: predicted number of transients at each location adjusted to the end A. How will the further refinement of the fatigue analyses be of the extended license period using refined finite element performed? Will it consider finite element analyses? evaluation as applicable. The refined analysis will account for B. If an aging management program is used, please include environmental effects as applicable using the FEN methodology a commitment to issue for NRC approval 24 months prior to described by the GALL report or other industry Codes and Standards entering period of extended operation. as approved by NRC.

C. Will replacement be of the same material type?

B. License renewal Commitment 31 includes a commitment to submit the aging management program to the NRC 24 months prior to the period of extended operation if the aging management program option is chosen.

C. Appropriate replacement material will be selected in accordance with PNPS design control procedures, if replacement is a chosen option.

347 Accepted Table 4.3-3, Note 1 states "No PNPS-specific value was A. Yes, this is a typo, it should be NUREG-6260. Patel, Erach Finnin, Ron available; used generic value from NUREG/CR-6220."

a. Wrong NUREG identified - should it be NUREG-6260? B. The CUF values from NUREG-6260 were intended as typical

b. The NUREG-6260 CUF is based on the specific plant values used to predict the magnitude of the effect of considering the used in that NUREG and is dependent on that plant's piping reactor coolant environment on fatigue for PNPS. PNPS will amend configuration. That value cannot be used for PNPS the LRA to remove the CUFs from Table 4.3-3 thatare taken from calculation. Please justify how this value applies to PNPS NUREG-6260.

unless the PNPS piping configurations are same as the NUREG-6260 plant or provide a PNPS specific CUF value. See Item 346 for PNPS's commitment to perform additional environmentally adjusted fatigue analyses prior to the periodVof extended operation.

This response requires an amendment to the LRA.

Page 3 of 77

Number Status Request Response NRC PNPS Lead 349 Closed [3.4.1-W-01] Listing TLAA - metal fatigue in the tables in Section 3 indicates Wen, Peter Finnin, Ron that the conditions for fatigue were present and that they needed to In numerous line items in Tables 3.4.2-2, 3.3.2-14-3, 9, 10, be evaluated. Associated components were subsequently 11, 17 and 18 of the Steam and Power Conversion System, evaluated in LRPD-06, TLAA - Metal Fatigue. If the evaluation found the applicant credits TLAA - Metal Fatigue to manage the no TLAA, it was not listed in Section 4 of the LRA. For aging effect of metal fatigue (cumulative fatigue damage), clarification, Entergy will revise the Section 3 tables to remove the and indicates that the evaluation of this TLAA is addressed TLAA - metal fatigue entries whenever there was no associated in Section 4.3 of the LRA. However, it appears that the TLAA discussed in Section 4 of the LRA.

write-up of the Section 4.3 does not cover the discussion for most components. Please explain the discrepancy. This item is closed to item 506.

350 Accepted [3.4.1-W-02] The Section 3.4.2.2.2 (1) further evaluation discussion is referenced Wen, Peter Lingenfelter, by Table 3.4.1 items 3.4.1-2, 3.4.1-4 and 3.4.1-6. Thediscussion Section 3.4.2.2.2 (1) of the LRA (page 3.4-4), the applicant column entry of item 3.4.1-6 indicates that the PSPM program states: applies to the condensate storage tanks. Although the water in these tanks would be subject to the water chemistry controls - BWR "Loss of material due to general, pitting and crevice program, the PSPM program is sufficient to manage loss of material corrosion for carbon steel piping, piping components, and and was the only program credited for these tanks. See the tanks, exposed to treated water and for carbon steel piping response to question 3.4.1-5 (item #353) which documents that the and components exposed to steam is an aging effect Water Chemistry Control - BWR program should have been credited requiring management in the steam and power conversion along with the PSPM program for the condensate storage tanks.

systems at PNPS, and is managed by the Water Chemistry Control - BWR and Periodic Surveillance and Preventive This requires a supplementlamendment to the LRA.

Maintenance (PSPM) Programs."

Please clarify the above summary, regarding the use of PSPM program., Is the use of PSPM program is in lieu of the OTI program to verify the effectiveness of the Water Chemistry Control - BWR program or some of the AEM combination will be managed by using PSPM alone.

351 Closed [3.4.1-W-03] Since the One-Time Inspection (OTI) Program is applicable to each Wen, Peter Fronabarger, water chemistry control program, it is also applicable to each line Why is OTI program not credited for those line items in item that credits a water chemistry control program. LRA Table Tables 3.4.2-x and Table 3.3.2-14-x (corresponding to 3.4.1 indicates that the One-Time Inspection Program is credited VIII.E-33, condensate system, VIII.C-6, extraction steam along with the water chemistry control programs for line items for system. VIII.D2-7, feedwater system, and VIII.B2-6, main which GALL recommends a one-time inspection to confirm water steam system) that reference item 3.4.1-4? chemistry control. Table 2 credits the OTI program through reference to the associated Table 1 line item.

This requires an amendment to the chemistry program descriptions in LRA Appendices A and B to clearly indicate that the One-Time Inspection Program will confirm the effectiveness of the Water Chemistry Control-BWR, Water Chemistry Control- Auxiliary Systems and the Water Chemistry Control- Closed Cooling Water programs.

This item is closed to Item 372.

Page 4 of 77

Number Status Request Response NRC PNPS Lead 352 Closed [3.4.1-W-04] Since the One-Time Inspection (OTI) Program is applicable to each Wen, Peter Fronabarger, water chemistry, control program, it is also applicable to each line Why is OTI program not credited for those line items in item that credits a water chemistry control program. LRA Table Table 3.3.2-14-x (corresponding to VIII.E-7, heat exchanger 3.4.1 indicates that the One-Time Inspection Program is credited components in condensate system) that reference item along with the water chemistry control programs for line items for 3.4.1-5? which GALL recommends a one-time inspection to confirm water chemistry control. Table 2 credits the OTI program through reference to the associated Table 1 line item.

This requires an amendment to the chemistry program descriptions in LRA Appendices A and B to clearly indicate that the One-Time Inspection Program will confirm the effectiveness of the Water Chemistry Control-BWR, Water Chemistry Control- Auxiliary Systems and the Water Chemistry Control- Closed Cooling Water programs.

This item is closed to Item 372.

353 Closed [3.4.1-W-05] Since the condensate storage tank contains fluid that is subject to Wen, Peter Orlicek, Jack the controls of the Water Chemistry Control - BWR Program, the The applicant references GALL item VIII.E-40 (steel tank in program applies to the tank. The LRA will be clarified to explicitly condensate system) for the condensate storage system credit the Water Chemistry Control - BWR Program in addition to carbon steel tank, as listed in LRA Table 3.4.2-1, (page PSPM with managing the effects of aging for the condensate 3.4-28), but takes credit of PSPM to manage the aging effect storage tank surfaces exposed to the treated water environment.

of loss of material. The GALL recommends using "Water Chemistry" and "OTI" programs for this component and AEM Since the One-Time Inspection (OTI) Program is applicable to each combination. Although the PSPM, as described in PNPS water chemistry control program, it is also applicable to each line LRA B1.24, has more stringent inspection requirement than item that credits a water chemistry control program. As stated in OTI, it does not include controlling water chemistry to LRA Table 3.4.1, the One-Time Inspection Program is credited to minimize component exposure to aggressive environment. verify effectiveness of the water chemistry control program for line Please explain why relying on PSPM alone is sufficient for items that reference item 3.4.1-6.

meeting the GALL's recommendations to manage the aging effect of loss of material for the condensate storage system This requires an amendment to the chemistry program descriptions carbon steel tank. in LRA Appendices A and B to clearly indicate that the One-Time Inspection Program will confirm the effectiveness of the Water The carbon steel tank listed in Table 3.3.2-14-10, feedwater Chemistry Control-BWR, Water Chemistry Control- Auxiliary Systems system (page 3.3-171) and Table 3.3.2-14-11, feedwater and the Water Chemistry Control- Closed Cooling Water programs.

heater drains and vents system (page 3.3-178), also reference GALL item VIII.E-40. Why is OTI program not This item is closed to Item 372.

credited for these line items that reference item 3.4.1-6.

Page 5 of 77

Number Status Request Response NRC PNPS Lead 354 Closed [3.4.1 -W-06] During the performance of routine maintenance on components that Wen, Peter Fronabarger, contain lubricating oil, visual inspections of these components Why is OTI program not credited for those line items in would identify degraded conditions that could be attributed to an Table 3.3.2-14-35 (corresponding to VIII.A-14) that reference ineffective Oil Analysis Program. The corrective action program at item 3.4.1-7? PNPS has a low threshold for the identification of degraded conditions such that corrosion or cracking of components would be identified as part of this program. The review of operating experience at PNPS for the last five years did not identify any condition reports that indicated an ineffective oil analysis program or that identified degraded component conditions such as corrosion or cracking in a lubricating oil environment. This review of operating experience at PNPS serves in lieu of a one-time inspection to provide confirmation of the effectiveness of the Oil Analysis Program.

During the past five years, many visual inspections of components containing lubricating oil have been performed during corrective and preventive maintenance activities. The visual inspections of these components would identify degraded conditions such as corrosion or cracking that could be attributed to an ineffective Oil Analysis Program. PNPS has a low threshold for the identification of degraded conditions such that corrosion or cracking of components would be identified and entered into the corrective action program.

No condition reports that identified degraded component conditions, such as corrosion or cracking in a lubricating oil environment, were initiated as a result of these inspections. These past inspections at PNPS serve in lieu of a one-time inspection to provide confirmation of the effectiveness of the Oil Analysis Program.

This item is closed to Item 376.

355 Closed [3.4.1-W-07] Since the One-Time Inspection (OTI) Program is applicable to each Wen, Peter . Fronabarger, water chemistry control program, it is also applicable to each line Why is OTI program not credited for those line items in item that credits a water chemistry control program. LRA Table Table 3.2.2-4, HPCI System, (page 3.2-49) and Table 3.4.1 indicates that the One-Time Inspection Program is credited 3.2.2-5, RCIC System, (page 3.2-62) (corresponding to along with the water chemistry control programs for line items for VIIIE-10) that reference item 3.4.1-9? which GALL recommends a one-time inspection to confirm water chemistry control. Table 2 credits the OTI program through reference to the associated Table 1 line item.

This requires an amendment to the chemistry program descriptions in LRA Appendices A and B to clearly indicate that the One-Time Inspection Program will confirm the effectiveness of the Water Chemistry Control-BWR, Water Chemistry Control- Auxiliary Systems and the Water Chemistry Control- Closed Cooling Water programs.

This item is closed to Item 372.

Page 6 of 77

Number Status Request Response NRC PNPS Lead 356 Closed [3.4.1-W-08] During the performance of routine maintenance on components that Wen, Peter Fronabarger, contain lubricating oil, visual inspections of these components Why is OTI program not credited for those line items in would identify degraded conditions that could be attributed to an Table 3.3.2-5, Station Blackout Diesel, (page 3.3-90) and ineffective Oil Analysis Program. The corrective action program at Table 3.3.2-6, Security Diesel Generator System, (page PNPS has a low threshold for the identification of degraded 3.3-102) (corresponding to VIII.G-15) that reference item conditions such that corrosion or cracking of components would be 3.4.1-10? identified as part of this program. The review of operating experience at PNPS for the last five years did not identify any condition reports that indicated an ineffective oil analysis program or that identified degraded component conditions such as corrosion or cracking in a lubricating oil environment. This review of operating experience at PNPS serves in lieu of a one-time inspection to provide confirmation of the effectiveness of the Oil Analysis Program.

During the past five years, many visual inspections of components containing lubricating oil have been performed during corrective and preventive maintenance activities. The visual inspections of these components would identify degraded conditions such as corrosion or cracking that could be attributed to an ineffective Oil Analysis Program. PNPS has a low threshold for the identification of degraded conditions such that corrosion or cracking of components would be identified and entered into the corrective action program.

No condition reports that identified degraded component conditions, such as corrosion or cracking in a lubricating oil environment, were initiated as a result of these inspections. These past inspections at PNPS serve in lieu of a one-time inspection to provide confirmation of the effectiveness of the Oil Analysis Program.

This item is closed to Item 376.

357 Closed [3.4.1-W-09] Since the One-Time Inspection (OTI) Program is applicable to each Wen, Peter Fronabarger, water chemistry control program, it is also applicable to each line Why is OTI program not credited for those line items in item that credits a water chemistry control program. LRA Table Table 3.4.2-2, Main Condenser and MSIV Leakage Pathway, 3.3.1 indicates that the One-Time Inspection Program is credited Table 3.3.2-14-9, Extraction Steam System, Table along with the water chemistry control programs for line items for 3.3.2-14-16, HPCI, Table 3.3.2-14-18, Main Steam System, which GALL recommends a one-time inspection to confirm water and Table 3.3.2-14-19, Offgas and Augmented Offgas chemistry control. Table 2 credits the OTI program through System that reference item 3.4.1-13? reference to the associated Table 1 line item.

This requires an amendment to the chemistry program descriptions in LRA Appendices A and B to clearly indicate that the One-Time Inspection Program will confirm the effectiveness of the Water Chemistry Control-BWR, Water Chemistry Control- Auxiliary Systems and the Water Chemistry Control- Closed Cooling Water programs.

This item is closed to Item 372.

Page 7 of 77

Number Status Request Response NRC PNPS Lead 358 Closed [3.4.1-W-10] Since the One-Time Inspection (OTI) Program is applicable to each Wen, Peter Fronabarger, water chemistry control program, it is also applicable to each line Since notes "A"and "C" were used in various Table item that credits a water chemistry control program. LRA Table 3.3.2-14-x line items, which reference item 3.4.1-14, why OTI 3.3.1 indicates that the One-Time Inspection Program is credited program is not credited for those lines? along with the water chemistry control programs for line items for which GALL recommends a one-time inspection to confirm water chemistry control. Table 2 credits the OTI program through reference to the associated Table 1 line item.

This requires an amendment to the chemistry program descriptions in LRA Appendices A and B to clearly indicate that the One-Time Inspection Program will confirm the effectiveness of the Water Chemistry Control - BWR, Water Chemistry Control - Auxiliary Systems and the Water Chemistry Control - Closed Cooling Water programs.

This item is closed to Item 372.

359 Closed [3.4.1-W-11] Since the One-Time Inspection (OTI) Program is applicable to each Wen, Peter Fronabarger, water chemistry control program, it is also applicable to each line Since note "C" was used in Table 3.3.2-144, Condensate item that credits a water chemistry control program. LRA Table Demineralizer System line items, which reference item 3.3.1 indicates that the One-Time Inspection Program is credited 3.4.1-15, why OTI program is not credited for those lines? along with the water chemistry control programs for line items for which GALL recommends a one-time inspection to confirm water chemistry control. Table 2 credits the OTI program through reference to the associated Table 1 line item.

This requires an amendment to the chemistry program descriptions in LRA Appendices A and B to clearly indicate that the One-Time Inspection Program will confirm the effectiveness of the Water Chemistry Control - BWR, Water Chemistry Control - Auxiliary Systems and the Water Chemistry Control - Closed Cooling Water programs.

This item is closed to Item 372.

Page 8 of 77

Number Status Request Response NRC PNPS Lead 360 Closed [3.4.1-W-12] Since the One-Time Inspection (OTI) Program is applicable to each Wen, Peter Fronabarger, water chemistry control program, it is also applicable to each line Since notes "A" and "C" were used in Table 3.4.2-14, item that credits a water chemistry control program. LRA Table Condensate Storage System and various Table 3.3.2-14-x 3.3.1 indicates that the One-Time Inspection Program is credited line items which reference item 3.4.1-16, why OTI program is along with the water chemistry control programs for line items for not credited for those lines? which GALL recommends a one-time inspection to confirm water chemistry control. Table 2 credits the OTI program through reference to the associated Table 1 line item.

This requires an amendment to the chemistry program descriptions in LRA Appendices A and B to clearly indicate that the One-Time Inspection Program will confirm the effectiveness of the Water Chemistry Control - BWR, Water Chemistry Control - Auxiliary Systems and the Water Chemistry Control - Closed Cooling Water programs.

This item is closed to Item 372.

361 Closed 3.4.1-W-13 During the performance of routine maintenance on components that Wen, Peter Fronabarger, contain lubricating oil, visual inspections of these components Why is OTI program not credited for those line items in would identify degraded conditions that could be attributed to an Table 3.4.2-14-35, Turbine Generator and Auxiliary System ineffective Oil Analysis Program. The corrective action program at (corresponding to VIII.A-3) that reference item 3.4.1-18? PNPS has a low threshold for the identification of degraded conditions such that corrosion or cracking of components would be identified as part of this program. The review of operating experience at PNPS for the last five years did not identify any condition reports that indicated an ineffective oil analysis program or that identified degraded component conditions such as corrosion or cracking in a lubricating oil environment. This review of operating experience at PNPS serves in lieu of a one-time inspection to provide confirmation of the effectiveness of the Oil Analysis Program.

During the past five years, many visual inspections of components containing lubricating oil have been performed during corrective and preventive maintenance activities. The visual inspections of these components would identify degraded conditions such as corrosion or cracking that could be attributed to an ineffective Oil Analysis Program. PNPS has a low threshold for the identification of degraded conditions such that corrosion or cracking of components would be identified and entered into the corrective action program.

No condition reports that identified degraded component conditions, such as corrosion or cracking in a lubricating oil environment, were initiated as a result of these inspections. These past inspections at PNPS serve in lieu of a one-time inspection to provide confirmation of the effectiveness of the Oil Analysis Program.

This item is closed to Item 376.

Page 9 of 77

Number Status Request Response ARC I PNPS Lead 362 Closed [3.4.1-W-14] During the performance of routine maintenance on components that Wen, Peter Fronabarger, contain lubricating oil, visual inspections of these components Why is OTI program not credited for those line items in would identify degraded conditions that could be attributed to an Table 3.4.2-14-35, Turbine Generator and Auxiliary System ineffective Oil Analysis Program. The corrective action program at (corresponding toV'VI.A-9 and VIII.G-3 ) that reference item PNPS has a low threshold for the identification of degraded 3.4.1-19? conditions such that corrosion or cracking of components would be identified as part of this program. The review of operating experience at PNPS for the last five years did not identify any condition reports that indicated an ineffective oil analysis program or that identified degraded component conditions such as corrosion or cracking in a lubricating oil environment. This review of operating experience at PNPS serves in lieu of a one-time inspection to provide confirmation of the effectiveness of the Oil Analysis Program.

During the past five years, many visual inspections of components containing lubricating oil have been performed during corrective and preventive maintenance activities. The visual inspections of these components would identify degraded conditions such as corrosion or cracking that could be attributed to an ineffective Oil Analysis Program. PNPS has a low threshold for the identification of degraded conditions such that corrosion or cracking of components would be identified and entered into the corrective action program.

No condition reports that identified degraded component conditions, such as corrosion or cracking in a lubricating oil environment, were initiated as a result of these inspections. These past inspections at PNPS serve in lieu of a one-time inspection to provide confirmation of the effectiveness of the Oil Analysis Program.

This item is closed to Item 376.

Page 10 of 77

a Number Status Request Response NRC PNPS Lead 363 Open - [3.4.1-W-15] Preventive Actions: Wen, Peter Ford, Bryan NRC Table 3.4.1, item 3.4.1-20 for steel tanks exposed to air - Protective coatings were applied during fabrication or installation of outdoor. PNPS uses the System Walkdown Program to the subject tanks well before development of aging management manage the aging effect of loss of material due to general, programs for license renewal.

pitting, and crevice corrosion through the use of periodic visual inspections. The GALL Report recommends the AMP The System Walkdown Program entails visual inspections of of Aboveground Steel Tanks Program (GALL Xl. M29) to be external surfaces of carbon steel tanks to identify degradation of used. While the System Walkdown Program may be an coatings, sealants, and caulking plus indications of leakage. The acceptable alternate for Aboveground Steel Tanks AMP for site corrective action process would require evaluation and repair, if inspection, the Aboveground Steel Tanks AMP has some necessary, of degraded coatings or caulking.

program attributes not addressed in the System Walkdown Program. For examples, the System Walkdown Program is Detection of Aging Effects:

silent on the preventive actions, but the Aboveground Steel Tanks AMP includes preventive measures to mitigate The condensate storage tank is a non-safety related carbon steel corrosion by protecting the external surface of steel tanks tank that contains treated water. The tank sits on a concrete pad with paint or coatings in accordance with standard industry with a sand and oil base cushion that is designed to remove practice. - moisture from the bottom of the tank to minimize the potential for corrosion. The internals of the tank which are subjected to Please explain how the preventive actions and detection of continuous wetting are periodically inspected for corrosion and aging effects at inaccessible locations such as the tank pitting including inaccessible areas (under water) as documented in bottom surface will be performed for the subject tanks using site procedure NE8.02. This same procedure also inspects exterior the System Walkdown AMP. caulking at the base of the tank for cracking in order to prevent water accumulation under the tank. This procedure is credited in the Periodic Surveillance and Preventive Maintenance program section 4.17 and Attachment 3 of LRPD-02 for management of the external and internal surfaces of this tank. Any degradation of the internals of the tank will result in a condition report and an evaluation of the extent of the condition, which may involve ultrasonic examination to determine remaining thickness.

Because the environment inside the tank is significantly harsher than the environment on the underside of the tank, internal degradation would be expected long before corrosion on the outside.

If degradation occurs on the inside (including the bottom),

examinations of the degraded areas would require a determination of the remaining wall thickness which ensures the integrity of the tank is maintained.

However, to ensure that significant degradation on the bottom of the tank is not occurring, PNPS commits to perform a one-time ultrasonic thickness examination in accessible areas on the bottom of the condensate storage tank prior to the period of extended operation. Standard examination and sampling techniques will be utilized. This is commitment number 36.

This requires an amendment to the LRA.

Page 11 of 77

A Number Status Request Response NRC PNPS Lead 364 Closed [3.4.1-W-16] A Bolting Integrity Program will be developed that will address the Wen, Peter Fronabarger, aging management of bolting in the scope of license renewal.

Table 3.4.1, item 3.4.1-22, for steel bolting and closure bolting exposed to air with steam or water leakage, air - The Bolting Integrity Program will be implemented prior to the period outdoor (external), or air - indoor uncontrolled (external). The of extended operation in accordance with commitment number 32.

applicant references GALL items VIII.H-1 and H-4 for the closure bolting in various Steam and Power Conversion This requires an amendment to the LRA to include descriptions of System, as listed in LRA Table 3.4.2-1 and 3.3.2-14-x, but the Bolting Integrity Program in Appendices A and B and to identify takes credit for the System Walkdown Program to manage where the program is applicable.

the aging effect of loss of material. The GALL Report recommends AMP XI.M18, Bolting Integrity Program, which This item is closed to Item 373.

includes a comprehensive bolting integrity program, as delineated in NUREG-1339, and industry recommendations, as delineated in the EPRI report NP-5769. Please justify how the additional attributes listed in GALL AMP XI.M18 for aging management of closure bolting are addressed in the System Walkdown Program.

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Number Status Request Response NRC PNPS Lead 365 Open - [3.6.2.2-N-0131 The PNPS electrical AMR, AMRE-01, in section 3.4.1 states for Nguyen, Duc Stroud, Mike NRC cable connections (metallic parts), "An evaluation of thermal In LRA Table 3.6.2-1 under Cable connections (metallic cycling, ohmic heating, electrical transients, vibration, chemical parts), you have stated that no aging effects and no AMP is contamination, corrosion, and oxidation stressors for the metallic required. NUREG-1801, Revision 1, AMP XI.E6, "Electrical parts of electrical cable connections identified no aging effects Cable Connection not Subject to 10 CFR 50.49 requiring management.

Environmental Qualification Requirements," specifies that connections associated with cables within the scope of - Metallic parts of electrical cable connections potentially exposed license renewal are part of this program, regardless of their to thermal cycling and ohmic heating are those carrying significant associated with active or passive components. Also, refer to current in power supply circuits. Typically, power cables are in a pages 107, 256, and 257 of NUREG-1833, "Technical continuous run from the supply to the load. Therefore, the Bases for Revision to the License Renewal Guidance connections are part of an active component and not subject to Documents," for additional information regarding AMP XI.E6. aging management review.

Provide a basis document including an AMP with the ten - The fast action of circuit protective devices at high currents elements for cable connections or provide a justification for mitigates stresses associated with electrical faults and transients.

why an AMP is not necessary. In addition, mechanical stress associated with electrical faults is not a credible aging mechanism because of the low frequency of occurrence for such faults. Therefore, electrical transients are not applicable stressors.

- Metallic parts of electrical cable connections exposed to vibration are those associated with active components that cause vibration.

Because they are part of an active component, they are not subject to aging management review.

- Corrosive chemicals are not stored in most areas of the plant.

Routine releases of corrosive chemicals to areas inside plant buildings do not occur during plant operation. Such a release, and its effects, would be an event, not an effect of aging. In addition, their location inside active components protects the metallic parts of electrical cable connections from contamination. Therefore, this stressor is not applicable.

