NL-08-051, Reply to Request for Additional Information Regarding License Renewal Application - Balance of Plant, Fire Protection, and Nickel Alloy

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Reply to Request for Additional Information Regarding License Renewal Application - Balance of Plant, Fire Protection, and Nickel Alloy
ML080780438
Person / Time
Site: Indian Point  Entergy icon.png
Issue date: 03/12/2008
From: Dacimo F
Entergy Nuclear Northeast
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-08-051I
Download: ML080780438 (31)
v • d • e


Text

Entergy Nuclear Northeast Indian Point Energy Center SEntergy- 450 Broadway, GSB P.O. Box 249 Buchanan, NY 10511-0249 Tel 914 788 2055 Fred Dacimno Vice President License Renewal March 12, 2008 Re: Indian Point Units 2 & 3 Docket Nos. 50-247 & 50-286 NL-08-051I U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

SUBJECT:

Reply to Request for Additional Information Regarding License Renewal Application -

Balance of Plant, Fire Protection, and Nickel Alloy

Reference:

NRC letter dated February 13, 2008; "Request for Additional Information for the Review of the Indian Point Nuclear Generating Unit Nos. 2 and 3, - Balance Of Plant, Fire Protection And Nickel Alloy"

Dear Sir or Madam:

Entergy Nuclear Operations, Inc is providing, in Attachment I, the additional information requested in the referenced letter pertaining to NRC review of the License Renewal Application

.for Indian Point 2 and Indian Point 3. The additional information provided in this transmittal addresses staff questions for Balance of Plant, Fire Protection, and Nickel Alloy.

There are no new commitments identified in this submittal. If you have any questions or require additional information, please contact Mr. R. Walpole, Manager, Licensing at (914) 734-6710.

I declare under penalty of perjury that the foregoing is true and correct. Executed on 3/ /o*

Fed R. Dacimo Vice President License Renewal A42 ý

NL-08-051 Docket Nos. 50-247 & 50-286 Page 2 of 2

Attachment:

Reply to NRC Request for Additional Information Regarding License Renewal Application - Balance of Plant, Fire Protection, and Nickel Alloy cc: Mr. Bo M. Pham, NRC Environmental Project Manager Ms. Kimberly Green, NRC Safety Project Manager Mr. John P. Boska, NRC NRR Senior Project Manager Mr. Samuel J. Collins, Regional Administrator, NRC Region I Mr. Sherwin E. Turk, NRC Office of General Counsel, Special Counsel IPEC NRC Senior Resident Inspectors Office Mr. Paul D. Tonko, President, NYSERDA Mr. Paul Eddy, New York State Dept. of Public Service

ATTACHMENT I TO NL-08-051 REPLY TO NRC REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE RENEWAL APPLICATION Balance of Plant, Fire Protection, and Nickel Alloy ENTERGY NUCLEAR OPERATIONS, INC INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 and 3 DOCKETS 50-247 and 50-286

NL-08-051 Attachment I Docket Nos. 50-247 & 50-286 Page 1 of 28 INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3 LICENSE RENEWAL APPLICATION (LRA)

REQUESTS FOR ADDITIONAL INFORMATION (RAI)

BALANCE OF PLANT, FIRE PROTECTION, AND NICKEL ALLOY The U.S. Nuclear Regulatory Commission (NRC or staff) has reviewed the information related to RCS and Structures provided by the applicant in the Indian Point Nuclear Generating Unit Nos.

2 and 3 (IP2 and IP3) LRA. The staff has identified that additional information is needed to complete the review as addressed below.

Balance of Plant RAI 2.3A.2.2-1 Containment Spray The aging management review (AMR) boundary for a system is typically highlighted on license renewal drawings. However, the license renewal drawings provided to the staff did not contain a depiction of (a)(2) boundaries or components. Section 2.3.2.2 of the license renewal application (LRA) states: "The containment spray system has no intended function for 10 CFR 54.4(a)(2)."

On Unit 2 license renewal drawing LRA-9321-2735 (containment spray system), the piping line

  1. 187, including valve 872D 3/4"-T58 was not highlighted, but it appears to be directly connected to safety-related spray piping. This piping is located downstream of the safety class boundary on the suction piping, 12"-S1-151 R- #181, from the refueling water storage tank (RWST) to the containment spray pump at branch connection, 2"-S1-151 R- #588, ending at valve 873B 2"-T58.