- Oxidation and corrosion usually occur in the presence of moisture or contamination such as industrial pollutants and salt deposits.

Enclosures or splice materials protect metal connections from moisture or contamination.

Since bolted connections are considered part of an active device and are maintained by the plant Maintenance Rule program, there are no aging effects requiring management for bolted connections of cable systems. Since PNPS maintains cable connections under a current maintenance program and has no indication of an aging mechanism due to loose connections, no AMP is needed in addition to the Maintenance Rule program.

Page 13 of 77

Number Status Request Response NRC PNPS Lead 366 Accepted [3.6.2.2-N-02] As shown by the OE (Operating Experience) cited in this question, Nguyen, Duc Stroud, Mike flashover due to salt contamination of insulators is caused by In LRA Table 3.6.2-1 under high voltage insulator (SBO), you events, typically storms, regardless of the age of the insulators.

have stated that no aging effects and no AMP is required. This is clearly not an effect of aging. Therefore, surface You further stated, in Section 3.6.2.2.2 of the LRA, that contamination is not an applicable aging mechanism for PNPS is located near the seacoast where salt spray is high-voltage insulators at PNPS. Since the condition is caused by considered. However, salt spray buildup is a short-term severe weather conditions unrelated to aging, an aging management concern based on local weather conditions (event driven). program is not appropriate to address this concern. However, while Therefore, you have concluded that surface contamination is salt spray buildup is a short-term concern based on local weather not an applicable aging mechanism for high voltage conditions (event-driven), such buildup can cause problems with the insulators at PNPS. offsite power supply system. Because of this operating experience, PNPS has applied Sylgard (RTV silicone) coatings to some NUREG 1800, Rev. 1, Standard Review Plan for Review of switchyard insulators to reduce flashover. The addition of Sylgard to License Renewal Application for Nuclear Power Plant, the insulators has reduced the likelihood of insulator flashover.

Section 3.6.2.2.2 identified degradation of high voltage insulator in presence of salt deposits or surface System walkdowns are performed at least once per refueling cycle contamination. Various airborne materials such as dust, and are normally performed more frequently to do a visual inspection salt and industrial effluent can contaminate insulator of the switchyard high-voltage insulators that are in-scope of surfaces. A large buildup of contamination enables the license renewal in accordance with EN-DC-178. These walkdowns conductor voltage to track along the surface more easily and will continue to be performed into the period of extended operation.

can lead to insulator flash over. Surface contamination can be problem in areas where there are greater concentration of airborne particles such as near facilities that discharge soot LRPD-02 will be revised as follows:

or near the sea coast where salt spray is prevalent. Industry The System Walkdown Program will be revised to include the visual operating experience identified the potential of loss of offsite inspection of high-voltage insulators in-scope of license renewal.

power due to salt deposition to switchyard insulators. On March 17, 1993, Crystal River Unit 3 experienced a loss of the 230 kV switchyard (normal offsite power to safety-related busses) when a light rain caused arcing across salt-laden 230 kV insulators and opened breakers in switchyard. In March 1993, the Brunswick Unit 2 switchyard experienced a flash over of some high-voltage insulators. The incident was attributed to a winter storm in the area. Since 1982, Pilgrim station has also experienced several loss of offsite power events when ocean storms deposited salt on the 345 kV switchyard causing the insulator to arc to ground. In light of these industry and plant operating experiences, provide justification of why an AMP is not necessary.

Page 14 of 77

Number Status Request Response NRC PNPS Lead 367 Closed [3.6.2.2-N-03] At PNPS, bus to bus connections are welded instead of bolted. Nguyen, Duc Stroud, Mike Switchyard buses are connected by flexible connectors to insulators In LRA, Table 3.6.2-1, under switchyard bus and and active components. Since switchyard bus is typically under a connections, you have stated that no aging effects requiring constant load, thermal cycling that could cause torque relaxation is management and no AMP is required. NUREG 1800, Rev. 1, infrequent. With no connections to vibrating equipment, vibration is Standard Review Plan for Review of License Renewal not an aging mechanism for switchyard bus. The switchyard Application for Nuclear Power Plant, Section 3.6.2.2.3 connections to the startup transformer are part of the active identifies loss of preload is an aging effect for switchyard assembly maintained by the plant maintenance program. Therefore, bus connections. Torque relaxation for bolted connection is torque relaxation is not an aging effects requiring management for a concern for switchyard bus connections and transmission switchyard bus.

conductor connections. An electrical connection must be designed to remain tight and maintain good conductivity In addition, thermography is performed at least once every 6 months through a large temperature range. Meeting this design to maintain the integrity of the connections. This program will requirement is difficult if the material specified for the bolt continue into the period of extended operation.

and the conductor are different and have different rates of thermal expansion. For example, copper or aluminum bus/conductor materials expand faster than most bolting materials. If thermal stress is added to stresses inherent at assembly, the joint members or fasteners can yield. If plastic deformation occurs during thermal loading (i.e.,

heatup) when the connection cools, the joint will be loose.

EPRI document TR-104213, "Bolted Joint Maintenance &

Application Guide," recommends inspection of bolted joints for evidence of overheating, signs of burning or discoloration, and indication of loose bolds. Provide a discussion for why torque relaxation for bolted connections of switchyard bus is not a concern for PNPS.

368 Closed [3.6.2.2-N-04] The preferred source of offsite power comes from the 345kV Nguyen, Duc Stroud, Mike switchyard. The feed from the switchyard breakers, 352-2 and 352-3, In LRA, Section 3.6.2.2.3, you have stated that PNPS does travels by switchyard bus to the startup transformer, X4, and then not utilize transmission conductors in the circuits for travels by underground cables to the safety buses in the plant. The recovery of offsite power following an SBO. Describe SBO alternate offsite power source comes from the 23kV switchyard and recovery paths for PNPS. Confirm that no transmission travels from breaker 252 by underground cables to the shutdown conductors are utilized in the circuits for recovery paths. transformer, X1 3, and then by underground cables to bus A8. From Support these answers with a main one line diagram. A8 the power travels by underground cables to the safety buses in the plant. Neither PNPS recovery path for offsite power uses transmission conductors. These paths are shown on Figure 2.5-1 of the LRA.

Page 15 of 77

Number Status Request Response NRC PNPS Lead 369 Closed [3.6.2.2-N-05] At PNPS, the station blackout diesel generator provides the Nguyen, Duc Stroud, Mike alternate AC power source. All SSCs associated with the.AAC 10 CFR 54.4 (a)(3) requires, in part, that all systems, diesel are in scope for license renewal. The LRA provides the structures, and components (SSCs) relied on in safety aging management review results for long-lived, passive SSCs analyses or plant evaluation to perform a function that associated with the AAC power source in each discipline section demonstrates compliance with the commission's of the LRA.

regulations for station black out (10 CFR 50.63) are within the scope of license renewal. What is your alternate ac (AAC) source used to meet SBO requirements? Are all SSCs (including electrical components) associated with AAC sources included in the scope of licensee renewal? If they are not, explain why not. If they are, provide an AMR for long-lived, passive SSCs associated with the AAC sources.

370 Accepted [3.6.2.2-N-06] The PNPS LRA Section 3.6.2.2 will be revised to read as follows: Nguyen, Duc Stroud, Mike "Some of the penetration assemblies at PNPS are not EQ. The Are all electrical and I&C containment penetrations EQ? If non-EQ penetration assemblies are subject to aging management not, provide AMRs and AMPs for non-EQ electrical and I&C review. The aging management review is provided in AMRE-01 and containment penetrations. The AMRs should include both the AMP for penetration assembly pigtails is provided in the non-EQ organic ( XLPE, XLPO, and SR internal conductor/pigtail insulated cables and connections program will manage the aging insulation, etc.,) as well as inorganic material (such as effects of the penetration assembly cables and connections. Table cable fillers, epoxies, potting compounds, connector pins, 3.6.2-1 includes the electrical penetration conductors and plugs, and facial grommets). connections in the line item for electrical cables and connections not subject to 10 CFR 50.49 - EQ."

The structural report for bulk commodities, AMRC-06, addresses the penetration assembly components, seals and sealing elements that form the radiological control barrier for containment in Table 3.5.2-1.

This requires an amendment to the LRA.

Page 16 of 77

Number Status Request Response ARC PNPS Lead 371 Closed [G.3.3.1-P-01] Section 14 includes all the systems that have intended functions Patel, Erach Fronabarger, that meet 10 CFR 54.4(a)(2) for physical interaction. To indicate Tables 3.3.2.14-1 through 3.3.2.14-35 address non-safety individual systems included in the aging management review for related components affecting safety related systems. (a)(2), Table 3.3.2-14 is subdivided by system. For example, Table However, these tables address all such systems in section 3.3.2-14-1 is for the circulating water system, a system which only 3.3, Auxiliary Systems, even though some of these systems has components included for (a)(2). For the core spray system, belong to section 3.2, ESF Systems, and section 3.4, Steam Table 3.3.2-14-7 shows the components included for (a)(2) but since and Power Conversion (S&PC) Systems. Tables 3.3.14-7, the system is also in scope for other reasons, Table 3.3.2-2 shows 14-16, 14-25, and 14-28 are for systems that belong to the components included for 54.4(a)(1) and (a)(3).

Section 3.2; and tables 3.3.14-1, 14-3, 14-5, 14-9, 14-10, 14-11, 14-17, and 14-18 are for systems that belong to The aging management review of the systems that have functions Section 3.4. The Table 1 item reference also specifies that met 10 CFR 54.4(a)(2) for physical interaction was done Tables 3.2.1 and 3.4.1. The audit report and the SER are separately from the review of systems with intended functions that based on systems as defined in GALL Report sections of met 10 CFR 54.4 (a)(1) or (a)(3). The results of this review were ESF, Auxiliary, and S&PC systems. As written in the LRA, it presented separately so that they could be reviewed separately on will make the audit report and SER confusing because the the basis of physical proximity rather than system function. This ESF systems section 3.2 write-up will include Tables from allows a reviewer to clearly distinguish which componenttypes in a section 3.3, and the S&PC systems section 3.4 write-up will system were included for 10 CFR 54.4(a)(2) for physical interaction.

include Tables from section 3.3. Different reviewers write Since most of these systems are auxiliary systems they were added these sections. as part of the auxiliary systems section.

Please justify why the non-safety systems associated with ESF and S&PC systems were included in the Auxiliary system section.

372 Accepted [G.3.3.1-P-02] Since the One-Time Inspection (OTI) Program is applicable to each Patel, Erach Fronabarger, water chemistry control program, it is also applicable to each line Discrepancy between Table 3.3.1 line items and Tables item that credits a water chemistry control program. LRA Table 3.3.2-X for those line items that credit water chemistry or oil 3.3.1 indicates that the One-Time Inspection Program is credited analysis program and a verification program such as along with the water chemistry control programs for line items for one-time inspection (OTI) program. The Table 1 item is which GALL recommends a one-time inspection to confirm water consistent with the GALL report and correctly credits the chemistry control. Table 2 credits the OTI program through chemistry program and the OTI program or for plant-specific reference to the associated Table 1 line item.

program also credits chemistry and OTI programs. However, the Table 2 line items that reference these Table 1 line This requires an amendment to the chemistry program descriptions items do not credit the OTI program. These Table 2 line in LRA Appendices A and B to clearly indicate that the One-Time items however have a footnote 'A', or 'C' which states that it Inspection Program will confirm the effectiveness of the Water is consistent with the MEAP combination in the GALL Chemistry Control - BWR, Water Chemistry Control - Auxiliary Report. Systems and the Water Chemistry Control - Closed Cooling Water programs.

Please justify why the OTI program is not credited in Table 2, even though it is credited in Table 1 and footnote 'A' implies total consistency with GALL for MEAP combination.

Page 17 of 77

Number Status Request Response NRC PNPS Lead 373 Accepted [G.3.3.1-P-03] A Bolting Integrity Program will be developed that will address the Patel, Erach Fronabarger, aging management of bolting in the scope of license renewal. A PNPS does not include Bolting Integrity Program in the LRA, copy of the aging management program basis document for the however credits other programs as alternate to the bolting Bolting Integrity Program will be provided for review with the LRA integrity program. The GALL Report AMP XI.M18, Bolting supplement.

Integrity Program provides several recommendations in the 10-element evaluation, specifically recommendations The Bolting Integrity Program will be implemented prior to the period associated with preventive actions such as selection of of extended operation in accordance with commitment number 32.

bolting material, use of lubricants and sealants and additional recommendations of NUREG-1 339. Some of the This requires an amendment to the LRA to include descriptions of alternate programs may be acceptable for inspection, the Bolting Integrity Program in Appendices A and B and to identify however, they do not address the preventive actions. where the program is applicable.

Please clarify how PNPS meets these recommendations when using alternate programs or please credit a Bolting Integrity Program for the various Table 2 line items as appropriate. For section 3.3, this applies to Table 3.3.1, line items 3.3.1-19, 3.3.1-27, 3.3.1-42, 3.3.1-43, 3.3.1-58, and 3.3.1-78.

374 Accepted [T.3.3.1-P-01] As defined in 10 CFR 54.3, a TLAA is a licensee calculation or Patel, Erach Finnin, Ron analysis that, among other things, involves time-limited Table 3.3.1, item 3.3.1-1, for steel cranes with an aging assumptions defined by the current operating term. There is no effect of cumulative fatigue damage, the GALL recommends analysis for steel cranes at PNPS that satisfies the definition.

TLAA to be evaluated for structural girders of cranes. The CMAA-70 defines allowable stress range based on joint category discussion section states that this line item was not used in and service class. Service class is based on load class (mean section 3.3, however steel cranes are evaluated in section effective load factor) and number of cycles.

3.5. Tables 3.5.2-2 and 3.5.2-4 address cranes but for an aging effect of loss of materials. Cumulative fatigue damage However, the number of cycles is NOT based on 40 years of of cranes is not addressed in section 3.5 or in the TLAA operation of this crane. The anticipated cycles for the PNPS reactor section 4.7 (plant specific TLAA). Also see TLAA question. building crane are well below any of the cycle ranges given in CMAA-70. Based on realistic estimates and the historical rate of use of the cranes to date, the PNPS reactor building and turbine Please explain where this line item is addressed in the LRA. building cranes would take over 350 years to reach the minimum cycle range for CMAA-70. Consequently there is no TLAA associated with crane load cycles.

Page 18 of 77

Number Status Request Response NRC PNPS Lead 375 Closed [T.3.3.1-P-02] Since the One-Time Inspection (OTI) Program is applicable to each Patel, Erach Fronabarger, water chemistry control program, it is also applicable to each line Table 3.3.1, item 3.3.1-5, for heat exchanger exposed to item that credits a water chemistry control program. LRA Table treated water > 60C (>140F), discussion states that OTI will 3.3.1 indicates that the One-Time Inspection Program is credited be used as verification program for water chemistry. along with the water chemistry control programs for line items for However, for those line items in Table 3.3.2-3 where item which GALL recommends a one-time inspection to confirm water 3.3.1-5 is referenced, OTI program is not credited. See chemistry control. Table 2 credits the OTI program through question G.3.3.1.2 above. reference to the associated Table 1 line item.

This requires an amendment to the chemistry program descriptions in LRA Appendices A and B to clearlyindicate that the One-Time Inspection Program will confirm the effectiveness of the Water Chemistry Control - BWR, Water Chemistry Control - Auxiliary Systems and the Water Chemistry Control - Closed Cooling Water programs.

This item is closed to Item 372.

376 Closed [T.3.3.1-P-03] During the performance of routine maintenance on components that Patel, Erach Fronabarger, contain lubricating oil, visual inspections of these components Table 3.3.1, item 3.3.1-14 for steel components exposed to would identify degraded conditions that could be attributed to an lubricating oil, GALL report recommends lubricating oil ineffective Oil Analysis Program. The corrective action program at analysis program and OTI as a verification program. PNPS has a low threshold for the identification of degraded However, in the discussion section only the oil analysis conditions such that corrosion or cracking of components would be program is credited. Section 3.3.2.2.7, item 1 states that identified as part of this program. The review of operating operating experience at PNPS has confirmed the experience at PNPS for the last five years did not identify any effectiveness of this program in maintaining contaminants condition reports that indicated an ineffective oil analysis program or within limits such that corrosion has not and will not affect that identified degraded component conditions such as corrosion or the intended functions of these components. cracking in a lubricating oil environment. This review of operating experience at PNPS serves in lieu of a one-time inspection to Please explain how PNPS can make this statement if provide confirmation of the effectiveness of the Oil Analysis inspection has not been performed. Program.

During the past five years, many visual inspections of components containing lubricating oil have been performed during corrective and preventive maintenance activities. The visual inspections of these components would identify degraded conditions such as corrosion or cracking that could be attributed to an ineffective Oil Analysis Program. PNPS has a low threshold for the identification of degraded conditions such that corrosion or cracking of components would be identified and entered into the corrective action program.

No condition reports that identified degraded component conditions, such as corrosion or cracking in a lubricating oil environment, were initiated as a result of these inspections. These past inspections at PNPS serve in lieu of a one-time inspection to provide ,

confirmation of the effectiveness of the Oil Analysis Program.

Page 19 of 77

Number Status Request Response NJýC PNPS Lead 377 Closed [T.3.3.1-P-04] Since the One-Time Inspection (OTI) Program is applicable to each Patel, Erach Fronabarger, water chemistry control program, it is also applicable to each line Table 3.3.1, item 3.3.1-17 for steel elements exposed treated item that credits a water chemistry control program. LRA Table water discussion states that OTI will be used as verification 3.3.1 indicates that the One-Time inspection Program is crelited program for water chemistry. Refer to question T.3.3.1.2 and along with the water chemistry control programs for line items for G.3.3.1.2. This applies to several line items in various which GALL recommends a one-time inspection to confirm water Table 2's that reference item 3.3.1-17. chemistry control. Table 2 credits the OTI program through reference to the associated Table 1 line item.

This requires an amendment to the chemistry program descriptions in LRA Appendices A and B to clearly indicate that the One-Time Inspection Program will confirm the effectiveness of the Water Chemistry Control - BWR, Water Chemistry Control - Auxiliary Systems and the Water Chemistry Control - Closed Cooling Water programs.

This item is closed to Item 372.

378 Accepted [T.3.3.1-P-05] Enhancements will be made to the Fire Protection program to credit Patel, Erach Fronabarger, existing or implement new preventive maintenance tasks for the fire Table 3.3.1, item 3.3.1-18 for steel and SS diesel engine pump diesel to ensure that all aging effects identified in Table exhaust piping, in the discussion column references section 3.3.2-9 line items that apply to the fire pump diesel components are 3.3.2.2.7 item 3 for further evaluation. Section 3.3.2.2.7 item adequately managed and intended functions are maintained without 3 states that the carbon steel diesel exhaust piping and crediting the detection of leakage as managing an aging effect.

components in the fire protection system is managed by the Fire Protection Program. The Fire Protection Program uses This requires an amendment to LRA appendices A and B.

visual inspections of diesel exhaust piping and components to manage loss of material. However, Appendix B.1.13.1 program description which identifies the system/commodities in scope for inspection does not include the inspection of the diesel exhaust piping and components. There is no enhancement identified in the program write-up to include this inspection during the period of extended operation.

Please explain this discrepancy between section 3.3.2.2.7 item 3 and the AMP B.1.13.1 program description or include this inspection in the AMP as an enhancement.

Page 20 of 77

Number Status Request Response NRC PNPS Lead 379 Closed [T.3.3.1-P-06] During the performance of routine maintenance on components that Patel, Erach Fronabarger, contain lubricating oil, visual inspections of these components Table 3.3.1, item 3.3.1-21 for steel components exposed to would identify degraded conditions that could be attributed to an lubricating oil. This is the same issue as in question ineffective Oil Analysis Program. The corrective action program at T.3.3.1.3 above, except the section is 3.3.2.2.9, item 2. PNPS has a low threshold for the identification of degraded conditions such that corrosion or cracking of components would be identified as part of this program. The review of operating experience at PNPS for the last five years did not identify any condition reports that indicated an ineffective oil analysis program or that identified degraded component conditions such as corrosion or cracking in a lubricating oil environment. 'This review of operating experience at PNPS serves in lieu of a one-time inspection to provide confirmation of the effectiveness of the Oil Analysis Program.

During the past five years, many visual inspections of components containing lubricating oil have been performed during corrective and preventive maintenance activities. The visual inspections of these components would identify degraded conditions such as corrosion or cracking that could be attributed to an ineffective Oil Analysis Program. PNPS has a low threshold for the identification of degraded conditions such that corrosion or cracking of components would be identified and entered into the corrective action program.

No condition reports that identified degraded component conditions, such as corrosion or cracking in a lubricating oil environment, were initiated as a result of these inspections. These past inspections at PNPS serve in lieu of a one-time inspection to provide confirmation of the effectiveness of the Oil Analysis Program.:

This item is closed to Item 376.

380 Closed [T.3.3.1-P-07] Since the One-Time Inspection (OTI) Program is applicable to each Patel, Erach Fronabarger, water chemistry control program, it is also applicable to each line Table 3.3.1, item 3.3.1-23 for SS heat exchanger item that credits a water chemistry control program. LRA Table components exposed to treated water. This is the same 3.3.1 indicates that the One-Time Inspection Program is credited issue as in question T.3.3.1.2 above, except the section is along with the water chemistry control programs for line items for 3.3.2.2.10, item 2. which GALL recommends a one-time inspection to confirm water chemistry control. Table 2 credits the OTI program through reference to the associated Table 1 line item.

This requires an amendment to the chemistry program descriptions in LRA Appendices A and B to clearly indicate that the One-Time Inspection Program will confirm the effectiveness of the Water Chemistry Control - BWR, Water Chemistry Control - Auxiliary Systems and the Water Chemistry Control - Closed Cooling Water programs.

This item is closed to Item 372.

Page 21 of 77

Number Status Request Response NRC PNPS Lead 381 Closed [T.3.3.1-P-08] Since the One-Time Inspection (OTI) Program is applicable to each Patel, Erach Fronabarger, water chemistry control program, it is also applicable to each line Table 3.3.1, item 3.3.1-24 for SS and aluminum components item that credits a water chemistry control program. LRA Table exposed to treated water. This is the same issue as in 3.3.1 indicates that the One-Time Inspection Program is credited question T.3.3.1.2 above, except the section is 3.3.2.2.10, along with the water chemistry control programs for line items for item 2. There are over 80 line items associated with this in which GALL recommends a one-time inspection to confirm water different table 2s. chemistry control. Table 2 credits the OTI program through reference to the associated Table 1 line item.

This requires an amendment to the chemistry program descriptions in LRA Appendices A and B to clearly indicate that the One-Time Inspection Program will confirm the effectiveness of the Water Chemistry Control - BWR, Water Chemistry Control - Auxiliary Systems and the Water Chemistry Control - Closed Cooling Water programs.

This item is closed to Item 372.

382 Closed [T.3.3.1-P-091 During the performance of routine maintenance on components that Patel, Erach Fronabarger, contain lubricating oil, visual inspections of these components Table 3.3.1, item 3.3.1-26 for copper alloy components would identify degraded conditions that could be attributed to an exposed to lubricating oil. This is the same issue as in ineffective Oil Analysis Program. The corrective action program at question T.3.3.1.3 above, except the section is 3.3.2.2.10, PNPS has a low threshold for the identification of degraded.

item 4. conditions such that corrosion or cracking of components would be identified as part of this program. The review of operating experience at PNPS for the last five years did not identify any condition reports that indicated an ineffective oil analysis program or that identified degraded component conditions such as corrosion or cracking in a lubricating oil environment. This review of operating experience at PNPS serves in lieu of a one-time inspection to provide confirmation of the effectiveness of the Oil Analysis Program.

During the past five years, many visual inspections of components containing lubricating oil have been performed during corrective and preventive maintenance activities. The visual inspections of these components would identify degraded conditions such as corrosion or cracking that could be attributed to an ineffective Oil Analysis Program. PNPS has a low threshold for the identification of degraded conditions such that corrosion or cracking of components would be identified and entered into the corrective action program.

No condition reports that identified degraded component conditions, such as corrosion or cracking in a lubricating oil environment, were initiated as a result of these inspections. These past inspections at PNPS serve in lieu of a one-time inspection to provide confirmation of the effectiveness of the Oil Analysis Program.

This item is closed to Item 376.

Page 22 of 77

Number Status Request Response NRC PNPS Lead 383 Closed [T.3.3.1-P-10] Since the One-Tim6 Inspection (OTI) Program is applicable to each Patel, Erach Fronabarger, water chemistry control program, it is also applicable to each line Table 3.3.1, item 3.3.1-30 for SS components exposed to item that credits a water chemistry control program. LRA Table sodium pentaborate solution. This is the same issue as in 3.3.1 indicates that the One-Time Inspection Program is credited question T.3.3.1.2 above, except the section is 3.3.2.2.10, along with the water chemistry control programs for line items for item 8. which GALL recommends a one-time inspection to confirm water chemistry control. Table 2 credits the OTI program through reference to the associated Table 1 line item.