Similarly, there is a non-highlighted mini-flow recirculation line from the pump. Piping downstream of the safety class boundary may not be required to perform the safety-related function, but may need to be included in scope under 10 CFR 54.4(a)(2).

Indicate whether portions of the above system(s) were evaluated for inclusion within the scope of license renewal in accordance with 10 CFR 54.4(a)(2). Identify all other instances, whereby a safety-related system, which has nonsafety-related components, was scoped in per 10 CFR 54.4(a)(1), but those nonsafety-related components were not identified as in scope for 10 CFR 54.4(a)(2).

Response for RAI 2.3A.2.2-1 The containment spray system (CSS) is in scope for 10 CFR 54.4(a)(1) and is shown primarily on drawing LRA-9321-2735. During the initial review of the CSS, piping line #187 and valve 872D 3/4"-T58 downstream of valve 873B as well as a %-inch mini-flow recirculation line downstream of valves 1806A and 1806B were not considered to be in scope based on the criterion of 10 CFR 54.4(a)(2). It has since been determined that the nonsafety-related CSS components listed above have an intended function to maintain integrity such that no physical interaction with safety-related components could prevent satisfactory accomplishment of a safety function. Therefore, this portion of the CSS system is in scope for 10 CFR 54.4(a)(2).

The 10 CFR 54.4(a)(2) scoping evaluation was reexamined and three instances were identified where a system that performs a safety function was in scope per 10 CFR 54.4(a)(1), but the nonsafety-related components were not identified as in scope for 10 CFR 54.4(a)(2). As a

NL-08-051 Attachment I Docket Nos. 50-247 & 50-286 Page 2 of 28 result, the IP2 component cooling water system (CCW), IP3 building vent sampling system (BVS), and IP3 component cooling water system (CCW) also have an intended function to maintain integrity of nonsafety-related components such that no physical interaction with safety-related components could prevent satisfactory accomplishment of a safety function and will be included in scope for 10 CFR 54.4(a)(2). LRA revisions to include portions of these systems and the IP2 CSS in scope for 54.4(a)(2) are provided below. (added text underlined, strikethroughs deleted)

LRA Table 2.3.3-19-A-IP2, Miscellaneous Systems within the Scope of License Renewal for 10 CFR 54.4(a)(2), is revised to add the following line items.

System System Name LRA Section Describing System Number CCW Component Cooling Water Section 2.3.3.3, Component Cooling Water CSS Containment Spray System Section 2.3.2.2, Containment Spray System LRA Table 2.3.3-19-A-1P3, Miscellaneous Systems within the Scope of License Renewal for 10 CFR 54.4(a)(2), is revised to add the following line items.

System Number System Name LRA Section Describing System BVS Building Vent Sampling Section 2.3.2.5, Containment Penetrations CCW Component Cooling Water Section 2.3.3.3, Component Cooling Water LRA Section 2.3.3.19, Miscellaneous Systems in Scope for (a)(2), Components Subject to Aging Management Review, is revised as follows.

The following tables provide additional information concerning areas or components excluded.

IP3 System Area or,Components Excluded Code BVS (*uilding A rcview of the liquid foiled componentS that were not included in oth n Vem reviews identified that these components are lccated where

.Samping.management they; cannot affect equipment with safety funcations.

NL-08-051 Attachment I Docket Nos. 50-247 & 50-286 Page 3 of 28 The following IP2 systems were not reviewed for 54.4(a)(2) for spatial interaction because all of their passive mechanical components were already included because of (a)(1), (a)(3), or other (a)(2) functions.

  • CCF (Containment Cooling and Filtration)

- ese%%AI  % r*,N...., %AI4Al CRD (Control Rod Drive) tC'Z *J~** rý

.,.~ -

Q0I'~.~.n..... Q J ý

  • FCCH (Fuel and Core Component Handling)

" ICI (In-Core Instrumentation)

  • IVSW (Isolation Valve Seal Water)

" RHR (Residual Heat Removal)

The following IP3 systems were not reviewed for 54.4(a)(2) for spatial interaction because all of their passive mechanical components were already included because of other (a)(1),

(a)(3), or other (a)(2) functions.

  • CBHV (Control Building HVAC)

" CO*VVI (Imp*nInt Coling VI Vte* )

  • ESS (Engineered Safeguards Initiation Logic)
  • IVSW (Isolation Valve Seal Water)
  • RPC (Reactor Protection and Control)

" SGLC (Steam Generator Level Control)

  • SPG (Security Propane Generator)

LRA Section Table 2.3.3-19-B-IP2, 10 CFR 54.4(a)(2) Aging Management Review Tables, is revised to add the following line items.

Table 2.3.3-19-B-IP2 10 CFR 54.4(a)(2) Aging Management Review Tables System Name Series 2.3.3-19-xx-IP2 Table Series 3.3.2-19-xx-IP2 Table Component Cooling Water Table 2.3.3-19-45-1P2 Table 3.3.2-19-45-1P2 Containment Spray System Table 2.3.3-19-46-IP2 Table 3.3.2-19-46-IP2

NL-08-051 Attachment I Docket Nos. 50-247 & 50-286 Page 4 of 28 LRA Section Table 2.3.3-19-B-IP3, 10 CFR 54.4(a)(2) Aging Management Review Tables, is revised to add the following line items.

Table 2.3.3-19-B-IP3 10 CFR 54.4(a)(2) Aging Management Review*Tables System Name Series 2.3.3-19-xx-IP3 Table Series 3.3.2-19-xx-IP3 Table Buildinq Vent Sampling Table 2.3.3-19-63-1P3 Table 3.3.2-19-63-1P3 Component Cooling Water Table 2.3.3-19-64-1P3 Table 3.3.2-19-64-1P3 The following tables are added to LRA Section 2.3.3-19 for IP2 and IP3.

Table 2.3.3-19-45-1P2 Component Cooling Water System Nonsafetv-Related Comnonents Potentially Affecting Safety Functions Subject to Aging Management Review Component Type Intended Function Bolting Pressure boundary Heat exchanger (shell) Pressure boundary "in Pressure boundary Thermowell Pressure boundary Valve body Pressure boundary

NL-08-051 Attachment I Docket Nos. 50-247 & 50-286 Page 5 of 28 Table 2.3.3-19-46-1P2 Containment Spray System Nonsafety-Related Components Potentially Affecting Safety Functions Subiect to A-ging Management Review Component Type Intended Function Bolting Pressure boundary Flow indicator Pressure boundary Piping Pressure boundary Tubing Pressure boundary Valve body Pressure boundary Table 2.3.3-19-63-1P3 Building Vent Sampling System Nonsafety-Related Components Potentially Affecting Safety Functions' Subiect to Aging Management Review Component Type Intended Function Bolting Pressure boundary Filter housing Pressure boundary Tubing Pressure boundary Valve body Pressure boundary

NL-08-051 Attachment I Docket Nos. 50-247 & 50-286 Page 6 of 28 Table 2.3.3-19-64-1P3 Component Coolinq Water System Nonsafety-Related Components Potentially Affecting Safety Functions Subiect to Aging Management Review Component Type Intended Function Bolting Pressure boundary Flow element Pressure boundary Heat exchanaer housing Pressure boundary Pipin Pressure boundary Strainer housing Pressure boundary Valve body Pressure boundary LRA Section 3.3, Conclusion, is revised to add the following tables.

Table 3.3.2-19-45-1P2: Component Cooling Water System NUREG- Table Intended Aging Effect ing 1801 Comp Tvye Function Material Environment Requiring Management 11 ae o Function Vol. 2 1 ItemNoe Management Programs Item Pressure Carbon Air- indoor VII.l-4 3.3.1- A Bolting boundary steel (ext) Loss of material Bolting integrity (AP-27) 43 Heat Hexataer Pressure Carbon Air - indoor L oterial External sras1-10 VII.F1-10 59 3.3.1- C e!xchanqer boundary steel (ext) Loss of material surfaces (AP-41) 59 shell monitoring Heat Pressure Carbon Treated water Water chemistry VI1.C2-1 3.3.1- B exchanaer boundary steel wate Loss of material control - closed (A-63) 48 shell cooling water Pressure Carbon Air- indoor External VII.I-8 3.3.1- A boundary steel Aexti Loss of material surfaces (A-77) 58 monitoring