This requires an amendment to the chemistry program descriptions in LRA Appendices A and B to clearly indicate that the One-Time Inspection Program will confirm the effectiveness of the Water Chemistry Control - BWR, Water Chemistry Control - Auxiliary Systems and the Water Chemistry Control - Closed Cooling Water programs.

This item is closed to Item 372.

384 Closed [T.3.3.1-P-1 1] During the performance of routine maintenance on components that Patel, Erach Fronabarger, contain lubricating oil, visual inspections of these components Table 3.3.1, item 3.3.1.33 for SS components exposed to would identify degraded conditions that could be attributed to an lubricating oil. This is the same issue as in question ineffective Oil Analysis Program. The corrective action program at T.3.3.1.3 above, except the section is 3.3.2.2.12, item 2. PNPS has a low threshold for the identification of degraded conditions such that corrosion or cracking of components would be identified as part of this program. The review of operating experience at PNPS for the last five years did not identify any condition reports that indicated an ineffective oil analysis program or that identified degraded component conditions such as corrosion or cracking in a lubricating oil environment. This review of operating experience at PNPS serves in lieu of a one-time inspection to provide confirmation of the effectiveness of the Oil Analysis Program.

During the past five years, many visual inspections of components containing lubricating oil have been performed during corrective and preventive maintenance activities. The visual inspections of these components would identify degraded conditions such as corrosion or cracking that could be attributed to an ineffective Oil Analysis Program. PNPS has a low threshold for the identification of degraded conditions such that corrosion or cracking of components would be identified and entered into the corrective action program.

No condition reports that identified degraded component conditions, such as corrosion or cracking in a lubricating oil environment, were initiated as a result of these inspections. These past inspections at PNPS serve in lieu of a one-time inspection to provide confirmation of the effectiveness of the Oil Analysis Program.

This item is closed to Item 376.

Page23 of 77

Number Status Request Response NRC PNPS Lead 385 Closed [T.3.3.1-P-12.1] Original Type 304 stainless steel piping and fittings between drywell Patel, Erach Taylor, Andy penetration X-14 and the 6" x 4" reducer downstream of MO-1201-5 Table 3.3.1, item 3.3.1-37 for SS components exposed to were replaced with type 316L stainless steel.

treated water >60C (>140F). This line item applies to RWCU system and GALL Report recommends AMP XI.M25, BWR Reactor Water Cleanup System. The applicant states "Supplement 1 to GL 88-01 states that IGSCC inspection of RWCU piping outside of the containment isolation valves is recommended only until actions associated with GL 89-10 on motor operated valves are completed. Since PNPS has satisfactorily completed all actions requested in NRC GL 89-10, the Water Chemistry Control BWR Program is used in lieu of the BWR Reactor Water Cleanup System Program to manage this potential aging effect." However, the AMP also states that in addition to meeting this criterion, piping is made of material that is resistant to IGSCC.

Please confirm what grade of stainless material is used and justify that it is resistant to IGSCC.

386 Closed [T.3.3.1-P-12.2] Since the One-Time Inspection (OTI) Program is applicable to each Patel, Erach Fronabarger, water chemistry control program, it is also applicable to each line Same issue as question T.3.3.1.2 above also applies here item that credits a water chemistry control program. LRA Table where OTI is not credited in Table 2 line items where 3.3.1 indicates that the One-Time Inspection Program is credited 3.3.1-37 is referenced. along with the water chemistry control programs for line items for which GALL recommends a one-time inspection to confirm water chemistry control. Table 2 credits the OTI program through reference to the associated Table 1 line item.

This requires an amendment to the chemistry program descriptions in LRA Appendices A and B to clearly indicate that the One-Time Inspection Program will confirm the effectiveness of the Water Chemistry Control - BWR, Water Chemistry Control - Auxiliary Systems and the Water Chemistry Control - Closed CoolingWater programs.

This item is closed to Item 372.

Page 24 of 77

Number Status Request Response NRC PNPS Lead 387 Closed [T.3.3.1-P-13] Since the One-Time Inspection (OTI) Program is applicable to each Patel, Erach Fronabarger, water chemistry control program, it is also applicable to each line Table 3.31, item 3.31-38 for SS components exposed to item that credits a water chemistry control program. LRA Table treated water >60C (>140F). 3.3.1 indicates that the One-Time Inspection Program is credited This is the same issue as in question T.3.3.1.2 above. along with the water chemistry control programs for line items for which GALL recommends a one-time inspection to confirm water chemistry control. Table 2 credits the OTI program through reference to the associated Table 1 line item.

This requires an amendment to the chemistry program descriptions in LRA Appendices A and B to clearly indicate that the One-Time Inspection Program will confirm the effectiveness of the Water Chemistry Control - BWR, Water Chemistry Control - Auxiliary Systems and the Water Chemistry Control - Closed Cooling Water programs.

This item is closed to Item 372.

388 Accepted [T.3.3.1-P-14] No carbon steel tanks in the fuel oil system exposed to air - outdoor Patel, Erach Nichols, Bill are included in scope for license renewal. The LRA will be Table 3.3.1, item 3.3.1-40 for steel tank in diesel fuel oil amended to remove the line item in table 3.3.2-7 for carbon steel system exposed to air-outdoor external environment. The tanks exposed to air-outdoor. The discussion for line item 3.3.1-40 GALL Report recommends AMP XI.M29 Aboveground Steel will be amended to state the line item is not used.

Tanks, however PNPS is crediting a different program, System Walkdown Program. This program is consistent with This requires a supplement/amendment to the LRA.

GALL Report AMP XI.M36, External Surfaces Monitoring.

While the System Walkdown Program is an acceptable alternate for Aboveground Steel Tanks AMP for inspection, however, the Aboveground Steel Tanks AMP has some preventive actions associated with it that are not addressed in the System Walkdown Program. Furthermore, the GALL AMP specifies wall thickness measurement of tank bottom if it is supported on earthen or concrete foundations.

Please clarify if the steel tanks are coated with protective paint or coating in accordance with industry practice, and whether sealant or caulking is applied at the interface edge between the tank and the foundation as per the GALL AMP XI.M29. Please state how the tank is supported.

Page 25 of 77

Number Status Request Response NRC PNPS Lead 389 Closed 3..3.A-P-¶ 51 A Bolting Integrity Program will be developed that will address the Patel, Erach Fronabarger, aging management of bolting in the scope of license renewal.

Table 3.3.1, item 3.3.1-43, for steel bolting and closure bolting exposed to air - indoor uncontrolled (external) or air - The Bolting Integrity Program will be implemented prior to the period outdoor (External). The GALL Report recommends AMP of extended operation in accordance with commitment number 32.

XI.M18,Bolting Integrity program, however PNPS is crediting a different program, System Walkdown Program. PNPS This requires an amendment to the LRA to include descriptions of indicates that the system walkdown program is similar to the Bolting Integrity Program in Appendices A and B and to identify XI.M36, External Surfaces Monitoring Program. However, the where the program is applicable.

XI.M36 AMP does not have any preventive actions, whereas the Bolting Integrity Program considers preventive action. This item is closed to Item 373.

Please justify how the preventive actions of GALL AMP XI.M18 are addressed in the system walkdown program.

390 Accepted [T.3.3.1-P-16] A Bolting Integrity Program will be developed that will address Patel, Erach Lingenfelter, managing the effects of aging on bolting in the scope of license Table 3.3.1, item 3.3.1-58, for steel external surfaces renewal. The Bolting Integrity Program will be implemented prior to exposed to air - indoor uncontrolled (external), air outdoor the period of extended operation in accordance with commitment (external), and condensation (external). For those line items number 32.

in Table 2's where this Table 1 line item is referenced for bolting, same issue as question T.15 should be addressed. The LRA will be clarified to include Fire Protection Program in the discussion for Item 3.3.1-58 of Table 3.3.1.

In Table 3.3.2-10, LRA page 3.3-123, for tank in Halon The revised discussion text will read as follows: "The System system, which references line item 3.3.1-58, Fire Protection Walkdown Program manages loss of material for external surfaces Program is credited. Please justify why the Fire Protection of steel components. For some fire protection system components, Program was not identified in the discussion column of the Fire Protection Program will manage loss of material." The Note Table 3.3.1, item 3.3.1-58 or supplement the LRA to include for the related line in Table 3.3.2-10 (steel halon tank exposed to this program air) will be changed from "B" to "E".

This requires an amendment to the LRA to include descriptions of the Bolting Integrity Program in Appendices A and B and to identify where the program is applicable.

This first part of this item is closed to Item 373.

The Fire Protection portion of this item requires an amendment to the LRA.

Page26of77

Number Status Request Response NRC PNPS Lead 391 Accepted [T.3.3.1-P-17] In Table 3.5.2-6 on Page 3.5-82 of the LRA, the aging effects for the Patel, Erach Lingenfelter, elastomer components penetration sealant and seismic joint filler in Table 3.3..1, item 3.3.1-61, for elastomer fire barrier a protected from weather environment are cracking and change in penetration seals exposed to air- outdoor or air indoor material properties. Depending on the specific application, the Fire uncontrolled. PNPS credits Fire Protection Program and Protection Program or the Structures Monitoring Program will states in the discussion column that this line item was not manage the effects of aging. For clarification, these component line used in the auxiliary systems tables. Fire barrier seals are items will be separated into individual line items as follows.

evaluated as structural components in Section 3.5. Cracking and the change in material properties of elastomer seals are Delete the following line items:

managed by the Fire Protection Program. Penetration sealant(fire rated, flood, radiation) H EN, FB, FLB, PB, SNS HIElastomer / Protected from weather / Cracking Change in However, in section 3.5, Table 3.5.2-6, Bulk Commodities, material properties//Fire protection/Structures Monitoring // II.A6-12 on pages 3.5-82, and 3.5-83, where line item 3.3.1-61 is (TP-7)// 3.5.1-44 1/ C referenced, PNPS credits the Fire Protection Program and the Structures Monitoring program. However, line item Seismic joint filler // FB, SNS // Elastomer // Protected from weather 3.3.1-61 does not credit structures monitoring program. As a /HCracking Change in material properties // Structures Monitoring, matter of fact, the Structures Monitoring Program is Fire Protection /I VII.G-1 (A-19) /H3.3.1-61 // C enhanced to add guidance for inspection of elastomer seals, etc. Please clarify if both programs are credited for Add the following line items:

managing aging effects for penetration seals as stated in Penetration sealant (fire rated) // EN, FB, PB, SNS HIElastomer //

Table 3.5.2-6, and if so, please supplement the LRA to Protected from weather /I Cracking Change in material properties //

include the Structures Monitoring program in Table 3.3.1, Fire Protection It VII.G-1(A-19) 1/ 3.3.1-61 // B item 3.3.1-61.

Penetration sealant (flood, radiation) // EN, FLB, PB, SNS //

Elastomer It Protected from weather// Cracking Change in material properties // Structures Monitoring // II.A6-12 (TP-7) // 3.5.1-44 // C Seismic isolation joint // FB, SNS // Elastomer // Protected from weather // Cracking Change in material properties // Fire protection//

VII.G-1 (A-19) // 3.3.1-61 // D Seismic isolation joint /I SNS // Elastomer // Protected from weather

// Cracking Change in material properties It Structures monitoring //

III.A6-12 (TP-7) // 3.5.1-44 // C This requires an amendment to the LRA.

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Number Status Request Response ARC PNPS Lead 392 Accepted [T.3;3.1-P-18] PNPS has a diesel driven fire pump with components addressed in Patel, Erach Fronabarger, Table 3.3.2-9. The fuel oil supply to the diesel driven fire pump is Table 3.3.1, item 3.3.1-64 for steel piping, piping included in Table 3.3.2-7. The line item of carbon steel piping with components, and piping elements exposed to fuel oil. The a fuel oil internal environment in Table 3.3.2-7 for the fuel supply intent of this line is to address the diesel-driven fire pump, line does not credit the Fire Protection Program. Although the which is why the Fire Protection Program is recommended by programs credited in Table 3.3.2-7 for the fuel supply line provide an the GALL Report. PNPS states that this line item was not acceptable alternative approach to manage the effects of aging, in used. Loss of material of steel components exposed to fuel order to achieve consistency with NUREG-1 801 the LRA will be oil was addressedby other items including line Items 3.3.1 revised to credit the Fire Protection Program. LRA Table 3.3.2-7 will 20 and 3.3.1 32. The Fire Protection program specifies that be revised to add an additional line item to credit the Fire Protection the diesel driven fire pump be periodically tested to ensure Program to manage the fuel supply line in addition to the Diesel that the fuel supply line can perform its intended function. Fuel Monitoring Program. This will also require a change to line PNPS B.1.13.1 has not taken any exception to this test and item 3.3.1-64 since the new line item will specify 3.3.1-64 as the is identified as being consistent with the GALL program. Table 1 item.

However, B.1.13.1, Fire Protection program is not credited in line item 3.3.1 20. This requires an amendment to the LRA.

Please clarify if PNPS has a diesel driven fire pump and if not, should an exception be taken to the GALL Report AMP.

If PNPS does have a diesel driven fire pump, where in the LRA section 3.3 is it addressed and is the Fire Protection program credited.

393 Closed [T.3.3.1-P-19] The internal components of the heat exchanger housing have the Patel, Erach Orlicek, Jack potential for being exposed to a combination of low temperature Table 3.3.1, item 3.3.1-72 for steel HVAC ducting and closed cooling water and high dewpoint indoor drywell air which components internal surfaces exposed to condensation could result (though not expected) in condensation on the cooling (Internal). However, there is only line in Table 2 where this coil that would be collected in the bottom of the housing. '

Table 1 line item is referenced. This line item is in Table Condensation was also identified on the un-insulated external 3.3.2-3, RBCCW system and the component is heat surfaces of the heat exchanger housing due to the potential of the exchanger housing. PNPS states in the discussion column housing surface temperature downstream of the cooling coil being of line 3.3.1-72 that loss of material of steel component less than or equal to the dew point of the surrounding air in the internal surfaces exposed to condensation is managed by drywell. These environments were conservatively identified even the System Walkdown Program. The System Walkdown though the expected environment would be indoor air with no Program manages loss of material for external carbon steel condensation since the cooling water temperature is normally components by visual inspection of external surfaces. For maintained at - 80°F. System Walkdown was credited because the systems where internal carbon steel surfaces are exposed to expected environment for both the internal and external surfaces the same environment as external surfaces, external would be the same in either case.

surfaces condition will be representative of internal surfaces.

Thus, loss of material on internal carbon steel surfaces is also managed by the System Walkdown Program.

Please clarify how PNPS concluded that the internal surface of the heat exchanger is the same as the external surface in the RBCCW system.

Page 28 of 77

Number Status Request Response NRC PNPS Lead 394 Accepted [T.3.3.2-P-01] Since it manages internal and external surfaces with the same Patel, Erach Fronabarger, material and environments, the System Walkdown Program Component types filter housing and turbo charger in Table described in 8.1.30 is a more appropriate program for the line items 3.3.2-9, Fire Protection - Water system and piping in Table in Table 3.3.2-9 that have indoor air (int) as an environment and 3.3.2-10, Fire Protection - Halon system reference Table credit the Fire Protection Program. In addition, line item 3.2.1-32 3.2.1, item 3.2.1-32. This Table 1 line item addresses steel should include the Fire Protection Program since Table 3.3.2-10 piping and ducting components and internal surfaces includes Halon system piping internal surfaces that credit the Fire exposed to air-indoor uncontrolled (internal) environment. Protection Program and rollup to this line item.

Discussion column of item 3.2.1-32 credits System Walkdown, Periodic Surveillance and Preventive This requires an amendment to the LRA.

Maintenance, and One-Time Inspection programs. However, the Table 3.3.2-9 and Table 3.3.2-10 components identified above credit Fire Protection Program, which is not credited in the discussion column of item 3.2.1-32. Furthermore, the program description of LRA Appendix B.1.13.1, Fire Protection Program does not include inspection of the above identified components.

Please clarify the discrepancy between the credited programs in item 3.2.1-32 and the program credited for the above identified component types. Also, please justify why the Fire Protection program description does not address inspection of these component types in these two systems or enhance the program to include these inspections.

395 Closed [T.3.3.2-P-02] During the performance of routine maintenance on components that Patel, Erach Fronabarger, contain lubricating oil, visual inspections of these components Component types heat exchanger tubes in Table 3.3.2-4, would identify degraded conditions that could be attributed to an Emergency Diesel Generator system and Table 3.3.2-9, Fire ineffective Oil Analysis Program. The corrective action program at Protection - Water system are made from copper alloy and PNPS has a low threshold for the identification of degraded ý exposed to lubricating oil environment, which reference conditions such that corrosion or cracking of components would be Table 3.2.1, item 3.2.1-9. PNPS only credits the Oil identified as part of this program. The review of operating Analysis program. This issue is the same as in question experience at PNPS for the last five years did not identify any T.3.3.1.3. condition reports that indicated an ineffective oil analysis program or that identified degraded component conditions such as corrosion or cracking in a lubricating oil environment. This review of operating experience at PNPS serves in lieu of a one-time inspection to provide confirmation of the effectiveness of the Oil Analysis Program.

See response to item 376.

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Number Status Request Response ARC PNPS Lead 396 Closed [T.3.3.2-P-03] During the performance of routine maintenance on components that Patel, Erach Fronabarger, contain lubricating oil, visual inspections of these components Component types heat exchanger tubes in Table 3.3.2-5, would identify degraded conditions that could be attributed to an Station Blackout diesel Generator system, and Table 3.3.2-6, ineffective Oil Analysis Program. The corrective action program at Security Diesel Generator system are made from steel and PNPS has a low threshold for the identification of degraded exposed to an external environment of fuel oil with an aging conditions such that corrosion or cracking of components would be effect of reduction of heat transfer due to fouling, which identified as part of this program. The review of operating reference Table 3.4.1, item 3.4.1-10. PNPS only credits the experience at PNPS for the last five years did not identify any Oil Analysis program. This issue is the same as in question condition reports that indicated an ineffective oil analysis program or T.3.3.1.3 that identified degraded component conditions such as corrosion or cracking in a lubricating oil environment. This review of operating Also, please clarify why one of the above component type experience at PNPS serves in lieu of a one-time inspection to identifies footnote 'D', whereas the other identifies footnote provide confirmation of the effectiveness of the Oil Analysis

'E', even though they have the same MEAP combination. Program.

During the past five years, many visual inspections of components containing lubricating oil have been performed during corrective and preventive maintenance activities. The visual inspections of these components would identify degraded conditions such as corrosion or cracking that could be attributed to an ineffective Oil Analysis Program. PNPS has a low threshold for the identification of degraded conditions such that corrosion or cracking of components would be identified and entered into the corrective action program.

No condition reports that identified degraded component conditions, such as corrosion or cracking in a lubricating oil environment, were initiated as a result of these inspections. These past inspections at PNPS serve in lieu of a one-time inspection to provide confirmation of the effectiveness of the Oil Analysis Program.

This item is closed to Item 376.

397 Closed [T.3.3.2-P-04] Since the One-Time Inspection (OTI) Program is applicable to each Patel, Erach Fronabarger, water chemistry control program, it is also applicable to each line Steel component types thermowell, tubing and valve body in item that credits a water chemistry control program. LRA Table Table 3.3.2-14-19, Off-Gas system reference Table 3.4.1, 3.4.1 indicates that the One-Time Inspection Program is credited item 3.4.1-13, which credits water chemistry and one-time along with the water chemistry control programs for line items for inspection program for verification. However the table 2 line which GALL recommends a one-time inspection to confirm water items do not credit the verification program. This is the chemistry control. Table 2 credits the OTI program through same issue as questions G.3.3.1.2 and T.3.3.1.2. reference to the associated Table 1 line item.

This requires an amendment to the chemistry program descriptions in LRA Appendices A and B to clearly indicate that the One-Time Inspection Program will confirm the effectiveness of the Water Chemistry Control - BWR, Water Chemistry Control - Auxiliary Systems and the Water Chemistry Control - Closed Cooling Water programs.

This item is closed to Item 372.

Page 30 of 77

Number Status Request Response NRC PNPS Lead 398 Closed [T.3.3.2-P-05] Since the One-Time Inspection (OTI) Program is applicable to each Patel, Erach Fronabarger, water chemistry control program, it is also applicable to each line Stainless steel component types thermowell, tubing and item that credits a water chemistry control program. LRA Table valve body in Table 3.3.2-14-19, Off-Gas system reference 3.4.1 indicates that the One-Time Inspection Program is credited Table 3.4.1, item 3.4.1-14, which credits water chemistry and along with the water chemistry control programs for line items for one-time inspection program for verification. However the which GALL recommends a one-time inspection to confirm water table 2 line items do not credit the verification program. This chemistry control. Table 2 credits the OTI program through is the same issue as questions G.3.3.1.2 and T.3.3.1.2. reference to the associated Table 1 line item.

This requires an amendment to the chemistry program descriptions in LRA Appendices A and B to clearly indicate that the One-Time Inspection Program will confirm the effectiveness of the Water Chemistry Control - BWR, Water.Chemistry Control - Auxiliary Systems and the Water Chemistry Control - Closed Cooling Water programs.

This item is closed to Item 372.

399 Closed [T.3.3.2-P-06] Since the One-Time Inspection (OTI) Program is applicable to each Patel, Erach Fronabarger, water chemistry control program, it is also applicable to each line Steel component types ejector, heat exchanger shell, orifice, item that credits a water chemistry control program. LRA Table piping, pump casing, thermowell, and valve body in Table 3.4.1 indicates that the One-Time Inspection Program is credited 3.3.2-14-19, Off-Gas system reference Table 3.4.1, item along with the water chemistry control programs for line items for 3.4.1-2, which credits water chemistry and one-time which GALL recommends a one-time inspection to confirm water inspection program for verification. However the table 2 line chemistry control. Table 2 credits the OTI program through items do not credit the verification program. This is the reference to the associated Table 1 line item.

same issue as questions G.3.3.1.2 and T.3.3.1.2.

This requires an amendment to the chemistry program descriptions in LRA Appendices A and B to clearly indicate that the One-Time Inspection Program will confirm the effectiveness of the Water Chemistry Control - BWR, Water Chemistry Control - Auxiliary Systems and the Water Chemistry Control - Closed Cooling Water programs.

This item is closed to Item 372.

400 Accepted [T.3.3.2-P-07] The appropriate entries for the last three columns for the line in Patel, Erach Lingenfelter, Table 3.3.2-14-27, RWCU system, steel component type heat Table 3.3.2-14-27, RWCU system, steel component type exchanger shell, in treated water environment with an aging effect of heat exchanger shell, in treated water environment with an loss of material, are VII.C2-14 (A-25), 3.3.1-47, and D.

aging effect of loss of material, PNPS credits Water Chemistry Control - Closed Cooling Water program and This requires an amendment to the LRA.

references Table 3.3.1, line item 3.3.1-17. However, line item 3.3.1-17 addresses Water Chemistry Control - BWR program.

Should line item 3.3.1-47 be referenced, which addresses the Water Chemistry Control - Closed Cooling Water for-the same MEAP combination? Please supplement the LRA accordingly.

Page31 of 77

Number Status Request Response NRC PNPS Lead 401 Accepted [T.3.3.2-P-08] The appropriate Table 1 Item entry for the line in Table 3.3.2-14-27, Patel, Erach Lingenfelter, RWCU system, stainless steel component type orifice, in treated Table 3.3.2-14-27, RWCU system, stainless steel water environment with an aging effect of loss of material, is component type orifice, in treated water environment with an 3.3.1-24.

aging effect of loss of material, references Table 3.3.1, line item 3.3.1-17. However, this line item is for steel This requires an amendment to the LRA.

components.

Should line item 3.3.1-24 be referenced, which addresses stainless steel components for the same EAP? Please supplement the LRA accordingly.

402 Closed [3.5.2.2.1.4-H-01] As stated in Section 3.5.2.2.1.4, PNPS inspections of the drywell Hoang, Dan Ahrabli, Reza shell below floor level identified no evidence of corrosion of the Loss of material due to General, Pitting and Crevice drywell shell. The drywell shell steel has a coated surface and no Corrosion. degradation of this coating was identified. The statement in question is not addressing the current condition but rather the Please, explain for your last statement in this section as it conditions expected in the future. It is difficult to say there will be said: "Therefore, significant corrosion of the drywell shell is absolutely no corrosion in the future, but there is reasonable not expected". Does this mean you DO have some assurance that corrosion, if any, will not be significant or meaningful corrosion? If not, why significant? with respect to degradation.

403 Closed [3.5.2.2.1.7-H-01O The "other" method which may be used to detect cracking is the Hoang, Dan Ahrabli, Reza existing Containment Leak Rate Program with augmented ultrasonic Stress Corrosion Cracking (SCC) becomes significant for exams. Observed conditions that have the potential for impacting an stainless steel if a tensile stress and a corrosion intended function are evaluated or corrected in accordance with the environment exist. The stress may be applied external or corrective action process. The Containment Leak Rate Program is residual (internal). Visual VT-3 examinations may be unable described in Appendix B.

to detect this aging effect. Potential susceptible components at PNPS are penetration sleeves and bellows.