NL-08-051 Attachment I Docket Nos. 50-247 & 50-286 Page 7 of 28 Table 3.3.2-19-45-1P2: Component Cooling Water System Intended Aging Effect - Aging NUREG-1801 TableNoe Comp Type Function Material Environment Requiring Management 1821 Tem Management Programs Item Water chemistry VII.C2- 3.3.1- B Piping boundary steel T ite Loss of material control - closed 14 47 cooling water (A-25) ePressure Carbon Air- indoor External VII.I-8 3.3.1- A Thermowell Presundary boundary steel steel Ai-(ext)

Loss of material surfaces monitoring (A-77) 58 Water chemistry VII.C2- 3.3.1- B1 Thermowell boundary Crtbeel T inr t Loss of material control - closed 14 47 b cooling water (A-25)

Pressure Carbon Air- indoor External VII.I-8 3.3.1- A Valve body Peure Carbo A Loss of material surfaces (A-77) 58 boundary steel (ext) monitoring Pressure Carbon Treated water Water chemistr VIIC2- 3.3.1- B V biLoss Of material control - closed 14 47 cooling water (A-25)

Table 3.3.2-19-46-1P2: Containment Spray System NUREG-Aging Effect An 1801 Table Intended ComD Type Intended aterial Environment Requiring Management 11 ae o Function Management Programs Vol.

Item22 1 Item Noe V.F- C Pressure Stainless Air-indoor 13 3.2.

Bolting boundary steel (ext) None None (EP- 1-57 19)

Flow Pressure Stainless Air-indoor None None V.F-13 3.2.1- A indicator boundar steel (ext) (EP-19) 5_

Water chemistry V.A-27 3.2.1- A Flow Pressure Stainless Treated water Loss of material control- (EP-4) 49 indicator boundary steel (int) primary &

secondary None None V.F-13 3.2.1- A "in Pressure Stainless Air-indoor boundary steel (ext) nEP-19) 57_

NL-08-051 Attachment I Docket Nos. 50-247 & 50-286 Page 8 of 28 Table 3.3.2-19-46-1P2: Containment Spray System NUREG-Aping Effect A 1801 Table Intended Come Type Function Material Environment Requiring Management -801 -Te Notes Management Programs , Item ,

Water chemistry V.A-27 3.2.1- A Pressure Stainless Treated bounday steel (int)water Loss of material control -&

primary (EP-I)

( 49 secondary Pressure Stainless Air-indoor V.F-13 3.2.1- A Tubing boundary steel (ext) None None (EP-19) 5"7 Water chemistry V.A-27 3.2.1- A Pressure Stainless Treated water control - (EP-41) 49 Tubing boundary steel kintm Loss of material primary & -

secondary Pressure Stainless Air-indoor V.F-13 3.2.1- A Valve body boundary steel (ext) None None (EP-1 9 57 Water chemistry V.A-27 3.2.1- A Pressure Stainless Treated water control - (EP-41) 49 Valve body boundary steel (into Loss of material primary &

secondary Table 3.3.2-19-63-1P3: Building Vent Sampling System InenedA-ging Effect A-ginq NUREG-1801 Tabl Comp Type Function Material Environment ReAuiring Mana gement 1801 Table Notes Management Programs Item Pressure Stainless Air-indoor VII.J-15 3.3.1- C Bolting boundar steel (ext) None None (AP-17) 94 Filter Pressure Stainless Air-indoor VII.J-15 3.3.1- A housing boundary steel (ext) None None (AP-17) 94 Filter Pressure Stainless Air-indoor None None -t) 3G housing boundary steel Pressure Stainless Air-indoor VII.J-15 3.3.1- A Tubing boundary steel (ext) None None (AP-17) 94 None None -- -- G Tubin Pressure Stainless Air-indoor (int) boundary steel

NL-08-051 Attachment I Docket Nos. 50-247 & 50-286 Page 9 of 28 Table 3.3.2-19-63-1P3: Building Vent Sampling System NUREG-Aging Effect Aging 1801 Table Intended ComD Type Fntin Material Environment Requiring Management - Notes Function Vol. 2 1 Item Management Programs Item Pressure Stainless Air-indoor VII.J-15 3.3.1- A Valve body boundary steel (ext) None None (AP-17) 94 Pressure *Stainless None -- -- __G Pressure Stess Air-indoor (int) None Valve body boundary steel Table 3.3.2-19-64-1P3: Component Cooling Water System AgincNUREG-Intended Aging Effect Aging 1801 Table Com) Type Function Material Environment Requiring Management Vol. 2 1 Item Notes Management Programs Item Pressure Carbon Air-indoor VII.l-4 3.3.1- A Bolting boundary steel (extA)r Loss of material Bolting integrity (AP-27) 43 Flow Pressure Carbon Air-indoor External VII.I-8 3.3.1- A Loss of material surfaces 58 element boundary steel . (ext) monitoringa Water chemistry VII.C2- 3.3.1- B Flow Pressure Carbon Treated water Loss of material control - closed 14 47 element boundary steel (int) cooling water (A-25)

Heat External VIIF1-10 3.3.1- C exchanger Pressure Carbo Arido Loss of material surfaces (AP-41) 59 housing boundar steel (ext) monitoring Heat Pressure Carbon Treated water Water chemistry VI1.C2-1 3.3.1- B exchanger boundary steel Loss

_int_ of material control - closed (A-63) 48 housing cooling water Pressure Carbon Air-indoor External VII.I-8 3.3.1- A Piing boundary steel Aext) Loss of material surfaces 58 monitoringa

, Water chemistry VII.C2- 3.3.1- B Pressure Carbon Treated water Loss of material control - closed 14 4_7 boundary steel (int) cooling water (A-25)

Strainer Pressure Carbon Air-indoor External Vom.er8 3.3.1- A housng stel bunday *monitoring boundaryLoss of material surfaces (A-77) 58

NL-08-051 Attachment I Docket Nos. 50-247 & 50-286 Page 10 of 28 Table 3.3.2-19-64-1P3: Component Cooling Water System NUREG-Intended A"ing Effect A 1801 Table Comp Type Function Material Environment Requiring Management Vol. 2 1 Item Notes Management Programs Item Water chemistry VII.C2- 3.3.1- B Strainer Pressure Carbon Treated water Loss of material control - closed 14 47 housing boundary steel (int) cooling water Pressure Carbon Air-indoor External VII.I-8 3.3.1- A Valve body boundary steel Aextd Loss of material surfaces (A-77) 58 monitoring Valve body Water chemistry VII.C2- 3.3.1- B Pressure Carbon Treated water Loss of material control - closed 14- 47 boundary steel n cooling water (A-25J RAI 2.3A.4.2-2 Auxiliary Feedwater Section 2.3.4.3 of the license LRA states: "The AFW system has no intended function for 10 CFR 54.4(a)(2)."

The following components on safety-related system(s) are not highlighted, but may need to be considered for 10 CFR 54.4(a)(2):

" auxiliary feedwater pump bearing cooling line on license renewal drawing LRA-9321-2018-0 (Unit 2),

" piping and associated valve SS-189 off of the auxiliary feedwater supply header on license renewal drawing LRA-9321-20183-001 (at location D-7) (Unit 3).

Indicate whether portions of the above system(s) were evaluated for inclusion within the scope of license renewal in accordance with 10 CFR 54.4(a)(2). It is noted that in D-RAI 2.3A.2.2-1, above, the extent of condition has been requested.

Response for RAI 2.3A.4.2-2 The auxiliary feedwater pump bearing cooling piping and valves shown on license renewal drawing LRA-9321-2018-0 are assigned to the city water system (CYW) and subject to aging management review based on the criterion of 10 CFR 54.4(a)(2). The component types are reviewed in LRA Table 3.3.2-19-7-1P2.

Valves BFD-65-5, BFD-65-7, BFD-65-17, and BFD-65-19 are shown as hidden (dashed lines) on drawing LRA-9321-2038-0 and therefore not highlighted, but are highlighted at coordinates B-1, B-3, B-6 and B-4 respectively on drawing LRA-9321-2019. These components are in

NL-08-051 Attachment I Docket Nos. 50-247 & 50-286 Page 11 of 28 scope and subject to aging management review based on the criterion of 10 CFR 54.4(a)(1) as part of the AFW system. Likewise, valves BFD-1 131, BFD-1 133, BFD-1 135, and BFD-1 137 are highlighted on LRA-9321-2019-0 at coordinates B-i, B-3, B-6, and B-4 respectively. The piping connected to these valves is shown on LRA-9321-2038 (coordinates C-4/5) and assigned to the chemical feed system (CF). The CF system is in scope for 10 CFR 54.4(a)(2) with component types reviewed in LRA Table 3.3.2-19-3-1P2.