Please identify the "Other" method of examination to detect this style of effect?

404 Closed [3.5.2.2.2.1-H-01] As stated in Section 3.5.2.2.2.1 of the LRA, PNPS has no structures Hoang, Dan Ahrabli, Reza that are not covered by Structures Monitoring Program that are within Aging of structures not covered by Structures Monitoring the scope of license renewal and subject to aging management Program. review.

Do you (PNPS) have any operating experience related to this area? Please, provide the details.

405 Closed [3.5.2.2.2.1.8-H-01] The lubrite plates associated with the radial beam seats are Hoang, Dan Ahrabli, Reza inspected under the Structures Monitoring Program. The lubrite Lock Up due to wear for Lubrite Radial beam Seats in BWR plates associated with the torus support structure are inspected by drywell and other Sliding Support Surfaces.. As indicated in the ISI (IWF) program.

this section that "...lock-up due to wear is not an aging effect requiring management at PNPS. However, Lubrite plates are including within the Structures Monitoring Program and Inservice Inspection (ISI-IWF) Programs..." Please, provide the cross reference in between these two programs.

Page 32 of 77

Number Status Request Response NRC PNPS Lead 406 Closed [3.5.2.2.2.6-H-01] Need clarification. What is meant by "the bolting integrity generic Hoang, Dan Ahrabli, Reza issue"?.

Aging Support not covered by Structures Monitoring Program.

Please provide: 1) Bolting material at PNPS consists of A325 - Type 1 conforming to ASTM-A325 and A490 Type 1 conforming to ASTM-A490, per

1. More information is needed about bolting materials used PNPS specification C-94-ER-Q-E3. The nominal yield strength for in structural applications at PNPS including Group B1.1 A325 is 92 ksi and for A490 is 130 ksi. For structural bolting applications. What are the bolting materials used? What applications, PNPS is consistent with NUREG 1801 in managing are the nominal yield strengths and upper-bound as-received the effects of aging with the structures monitoring program or ISI yield strengths? Describe the PNPS resolution of the bolting (IWF), as applicable. No PNPS bolting has been identified that is integrity generic issue, as it relates to structural bolting. susceptible to SCC.

Was any structural bolting identified as potentially susceptible to cracking due to SCC? Was any structural 2) In general, PNPS manages loss of material for bolting with visual bolting replaced as part of the resolution? inspections. For structural bolting, the visual inspections are part of the Structures Monitoring Program. Loss of preload due to stress

2. Describe the scope and AMR for Class MC Pressure relaxation (creep) would only be a concern in very high temperature Retaining Bolting. How is loss of preload managed? applications (> 700°F) as stated in the ASME Code,Section II, Part D, Table 4. No PNPS structural bolting operates at >700°F.

Therefore, loss of preload due to stress relaxation (creep) is not an applicable aging effect for structural bolting. Other causes of loss of preload include inadequate bolted joint design and ineffective maintenance practices. Loss of preload due to these causes is prevented by incorporation of industry guidance for good bolting practices into PNPS procedures for design and maintenance of bolted joints.

407 Accepted [3.5.1-13-H-01] Line item 3.5.1-13 addresses steel, stainless steel elements, Hoang, Dan Ahrabli, Reza dissimilar metal welds: torus; ventline; vent header; ventline bellows In Table 3.5.2-1 on Page 3.5-51 of the LRA, for component and downcomers. For PNPS ventline bellows and associated Bellows the AMPs shown is ClI-lWE, which is a welds, this line item is consistent with the NUREG-1801 AMR plant-specific AMP. A Note C has been assigned to this results, but the PNPS CII-IWE program described in Appendix B is a AMR line item, component is different, but consistent with plant-specific program. The Drywell to torus vent line bellows item material, environment, aging effect, and aging management on LRA Page 3.5-51 references line item 3.5.1-13 and correctly program for NUREG-1801 line item. This AMP is consistent indicates Note "E".

with NUREG-1801 the GALL description.

For the Bellows (reactor vessel and drywell) line item in Table Table 1 line item 3.5.1-13 bellows. Explain how the 3.5.2-1 on Page 3.5-51 of the LRA, reference to line item 3.5.1-13 is plant-specific PNPS CII-IWE AMP is consistent with the not appropriate. The Table 3.5.2-1 line item "Bellows (reactor GALL specified AMP. vessel and drywell)" and the corresponding line item in Table 2.4-1, Page 2.4-13, were inadvertently included in the LRA and should be deleted. The reactor vessel and drywell bellows perform no license renewal intended function. These components are not safety-related and are not required to demonstrate compliance with regulations identified in 10 CFR 54.4(a)(3). Failure of the bellows will not prevent satisfactory accomplishment of a safety function.

Leakage, if any, through the bellows is directed to a drain system that prevents the leakage from contacting the outer surface of the drywell shell.

Deleting the line items discussed above requires an amendment to the LRA.

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Number Status Request Response NRC PNPS Lead 408 Accepted [3.5.1-16-H-01O PNPS primary containment does not have a moisture barrier. Hoang, Dan Ahrabli, Reza Therefore an AMP is not required. The referenced line item on Page In Table 3.5.2-1 on page 3.5-55 of the LRA for Primary 3.5-55 applies only to primary containment electrical penetration Containment Etectrcal Penetration seals and sealant, the seals and sealant.

AMP shown is Structures Monitoring. The applicant is asked to verify that the ClI-IWE AMP will not be used instead to Table Line Item 3.5.1-16 will be updated to read: "The aging effects manage the aging of the moisture barrier. cited in the NUFREG-1801 item are loss of sealing and leakage.

Loss of sealing is a consequence of the aging effects cracking and change in material properties. For PNPS, the Containment Leak Rate program manages cracking and change in material properties for the primary containment seals and gaskets. There is no moisture barrier where the drywell steel shell becomes embedded in the drywell concrete floor."

This requires an amendment to the LRA.

409 Accepted [3.5.1-44-H-01] In Table 3.5.2-6 on Page 3.5-83 of the LRA, for component seals Hoang, Dan Ahrabli, Reza and gaskets, material rubber in a protected from weather In Table 3.5.2-6 on Page 3.5-83 of the LRA, for component environment, Note "E" was used because it applies to the top half of seals and gaskets, material rubber in a protected from the line item. The LRA will be clarified to indicate that Note "A" weather environment; the aging effects are cracking and applies to the lower half of the line item.

change in material properties. One of the aging management programs shown is the Structures Monitoring This requires an amendment to the LRA.

Program. The GALL line item referenced is III.A6-12 and the Table 1 reference is 3.5.1-44. The note shown is E, a different AMP than shown in GALL. However, GALL Line Item I1.A6-12 and Table 1 Line Item 3.5.1-44 both specify the Structures Monitoring Program. Explain why the note shown is not A instead of E for the lower half of this AMR line item.

410 Accepted [3.5.1-58-H-01] NUREG-i 801 does not mention every type of component that may be Hoang, Dan Ahrabli, Reza subject to aging management review (e.g., panel is not in In Table 3.5.2-6 on Page 3.5-73 of the LRA, for component NUREG-1801) nor does the terminology used at a specific plant electrical and instrument panels and enclosures, material always align with that used in GALL. Consequently, matching plant galvanized steel in a protected from weather environment; the components to NUREG-1 801 components is often subjective. In aging effect is none. The GALL line item referenced is this particular case, panels, which have no specific function other III.B3-3, which is for the following components: Support than to support and protect electrical equipment, were considered rhembers; welds; bolted connections; support anchorage to support members and Note A was applied. The use of either Note A building structure. Explain why the LRA AMR line item has a or C has no impact on the aging management review results.

Note A shown instead of a Note C, different component with respect to the GALL line item. Or as an alternative, a letter Note "A" will be changed to Note "C" for component electrical and Note A with a number note explaining that the component is instrument panels and enclosures, material galvanized steel in a different. protected from weather environment in Table 3.5.2-6 on Page 3.5-73 of the LRA. No change is required to the other entries for this line item.

This requires an amendment to the LRA.

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Number Status Request Response NRC PNPS Lead 411 Accepted [3.5.1-8-H-01O For Table 3.5.2-1 on Page 3.5-54 of the LRA for component Torus Hoang, Dan Ahrabli, Reza shell with the aging effect cracking-fatigue, Note "E" will be changed In Table 3.5.2-1 on Page 3.5-54 of the LRA foT component to Note "A".

Torus shell with the aging effect cracking-fatigue, the note assigned is E. Note E is consistent with NUREG-1801 This requires an amendment to the LRA.

material, environment, and aging effect but a different aging management program is credited. Explain why this note is E when the AMP shown for this line item is TLAA and the referenced GALL Line Item 113.1.1-4 also specifies a TLAA.

412 Accepted [3.5.1-5-H-01] For LRA Table 3.5.1, Item 3.5.1-5, the discussion in Section Hoang, Dan Ahrabli, Reza 3.5.2.2.1.4, Page 3.5-9, should have the reference to moisture barrier LRA table 3.5.1, Item Number 3.5.1-5, has the following deleted, since the PNPS drywell does not contain this commodity.

statement under the discussion column: "The drywell steel where the drywell shell is embedded is inspected in accordance with the Containment Inservice Inspection (IWE) For LRA Table 3.5.1, Item 3.5.1-5, the discussion column should Program and Structures Monitoring Program". This is an read: "The drywell steel shell and the area where the drywell shell difficult inspection. Change this discussion statement to becomes embedded in the drywell concrete floor are inspected in agree with LRA Section 3.5.2.2.1.4 that states: The drywell accordance with the Containment Inservice Inspection (IWE) steel shell and the moisture barrier where the drywell shell Program."

becomes embedded in the drywell concrete floor are inspected in accordance with the Containment Inservice The last sentence of the first paragraph in LRA Section 3.5.2.2.1.4, Inspection (IWE) Program and Structures Monitoring should read: "The drywell steel shell and the area where the drywell Program. shell becomes embedded in the drywell concrete floor are inspected in accordance with the Containment Inservice Inspection (IWE)

Program."

This requires an amendment to the LRA.

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Number Status Request Response NRC PNPS Lead 413 Accepted [3.5.1-9-H-01] Fatigue analyses have been evaluated for the torus, torus vent Hoang, Dan Ahrabli, Reza system, and torus penetrations. The following line will be added to LRA Table 3.5.1, Item Number 3.5.1-9, has the following Table 3.5.2-1: "Torus mechanical penetrations II PB, SSR // Carbon statement under the discussion column: Not applicable. steel // Protected from weather// Cracking II TLAA-metal fatigue//

See Section 3.5.2.2.1. This should be read as Section I1.B4-4(C-13) H 3.5.1-9//A" 3.5.2.2.1.6. However, the following statement is made in LRA Section 3.5.2.2.1.6: "Fatigue TLAAs for the steel The evaluation of the torus vent system fatigue analysis determined drywell, torus, and associated penetrations are evaluated that it was not a TLAA. The significant contributor to fatigue of the and documented in Section 4.6." The components vent system is post-LOCA chugging, a once in plant-life event. As associated with LRA Table 3.5.1, Item Number 3.5.1-9 are: there will still be only one design basis LOCA for the life of the penetration sleeves, penetration bellows; suppression pool plant, including the period of extended operation, this analysis is not shell, unbraced downcomers. Explain how Item number based on a time-limited assumption and is not a TLAA. Fatigue for 3.5.1-9 is not applicable when a fatigue TLAA has been the vent system is event-driven and is not an age-related effect.

performed for the torus and penetrations. Explain why the vent line, vent header and vent line bellows are not listed in The discussion column entry for Table 3.5.1 item 3.5.1-8 will be LRA Sections 3.5.2.2.1.6 and 4.6 as referenced in Table changed to read as follows: "Fatigue analysis is a TLAA for the 3.5.1, Line Item 3.5.1-8. torus shell. Fatigue of the vent system is event-driven and the analysis is not a TLAA. See Section 3.5.2.2.1.6."

The discussion column entry for Table 3.5.1 item 3.5.1-9 will be changed to read as follows: "Fatigue analysis is a TLAA for the torus penetrations. See Section 3.5.2.2.1.6."

Section 3.5.2.2.1.6 will be changed to read as follows: "TLAA are evaluated in accordance with 10 CFR 54.21 (c) as documented in Section 4. Fatigue TLAAs for the torus and associated penetrations are evaluated and documented in Section 4.6."

Section 3.5.2.3, Time-Limited Aging Analyses, will be changed to read as follows: "TLAA identified for structural components and commodities include fatigue analyses for the torus and torus penetrations. These topics are discussed in Section 4.6."

These changes require an amendment to the LRA.

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Numher Status Request Response NRC PNPS Lead 414 Accepted [3.5.1-12-H-01] A link from items 3.5.1-12 and 3.5.1-13 will be added to section Hoang, Dan Ahrabli, Reza 3.5.2.2.1.8.

LRA Table 3.5.1, Item Number 3.5.1-12 and 3.5.1-13, under the discussion column, does not make reference to LRA Section 3.5.2.2.1.8 should state: "Cyclic loading can lead to Section 3.5.2.2.1.8 for further evaluation. Explain why this cracking of steel and stainless steel penetration bellows, and link is not made to the further evaluation section. Explain the dissimilar metal welds of BWR containments and BWR need for augmented ultrasonic exams to detect fine cracks suppression pool shell and downcomers."

since a CLB fatigue analysis does exist.

Cracking due to cyclic loading is not expected to occur in the drywell, torus and associated penetration bellows, penetration sleeves, unbraced downcomers, and dissimilar metal welds. A review of plant operating experience did not identify cracking of the components and primary containment leakage has not been identified as a concern. Nonetheless, the Containment Leak Rate Program with augmented ultrasonic exams and Containment Inservice Inspection - IWE, will continue to be used to detect cracking. Observed conditions that have the potential for impacting an intended function are evaluated or corrected in accordance with the corrective action process. The Containment Inservice Inspection - WE and Containment Leak Rate programs are described in Appendix B.

This requires an amendment to the LRA.

415 Closed [3.5.1-16-H-01] There is no gap to seal at the joint between the containment drywell Hoang, Dan Ahrabli, Reza shell and the concrete floor. Concrete grout is poured directly LRA Table 3.5.1, Item Number 3.5.1-16, under the against the drywell shell. The installation is shown as Detail 1 on discussion column, states that seals and gaskets are not Drawing C-71. The Containment Inservice Inspection Program included in the Containment Inservice Inspection Program at includes inspection of this joint.

PNPS. One of the components for this item number is moisture barriers. Explain how PNPS seals the joint (Also see audit question #408 which addresses changes to LRA) between the containment drywell shell and drywell concrete floor if there is no moisture barrier. Explain why the inspection of this joint is not part of the Containment Inservice Inspection Program.

416 Closed [3.5.1-33-H-01] The maximum bulk area ambient temperatures for Groups 1-5 occurs Hoang, Dan Ahrabli, Reza in the drywell and is an average temperature of 148°F, reference For LRA Table 3.5.1, Item Number 3.5.1-33, provide the UFSAR Table 5.2-2. For structures outside the drywell the bulk area maximum temperatures that concrete experience in Group maximum temperature is 120°F for Groups 1-5 structures as 1-5 structures. identified in Table 10.9-2 of PNPS UFSAR. Concrete within the drywell consist of the reactor pedestal, sacrificial shield wall and the drywell floor. Assurance that bulk concrete temperatures within the drywell remain below 150 degrees F is obtained through maintaining average bulk containment temperature within the limits allowed by PNPS Technical Specification Section 3.2-H (Page 3/4.2-5). Although upper elevations of the drywell may exceed 150'F, the concrete of the drywell is at lower elevations. The drywell cooling system provides cooling to ensure temperature limits are not exceeded. The highest concrete in the drywell is the sacrificial shield wall. The concrete in this wall is not load bearing.

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Number Status Request Response NRC PNPS Lead 417 Accepted [3.5.1-34-H-01] NUREG-1800, Item Number 3.5.1-34 indicates that further evaluation Hoang, Dan Ahrabli, Reza is necessary only for aggressive environments. No reference was LRA Table 3.5.1, Item Number 3.5.1-34, under the provided to further evaluation in LRA Section 3.5.2.2.2.4 (1) since discussion column, does not make reference to LRA Section the PNPS environment is not aggressive as noted in LRA Table 3.5.2.2.2.4 (1) for further evaluation. Explain why this link is 3.5.1, Item Number 3.5.1-34, under the discussion column.

not made to the further evaluation section.

For clarification, LRA Table 3.5.1, Line Item 3.5.1-34 discussion will be revised to add "See Section 3.5.2.2.2.4(1 )".

This requires an amendment to the LRA.

418 Accepted [3.5.1-35-H-01] For clarification, LRA Table 3.5.1, Item 3.5.1-35 discussion will be Hoang, Dan Ahrabli, Reza revised to add reference to Section 3.5.2.2.2.4(2). LRA Table 3.5.1, LRA Table 3.5.1, Item Number 3.5.1-35, under the Item 3.5.1-35 discussion will be revised to refer to ACI 318 in lieu of discussion column, does not make reference to LRA Section ACI-301, since the provided reference to ACI should have been ACI 3.5.2.2.2.4 (2) for further evaluation. Explain why this link is 318 and not ACI 301.

not made to the further evaluation section.

This requires an amendment to the LRA.

419 Accepted [3.5.1-36-H-01] LRA Table 3.5.1, Line item Number 3.5.1-36 discussion will be Hoang, Dan Ahrabli, Reza revised to read as follows: "Reaction with aggregates is not an LRA Table 3.5.1, Item Number 3.5.1-36, under the applicable aging mechanism for PNPS concrete components. See discussion column, does not make reference to LRA Section Section 3.5.2.2.2.1(5) (although for Groups 1-5, 7, 9 this discussion 3.5.2.2.2.4 (3) for further evaluation. Explain why this link is is also applicable for Group 6) and Section 3.5.2.2.2.4(3) additional not made to the further evaluation section. The statement: discussion. Nonetheless, the Structures Monitoring Program will "See Section 3.5.2.2.2.1 (5) for additional discussion" needs confirm the absence of aging effects requiring management for further clarification that this section is for Groups 1-5, 7-9, PNPS Group 6 concrete components."

however it would apply to accessible Group 6 concrete.

Explain why LRA Section 3.5.2.2.2.4 (3) lists cracking of Due to an administrative oversight, the heading of LRA Section concrete due to Stress Corrosion Cracking (SCC). 3.5.2.2.2.4 (3) inadvertently lists cracking of concrete due to Stress Corrosion Cracking (SCC). This section heading should have begun with "Cracking Due to Expansion and Reaction with Aggregates...".

Stress corrosion cracking is not discussed in the body of this section.

This change requires an amendment to the LRA.

420 Accepted [3.5.1-40-H-01] Building concrete at locations of expansion and grouted anchors; Hoang, Dan Ahrabli, Reza grout pads for support base plates are shown as "foundation" and LRA Table 3.5.1, Item Number 3.5.1-40, under the "Reactor vessel support pedestal" in LRA Table 3.5.2-1 (page discussion column, states: "...Plant experience has not 3.5-55), "foundation" in Tables 3.5.2-2 through 3.5.2-5 (pages 3.5-59, identified reduction in concrete anchor capacity or other 3.5-61, 3.5-64, and 3.5-67), and as "Equipment pads/foundations" in concrete aging mechanisms. Nonetheless, the Structures Table 3.5.2-6 (page 3.5-80). Further evaluation is provided in LRA Monitoring Program will confirm absence of aging effects section 3.5.2.2.2.6(1), page 3.5-15.

requiring management for PNPS concrete components."

The project team cannot find an AMR line item in Table 2 for For clarification, LRA Table 3.5.1, Item Number 3.5.1-40 discussion this component (Building concrete at locations of expansion will be revised to add "See Section 3.5.2.2.2.6(1)".

and grouted anchors; grout pads for support base plates).

Provide the Table 2 number, LRA page number, and This requires an amendment to the LRA.

component for where this AMR line item is evaluated and shown.

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Number Status Request Response NRC PNPS Lead 421 Accepted [3.5.1-50-H-01] For LRA Table 3.5.1, Item Number 3.5.1-50, the discussion column Hoang, Dan Ahrabli, Reza should read: "This aging effect is managed by the Structures LRA Table 3.5.1, Item Number 3.5.1-50, under the Monitoring Program."

discussion column, states that loss of material is not applicable to PNPS. NUREG-1833 on Page 93 for Item TP-6 Components that may be considered in the B2 and B4 grouping states an approved precedent exists for adding this material, consist of those line items in Table 3.5.2-6 with materials environment, aging effect, and program combination to the galvanized steel, aluminum, or stainless steel.

GALL Report. As shown in RNP SER Section 3.5.2.4.3.2, galvanized steel and stainless steel in an outdoor air This requires an amendment to the LRA.

environment could result in loss of material due to constant wetting and drying conditions. Aluminum would also be susceptible to a similar kind of aging effect in the outdoor environment. Provide a discussion of the actual group B2 and B4 galvanized steel, aluminum, and stainless steel PNPS components which are within the scope of license renewal and exposed to an outdoor air environment. Discuss the location of these components at PNPS and how they are protected from constant wetting and drying conditions.

422 Accepted [3.5.1-52-H-01] Loss of material due to corrosion is an aging effect that can cause a Hoang, Dan Ahrabli, Reza loss of intended function. Loss of mechanical function would be LRA Table 3.5.1, Item Number 3.5.1-52, under the considered a loss of intended function. Loss of mechanical discussion column, states that loss of mechanical function function is not an aging effect, but is the result of aging effects.

due to the listed mechanisms is not an aging effect. Proper There have been component failures in the industry due to design prevents distortion, overload, and fatigue due to distortion, overload, and excessive vibration. Such failures typically vibratory and cyclic thermal loads. Explain how loss of result from inadequate design or events rather than the effects of mechanical function due to corrosion is not an aging effect aging. Failures due to cyclic thermal loads are very rare for which needs to be managed for the period of extended structural supports due to their relatively low temperatures. The operation. If proper design prevents distortion, overload, and sliding surface material used at PNPS is lubrite, which is a fatigue due to vibratory and cyclic thermal loads, explain if corrosion resistant material. Components are inspected under there has ever been a component failure at PNPS due to any ISI-IWF for torus saddle supports and Structures Monitoring Program of these conditions. Explain if there has ever been a for the lubrite components of radial beam seats. Plant operating component failure in the nuclear industry due to any of these experience has not identified failure of lubrite components used in conditions. Explain where sliding support bearing and structural applications. No current industry experience has identified sliding support surfaces are used in component groups B2 failure associated with lubrite sliding surfaces. Components and B4 at PNPS and provide the environment they are associated with B2 grouping are limited to the torus radial beam exposed to. seats and support saddles. There are no sliding support surfaces associated with the B4 component grouping for sliding surfaces at PNPS.

For clarification, LRA Table 3.5.1, Item 3.5.1-52 will be revised to read as follows: "Loss of mechanical function due to the listed mechanisms is not an aging effect. Such failures typically result from inadequate design or operating events rather than from the effects of aging. Failures due to cyclic thermal loads are rare for structural supports due to their relatively low temperatures."

This requires an amendment to the LRA.

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Number Status Request Response NRC PNPS Lead 423 Accepted [3.5.1-54-H-011 The discussion for Item Number 3.5.1-54 was not implying that Hoang, Dan Ahrabli, Reza failures have not occurred, but that loss of mechanical function is LRA Table 3.5.1, Item Number 3.5.1-54, under the not an aging effect. For license renewal, Entergy identifies a discussion column, states that loss of mechanical function number of aging effects that can cause loss of intended function.

due to the listed mechanisms is not an aging effect. Proper Loss of intended function includes loss of mechanical function.

design prevents distortion, overload, and fatigue due to The loss of function is not considered an aging effect. Aging vibratory and cyclic thermal loads. Explain how loss of effects that could cause loss of mechanical function for mechanical function due to corrosion is not an aging effect components in Item Number 3.5.1-54 are addressed elsewhere in which needs to be managed for the period of extended the aging management reviews. For example, loss of material due operation. If proper design prevents distortion, overload, and to any mechanism is addressed in Table 3.5.2-6 under listings for fatigue due to vibratory and cyclic thermal loads, explain if component and piping supports ASME Class 1, 2, 3 and MC (Page there has ever been a component failure at PNPS due to any 3.5-71), and component and piping supports (Page 3.5-72).

of these conditions. Explain if there has ever been a Component failures at PNPS and in the nuclear industry have component failure in the nuclear industry due to any of these certainly occurred due to overload (typically caused by an event such conditions. Explain what PNPS inspects for during VT-3 as water hammer) or vibratory and cyclic thermal loads. Because of visual examinations of groups B1.1, B1.2 and B1.3 the low operating temperatures, failures due to cyclic thermal loads components under its Inservice Inspection Program during are extremely rare for structural commodities. Failures due to its current license and also anticipated VT-3 visual distortion or vibratory loads have also occurred due to inadequate examinations during its possible extended license. design, but rarely if ever, due to the normal effects of aging. PNPS inspections during VT-3 visual examinations of groups B1.1, B1.2 and B1.3 components are consistent with what is required by code.

For clarification, LRA Table 3.5.1, Item 3.5.1-54 will be revised to state: "Loss of mechanical function due to distortion, dirt, overload, fatigue due to vibratory, and cyclic thermal loads is not an aging effect requiring management. Such failures typically result from inadequate design or events rather than the effects of aging. Loss of material due to corrosion, which could cause loss of mechanical function, is addressed under Item 3.5.1-53 for Groups B1.1, B1.2, and B1.3 support members."

This requires an amendment to the LRA.

424 Accepted Table 3.3.2-4, Emergency Diesel Generator System, for PNPS included the expansion joint with the exhaust piping in Patel, Erach Finnin, Ron carbon steel expansion joints in an internal environment of Section 4.3.2 of the LRA. PNPS documentation does not identify exhaust gases credits the TLAA - fatigue for managing any design code for the expansion joint separate from the exhaust cracking due to fatigue. TLAA section 4.3.2, Non-Class 1 piping (831.1). Partial cycles are not a concern for the diesel Fatigue, assumes, in general 7000 thermal cycles for piping exhaust system since the exhaust temperature is assumed to reach systems, allowing a stress reduction factor of 1.0 in the normal operating temperature with each start of the engine. The stress analysis. This is a good assumption for pipe, fittings, expansion joint is exposed only to the same number of full cycles to etc., however, may not be a good assumption for expansion which the rest of the piping is exposed. The expansion joint is joints. designed specifically to accommodate movement that could result from the heating and cooling of the exhaust piping; in other words, Please confirm if the expansion joints are included in its design intent is to have better fatigue response than the rest of section 4.3.2, and justify that the assumption of 7000 cycles the piping. Therefore, PNPS assumed the piping would be more is appropriate. limiting than the expansion joint for the allowable number of cycles prior to requiring management of cracking due to fatigue.

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Number Status Request Response NRC PNPS Lead 425 Open - As part of the Thermal Power Optimization Project, GE a) The Pilgrim records system had not been updated to include the Patel, Erach Finnin, Ron NRC performed another fatigue analysis. GE issued a report, changes in CUF due to the 2003 TPO program in time to support GE-NE-0000-0000-1892-02, Rev. 0, March 2002, Thermal LRA preparation. TPO has a small impact on CUF as detailed in Power Optimization, Task-302 - RPV - Stress Evaluation. GE-NE-0000-000-1898-02, Rev. 1, 3/2002. The records system has This report calculated new CUFs, which in some cases are been updated and the PNPS corrective action program requires that different than what is shown in the LRA, Table 4.3-1, the information be assessed for potential impact on other LRA Maximum CUFs for Class 1 Components. The GE Report, sections. PNPS will update LRA table 4.3-1 to include the values Section 3.3, Results, states that feedwater nozzle CUF from the TPO.

recalculation indicate a CUF that went from <0.8 to <1.0.

Similarly, Table 3.3.1.3 fatigue summary, last column, In preparing the TPO stress evaluation, GE reviewed only those RPV indicates CLTP/TLTP values. Again, specific values are components whose pressure, temperature, and flow conditions provided for 3 line items, however, for feedwater nozzle, only were more severe due to the TPO and with fatigue usage factors

<1.0 is specified. greater than 0.5. These CUFs were not recalculated by traditional methods, but rather were estimated by conservatively scaling the Please justify what <1.0 means. Please provide a specific stresses, determining the code allowable number of cycles for those calculated value. Also, please justify why the revised TPOP stresses, then determining the incremental usage factor for a group CUF values were not identified in the LRA Table 4.3-1, of cycles considered in the original stress report. Before the TPO, instead of old values calculated by ALTRAN Corporation in the CUF for the feedwater nozzle (Altran Report) was listed as <0.8, 1994. for the TPO this CUF increased to <1.0. No precise value was calculated. As stated in the response to Question 345, PNPS will Are there other LRA TLAA sections affected by the TPO perform a new feedwater nozzle fatigue analysis prior to the period of project, such as Section 4.2, RPV Neutron Embrittlement extended operation.

Analysis.

b) No other sections of the LRA are affected by the TPO. The fluence values used in Section 4.2 were based on the higher power level.

426 Accepted [T.3.3.2-P-09] TLAA-metal fatigue is not an aging management program. Under the Patel, Erach Fronabarger, standard LRA format, TLAA-metal fatigue is inserted under the Table 3.3.2-4, EDG System, page 3-78, for carbon steel aging management program as a convenience to indicate that a expansion joints, in an internal environment of exhaust gas TLAA for metal fatigue applies to that line item. The carbon steel credits TLAA-fatigue to manage the aging effect of cracking expansion joints are designed per the requirements of ASME B31.1 due to fatigue. for a limited number of thermal cycles. The evaluation of fatigue for ASME B31.1 components is discussed in Section 4.3.2. The Please confirm if TLAA Section 4.3.2, Non-Class I Fatigue, evaluation determined that the EDG components will remain below includes these expansion joints. Also, see TLAA question 8. the cycle limit for 60 years such that cracking is not expected.

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Number Status Request Response NRC PNPS Lead 427 Closed [T.3.3.2-P-10] TLAA-metal fatigue is not an aging management program. Under the Patel, Erach Lloyd, Leland standard LRA format, TLAA-metal fatigue is inserted under the For aging effect of cracking due to fatigue, PNPS has aging management program as a convenience to indicate that a credited TLAA - metal fatigue as an aging management TLAA for metal fatigue applies to that line item. The EDG exhaust program for components in an internal environment of systems are designed per the requirements of ASME B31.1 for a exhaust gas in Table 3.3.2-4, EDG Systems; however in limited number of thermal cycles. The evaluation of fatigue for Table 3.3.2-5, SBDG System and Table 3.3.2-6, SDG ASME B31.1 components is discussed in Section 4.3.2. The System, the Periodic Surveillance and Preventive evaluation determined that the EDG components will remain below Maintenance (PSPM) Program is credited, which includes the cycle limit for 60 years such that cracking is not expected. The visual or other NDE techniques to inspect exhaust system exhaust systems for the station blackout diesel generator and components to manage cracking. security diesel generator are not designed to a code or standard where thermal cycles are a consideration. Therefore, the Periodic Please justify why the PSPM program is not credited for the Surveillance and Preventive Maintenance (PSPM) program will EDG system components for managing aging effect of manage or confirm the absence of cracking due to thermal fatigue.

cracking. It is only credited for loss of material and fouling.

428 Closed [T.3.3.2-P-1 1] The aging effect of fatigue cracking is conservatively identified for Patel, Erach Fronabarger, the fire pump diesel engine. If the exhaust components were Table 3.3.2-9, Fire Protection - Water System, for piping, designed per ASME B31.1 code, a limited number of cycles would silencer and turbocharger in an internal exhaust gas be the threshold for susceptibility to cracking due to fatigue. Since environment with an aging effect of cracking due to fatigue, the system is normally in standby and used primarily during testing, PNPS has credited the Fire Protection Program to manage it is unlikely to reach any legitimate threshold to produce fatigue this aging effect. The program element 6, Acceptance cracking. Furthermore, through monitoring and trending of Criteria, is enhanced to verify that the diesel engine did not performance data under the Fire Protection Program, cracking of exhibit signs of degradation while it was running; such as system components will be identified and corrected through the exhaust gas leakage. corrective action program. As described in section B.1.13.1, observation of degraded performance produced corrective actions Please justify how the aging effect of cracking is managed including engine replacement in 2002 prior to loss of intended by verifying for exhaust gas leakage. If there is leakage, it function. Consequently, continued implementation of the Fire implies a through-wall crack has occurred. Verifying for Protection Program provides reasonable assurance aging effects leakage is not an adequate aging management program for will be managed for the diesel fire pump exhaust subsystem. In managing cracking. addition, PNPS performs fire pump inspection, testing and maintenance in accordance with NFPA 25 which would also detect the presence of cracking in the exhaust system prior to loss of intended function.

This item is closed to item 378.

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Number Status Request Response NRC PNPS Lead 429 Closed [T3.3.2-P-12] The program description listed in Section B.1.13.1 matches the Patel, Erach Fronabarger, description cited in GALL section XI.M26, Fire Protection which In LRA Section 3.3.2.2.7.3, PNPS states that the carbon includes the diesel driven fire pump. The exhaust piping and steel diesel exhaust piping and components in the fire components are part of the fire pump. Enhancements for aging protection system is managed by the Fire Protection management of the exhaust subsystem are described for attributes Program. The Fire Protection Program uses visual 3-parameters monitored/inspected and 6-acceptance criteria of the inspections of diesel exhaust piping and components to program.

manage loss of material.

This item is closed to item 378.

If Fire Protection Program (LRA B.1.13.1) is credited for managing aging of these components, please explain why these system components are not included in the program description of the Fire Protection Program. Furthermore, no enhancement is addressed that would include these components in the Fire Protection Program.

430 Closed [T.3.3.2-P-13] See the response to Item 394 that addresses items in Table 3.3.2-9. Patel, Erach Fronabarger, For the piping component line item in Table 3.3.2-10 that has Subsequent to question T.3.3.2.1, the applicant has credited indoor air (int) as an environment the Fire Protection Program Fire Protection Program in lieu of GALL AMP XI.M38, includes a visual inspection of the external surfaces of the Halon Inspection of Internal Surfaces of Miscellaneous Piping and system piping and tanks. Since external surfaces are representative Ducting Components as recommended for GALL item of internal surfaces that are exposed to the same environment, the V.D2-16, which is referenced by the applicant for these line Fire Protection Program is adequate for managing the aging effects items. The GALL AMP XI.M38 states that visual inspection of components exposed to indoor air.

of internal surfaces of plant components is performed during maintenance or surveillance activities for visible evidence of This item is closed to item 378.

corrosion to indicate possible loss of material.

Since PNPS is using the Fire Protection Program in lieu of GALL AMP XI.M38, please explain how the Fire Protection Program performs this visual inspection. As written in the LRA, the Fire Protection Program is not adequate to manage loss of material for these components.

431 Closed [T3.2.2-P-01] NUREG-1 801 does not specify X.M1, Metal Fatigue of Reactor Pavinich, Wayne Lingenfelter, Coolant Pressure Boundary in the AMP column for items identifying Table 3.2.2, question 1 cumulative fatigue damage. NUREG-1801 identifies fatigue as a TLAA and refers to guidance in SRP Section 4.3 which in turn The PNPS B.1.12 Fatigue Monitoring is credited for describes treatment of fatigue in a variety of ways depending on the managing the aging effect "Cracking fatigue" for components component. Since NUREG-1 801 does not credit the Fatigue in the RHR (Table Number 3.2.2- 1), ADS (Table Number Monitoring Program, exceptions in this program have no bearing on 3.2.2- 3), HPIC (Table Number 3.2.2 4), RCIC (Table Number the selection of notes.

3.2.2 5) systems. In most cases the components have been assigned Note "A" or Note "C". However, the PNPS B.1.12 Fatigue Monitoring program has exceptions to the GALL program, X.M1, Metal Fatigue of Reactor Coolant Pressure Boundary. Therefore, Note "C" should be Note "D" and Note "A" should be Note "B" as appropriate for these components.

Page 43 of 77

Number Status Request Response NRC PNPS Lead 432 Closed [T3.2.2-P-02] A Bolting Integrity Program will be developed that will address the Pavinich, Wayne Fronabarger, aging management of bolting in the scope of license renewal.

Table 3.2.2, question 2 The Bolting Integrity Program will be implemented prior to the period The PNPS B.1.30 System Walkdown Program is used to of extended operation in accordance.with commitment number 32.

detect LOM for carbon steel bolting instead of GALL XI.M18 Bolting Integrity. XI.M18 invokes visual VT-1 examination for This requires an amendment to the LRA to include descriptions of bolting less than 2 inches in diameter. It is not clear ifVT 1 the Bolting Integrity Program in Appendices A and B and to identify is used for bolting that is examined in accordance with the where the program is applicable.

System Walkdown Program. What standard is used for visual inspection of bolting under the System Walkdown Program. This item is closed to Item 373.

433 Closed [T3.2.2-P-03] Since the One-Time Inspection (OTI) Program is applicable to each Pavinich, Wayne Fronabarger, water chemistry control program, it is also applicable to each line Table 3.2.2, question 3 item that credits a water chemistry control program. LRA Table 3.2.1 indicates that the One-Time Inspection Program is credited Stainless steel and steel components that are exposed to along with the water chemistry control programs for line items for treated water in Table 3.2.2 do not specify one-time which GALL recommends a one-time inspection to confirm water inspection to detect loss of material although Table 3.2.1 chemistry control. Table 2 credits the OTI program through indicates OTI. Add OTI as AMPs for these components for reference to the associated Table 1 line item.

consistency with Table 3.2.1 or provide a justification for not performing OTI. This requires an amendment to the chemistry program descriptions in LRA AppendicesA and B to clearly indicate that the One-Time Inspection Program will confirm the effectiveness of the Water Chemistry Control - BWR, Water Chemistry Control - Auxiliary Systems and the Water Chemistry Control - Closed Cooling Water programs.

This item is closed to Item 372.

434 Closed [T3.2.2-P-04] Pavinich, Wayne Fronabarger, The System Walkdown Program is not intended to inspect interior Table 3.2.2, question 4 piping and component surface unless they have been exposed for inspection during maintenance and repairs. As indicated in the It is not clear if the System Walkdown Program provides for tables in Section 3 of the LRA, the System Walkdown Program inspection interior surfaces of carbon steel components manages aging for external surfaces of components. The program exposed to indoor air for LOM. Please provide details also manages loss of material from internal surfaces in situations in showing inspection of interior surfaces for this component. which internal and external material and environment combinations are the same such that external surface condition is representative of internal surface condition.

435 Closed [T3.2.2-P-05] The various piping components in tables 3.2.2-4, 3.2.2-5, and Pavinich, Wayne Lingenfelter, 3.3.2-14-16, to which Note "C" was assigned, have steam as the Table 3.2.2, question 5 environment. The systems represented by these tables are all ESF systems; however, NUREG-1 801 does not include the combination Item numbers 3.2.2-4, 3.2.2-5, and 3.3.2-14-16 are stainless of stainless steel in a steam environment for any ESF component steel piping components (e.g. orifices, strainers). Please (Chapter V). Consequently, comparisons were made to steam and explain why Note "C" was assigned to these components. power conversion systems components (Chapter VIII) where the stainless steel/steam combination is addressed. Since the systems do not match, a Note "C" is applied.

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Number Status Request Response NRC PNPS Lead 436 Closed [T3.2.2-P-06] The various steel piping components in table 3.3.2-14-16, to which Pavinich, Wayne Lingenfelter, Note "C"was assigned, have steam as the environment with the Table 3.2.2, question 6 aging effect of either cracking - fatigue or loss of material. The system represented by this table is an ESF system; however, the Item number 3.3.2-14-16, are steel piping components (e.g. only aging effect identified in the NUREG-1801 ESF tables (Chapter orifices, strainers). Please explain why Note "C"was V) for a combination of steel in a steam environment, is flow assigned to these components. accelerated corrosion. Consequently, comparisons were made to steam and power conversion systems components (Chapter VIII) where the steel/steam combination includes cracking - fatigue and loss of material as aging effects. Since the systems do not match, a Note "C"is applied.

437 Closed [T3.2.2-P-07] During the performance of routine maintenance on components that Pavinich, Wayne Fronabarger, contain lubricating oil, visual inspections of these components Table 3.2.2, question 7 would identify degraded conditions that could be attributed to an ineffective Oil Analysis Program. The corrective action program at SRP-LR, 3.2.2.2.8 Loss of material due General, Pitting, and PNPS has a low threshold for the identification of degraded Crevice Corrosion, Item 3 provides for the verification of the conditions such that corrosion or cracking of components would be effectiveness of the lubricating oil program through one-time identified as part of this program. The review of operating inspection of selected steel components at susceptible experience at PNPS for the last five years did not identify any locations. Carbon steel components are not, specifically or condition reports that indicated an ineffective oil analysis program or through a representative component, subjected to a one-time that identified degraded component conditions such as corrosion or inspection for loss of material. Add OTI as AMPs for these cracking in a lubricating oil environment. This review of operating components for consistency with Table 3.2.1 or provide a experience at PNPS serves in lieu of a one-time inspection to justification for not performing OTI. provide confirmation of the effectiveness of the Oil Analysis Program.

During the past five years, many visual inspections of components containing lubricating oil have been performed during corrective and preventive maintenance activities. The visual inspections of these components would identify degraded conditions such as corrosion or cracking that could be attributed to an ineffective Oil Analysis Program. PNPS has a low threshold for the identification of degraded conditions such that corrosion or cracking of components would be identified and entered into the corrective action program.

No condition reports that identified degraded component conditions, such as corrosion or cracking in a lubricating oil environment, were initiated as a result of these inspections. These past inspections at PNPS serve in lieu of a one-time inspection to provide confirmation of the effectiveness of the Oil Analysis Program.

This item is closed to Item 376.

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Number Status Request Response ARC PNPS Lead 439 Closed [T3.2.2-P-09] Item 3.2.1-35 specifies the Periodic Surveillance and Preventive Pavinich, Wayne Ivy, Ted Maintenance Program instead of XI.M20, Open-Cycle Cooling Water Table 3.2.2, question 9 System Program, because the environment indicated as raw water in tables 3.2.2-,6 and 3.2.2-7 is used to idenrtiy water which is The GALL specifies XI.M20, Open-Cycle Cooling Water untreated but is not part of the raw cooling water system. Therefore, System Program for carbon steel piping and PNPS credits the preventive actions from GL 89-13 that are described in the plant-specific Periodic Surveillance and Preventive NUREG-1801 XI.M20 do not apply. The remaining preventive action Maintenance Program. Although the plant-specific program specified in XI.M20 is not actually an ongoing AMP element, but is provides for visual and/or UT inspection as in XI.M20, it does the design consideration that components are constructed of not provide for preventive actions. What is the justification appropriate materials. The site corrective action program provides for not implementing preventive actions? reasonable assurance that if appropriate materials were not provided in the original component design, any resulting problems would be evaluated and appropriate corrective actions would be taken to address those problems.

440 Closed [T3.2.1-1-P-01] The use of 220 degrees (carbon steel) and 270 degrees (stainless Pavinich, Wayne Finnin, Ron steel) as a screening criteria below which there is no consideration Table 3.2.1-1, question 1 of mechanical fatigue as an aging mechanism is documented in Appendix H to EPRI 1003056, "Non-Class 1 Mechanical The PNPS LRA, Section 3.2.2.2.1 indicates that cumulative Implementation Guideline and Mechanical Tools," usually referred to fatigue damage is a TLAA evaluated in accordance with as the Mechanical Tools. This document takes the screening 10CFR54.21(c). However, PNPS aging management reviews limits of 220/270 degrees from the EPRI Fatigue Management do not consider cumulative fatigue damage a concern for Handbook, TR-104534. Fatigue is based on thermal cycles seen by steel or stainless steel unless system temperature exceeds the component, and if the component doesn't go above these 220 degrees F or 270 degrees F, respectively which is not a temperatures it is not seeing thermal cycles large enough to condition of the SRP LRA Section 3.2.2.2.1. Provide an contribute to fatigue.

analysis that justifies the exemption of evaluation for cumulative fatigue damage for steel or stainless steel components in systems that operate below 220 degrees F or 270 degrees F, respectively, Page46 of 77

Number Status Request Response NRC PNPS Lead 441 Closed [T3.2A-3-P-01, Since the One-Time Inspection (OTI) Program is applicable to each Pavinich, Wayne Fronabarger, water chemistry control program, it is also applicable to each line Table 3.2.1-3, -5, -6, -8, -9, -10, -14, -15, 18,question 2 item that credits a water chemistry control program. LRA Table 3.2.1 indicates that the One-Time Inspection Program is credited These item numbers specify One-Time Inspection along along with the water chemistry control programs for line items for with another program such as Water Chemistry or Lubricating which GALL recommends a one-time inspection to confirm water Oil Analysis. However, Table 3.2.2 components that chemistry control. Table 2 credits the OTI program through correspond to these Table 3.2.1 items do not specify one reference to the associated Table 1 line item.

time inspection to detect loss of material. Please change component line items to include One-Time Inspection or During the performance of routine maintenance on components that provide the basis for excluding OTI. contain lubricating oil, visual inspections of these components would identify degraded conditions that could be attributed to an ineffective Oil Analysis Program. The corrective action program at PNPS has a low threshold for the identification of degraded conditions such that corrosion or cracking of components would be identified as part of this program. The review of operating experience at PNPS for the last five years did not identify any condition reports that indicated an ineffective oil analysis program or that identified degraded component conditions such as corrosion or cracking in a lubricating oil environment. This review of operating experience at PNPS serves in lieu of a one-time inspection to provide confirmation of the effectiveness of the Oil Analysis Program.

This requires an amendment to the chemistry program descriptions in LRA Appendices A and B to clearly indicate that the One-Time Inspection Program will confirm the effectiveness of the Water Chemistry Control - BWR, Water Chemistry Control - Auxiliary Systems and the Water Chemistry Control - Closed Cooling Water programs.

This item is closed to Item 372.

During the past five years, many visual inspections of components containing lubricating oil have been performed during corrective and preventive maintenance activities. The visual inspections of these components would identify degraded conditions such as corrosion or cracking that could be attributed to an ineffective Oil Analysis Program. PNPS has a low threshold for the identification of degraded conditions such that corrosion or cracking of components would be identified and entered into the corrective action program.

No condition reports that identified degraded component conditions, such as corrosion or cracking in a lubricating oil environment, were initiated as a result of these inspections. These past inspections at PNPS serve in lieu of a one-time inspection to provide confirmation of the effectiveness of the Oil Analysis Program.

This item is closed to Item 376.

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Number Status Request Response NRC PNPS Lead 442 Closed [T3.2.1-35-P-01] Pavinich, Wayne Ivy, Ted Item 3.2.1-35 specifies the Periodic Surveillance and Preventive Table 3.2.1-35, question 3 Maintenance (PSPM) Program instead of XI.M20, Open-Cycle Cooling Water System Program, because the environment indicated The GALL specifies XI.M20, Open Cycle Cooling Water asraw water in tables 3.2.2-6 and 3.2.2-7 is used to identify water System Program and PNPS credits the plant specific which is untreated but is not part of the raw cooling water system.

Periodic Surveillance and Preventative Maintenance Therefore, the preventive actions from GL 89-13 that are described in Program. Although the plant specific program provides for NUREG-1801 XI.M20 do not apply. The remaining preventive action visual and/or UT inspection as in XI.M20, it does not provide specified in XI.M20 is not actually an ongoing AMP element, but is for preventive actions. Provide justification for not adhering the design consideration that components are constructed of to XI.M20. appropriate materials. The site corrective action program provides reasonable assurance that if appropriate materials were not provided in the original component design, any resulting problems would be evaluated and appropriate corrective actions would be taken to address those problems.

443 Closed [General-P-01] A Bolting Integrity Program will be developed that will address the Pavinich, Wayne Fronabarger, aging management of bolting in the scope of license renewal.

In general, System Walkdown is credited for managing LOM for bolting. However, other aging effects may be active for The Bolting Integrity Program will be implemented prior to the period bolting and System Walkdown does not provide for preventive of extended operation in accordance with commitment number 32.

actions. Aging Effects for bolting should be managed under the umbrella of a Bolting Integrity Program in accordance This requires an amendment to the LRA to include descriptions of with GALL program XI.M18. the Bolting Integrity Program in Appendices A and B and to identify where the program is applicable.

This item is closed to Item 373.

444 Closed [General-P-02] Through monitoring of air quality, the Instrument Air Quality Program Pavinich, Wayne Nichols, Bill maintains instrument air free of significant contaminants and water, Components in the SGT system that are exposed to thereby preventing loss of material. This approach to managing instrument air are managed with the plant-specific loss of material is more effective than leakage monitoring and Instrument Air Quality Program (PNPS AMP B.1.17). This repetitive inspection for corrosion. Performance monitoring under program only monitors the air quality. However, the GALL the maintenance rule addresses active components that would be Compressed Air Monitoring Program, XI.M24, additionally included in performance testing. No additional aging effects were requires testing for leakage rates, inspection for corrosion, identified whose management required these other attributes of the and performance testing components. What program(s) Compressed Air Monitoring Program, XI.M24. Recent internal provide for these additional requirements? If these inspections of the air receiver tanks and moisture checks of the additional requirement of XI.M24 are not covered by another instrument air system have not detected significant corrosion or program, please provide justification for not including them. moisture in the system. These past inspections at PNPS serve in This comment is applicable to the IA system as well. lieu of a one-time inspection to provide confirmation of the effectiveness of the Instrument Air Quality program in managing aging effects of components exposed to instrument air without the additional program attributes recommended by GALL XI.M24.