Piping and associated valve SS-1 89 from the auxiliary feedwater supply header on license renewal drawing LRA-9321-20183-001 at location D-7 are assigned to the secondary plant sampling system (SS) and in scope and subject to aging management review based on the criterion of 10 CFR 54.4(a)(2). The component types are reviewed in LRA Table 3.3.2-19 IP3.

RAI 2.2B-2 Nonsafety-related SSCs directly connected to safety-related SSCs must be structurally sound in order to maintain the pressure boundary integrity of safety class piping. The nonsafety-related piping and supports up to and including the first seismic anchor beyond the safety/nonsafety interface may need to be in-scope in order to assure that the safety-related portion of the piping will be able to perform its intended function.

In the (a)(2) scoping document and LRA Table 2.2-2-1P3, the hydrogen gas system was labeled not in-scope. This system, along with the nitrogen system, has the function to provide the volume control tank (VCT) with gas for oxygen scavenging. Since the piping is directly connected to the VCT, the applicant should consider including the system in-scope for (a)(2) for, potential physical interaction between the nonsafety and safety-related equipment.

Evaluate placing the hydrogen system and/or nitrogen system in-scope for (a)(2) and evaluate any other interfaces of gas system interaction with safety-related equipment.

Response for RAI 2.2B-2 The IP3 VCT, shown on drawing LRA-9321-27363, is in scope and subject to aging management review based on the criterion of 10 CFR 54.4(a)(1). The nitrogen system piping and valve components upstream of check valve 270 are in scope and subject to aging management review based on the criterion of 10 CFR 54.4(a)(2) with component types evaluated in LRA Table 3.3.2-19-37-1P3. In addition, the piping and valves connected to check valve 270 have an intended function to maintain integrity such that no physical interaction with safety-related components could prevent satisfactory accomplishment of a safety function due to structural support. Therefore, the H2 system should be in scope for 10 CFR 54.4(a)(2). LRA revisions to include the H2 system are as follows (added text underlined, strikethroughs deleted).

NL-08-051 Attachment I Docket Nos. 50-247 & 50-286 Page 12 of 28 LRA Table 2.2. la-IP3, Mechanical Systems within the Scope of License Renewal, is revised to add the following line item.

LRA Table 2.2-2-1P3, Mechanical Systems Not Within the Scope of License Renewal, is revised to remove the following line items.

System Unit 2 System Name UFSAR Reference Code H C Sections 10.2.2 and 11.1 LRA Table 2.3.3-19-A-1P3, Miscellaneous Systems within the Scope of License Renewal for 10 CFR 54.4(a)(2), is revised to add the following line item.

System System Name LRA Section Describing System Number H2 Hydrogen Section 2.3.3.19, Miscellaneous Systems in Scope for (a)(2)

LRA Section 2.3.3.19, Miscellaneous Systems in Scope for (a)(2), System Description, is revised to add the following IP3 system description for hydrogen.

Unit 3 Hydrogen The purpose of the H2 system is to provide hydrogen to the main generator for cooling and to the CVCS for volume control tank cover gas. For the CVCS, cylinders of hydrogen supply the hydrogen manifold which in turn supplies the volume control tank. The system includes the piping and valves from the hydrogen cylinders to the CVCS. The system includes no safety-related components.

NL-08-051 Attachment I Docket Nos. 50-247 & 50-286 Page 13 of 28 LRA Section Table 2.3.3-19-B-IP3, 10 CFR 54.4(a)(2) Aging Management Review Tables, is revised to add the following line items.

Table 2.3.3-19-B-IP3 10 CFR 54.4(a)(2) Aging Management Review Tables System Name Series 2.3.3-19-xx-IP3 Table Series 3.3.2-19-xx-IP3 Table Hydrogen Table 2.3.3-19-65-1P3 Table 3.3.2-19-65-1P3 The following table is added to Section 2.3.3-19 for IP3.

Table 2.3.3-19-65-1P3 Hydrogen System Nonsafety-Related Components Potentially Affecting Safety Functions Subiect to Aging Management Review Component Type Intended Function Bolting Pressure boundary Riping Pressure boundary Valve body Pressure boundary LRA Section 3.3, Conclusion, is revised to add the following table.

Table 3.3.2-19-65-1P3: Hydrogen System Effect Lk "in NUREG-1801 Tabl IntededAging Comp Type Intended Material Environment Eangent ReAuiring 1801 Table Notes Function Management Programs Vol. 2 1 Item Item Pressure Carbon Air-indoor VII.I-4 3.3.1- A Bolting ur steel ext) Loss of material Bolting integrity (AP-27) 4-3 bo1dr ste - I I

NL-08-051 Attachment I Docket Nos. 50-247 & 50-286 Page 14 of 28 Table 3.3.2-19-65-IP3: Hydrogen System NUREG-ntendedin Effect n 1801 Table Como Type Function Material Environment Requiring Management - Notes Management Programs Item Pressure Stainless Air-indoor P VIINJ-15 3.3.N1o-Bolting boundary steel ext None None (AP-17) 94 VII.J-15 3.3.1- A Pipina Pressure Stainless Air-indoor boundary steel (ext) None None (AP-17) 924 Pressure Stainless VII.J-19 3.3.1- A Piia boundary steel Gas (in) None None (AP-22) 97 Pressure Copper PrssreAi-idorNone Air-indoor None V.F-3 (Pl) 53.2.1- C alve body boundary >15%zn (ext) (EP-10) 53 Pressure Copper VII.J-4 3.3.1- A bound alloy Gas (int) None None (AP-9) 97

>15%zn Pressure Stainless Air-indoor VII.J-15 3.3.1- A Valve body boundary steel (ext) None None (AP-17) 94 Pressure Stainless VII.J-19 3.3.1- A Valve body boundary steel Gas (int) None None (AP-22) 97 No additional changes are required due to other gas system interaction with safety-related equipment.

RAI 2.3.0-2 Several LRA drawings identify various components as "Not A Long Lived Component," i.e., the component is not subject to an aging management review (AMR).

" Drawing LRA-9321-2720 and LRA-9321-27203 for Unit 2 and Unit 3, respectively, show several components for the component cooling water system to the reactor coolant pumps 21, 22, 23, and 24.

NL-08-051 Attachment I Docket Nos. 50-247 & 50-286 Page 15 of 28 In NUREG-1800, Rev. 1, Section 2.1.3.2.2 describes long-lived structures and components as those that are not subject to periodic replacement based on a qualified life or specified time period. Furthermore, it states that replacement programs may be based on vendor recommendations, plant experience, or any means that establishes a specific replacement frequency under a controlled program.

Other license renewal applications typically have not designated pumps, motors, and heat exchangers as "not long lived," i.e., these components, or portions thereof, are subject to an AMR.

a) Identify the component types serviced by the component cooling water system indicated in the above mentioned drawings that are shown as not long lived.

b) Provide a basis for designating these components as "not long lived" to include details on how the "qualified life" of the components was established and describe the program under which aging management activities for the components are performed, and any available plant-specific operating experience confirming the effectiveness of management activities.

Response for RAI 2.3.0-2 The components shown on drawings LRA-9321-2720/27203 identified as not long-lived are the reactor coolant pump (RCP) motor upper and lower bearing heat exchangers. Upon further review of the documentation that specified the RCP motor upper and lower bearing heat exchangers were short-lived, it was determined that these components are actually only inspected and rebuilt as required but not replaced. Therefore, these components are subject to aging management review and the LRA is revised as follows (added text underlined).

LRA Section 3.3.2.1.3, Component Cooling Water, Environment, is revised as follows.

Component cooling water system components are exposed to the following environments.

  • air - indoor
  • condensation
  • raw water
  • treated borated water
  • treated borated water > 140'F
  • treated water
  • treated water > 140°F LRA Section 3.3.2.1.3, Component Cooling Water, Aging Management Programs, is revised as follows.

The following aging management programs manage the aging effects for the component cooling water system components.