Page48 of 77

Number Status Request Response NRC PNPS Lead 445 Closed [3.1.1-J-01] The actual environments for these components are all essentially Jackson, Wilbur Finnin, Ron the same regardless of the listed temperature. The environments Some of the items that roll up to Item 3.1.1-2 are described specifying the two temperature ranges indicate that the system in LRA Table 3.1.2-1 as in an environment of Treated Water temperature is above the threshold value that can result in cracking

> 220 deg F, and some are described as in Treated Water > due to fatigue for the specific component material. The nominal 270 deg F. fatigue threshold for stainless steel is 270°F and for carbon steel, 220°F as stated in the EPRI Mechanical Tools (EPRI Report Please justify the use of two temperature ranges to describe 1003056).

the environments for the components that roll up to Item 3.1.1-2.

446 Closed [3.1.1-J-02] Drawings were available for NRC review during the site visit. Jackson, Wilbur Chan, Laris In-core Housings; Nozzles - Head Seal Leak-Off (N12, N13).

447 Closed [3.1.1-J-03] The license renewal function of these components (pressure Jackson, Wilbur Finnin, Ron boundary) concerns the weld between the ID attachment and the In LRA Table 3.1.2-1, the Component Type ID Attachment vessel. Because these components are directly attached to the Welds (core spray, dryer hold down pads, etc) are indicated pressure boundary, they were conservatively given an intended as having the intended function of "pressure boundary." function of pressure boundary. This is consistent with the treatment of vessel ID attachment welds in NUREG-1801 Sections IV.A1-12 Please justify that these components provide a pressure and XI.M4.

boundary function.

448 Closed [3.1.1-J-04] These attachment welds are not specifically listed in the reactor Jackson, Wilbur Finnin, Ron vessel stress report; however, they are bounded by the results of that LRA Table 3.1.2-1 indicates that for ID Attachment Welds, report. Any vessel stress report done per ASME Section III contains the aging effect of "Cracking-fatigue" is managed by a TLAA. CUFs only for those locations that the designer felt could be fatigue limiting. While only these limiting areas are actually calculated, the stress report covers the entire vessel.

Please discuss whether these components are explicitly addressed in the TLAA or bounded by the results of the A copy of the vessel stress report (Combustion Engineering TLAA. What is the specific TLAA that manages the aging CENC-1 139) was provided to the inspector.

effects of "Cracking-fatigue" in these components?

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Number Status Request Response ARC PNPS Lead 449 Closed [3.1.1-J-05] As identified in the discussion column entry of Table 3.1.1 Item 13 Jackson, Wilbur Finnin, Ron (3.1.1-13), Water Chemistry Control - BWR is augmented by the In LRA Table 3.1.2-3, carbon steel piping and fittings and One-Time Inspection Program to assure effectiveness of the water valves in a treated water environment are shown as having chemistry program. This is true wherever the water chemistry the aging effect of loss of material. The aging management program is credited. The Water Chemistry Control - BWR and program recommended by corresponding GALL line item One-Time Inspection Programs, by themselves, satisfy the Volume 1, Table 1, Item 13, is Water Chemistry and NUREG-1801 recommendations. The ISI Program supplements the One-Time Inspection. Water Chemistry and One Time Inspection Programs, but is not necessary to satisfy the NUREG-1 801 recommendations. Since the For piping and fittings and valves with diameter >- 4" NPS, Water Chemistry Control - BWR and One-Time Inspection Programs the aging management program is shown as "Water are consistent with the NUREG-1 801 programs, a Note "A" or "C" is Chemistry Control - BWR" and "Inservice Inspection" in LRA appropriate. Since the only viable comparison for these piping and Table 3.1.2-3. For piping and fittings and valves with valve lines is to IV.C1-6 for isolation condenser components, Note diameter < 4" NPS, the aging management program is shown "C" must be used.

as "Water Chemistry Control - BWR" in LRA Table 3.1.2-3.

The note associated with the line items in LRA Table For components with diameter < 4" NPS, the answer is the same.

3.1.2-3 is Note "C". Both Water Chemistry Control - BWR and One-Time Inspection Programs apply to these components, which is consistent with the Questions: recommendations of NUREG-1801. Since the only viable comparison for these piping and valve lines is to IV.C1-6 for For the carbon steel piping and fittings and valves with isolation condenser components, Note "C" must be used.

diameter >= 4" NPS, please provide justification that Note C is the correct note to apply for these components.

For carbon steel piping and fittings and valves with diameter

,4" NPS, please provide justification that Note C is the correct note to apply for these components. Also, for these components please provide justification for not performing a one-time inspection as recommended by GALL line item Volume 1, Table 1, Item 13.

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Number Status Request Response NRC PNPS Lead 450 Closed [3.1.1-J-06] 1) As explained in Section B.1.23 of the LRA: Jackson, Wilbur Finnin, Ron "The elements of the program include (a) determination of the In LRA Table 3.1.2-1, some of the components with aging sample size based on an assessment of materials of fabrication, effect "Loss of Material" that roll up to LRA Table 1 line item environment, plausible aging effects, and operating experience; (b) 4.1.1-14 show that aging management is provided by "Water identification of the inspection locations in the system or Chemistry Control- BWR and Inservice Inspection"; others of component based on the aging effect; (c) determination of the the components with aging effect "Loss of Material" that roll examination technique, including acceptance criteria that would be up to LRA Table 1 line item 4.1.1-14 show that aging effective in managing the aging effect for which the component is management is provided by "Water Chemistry Control - examined; and (d) evaluation of the need for follow-up examinations BWR." The corresponding line item in GALL - Line 14 in to monitor the progression of any aging degradation."

Volume 1, Table 1 - shows the Aging Management In addition, guidance of NUREG-1 801 for XI.M32 and XI.M35 will be Programs as "Water Chemistry" and "One-Time Inspection." used to select sample points.

LRA Note 3.1.2.2.2, paragraph 3, indicates that One-Time inspection of representative samples will be used to confirm 2) They will be included in the population from which the samples the effectiveness of the Water Chemistry Control program. are selected. Which specific items will be inspected will be determined by applying the guidance from NUREG-1801, Section Question: XI.M32 and XI.M35, when PNPS implements this program.

Please discuss the criteria for selecting the sample points 3) These components are welded to the reactor coolant pressure for the One-Time Inspections. boundary. Consequently, these components were conservatively given an intended function of pressure boundary. Thermal sleeves Will the Thermal Sleeves that roll up to LRA Table 1 line are considered subject to aging management review in item 4.1.1-14 be specifically inspected? Or, will they be NUREG-1801 item IV.Al-7.

included in the population from which components are selected for one-time inspection, but not specifically inspected?

Please describe how the thermal sleeves provide the intended function of "Pressure Boundary." Does "pressure boundary" - in this context - mean RPV pressure boundary.

451 Closed [3.1.1-J-07] The detectors indicated as "Detector (CRD)" are detectors for Jackson, Wilbur Finnin, Ron pressure and level in the scram accumulators.

Please clarify the function of the component in Table 3.1.2-3 identified as "Detector (CRD)"? Is this the rod position indicator assembly, or something else?

452 Closed [3.1.1-J-08] Jackson, Wilbur Chan, Laris A copy of BWRI P-1 39 was provided to the inspector.

Please make available during the site visit a copy of the BWRVIP recommendations related to aging management of the steam dryer.

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Number Status Request Response NRC PNPS Lead 453 Accepted [3.1.1-J-09] Note "E" is used rather than Note "A" because the NRC and NEI Jackson, Wilbur Finnin, Ron agreed to use Note "E" rather than Note "A" when GALL specifies a The GALL's recommended aging management program for plant-specific program. This indicates the need for the staff to the steam dryer is "A plant-specific aging management review the acceptability of the program, while Note "A" would program is to be evaluated." In Table 3.1.2-2 the Aging indicate that the use of the program had already been accepted as Management Program identified for the steam dryer is "BWR documented in the GALL report.

Vessel Internals" and Note "E" is applied. Please explain why Note E (rather than Note A) is applied for this line item. The appropriate reference for the LRA standard format is NEI 95-10, Revision 6, Appendix D rather than Appendix F. This requires an The discussion of "Notes" on LRA pages 3.0-4 and 3.0-5 amendment to the LRA.

states that "letter designations are standard notes based on Appendix F of NEI 95-10 (Reference 3.0-3)." The reference is This response requires an amendment to the LRA.

to NEI 95-10, Revision 6. However, review of the reference finds that Appendix F is about "Industry Guidance on Revised 54.4(a)(2) Scoping Criteria"; and Notes are discussed in Table 4.2-2 of that document. Please correct this administrative error in the LRA.

454 Closed [3.1.1-J-10] A portion of this question requires clarification. Table 3.1.2-1 does Jackson, Wilbur Finnin, Ron not include a component type specifically named "flux monitor GALL item VI.A-5 indicates that penetrations for flux penetration." The incore housings, which provide vessel monitor and for the drain line roll up to GALL, Volume 1, penetrations for flux detectors, are made of stainless steel and for Table 1, Item 40. The LRA does not indicate that the aging effect of cracking, the pointer to Table 3.3.1 is item 40.

penetrations for the drain line and for flux monitor roll up to LRA Table 3.1.1, Item 40. Please justify why the drain line The drain nozzle in Table 3.1.2-1, which presumably is the drain line penetrations and the flux monitor penetrations are not penetration indicated in the question, is composed of carbon steel, so rollup to Table 3.1.1 item 40, for stainless steel components, would be inappropriate.

455 Closed [3.1.1-J-11] The PNPS BWR Penetrations Program is consistent with the Jackson, Wilbur Finnin, Ron NUREG-1 801 Section XI.M8, which covers only SLC/DP nozzle and In LRA Table 3.1.2-1 the aging effect of cracking for CRD instrument penetrations as discussed in BWRVIP-27 and Stub Tubes and In-Core Housings is shown as managed by BWRVIP-49. PNPS includes the CRD stub tubes and instrument Water Chemistry Control and BWR Vessel Internals AMPS. housings in the BWR Vessel Internals Program as they are covered In GALL the aging effect of cracking for these components is by BWRVIP-47, Lower Plenum, which is included in NUREG-1801 shown as managed by Water Chemistry Control and BWR program XI.M9. This is slightly inconsistent with NUREG-1 801 Penetrations. Section IV, but PNPS felt it was better to be consistent with the programs in Section XI than the one line item in Section IV. At Please discuss why PNPS has included these component PNPS, both the BWR Penetrations Program and the BWR Vessel in the BWR Vessel Internals program rather than in the BWR Internals Program are implemented by the same plant procedure.

Penetrations program as recommended by GALL.

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Numher Status Request Response NRC PNPS Lead 456 Closed [3.1.1-J-12] The CRGT base is located near the bottom of the guide tube and Jackson, Wilbur Finnin, Ron supports the control rod when the drive is disconnected and In LRA Table 3.1.2-2 the Component Type "Control rod guide removed for service.

tubes - tube" is in an environment of "Treated water" > 270 deg-F, and the Component Type "Control rod guide tubes - The control rod guide tube is made of stainless steel. Its base" is in an environment of "Treated water > 482 deg-F". environment is given as >270 "F because that is the threshold for Please clarify what is meant by "Control rod guide tubes - fatigue of stainless steel per the EPRI Mechanical Tools base" and explain why its environment is different from the ((1003056). The guide tube base is made of CASS and "Control rod guide tubes - tube." consequently its environment was quoted as >482 "F as this is the threshold for thermal embrittlement in CASS. The limiting temperature was listed for each component. Both components see the same temperatures.

457 Closed [3.1.1-J-13] Flow-accelerated corrosion (FAC) is not expected to be a significant Jackson, Wilbur Finnin, Ron aging mechanism for the majority of the reactor coolant system.

In LRA Table 3.1.2-3 the only components identified as (including piping and fittings <4" NPS) as the lines are either seldom having the aging effect of Loss of Material [due to FAC] and used (such as, scram discharge header, core spray, HPCI, nuclear included in the Flow Accelerated Corrosion AMP are carbon system pressure relief, PASS, RCIC, RHR, and SLC) or there is little steel piping and fittings >= 4" NPS. The GALL description of flow while in use (CRD, NBVI, RWCU). InmLRA Table 3.1.2-3, carbon the FAC AMP (XI.M1 7) does not limit applicability of this steel piping segments >=4" NPS (such as feedwater piping) are included program based on pipe diameter. Please justify why only the in the FAC Program.

large-diameter piping in Table 3.1.2-3 is included in the FAC program. Please identify the piping segments that are PNPS has reviewed the FAC program and determined that it includes included in the FAC program in LRA Table 3.1.2-3. a portion of the reactor vessel drain piping that supplies RWCU, and this is small bore - carbon steel piping.

PNPS will add loss of material due to flow accelerated corrosion to the line entry for small bore piping (<4" NPS) in LRA table 3.1.2-3 (page 3.1-63).

The new entry will identify Flow accelerated corrosion as a separate aging effect as done for the large bore carbon steel piping entry on page 3.1-65.

The GALL comparison will be Volume 2 item IV.C1-7 which rolls up to Table 3.1.1-45.

This requires an amendment to the LRA.

458 Closed [3.1.1-J-14] The items in Table 3.1.2-2 that roll up to Line Item 3.1.1-47 (GALL Jackson, Wilbur Finnin, Ron table IV item IV.Al-6) are for loss of material due to pitting and In LRA Table 3.1.2-2, for components with aging effect "Loss crevice corrosion. NUREG-1801 repeatedly credits Water Chemistry of Material" that roll up to LRA Table 1 Item 3.1.1-47, the Control - BWR augmented by the One-Time Inspection program to AMP is identified as "Water Chemistry Control - BWR." manage loss of material due to pitting and crevice corrosion (for However, in the GALL the aging effect of Loss of Material for example IV.A1-8, IV.A1-11). This program combination is adequate these components is managed by both Water Chemistry and to manage this aging effect in that the loss of material due to pitting Inservice Inspection (IWB, IWC, and IWD). Please justify and crevice corrosion for the internals is no different than the loss of why Water Chemistry Control - BWR with no associated material due to pitting and corrosion for other stainless steel inspection is adequate to manage the aging effect of Loss of components exposed to reactor coolant. As noted in Table 3.1.1, Material for these components. the One-Time Inspection Program will verify effectiveness of the Water Chemistry Control - BWR Program.

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Number Status Request Response NRC PNPS Lead While ASME Code table IWB-2500-1 (Category B-N-i) does require VT-1 or VT-3 inspection of the interior attachments and core support structures, it does not require inspection of the majority of the internals. Therefore, crediting ISI for managing loss of material of the intemals in general is inappropriate.

The PNPS One-Time Inspection Program will incorporate the results of other inspections that are performed including ISI inspections done per ASME Xl IWB-2500-1 B-N-2 and other opportunistic inspections.

459 Accepted 13.1.1-J-15] Perhaps the statement that ISI does not apply is misleading. We Jackson, Wilbur Finnin, Ron should have said that PNPS does not credit ISI for aging In LRA Table 3.1.1, Item Number 3.1.1-48 Discussion management of piping <4". ISI typically only requires surface includes the statement, "Inservice inspection is not examinations of these components and the aging effects requiring applicable to components < 4" NPS." ASME Section Xl, management initiate on the ID,therefore we did not credit ISI for Table IWB 2500-1, Examination Category B-J, requires managing these effects.

Surface (but not Volumetric) examination for pressure retaining welds in Class 1 pipe that is < 4" NPS. Please An LRA amendment is required. PNPS will amend the LRA to reconcile the statement in Item 3.1.1-48 Discussion with the delete the statement "Inservice inspection is not applicable to ASME Section XI requirements stated above. components < 4" NPS." from the discussion in line item 3.1.1-4.

This will require an amendment to the LRA.

460 Accepted [3.1.1-J-16] For clarification, the statement "Cracking in steel components Jackson, Wilbur Lingenfelter, due to thermal and mechanical loading is not directly dependent on In LRA Table 3.1.1, Item Number 3.1.1-48 Discussion water chemistry, so only the One-Time Inspection Program includes the statement, "Cracking in steel components due is credited" should be deleted.

to thermal and mechanical loading is not directly dependent on water chemistry, so only the One-Time Inspection An LRA amendment is required. PNPS will amend the LRA to Program is credited." However, there are no line items in the delete the statement "Cracking in steel components due to thermal 3.X.2 Tables where "One-Time Inspection" by itself rolls up and mechanical loading is not directly dependent on water to Item Number 3.1.1-48. Please explain the apparent chemistry, so only the One-Time Inspection Program is credited."

inconsistency between the LRA statement and the way that from the discussion in line item 3.1.1-48.

the roll-ups to Item Number 3.1.1-48 are done in the LRA.

This will require an amendment to the LRA.

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Number Status Request Response NRC PNPS Lead 461 Accepted I.A.-J-i7* TIMELINE OF SHROUD ACCESS HOLE COVER EXAMINATIONS: Jackson, Wilbur Pardee, Rich In GALL Volume 1, Table 1, Item 49, an augmented - 1988 - GE issues SIL 462 inspection using UT or other demonstrated acceptable inspection is recommended for BWRs with a crevice in the - 1991 (RFO-8) - UT of both covers (for circ. flaws only) access hole covers.

- 1993 (RFO-9) - UT of both covers (for.circ. and radial flaws)

Does PNPS have a crevice in the access hole covers?

- 1995 (RFO-1 0) - UT of zero degree cover only Does PNPS perform an inspection of the access hole covers using UT or other demonstrated acceptable inspection - 1995 (RFO-10) - VT-1 of both covers techniques?

- 2001 - GE issues SIL 462 Rev.1 on 3/01

-2003 (RFO-14) - EVT-1 of both covers

- 2005 (RFO-1 5) - no exams

- 2007 (RFO-1 6) - Plan to inspect at 180 degrees by VT-1

- 2009 (RFO-1 7) - Plan to inspect at 0 degrees by VT-1 Pilgrim will continue to inspect.the access hole covers at 180 degrees and 0 degrees visually at 4 and 6 year intervals, respectively, during the current licensing period. If new BWRVIP guidance is issued on these components, PNPS will perform inspections in accordance with that guidance.

Within the first 6 years of the period of extended operation and every 12 years thereafter, PNPS will inspect the access hole covers with UT methods. Alternatively, PNPS will inspect the access hole covers in accordance with BWRVIP guidelines should such guidance become available.

This is commitment item 34.

462 Closed [3.1.1-J-18] Category B-G-1 of the ASME XI code contains the requirements for Jackson, Wilbur Pardee, Rich all pressure-retaining bolting >2" dia. in the ISI Program. The code RA Table 3.1.2-1 lists the ISI program as the AMP used to requires a volumetric (ultrasonic) exam for all RPV closure studs managing the aging effect of cracking in "Other Pressure (examined in place) and a VT-1 visual exam for all RPV closure nuts Boundary Bolting - Upper head flange bolts and nuts - CRD every 10 years.

flange bolting. Please identify the ASME Examination Category and Requirements that are applicable for these Category B-G-2 of the ASME XI code contains the requirements for components. pressure-retaining bolting <=2" dia. in the ISI Program. The code requires a VT-1 visual exam every 10 years for bolting in this category (includes CRD flange bolting, RPV head N7 & N8 nozzle flange bolting).

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Number Status Request Response ARC PNPS Lead 463 Accepted [3.1.1-J-19] NUREG-1 801 program XI.M12 "Thermal Aging Embrittlement of Cast Jackson, Wilbur Finnin, Ron Austenitic Stainless Steel (CASS)" applies to CASS pressure LRA Table 3.1.2-2 identifies "Thermal Aging Embnittlement boundary components in the RCS. This program is not applicable of CASS" as the AMP to manage the aging effect of to PNPS, as we have no CASS pressure boundary components.

"reduction in fracture toughness" for three component types: NUREG-1801 program XI.M13, "Thermal Aging and Neutron "Control Rod Guide Tubes - Base", "Fuel Support Pieces - Irradiation Embrittlement of Cast Austenitic Stainless Steel (CASS)"

Four Lobed", and "Jet Pump Assemblies [various applies to reactor vessel internals (non-pressure boundary) pieces components]." However LRA Table B-2 says that the made of CASS. The mentioned components above are all reactor NUREG-1 801 Program "Thermal Aging Embrittlement of vessel internals and are covered by this program. In some CASS" is "not applicable" at PNPS. Please correct or justify instances, the LRA refers to Thermal Aging Embrittlement of CASS this apparent inconsistency in the LRA. Also, if an LRA Program as a shortened name for and with a hyperlink to the correction is needed, please ensure that the Notes for each Thermal Aging and Neutron Irradiation Embrittlement of Cast of the three component line items are validated or changed Austenitic Stainless Steel (CASS) Program. For clarification, those to be consistent with any changes made in the LRA. instances will be revised to clearly indicate the appropriate program.

This requires an amendment to the LRA.

464 Closed [3.1.1-J-20] To clarify the LRA discussion in line item 3.1.1-52, the phrase "not a Jackson, Wilbur Finnin, Ron significant aging effect" means not an aging effect requiring GALL Volume 1, Table 1, Line 52 identifies the aging effects management. This is consistent with the EPRI Mechanical Tools for RCPB closure bolting as "Cracking due to SCC, loss of that do not consider loss of material due to wear an aging effect for material due to wear, loss of pre load due to thermal effects, bolted closures. In addition, loss of material due to wear was not gasket creep and self-loosening." Only the aging effect of identified as an area of concern in the resolution of GSI-29 for "Cracking" is identified in LRA Table 3.1.2-1 for component bolting. The general system bolting to which this line item applies that roll up to LRA Line Item 3.1.1-52. The "Discussion" in is not routinely disassembled. Occasional thread failures due to the LRA for Line Item 3.1.1-52 provides discussion of why wear mechanisms such as galling, are not age related but are the other aging effects listed in GALL are not included event-driven conditions that are resolved when they occur.

applicable at PNPS.

Bolting at PNPS is standard grade B7 carbon steel, or similar Question: material, except in specialized applications where stainless steel bolting is utilized. Loss of preload due to stress relaxation (creep)

Please provide PNPS' basis for the Discussion statement would only be a concern in very high temperature applications (>

that "Industry operating experience indicates that loss of 700°F) as stated in the ASME Code,Section II, Part D, Table 4. No material due to wear is not a significant aging effect for this PNPS bolting operates at >700°F. Therefore, loss of preload due to bolting." Please clarify what is meant by "not a significant stress relaxation (creep) is not an applicable aging effect for the aging effect." reactor coolant system. A copy of this section of the code was available during the audit.

Please provide a copy of technical reference(s) supporting the LRA statement that "Loss of preload due to stress relaxation (creep) would only be a concern in very high temperature applications (> 700 deg-F).

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Number Status Request Response NRC PNPS Lead 465 Closed [3.1.1-J-21] GL 91-17, Generic Safety Issue 29, Bolting degradation or failure in Jackson, Wilbur Chan, Laris nuclear power plants is dated 10/17/91. The GL required no The LRA Discussion for Line Item 3.1.1-52 includes the response and no docketed correspondence was submitted. PNPS statement, "To address these bolting operational concerns, did review GL 91-17 in 1991 and a review summary was provided to PNPS has taken actions to address NUREG-1339, the NRC audit team during the site visit.

"Resolution of Generic Safety Issue 29: Bolting Degradation or Failure in Nuclear Power Plants." Partly as a result of the PNPS review of GL 91-17, Station Maintenance procedure for bolting, 3.M.4-92 was developed based Please identify and provide a copy of any previous, docketed on EPRI NP-5067, "Good Bolting Practices".

correspondence in which PNPS describes its actions and commitments (if any) with regard to NUREG-1 339.

466 Closed 13.1.1-J-22] In the Non-Class 1 Mechanical Implementation Guideline and Jackson, Wilbur Finnin, Ron Mechanical Tools, Revision 3, EPRI, Palo Alto, CA: 2001. 1003056 In LRA Table 3.1.2-1 a line item identifies the aging effect of (The Mechanical Tools) Appendix E, low alloy steel exposed to "Loss of Material" for the component type "Closure flange indoor air containing moisture (humidity) is subject to loss of studs, nuts, washers, and bushings." Note "H" is applied for material due to the aging mechanism of general corrosion. This this line item, indicating that the aging effect is not in bolting item has this material and environment combination and NUREG-1 801 for this component, material and environment therefore the aging effect is applicable. In accordance with the combination. operating experience provided in the Reactor Head Closure Studs Program, examination of 18 reactor head closure studs and visual Please identify and discuss the mechanism that creates the examination of 18 nuts and 18 washers during RFO1 5 found no new aging effect of "Loss of Material" in these components. recordable indications of loss of material.

Please identify and describe PNPS-specific or industry experience where the aging effect of "Loss of Material" has LRA Table Line Item 3.1.1-52 is based on NUREG-1801, Volume 1, been observed in these components. Table 1 which addresses loss of material due only to wear for carbon and stainless steel bolting. Since the NUREG-1801 line Please include a discussion of why "Loss of Material" is an item does not address any other aging mechanisms that result in aging effect applicable for these components but not for loss of material, it was deemed that the line item is not applicable components that roll up to LRA Table Line Item 3.1.1-52. for loss of material due to general corrosion.

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Number Status Request Response NRC PNPS Lead 467 Closed [3.1.1-J-23] The main steam line flow restrictors are not pressure retaining Jackson, Wilbur Finnin, Ron components (no pressure boundary function). They are a cast piece LRA Table 3.1.2-3 includes a line item for Main Steamline that is inserted inside the main steam piping. The main steam Flow Restrictors made of CASS, in an environment of piping is the pressure boundary. Consequently, the main steam flow Treated Water > 482 deg-F, aging effect of Reduction in restrictors are not a good candidate for GALL program XI.M12.

Fracture Toughness. For Class 1 piping components made a) No, PNPS has not done the screening for the main steam line of this material, in this environment and with this aging flow restrictors.

effect, the GALL recommends the AMP XI.M12, "Thermal b) While the inspection procedure has not yet been developed, the Aging Embrittlement of Cast Austenitic Stainless Steel planned inspection is a visual examination performed by inserting a (CASS)." In lieu of the recommended AMP, PNPS proposes camera into the main steam line.

to use a One-Time Inspection. c) Reduction of Fracture Toughness (Cracking) and Loss of Material of the main steam line flow restrictors are not considered likely Questions: effects during the period of extended operation (No aging of these restrictors is identified by NUREG-1801). Loss of material will be The GALL-recommended AMP includes screening criteria to mitigated by BWR - Water Chemistry Control. Nonetheless, PNPS determine which CASS components are potentially has committed to do a one-time inspection to verify that these aging susceptible to thermal aging embrittlement and require effects are not occurring. Since the flow restrictors are not pressure augmented inspection. Has PNPS applied the screening retaining components, the One-Time Inspection Program is criteria to the Main Steamline Flow Restrictors? If so, what adequate to manage the effects of aging.

were the results?

Please describe what examination requirements, methods and standards will be used in PNPS's proposed One-Time Inspection of the Main Steamline Flow Restrictors.

Please justify that a One-Time Inspection provides adequate aging management of the Main Steamline Flow Restrictors during the period of extended operation.

468 Closed [3.1.1-J-24] As stated in the question, item 3.1.1-53 refers to steel components. Jackson, Wilbur Lingenfelter, CASS is considered stainless steel. The material and environment LRA Item Number 3.1.1-53 Discussion states, "There are no combination of stainless steel in closed cycle cooling water does steel components of the Class 1 reactor vessel, vessel not appear in the RCS (Chapter IV) tables of NUREG-1801; therefore, internals or reactor coolant pressure boundary exposed to the line item for the pump cover - thermal barrier is compared to the closed cycle cooling water." However, LRA Table 3.1.2-3 ESF tables of NUREG-1801.

(page 3.1-68) includes line items for Pump cover - Thermal barrier (RR) made of CASS where the aging management.

programs are identified as "Water Chemistry Control - Closed Cooling Water" and "Inservice Inspection." These line items appear to be inconsistent with the Discussion in 3.1.1-53.

Please explain why these line are not inconsistent with the Discussion in 3.1.1-53 or correct the inconsistency.

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Number Status Request Response NRC PNPS Lead 469 Closed [3.1.1-J-25] The selection of the aging effect of loss of material or of no aging Jackson, Wilbur Lingenfelter, effect was dependent upon the temperature of the component during PNPS LRA Table 3.1.2-3 includes entries for piping and normal. operation. Components with a temperature above the fittings made of carbon steel in a environment of Air-indoor boiling point of water will preclude moisture accumulation. As a (ext). Some of these entries have an aging effect of loss of matter of convenience, the transition point was assumed at the material; some of these entries have an aging effect of temperature threshold of 220°F for cracking due to fatigue in steel.

"none." For the entries with aging effect of "none", Note 101 Although these components can be below this threshold during is applied and states, "High component surface temperature shutdown conditions, and some components could possibly see precludes moisture accumulation that could result in temperatures both above and below this threshold during normal corrosion." operation, these components should rarely, if ever, be at a temperature below the local dew point. Consequently, even during Please clarify the high temperature conditions that are shutdown conditions, moisture accumulation should be negligible.

mentioned in the note: What is the "high temperature" threshold? For piping that experiences significant The PNPS position on loss of material on exterior surfaces of steel temperature changes during operation, approximately what piping grew out of earlier license renewal application experience.

percentage of operation at temperature below the high Loss of material on external surfaces is normally managed by temperature threshold is assumed or anticipated for those system walkdowns; however, system walkdowns don't inspect the piping and fittings where the aging effect is "none"? exterior surface of insulated piping unless the insulation is removed Please discuss the methodology that PNPS uses to identify for maintenance. There is no need to remove insulation and directly which piping is classified as having aging effect of "loss of inspect pipe external surfaces as the heat that requires the material" and which has aging effect of "none." insulation prevents moisture accumulation which in turn prevents loss of material. PNPS's plan is to inspect uninsulated steel piping for loss of material via system walkdowns and not remove any insulation.

470 Accepted [3.1.1-J-26] Table 3.1.1 Item number 3.1.1-52 specifies the aging effect of Jackson, Wilbur Finnin, Ron cracking due to stress corrosion cracking for carbon and stainless PNPS LRA Table 3.1.2-3 contains two line items for "Bolting steel reactor coolant system pressure boundary closure bolting.

(flanges, valves, etc)" where the material is-either low alloy Inservice inspection of bolting components is specified in GALL steel or stainless steel, the environment is Air-indoor XI.M18, Bolting Integrity, for management of cracking and loss of (extemal), and the aging effect is cracking. material of pressure retaining bolting inspected in accordance with ASME Section XI. Therefore, inservice inspection is acceptable for Please identify the mechanism that causes this aging effect managing cracking in reactor coolant pressure boundary bolting.

in these components. Please justify that the inservice However, a Bolting Integrity Program that credits inservice inspection program provides aging management of these inspections will be developed that will address the aging components adequate to ensure that they continue to management of bolting in the scope of license renewal.

perform their intended function during the period of extended operation. Please clarify whether PNPS will be developing a This requires an amendment to the LRA to include descriptions.of bolting integrity program modeled on Section XI.M18 to the Bolting Integrity Program in Appendices A and B and to identify include these components. where the program is applicable.

This item is closed to Item 373.

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Number Status Request Response NRC PNPS Lead 471 Closed [3.1.1-J-27] The aging effect of cracking due to fatigue depends on the thermal Jackson, Wilbur Lingenfelter, and mechanical loading of the component and is effectively In LRA Table 3.1.2-3, MEAP combination Bolting, Stainless independent of the environment at the surface of the component.

steel, Air-indoor, Cracking-fatigue, TLAA - the notes are "A, The tables in NUREG-1801; Volume 2, Chapter IV (outside of 105." Please explain why note 105 is applicable to this line Subsection All) include components with an air environment and an item. aging effect of cracking due to fatigue. While one of these lines could have been used as a substitution, the choice of a line within the corresponding system table (Table IV.C1 in this case) was preferred. Plant specific Note 105 explains that the difference in environments is acceptable for the evaluation of cracking due to fatigue.

472 Closed [3.1.1-J-28] The aging effect of cracking due to fatigue depends on the thermal Jackson, Wilbur Lingenfelter, and mechanical loading of the component and is effectively In LRA Table 3.1.2-1, MEAP combinations "Closure flange independent of the environment at the surface of the component.

studs" or "Other pressure boundary bolting," Low alloy steel, The tables in NUREG-1 801, Volume 2, Chapter IV (outside of Air-indoor, Cracking-fatigue, TLAA - the notes are "C, 105." Subsection Al) include components with an air environment and an Please explain why note 105 is applicable to these line items. aging effect of cracking due to fatigue. While one of these lines could have been used as a substitution, the choice of a line within the corresponding system table (Table IV.A1 in this case) was preferred. Plant specific Note 105 explains that the difference in environments is acceptable for the evaluation of cracking due to fatigue.

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Number Status Request Response ARC PNPS Lead 473 Closed [3.1.1-J-29] The cracking referred to in these entries is stress corrosion cracking Jackson, Wilbur Finnin, Ron of the stainless steel cladding. This was not entered based on In LRA Table 3.1.2-1, the following components are BWRVIP-74, but was based on the mechanical tools and industry identified as having the aging effect of "cracking," and Note H operating experience. NtJREG-1801 also specifies cracki:ng due to is applied: Dome (Bottom Head); Dome (Upper Closure SCC as an aging effect for many stainless steel material entries.

Head); Flanges (Shell closure flange and Upper head Note that for entries such as Nozzle, Drain (N1i1) which is unclad closure flange); Vessel Shell (Beltline shell); Vessel shell carbon steel there is no cracking entry other than cracking-fatigue.

(Intermediate nozzle shell, lower shell; upper shell); Nbzzles (Main steam).

Table 3-1 in BWRVIP-74-A (Reactor Pressure Vessel Inspection and Flaw Evaluation Guidelines for License Renewal) addresses various potential age related mechanisms and indicates the components to which the mechanisms apply. Except for the mechanism of "fatigue" which applies to some of the components listed in the paragraph above, there is no mechanism in Table 3-1 of BWRVIP-74-A that causes cracking and that BWRVIP-74-A identifies as applicable for the components listed above.

Question:

Please provide a discussion of the methodology that PNPS used to determine that the aging effect of "cracking" is applicable for the components listed in the first paragraph, above. Please identify the mechanism(s) that cause cracking in these components.

Please explain how or whether PNPS incorporated the information contained in BWRVIP-74-A into its determination that cracking is an aging effect applicable for these components.

Please discuss the plant-specific or industry experience reviewed by PNPS in making the determination that cracking is an aging effect applicable for these components.

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Numher Status Request Response NRC PNPS Lead 474 Accepted [3.1.1-J-30] The entry in table 3.1.2-1 is for both the support skirt and the Jackson, Wilbur Finnin, Ron stabilizer pads. The support skirt was conservativel' considered In LRA Table 3.1.2-1, the.component Stabilizer Pads (part of susceptible to loss of material as it remains below 220 0F. The Supports - Stabilizer pads, support skirt) is identified as stabilizer pads are located on the sides of the vessel, and are having an aging effect of "loss of material" and the AMP is typically greater than 220 *F. Consistent with other LRA Inservice Inspection. components, these pads should not be subject to loss of material.

The LRA will be clarified to indicate that the loss of material entry Questions: applies only to the support skirt.

What is the mechanism that causes the aging effect of loss This requires an amendment to the LRA.

of material?

The stabilizer pads are inspected per ASME Section XI Table Please describe the Inservice Inspection for the Stabilizer IWB-2500-1 category B-K. The code (footnote 7 to Table pads: What is the examination frequency? Examination IWB-2500-1 category B-K) allows surface examination from an requirement? Examination method? Acceptance standard? accessible side of the weld. At PNPS the top side of the weld is Are there any currently approved relief requests applicable for accessible and PNPS performs magnetic particle testing of the top this component? side of each bracket weld in every 10 year interval. PNPS meets the code requirements and therefore has no relief request for these inspections.

475 Closed [TLAA-H-01] [1] The design code for the drywell liner plate is ASME Code, Hoang, Dan Chan, LarisSection III. The code includes Code Case 1330-1 and Code Case The applicant is requested to provide the design codes for 1177-5, and the latest edition as of June 9, 1967. [Reference the liner plate, torus down comer/vent header and Chicago Bridge and Iron (CB&I) document 9-8014]. For the torus torus-attached piping, and SRV piping for review. shell, the design code is ASME Code,Section III. The code includes Code Case 1330-1 and Code Case 1177-5, and the latest edition as of June 9, 1967. It was later evaluated to the requirements of ASME Section III Division I with addenda through Summer 1977 and Code Case N-197 as part of the Mark 1 Torus Program.

[Reference Teledyne Engineering Services (TES) document TR-5310-1].

[2] The original design code for the torus downcomedvent header is ANSI B31.1, 1967 edition. It was later evaluated to the requirements of ASME Section III Division I with addenda through Summer 1977 and Code Case N-1 97 as part of the Mark 1 Torus Program.

[Reference TES document TR-5310-1].

[3] The original design code for the torus attached piping is ANSI B31.1, 1967 edition. It was later evaluated to the requirements of ASME Section III, 1977 edition, with Addenda through Summer 1977 as part of the Mark 1 Torus Program. Pipe support analysis was performed to Section IIISubsection NF [Reference TES document TR-5310-2].

[4] The original design code for the SRV piping is ANSI B31.1, 1967 edition. It was later evaluated to the first anchor from the torus to the requirements of ASME Section III, 1977 edition, with addenda through Summer 1977 as part of the Mark 1 Torus Program.

[Reference TES document TR-5310-2J. The SRV/DL piping was analyzed for higher discharge flow as part of the Thermal Power Optimization (TPO) Program to the same design code.

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Number Status Request Response NRC PNPS Lead 476 Closed [TLAA-H-021 PNPS has tracked SRV actuations from 1992 to 2005. A total of 14 Hoang, Dan Chan, Lars actuations have been recorded on valve A, and 13 each on valves B, The applicant is requested to provide a statement indicating C and D. Using the 14 actuations in this thirteen year period, the that the estimate of the total number of 60-year SRV projected actuations for the rest of 60 years are 31 lifts. The number actuations used in the design fatigue analysis remains valid of lifts in the first 21 years of plant life (1972 - 1993) were not and conservative, based on the actual SRV actuations recorded. These lifts were more frequent in the early years, so counted through 2005. PNPS estimated these 21 years at 5 times the recorded rate. This yields 120 lifts in the first 21 years. Combining the early period, the recorded period, and the projected period, there will be an estimated 165 lifts in 60 years.

PNPS plant specific analysis (Teledyne Engineering Services document TR-5310-2) states that the SRV penetrations are qualified for 7500 cycles of maximum load Based on this, the projected CUF for 60 years is calculated as 0.022.

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Number Status Request Response NRC PNPS Lead 477 Closed [TLAA-H-03] Teledyne Engineering Services document TR-5310-2 documents Hoang, Dan Finnin, Ron stress evaluations for the SRV piping for various load combinations, Please provide Fatigue Analysis of the SRV discharge but does not include a fatigue analysis. (The fatigue analysis of piping and Fatigue analysis of other Torus attached piping. the SRV piping along with all the other torus attached piping.) (TAP is bounded by MPR-751, the GE Mark 1 containment program.

MPR-751 concluded that for all plants and piping systems considered, in all cases the fatigue usage factors for an assumed 40-year plant life was less than 0.5. In a worst-case scenario, extending plant life for an additional 20 years would produce usage factors below 0.75. Since this is less than 1.0, the fatigue criteria are satisfied. The MPR-751 generic fatigue analysis is thus protected for the period of extended operation in accordance with 10 CFR 54.21 (c)(1)(ii).

A PNPS/plant specific analysis addresses the SRV discharge piping and its supports, as well as the main vent penetration through which the SRV discharge enters the torus. This analysis states that the SRV penetrations are qualified for 7500 cycles of maximum load while the SRVs are expected to see less than 50 cycles at maximum load and less than 4500 cycles a partial load. The report concludes "Since the 7500 cycles of maximum load bounds both of these by such a large margin and since no other significant loads are imposed on the line, the penetration was assumed acceptable for fatigue without further evaluation." Increasing the 40 year cycles by 1.5 for the period of extended operation would still be only 75 maximum load cycles and 6750 low load cycles for a total of 6850 mixed load cycles, less than the 7500 maximum load cycles permitted. The fatigue analysis for torus penetrations thus remains valid for the period of extended operation in accordance with 10 CFR 54.21(c)(1)(i).

The PNPS plant-specific analysis (TR-5310-2) references the generic GE Mark 1 Containment program for other torus attached piping. The results of the generic GE Mark 1 containment program (based on 40 years of operation) were that 92% of the TAP would have cumulative usage factors of less than 0.3, and that 100%

would have usage factors less than 0.5. Conservatively multiplying the CUFs by 1.5 shows that for 60 years of operation, 92% of the TAP would have CUFs below 0.45, and 1,00% would have CUFs below 0.75. These calculations have thus been projected through the period of extended operation in accordance with 10 CFR 54.21(c)(1 )(ii).

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Number Status Request Response ARC PNPS Lead 490 COosed What is the operating history ior buried pipes in terms ol the In the past 5 years there has been limited experience with the Davis, Jim Ivy, Ted number of inspections and any leaks and their cause, inspection of buried piping at PNPS. This experience has occurred (internal or external caused leaks)? Have any buried pipes mainly on the fire water underground distribution system. This been replaced due to corrosion or coating problems? If the system is approximately 35 years old and consists of cement lined phased array UT technique is used, how will it be qualified malleable iron pipe with mechanical joints. There has been no and how will the operators be qualified? history of significant leaks other than during two instances, one in 2001 and one in 2005. In the first event the 8" underground line -

down stream of 8-L-22 failed. The probable cause of failure was most likely induced by minor fabrication anomalies compounded by marginal installation techniques. When this piping was examined it was found to be overall in very good condition externally except for a small area of surface corrosion, attributed to marginal installation techniques. In the second event the 8" underground pipe failed in the area of the N2 tank adjacent to the EDG building. Due to congestion and the presence of the tank, which was installed subsequent to the installation of the piping, it was not possible to dig up the piping to examine it and determine the cause of the failure but may be related to the installation of the tank. In addition to these two instances there have been a number of valves excavated during maintenance which found the valves and piping to be in remarkably good condition.

From an additional historical perspective, the salt service water (SSW) system at PNPS has experienced leaks on the buried inlet (screenhouse to auxiliary bays) piping as a result of intemal corrosion. The original piping material was rubber lined carbon steel wrapped with reinforced fiberglass wrapping and coal tar saturated felt and heavy Kraft paper. The leaks were determined to be the result of the degraded rubber lining being in contact with sea water. These pipes have since been replaced with unlined Titanium wrapped with the same external coating as the original pipe. This pipe replacement occurred in 1995 and 1997. In addition, the SSW buried discharge piping (also rubber lined carbon steel with external pipe wrapping, same as inlet piping) from the auxiliary bays to the discharge canal also experienced severe internal corrosion due to failure of the rubber lining. Two 40' lengths of 22" diameter pipes (one on each loop) were replaced in 1999 as a result of the failed rubber lining and internal corrosion. These spools were replaced with carbon steel coated internally and externally with an epoxy coating. The piping that was removed was examined after its wrapping was removed and its external surface was found to be in good condition. Since that time, the entire length of both SSW buried discharge loops have been lined internally with cured-in-place pipe linings, "B" Loop in 2001 and "A" Loop in 2003.

The phased array inspection technique, was provided merely as an example of a potential future examination technique. It and other remote techniques will potentially be able to assess the condition of extensive portions of buried piping without the need for excavation.

This exception was taken to allow the potential use of this technique or others in lieu of excavating piping in order to provide a more effective assessment of overall piping condition while eliminating the potential for damaging the piping during excavation.

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Number Status Request Response NRC PNPS Lead Since a superior inspection technique is not yet available, specifics regarding qualification of the process and technicians are not available.

494 Closed Five line items in Table 3.3.2-14-1 (LRA pages 3.3-134 The circulating water system consists primarily of two circulating Wen, Peter Ivy, Ted through 137) reference Table 3.4.1 item 3.4.1-8 and credit water pumps and associated piping and valves as shown primarily PSPM Program to manage the aging effect of LOM for steel on M211. The review to determine the 10 CFR 54.4(a)(2) piping, piping components, and piping elements exposed to components used a spaces approach that identified all component raw water. Please identify the specific components in the types and material combinations in the system that were in scope Circulating Water System that are represented by these but did not list individual component numbers. As identified in LRA Table 2 line items and provide procedures under which Table 2.3.3.14-B, the only areas of the turbine building that were PSPM will be implemented to manage the aging effect of excluded were the components inside.the main condensers and the LOM due to general, pitting, crevice, MIC, and fouling. only portions of the intake structure that were excluded were the intake structure hypochlorite pump room and chlorination area.

The components included bolting, circulating water pump casings, the above ground piping, tubing, thermowells, the condenser inlet outlet and cross connect valves, expansion joints and the associated vent, drain, and instrument valve bodies. The water box scavenging system shown on M211 is no longer in use, but the portions that still form a pressure boundary for the water boxes are included. As identified on M212 Sheet 1, the residual chlorine sample pump is no longer used, but portions of the system were included that still form the pressure boundary.

As indicated in Attachment 3 of LRPD-02, Aging Management Program Evaluation Report (AMPER), procedures do not exist for the inspection of these components, and a complete listing of components that will be included in the procedures is not available.

As stated in LRA Appendix B and Commitment 21, program activity implementing documents will be enhanced prior to the period of extended operation to incorporate the attributes of this inspection described in the AMPER. This will assure that the effects of aging will be managed such that applicable components will continue to perform their intended functions consistent with the current licensing basis for the period of extended operation.

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Number Status Request Response NRC PNPS Lead 495 Closed Four line items in Table 3.3.2-14-1 (LRA pages 3.3-134 and Some of the circulating water system piping in scope for Wen, Peter Ivy, Ted 135), PNPS claimed that Circulating Water System [Maintenance Rule 10 CFR 50.651 (a)(2) shown on the piping &

components of piping and tanks which are made of plastic, instrument diagrams is piping codes JE and JF. Pipe class JE is have no aging effect under condensation external and raw fiberglass reinforced plastic. As identified in the PNPS water internal environments. What kind of plastic material Specification for Piping M300, piping code JF allows the use of are they. Why are they not subject to aging effect? PVC piping. Per Note 3 on M21 1, some of the piping is PVC. The 55 gallon drum shown on M212 Sheet 1 which is the tank in this line item is also PVC.

Aging effects were identified for (a)(2) components included in AMRM-30 using the Non-Class 1 Mechanical Implementation Guideline and Mechanical Tools, Revision 3, EPRI, Palo Alto, CA:

2001, 1003056 (The Mechanical Tools). In accordance with the Mechanical Tools, Section 2.1.8 of Appendix A, PVC and thermoplastics are relatively unaffected by water or humidity. The components in question are installed indoors and contain raw water.

Therefore, based on the Mechanical Tools and industry operating experience, this piping has no aging effects requiring management in raw water or condensation environments.

496 Closed Four line items in Table 3.3.2-14-1 with note F(LRA page As indicated in Attachment 3 of LRPD-02, Aging Management Wen, Peter Ivy, Ted 3.3-133), the applicant proposed to manage cracking and Program Evaluation Report (AMPER), inspections will be performed change in material properties of the elastomer for condenser to determine the surface condition and flexibility of the circulating expansion joint exposed to raw water and condensation in water expansion joints. As indicated in the AMPER, a external environment using AMP of Periodic Surveillance and representative sample of the expansion joints will be visually Preventive Maintenance (PSPM). Please provide technical inspected and manually flexed every 5 years to verify no significant justification as why PSPM alone is sufficient to manage the cracking or other abnormalities while flexing elastomer components.

aging effects of cracking and change in a material properties. A visual inspection and physical manipulation of this component ensures that the elastomer is not cracking and that the material properties of flexibility are still adequate for the expansion joint to maintain its pressure boundary and not affect safety-related components. Industry operating experience for components of this type has shown that the frequency of inspection should be adequate to manage these aging effects.

497 Closed Three line items in Table 3.3.2-14-1 (LRA pages 3.3-134, While these components are managed by the selective leaching Wen, Peter Ivy, Ted 135, and 136), the applicant proposed to manage LOM of program for the internal surface, the selective leaching program is copper alloy >15% Zn for piping, strainer housing and valve not credited with the management of loss of material for external body exposed to condensation external environment using surfaces that are only wetted by condensation. If these components AMP of System Walkdown. Please provide technical were to experience selective leaching, the aging effect will occur on justification as why System Walkdown alone is sufficient to and be identified by the Selective Leaching Program for the internal manage the aging effect of LOM. Do you consider the aging surface that is exposed to raw water before any significant selective effect of loss of material due to selective leaching for these leaching is experienced on the external surface that is wetted only line items. by periodic condensation. This is due to the minimal amount of electrolyte that is present in a periodic condensation environment.

Therefore, the System Walkdown Program alone is expected to be an adequate program for the external surfaces of these components.

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Number Status Request Response NRC PNPS Lead 498 Closed Eleven line items in Table 3.3.2-14-9 with note G (Extraction As can be seen in section 4.24.2 of LRPD-02, Aging Management Wen, Peter Ivy, Ted Steam System, the applicarnt proposed to manage cracking, Program Evaluation Report (AMPER), the water chemistry LOM, and cracking-fatigue of nickel alloy for expansion joint control-BWR program includes periodic monitoring and control of exposed to treated water using water chemistry control BWR known detrimental contaminants such as chlorides, dissolved and TLAA metal fatigue. Two line items related to TLAA oxygen, and sulfate concentrations below the levels known to result metal fatigue will be lumped to Question 3.4.1-W-01 for in loss of material or cracking. As identified in Attachment 2 of the discussion. For the other 9 line items, please provide AMPER, a One-Time Inspection Program will be completed to verify technical justification as why Water Chemistry Control BWR the effectiveness of the water chemistry control-BWR program to alone is sufficient to manage the aging effects of cracking manage the aging effects of loss of material and cracking.

and LOM. Therefore, the combination of these two programs is sufficient to manage the aging effects of cracking and loss of material for nickel alloy components exposed to treated water.

This requires an amendment to the chemistry program descriptions in LRA Appendices A and B to clearly indicate that the One-Time Inspection Program will confirm the effectiveness of the Water Chemistry Control - BWR, Water Chemistry Control - Auxiliary Systems and the Water Chemistry Control - Closed Cooling Water programs.

This item is closed to Item 372.

499 Closed [T.3.3.2.14] In accordance with AMP B.1.13.1, procedures will be enhanced Patel, Erach Ivy, Ted (attributes 3 and 6) to verify that the diesel engine does not exhibit In Table 3.3..2-9, Fire Protection - Water System, PNPS signs of degradation while running; such as fuel oil, lube oil, credits LRA AMP B.1.13.1, Fire Protection Program to coolant (jacket water), or exhaust gas leakage. Through monitoring manage loss of material and fouling of gray iron and copper and trending of performance data, specifically jacket cooling water, ally >15% Zn heat exchanger shell and tubes. However, the fouling and loss of material for the fire pump diesel jacket water heat Fire Protection program description does not include these exchanger will be identified and corrected through the corrective components nor has the program been enhanced to include action program. As described in operating experience for AMP these components. B.1.13.1, observation of degraded performance produced corrective actions including engine replacement in 2002 prior to loss of Please clarify how the Fire Protection Program will manage intended function. Consequently, continued implementation of the these aging effects for these components. Fire Protection Program provides reasonable assurance aging effects will be managed for the diesel fire pump jacket water heat exchanger. In addition, PNPS performs fire pump inspection, testing and maintenance in accordance with NFPA 25 which would also detect the presence of aging effects in the jacket water system prior to loss of intended function.

This item is closed to item 378.

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Number Status Request Response NRC PNPS Lead 500 Closed [T.3.3.2.15] At PNPS piping codes JE, JF, JG and HT are plastic or fiberglass. Patel, Erach Ivy, Ted As identified in the PNPS Specification for Piping M300, pipe class In the LRA, PNPS has indicated "None-None" for AE/AMP JE is fiberglass reinforced plastic, piping code JF allows the use of combination in several Table 2's in section 3.3, for plastic polyvinyl chloride (PVC) piping, and class HT piping is PVC. Per components in various environments. note 3 on M2.1 1, some of the pipe code JG is PVC.

Please identify what kind(s) of plastic material is (are) used Some specific components are also identified as plastic in the LRA at PNPS. that are not included in the piping class summary sheets which required component specific reviews to identify the material. For instance some components such as the tank shown on M212 sheet 1 is identified on the drawing as a 55 gallon PVC drum and some piping like the piping on M273 sheet 3 is identified on the drawing as chlorinated polyvinyl chloride (CPVC).

The fuel oil system table 3.3.2-7 also identifies a plastic filter housing used on the station blackout diesel fuel oil filter X-176.

These are plastic bowls at the bottom of the filter housing that collect water and sediment. The exact type of plastic is not known but was selected for use by the original manufacturer in this application. In addition, similar to all the plastic materials described above it is not exposed to direct sunlight and was designed to be used with fuel oil. Therefore, as stated in the EPRI Mechanical Tools none of these components is expected to experience aging effects that require management in the environments to which they are exposed.

501 Accepted [T.3.3.2.16] The only table that did not identify loss of material for stainless Patel, Erach Ivy, Ted steel bolting in an air-outdoor environment was Table 3.3.2-7 for the In some Table 2's, PNPS has stated "None-None" for fuel oil system. Loss of material is an aging effect requiring AE/AMP combination for stainless steel bolting in an management that should have been identified for the stainless steel air-outdoor environment, however, in Tables 3.3.2-5 and bolting with an environment of air-outdoor. This aging effect is 3.3.2-9, PNPS identified loss of material as an aging effect managed by the System Walkdown Program.

for the same material/environment combination and credited the system walkdown program to manage this aging effect. In This requires an amendment to the LRA.

an outdoor environment, stainless steel material could be susceptible to loss of material.

Please clarify this discrepancy.

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Number Status Request Response NRC PNPS Lead 502 Closed T.3.3.2.17 The "Scope of Program" section of B.1.32.1 of the LRA states city Patel, Erach Ivy, Ted water is taken from the Town of Plymouth water main and distributed In Table 3.3.2-14-21, PNPS has credited the Water throughout the potable and sanitary water system at town water Chemistry Control - Auxiliary Systems program to manage the pressure. City water is monitored and treated by the Town of aging effect of loss of material for components in the Plymouth to meet the regulations of the Commonwealth of potable and sanitary water system. However, the program Massachusetts.

description and the scope of the program only address stator cooling water chemistry. The only element where potable As stated in the "Detection of Aging Effects" section of B.1.32.1 of and sanitary water is mentioned is in the element for the LRA, verification that the water monitoring and treatment by the detection of aging effects. Town of Plymouth is effective will occur under the One-Time Inspection Program, which entails inspections to verify the Please justify why potable and sanitary water is not identified effectiveness of water chemistry control programs to ensure that in the program description and scope of work or supplement significant degradation is not occurring and component intended the program to include it. function is maintained during the period of extended operation.

Therefore potable and sanitary water is included in the program.

503 Open - Question 4.3-1: Identify which components/commodity This response addresses Question 504 and Question 505. Medoff, Jim Finnin, Ron Plant groups in AMR Tables 3.1.2-1, -2, and -3 were designed to ASME Section Ill. Clarify which components/commodity groups received an ASME Section III CUF calculation, and identify which commodity group listing in LRA Table 4.3-1 provides the applicable CUF result. If no CUF calculation was performed, justify the basis for exclusion and propose an acceptable AMP to manage the aging effect "cracking fatigue" in accordance with the criterion in 10 CFR 54.21 (c)(1)(iii). If an exclusion from performing a CUF calculation is based on an ASME Section 111,provide the paragraph in the Code.

504 Closed Question 4.3-2: Identify which components in AMR Tables Answered in Question 503. Medoff, Jim Finnin, Ron 3.1.2-1, -2, and -3 were designed in accordance with the ASME B31.1 Code. Clarify whether the commodity groups were evaluated for an allowable stress reduction assessment based on the 7000 thermal cycles in accordance with the B31.1 Code. Identify whether:

(1) the allowable stress reduction analysis remains bounded under 10 CFR 54.21 (c)(1)(i),

(2) the allowable stress range needs to be reduced in accordance with the stress reduction criteria in the B31.1 Code to comply with 10 CFR 54.21 (c)(1)(ii), or (3) the aging effect "cracking - fatigue" needs to be managed for the period of extended (EPO) operation in accordance with 10 CFR 54.21 (c)(1)(iii) and propose an acceptable AMP to manage the aging effect.

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Number Status Request Response NRC PNPS Lead 505 Closed Question 4.3-3: For non-piping components/commodity Answered in Question 503. Medoff, Jim Finnin, Ron groups in LRA Tables 3.1.2-1, -2, and -3 that were not designed to ASME Section IIIor AMSE B31.1, identify which design code applies to the particutar commodity group and clarify whether the design code required a metal fatigue analysis. If a metal fatigue analysis was required, summarize what type of metal fatigue calculation was required to be performed and discuss how: (1) the analysis remains bounding under 10 CFR 54.21(c)(11)(i), (2) has been projected to the expiration of the EPO and remains acceptable pursuant to 10 CFR 54.21 (c)(1)(ii), or (3) whether an AMP needs to be proposed to manage the aging effect of "cracking - fatigue" for the EPO and state which AMP will be used to manage the aging effect. If a metal fatigue analysis was not performed and "cracking -fatigue" needs to be manage for the EPO, propose an acceptable AMP for the management of the aging effect in accordance with the criterion in 10 CFR 54.21 (c)(1)(iii).

506 Open - Question 4.3-4: For non-piping components/commodity Medoff, Jim Finnin, Ron Plant groups in LRA Tables 3.2.2-X, 3.3.2-X and 3.4.2-X, identify which design code applies to the particular commodity group and clarify whether the design code required a metal fatigue analysis. If a metal fatigue analysis was required, summarize what type of metal fatigue calculation was required to be performed and discuss how:

(1) the analysis remains bounding under 10 CFR 54.21(c)(1)(i),

(2) has been projected to the expiration of the EPO and remains acceptable pursuant to 10 CFR 54.21 (c)(1)(ii), or (3) whether an AMP needs to be proposed to manage the aging effect of "cracking - fatigue" for the EPO and state which AMP will be used to manage the aging effect.

If a metal fatigue analysis was not performed and "cracking

-fatigue" needs to be manage for the EPO, propose an acceptable AMP for the management of the aging effect in accordance with the criterion in 10 CFR 54.21 (c)(1)(iii).

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Number Status Request Response NRC PNPS Lead 507 Open - Question 4.3-5: The application states that, while not The statement that the reactor vessel internals were built to the Medoff, Jim Finnin, Ron NRC mandatory, the design of the RPV internal components is in intent of ASME section XI came from the FSAR. GE made this accordance with the intent of ASME Section II1. Please statement in many of the FSARs for BWRs of Pilgrim's vintage.

clarify from both a regulatory and technical point of view what is meant by designed in accordance with the "intent ASME This statement means that the design of the reactor internals was Section II1." Identify which Edition of ASME Section III is better than commercial grade quality. Materials, wall thickness, being referred to with respect to the design of the RPV construction-techniques (including welding) were what would have internals. been used for an ASME component. However, analyses and testing were not performed or documented as required for a component designed "in accordance with" the ASME code.

As no specific code was adhered to, no specific code year was specified; however, as the internals were designed as part of the plant design it can be assumed the same code year (1965) was used for general guidance.

LRA Section 4.3.1.2 will be revised to delete the statement that the internals are designed to the intent of the ASME code as follows:

"4.3.1.2 Reactor Vessel Internals A review of the design basis document reveals that the only internals component for which there is a fatigue analysis is the core shroud stabilizer (tie rods), the result of a repair to structurally replace circumferential shroud welds surrounding the core. This analysis is a TLAA. The maximum CUF identified for the shroud for 40 years of operation is 0.33. The CUF is included in Section 4.3.1.

The Fatigue Monitoring Program ensures the fatigue analyses remain valid by monitoring the actual numbers of cycles and evaluating them against the design values for numbers of allowable cycles. Time-limited aging analyses (fatigue analyses) for the core shroud stabilizer will remain valid for the period of extended operation in accordance with 10 CFR 54.21 (c)(1 )(i) or the effects of aging on the intended function(s) will be adequately managed for the period of extended operation in accordance with 10 CFR 54.21 (c)(1)(iii)."

This requires an amendment to the LRA.

508 Open - Question 4.3-6: The first full paragraph on page 4.3-2 states PNPS identified no fracture mechanics (flaw growth) analyses that Medoff, Jim Finnin, Ron NRC that fracture mechanics analyses or flaw growth analyses are were TLAA.

TLAAs for PNPS if the analyses are based on time-limited assumptions. Identify all fracture mechanics or flaw growth The results of the PNPS review of these analyses are located in safety assessments that meet the criteria for TLAAs in 10 Section 2.4 of PNPS document LRPD-06, -Limited Aging Analyses CFR 54.3. If any exist, amend Section 4.0 of the LRA to - Mechanical Fatigue. Three flaw growth analyses were found (the include them as TLAAs for the application and evaluate CRD nozzle to end cap weld, the Reactor Recirculation nozzle them in accordance with the requirements of 10 CFR thermal sleeves, and Reactor Recirculation nozzle N2F). None of 54.21 (c)(1). Include enough technical information to justify these analyses were TLAA.

acceptability of the fracture mechanics or flaw growth analyses. Any fracture mechanics or flaw growth analyses that meet these TLAA criteria will be evaluated by the NRC's technical staff in the Division of Component Integrity, Office of Nuclear Reactor Regulation.

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Number Status Request Response NRC PNPS Lead 509 Accepted [3.6.2.2-N-07] Loss of material due to mechanical wear is an aging effect for strain Nguyen, Duc Stroud, Mike and suspension insulators if they are subject to significant In LRA Section 3.6.2.2, you have stated that mechanical movement. A possible cause for movement of the insulators is wind wear is an aging effect for strain and suspension insulators blowing the supported transmission conductor, allowing the in that they are subject to movement. Wear has not been conductor to swing from side to side. Although this mechanism is apparent during routine inspections. If left unmanaged for possible, industry experience has shown transmission conductors the period of extended operation, surface rust would not do not normally swing and that when they do, due to a substantial cause a loss of intended function and thus, is not a. wind, they do not continue to swing for very long once the wind has significant concern. Provide a technical justification of why subsided. PNPS has no transmission conductors supported by loss of material due to mechanical wear caused by wind high-voltage insulators in-scope of license renewal and therefore blowing of supported transmission conductors is not an loss of material due to wear of high-voltage insulators is not an aging effect requiring management for high-voltage aging effect requiring management for the period of extended insulators. Also, provide a technical justification of why operation.

surface rust would not cause a loss of intended function and is not a significant concern for high-voltage insulators if left Various airborne materials such as dust, salt and industrial unmanaged for the period of extended operation. effluents can contaminate insulator surfaces. The buildup of surface contamination is gradual and in most areas washed away by rain, while the glazed and coated insulator surfaces at PNPS aids in contamination removal. PNPS applied Slygard (RTV silicone) coatings to some switchyard insulators to reduce flashover. Surface contamination can be a problem in areas where there are greater concentrations of airborne particles such as near facilities that discharge soot. PNPS is not located near any facilities that produce airborne particles such as soot. Therefore, surface contamination is not an applicable aging mechanism for high-voltage insulators at PNPS.

LRA Section 3.6.2.2.2 has a typo in the fourth paragraph. The paragraph should read as follows: "Mechanical wear is an aging effect for strain and suspension insulators in that they are subject to movement. Wear has not been apparent during routine inspections.

If left unmanaged for the period of extended operation, surface contamination would not cause a loss of intended function and thus, is not a significant concern."

This requires an amendment to the LRA.

510 Closed [3.6.2.2-N-08] Since various airborne materials such as dust, salt and industrial Nguyen, Duc Stroud, Mike effluents can contaminate insulator surfaces. The buildup of Various airborne materials such as dust and industrial surface contamination is gradual and in most areas washed away by effluent can contaminate insulator surfaces. A large buildup rain, while the glazed and coated insulator surfaces at PNPS aids of contamination enables the conductor voltage to track in contamination removal. PNPS applied Slygard (RTV silicone) along the surface more easily and can lead to insulator coatings to some switchyard insulators to reduce flashover. Surface flashover. Explain why surface contamination such as dust contamination can be a problem in areas where there are greater and industrial effluent is not a significant aging effect concentrations of airborne particles such as near facilities that requiring management for high-voltage insulators at PNPS. discharge soot. PNPS is not located near any facilities that produce airborne particles such as dust or soot. Therefore, surface contamination is not an applicable aging mechanism for high-voltage insulators at PNPS.

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Number Status Request Response NRC PNPS Lead 511 Closed [3.6.2.2-N-09] A potential mechanism contributing to aging of switchyard bus Nguyen, Duc Stroud, Mike connections is surface oxidation, which can lead to increased Provide a technical justification of why increased resistance contact or connection resistance. Connection surface oxidation is of switchyard bus connections due to oxidation is not an not significant for switchyard bus connections at PNPS sine the aging effect requiring management. switchyard bus connections are welded. Therefore, no aging effects due to surface oxidation are required to be managed for the period of extended operation.

The connections to active devices are inspected under the Maintenance Rule program. In addition, thermography is performed at least once every 6 months to maintain the integrity of the connections. This program will continue into the period of extended operation.

512 Accepted [3.1.1-13] As stated in PNPS AMRM-33, "cracking due to flaw growth is Jackson, Wilbur Finnin, Ron managed by the inspection requirements for Class 1 components in LRA Table 3.1.1, Item Number 48, is applicable for Class 1 accordance with ASME Section Xl, Subsection IWB. Because piping, fittings and branch lines <NPS 4" exposed to reactor inservice inspection per ASME Section Xl is required in accordance coolant. The GALL Report indicates that the aging effects of with 10 CFR 50.55a, cracking due to flaw growth is not identified on cracking due to thermal and mechanical loading apply for the tables in Attachment 1." Cracking due to flaw growth is both carbon steel and stainless steel components. considered equivalent to the NUREG-1 801 entry of cracking due to However, no Class 1 piping components made of carbon thermal and mechanical loading. The ISI Program applies to Class steel are rolled up to this line item. 1 carbon steel piping components at PNPS.

Please explain why no carbon steel piping components are The LRA will be clarified to show that cracking is an aging effect rolled up to this line. Are there no Class 1 carbon steel requiring management for Class 1 carbon steel piping components piping components <NPS 4" at PNPS? If there are Class 1 <NPS 4" at PNPS and that the appropriate aging management carbon steel piping components <NPS 4" at PNPS, then programs include the ISI Program and the One-Time Inspection please justify why they are not rolled up to line item 3.1.1-48. Program. The discussion column for Item 3.1.1-48 will be revised to be consistent with this change. The credited aging management programs will be the same as those listed for the NUREG-1 801 line items corresponding to LRA Table 3.1.1, Item 48.

This requires an amendment to the LRA.

513 Accepted As a follow-up to question T3.2.1-35-P-01 (Item 442) one of The Periodic Surveillance and Preventive Maintenance (PSPM) Pavinich, Wayne Ivy, Ted the line items that rolls up to Item 3.2.1-35 only credits the Program is more appropriate to manage loss of material for piping Containment Leak Rate program for managing the aging and valve body in a raw water internal environment in Table 3.2.2-7.

effect of loss of material. In accordance with GALL XI.S4 this program by itself does not detect that aging degradation has initiated. Please explain how the use of the The LRA will be revised to credit this program instead of Containment Leak Rate program is acceptable by itself to Containment Leak Rate Program to manage the aging effect of loss manage aging effects. of material. In addition, the discussion in Item 3.2.1-35 of Table 3.2.1 will be revised to read as follows: "The Periodic Surveillance and Preventive Maintenance Program manages the loss of material for steel components exposed to raw water."

This requires an amendment to the LRA to revise Table 3.2.2-7, 3.2.1 and Appendix B.

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Number Status Request Response NRC PNPS Lead 514 Accepted [3.1.1-32] Throughout the application, the One-Time Inspection (OTI) Program Jackson, Wilbur Finnin, Ron has been treated as a support program for the water chemistry LRA Table Items 3.1.1-14, 3.1.1-15 and 3.1.1-47 all include program for the purposes of verifying water chemistry program discussions saying that aging of the components rolling up effectiveness. The One-Time Inspection Program has not been to those lines will be by Water Chemistry augmented by the treated as an aging management program directly applicable to the One Time Inspection Program. Attachment 2 of LPRD-02, systems that credit water chemistry for aging management. This Revision 02, provides a list of AMRM's affected by the treatment was considered appropriate since the verification of water One-Time Inspection Activities. However, Attachment 2 chemistry program effectiveness will be one integrated task that does not include AMRM-31 (Reactor Pressure Vessel) or verifies effectiveness of the program for all systems that credit water AMRM-32 (Reactor Vessel Internals) in the list of affected chemistry; the water chemistry program effectiveness will not be AMRM's. verified separately for each system. For the cases where the One-Time Inspection Program addresses component specific Please provide an explanation of why AMRM-31 and inspections, it is listed in the LRA as an aging management AMRM-32 are not included in Attachment 2 of LRPD-02, program directly applicable to the components.

Revision 02. How will PNPS ensure that appropriate one-time inspections are performed for the RPV and RVI The first row of Attachment 2 of LRPD-02 identifies the activities of components where such inspections are credited for Aging the One-Time Inspection Program that will verify water chemistry Management during the period of extended operation? program effectiveness for all systems that credit water chemistry.

This line applies to the water chemistry programs, including Water Chemistry Control - BWR, which in turn applies to many of the systems listed in the application. The reactor pressure vessel and reactor vessel internals components credit the Water Chemistry Control - BWR program, so this line applies to AMRM-31 and AMRM-32.

The remaining lines of Attachment 2 of LRPD-02 identify activities of the One-Time Inspection Program that address component specific inspections. Applicable systems are identified for these inspections.

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L Number Status Request Response NRC PNPS Lead 515 Open - LRA Table 4.3-1 provides the limiting LRPD-06 was not intended to imply that the CUFs should be projected Medoff, Jim Finnin, Ron Plant 40-year cumulative usage iactors (CUFs) for the RPV, RPV out to 60 years in accordance wTh 10 CFR 54.21 (c)(1)(ii). CUFs in internal components, and reactor coolant pressure boundary Table 4.3-1 are based on assumed numbers of transient cycles, (RCPB) piping that were designed to ASME not on a number of years. These CUFs are not necessarily 40-year Section II1. With the exception of the CUF values for RPV limiting values. As long as the cycles are not exceeded, the CUFs feedwater nozzles, PNPS has accepted the TLAA metal do not need to be recalculated. While some of the numbers of cycles fatigue CUF analyses and stated that the 40-year CUF projected for 60 years in Table 4.3-2 exceed the design basis assumptions conclusion remains valid for the period of extended operation for numbers of cycles, the Fatigue Monitoring Program assures (EPO) in accordance with 10 CFR 54.21 (c)(1)(i) or that the that the analyses will be revised to increase the allowable effect of "cracking - fatigue" will be managed for the EPO. number of cycles before exceeding the design basis assumptions.

The last paragraph on Page 11 of LRPD-06 states that "more While LRPD-06 projects numbers that exceed the design basis than half of the design basis transients defined in the assumptions, the projections are conservative and the actual UFSAR projections show that the allowable limit, as defined numbers of cycles may not exceed the design basis assumptions by the RPV cyclic load analysis, will be exceeded before the on the numbers of cycles. CUFs will require recalculation if end of the period of extended operations." The paragraph the numbers of actual transients approach the design basis values.

further states that "A detailed analysis beyond the scope of Because the CUFs in Table 4.3-1, with the exception of the feedwater this report would be required to re-evaluated the CUFs if the nozzle, are well below 1, the allowable numbers of cycles transient limits are in fact exceeded," and that "The existing can be increased through reanalysis assuming higher numbers of cycle monitoring program will monitor the cycles and require cycles.

corrective action upon approaching a limit."

Please explain how the 40-year CUF conclusion will remain valid for the EPO when PNPS Report No. LRPD-06 implies that the CUFs should be recalculated and projected out 60 years. Please take in account the fact that Draft Commitment 31 requires corrective action when the CUFs exceed 1.0, and not when the implementation of AMP B.1.12, "Fatigue Monitoring Program" determines that the actual transient cycles will approach the number of design transient cycles that are allowed in the design basis. If the CUFs should have been projected and recalculated for 60-years, as indicated in LRPD-06, provide a commitment when the 60-year CUFs values for the RCPB components will be provided to the NRC for review and approval under either 10 CFR 54.21(c)(1)(ii) or (iii). The response to this question may require amendment of Commitment 31 and/or UFSAR Supplement Summary Description A.2.2.2.1, "Class 1 Metal Fatigue."

This item goes with item 425.

516 Open - The TPO project documented the results of reactor vessel Patel, Erach Finnin, Ron Plant fatigue usage factors of limiting components in table 3-2 in GE report GE-NE-0000-0000-1898-02, Rev.0 March 2002. In the summary Table, it states that for CRD nozzle - stub tube, the existing PNPS CUF value was 0.8, and is now changed to 0.870 for TPO. However, the LRA Table 4.3.1, which identifies class 1 CUF values, the CRD nozzle value of 0.8 was not identified.

Please justify why this value was not included in the LRA.

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.4, Number Status Request Response NRC PNPS Lead 517 Open - Question 4.3-8: PNPS provided the project team with the Medoff, Jim Finnin, Ron Plant stress analyses and cumulative usage factor calculations for the PNPS recirculation replacement piping systems and core shroud stabilizers in the following documents:

- DC23A4084 & 23A4084, Rev.1, Pilgrim Recirculation Piping Replacement, June 27, 1985.

- GE Report 25A5685, Revision 1, Stress Report - Shroud Stabilizers Vessel, June 19, 1995.

• GE Report GENE-771-79-1194, Revision 2, Shroud Repair Hardware Stress Analysis, June 19, 1995.

LRA Table 4.3-1 lists that the limiting 40-year CUF for the recirculation piping is 0.110 and that the limiting 40 year CUF for the core shroud stabilizers is 0.330. The limiting 40 year CUF values provided in these reports for these components are 0.923 and 0.008, respectively. These values do not correlate to the 40-year CUF values provided in LRA Table 4.3-1. Explain why the 40-year CUF values in these design basis documents differ from the 40-year values provided in LRA Table 4.3-1 . If these design basis document do not constitute the most current design basis CUF bases for the replacement recirculation piping system and core shroud stabilizers, clarify which documents do contain the latest design basis CUF calculations for these component commodity groups. Should this be the case, this question will remain open until the staff can review the appropriate design basis calculations for these component commodity groups.

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