  • Bolting Integrity

" Boric Acid Corrosion Prevention

NL-08-051 Attachment I Docket Nos. 50-247 & 50-286 Page 16 of 28 0 External Surfaces Monitoring 0 Heat Exchanger Monitoring 0 Oil Analysis 0 Selective Leaching

  • Water Chemistry Control - Closed Cooling Water
  • Water Chemistry Control - Primary and Secondary LRA Table 3.3.2-3-1P2, Component Cooling Water, is revised to add the following line items.

Table 3.3.2-3-IP2: Component Cooling Water NUREG-Intended MAging Effect Aging 1801 Table Comp Type Function Material Environment Requiring Management Management Programs Vl21 Vol 2 1 Te Itemt Notes Item Heat Pressure Carbon Air- indoor Loss of material External VII.1-8 3.3.1- A exchanger boundary steel (ext) Surfaces (A-77) 58 (bonnet) Monitoring Heat Pressure Carbon Treated water Loss of material Water VII.C2-1 3.3.1- A exchanger boundary steel (int) Chemistry (A-63) 48 (bonnet) Control -

Closed Cooling Water Heat Pressure Copper Lube oil (ext) Loss of material Oil Analysis VI1.C2-5 3.3.1- Q exchanger boundary alloy Program (AP-47) 26 (tubes)

Heat Pressure Copper Treated water Loss of material Water VI1.C2-4 3.3.1- 0 exchanger boundary alloy (int) Chemistry (AP-12) 51 (tubes) Control -'

Closed Cooling Water LRA Table 3.3.2-3-1P3, Component Cooling Water, is revised to add the following line items.

Table 3.3.2-3-IP3: Component Cooling Water NUREG- Table Intended MAging Effect Aging 1801 Comp Type Inten .aterial Environment Requiring Management Vol. 2 1 Item Notes Function Management Programs Item Heat Pressure Carbon Air- indoor Loss of material External VII.l-8 3.3.1- A exchanger boundary steel (ext) Surfaces (A,-77 58 (bonnet) Monitorinq

NL-08-051 Attac'hment I Docket Nos. 50-247 & 50-286 Page 17 of 28 Table 3.3.2-3-1P3: Component Cooling Water

  • NUREG- Table Intended Aging Effect Aging 1801 Comp Type Inctiond Material Environment Requiring Management Vol.

Item2 Management Programs 1 Item Notes Heat Pressure Carbon Treated water Loss of material Water VII.C2-1 3.3.1- A exchanger boundary steel (int) Chemistry (A-63) 48 (bonnet) Control -

Closed Cooling Water Heat Pressure Cogper Lube oil (ext) Loss of material Oil Analysis VII.C2-5 3.3.1- Q exchanger boundary alloy Pro-gram (AP-47) 26 (tubes)

Heat Pressure Copper Treated water Loss of material Water VI1.C2-4 3.3.1- 0 exchanger boundary alloy (int) Chemistry (AP-12) 51 (tubes) Control -

Closed Cooling Water The components shown on drawings LRA-9321-2028/20283 identified as not long-lived are the emergency diesel generator (EDG) jacket cooling water flexible connections and pump casings.

In accordance with vendor recommendations, EDG jacket cooling water flexible connections are replaced every eight years and pumps are replaced every sixteen years. Therefore, these components are not subject to aging management review. A review of plant-specific operating experience did not identify any instances of EDG jacket cooling water flexible connection or pump failures which confirms the effectiveness of the replacement activities.

Nonsafetv-Related ComDonents LRA Sections 2.1.1.2 and 2.1.2.1.2 describe the specific details for applying the methodology for identifying nonsafety-related portions of systems with a potential for adversely affecting safety-related functions in accordance with 10 CFR 54.4(a)(2). LRA Section 2.1.2.1.3 states that license renewal drawings were prepared to indicate portions of systems that support system intended functions with the exception of those systems in-scope for 10 CFR 54.4(a)(2) for physical interactions.

Because nonsafety-related system portions meeting 10 CFR 54.4(a)(2) for physical interactions are not indicated on the license renewal drawings, further information is required by the staff to complete its reviewto confirm that the licensee has adequately identified components in-scope for (a)(2).

For each of the following license renewal drawings identified below, describe the specific portions of the system piping that are within the scope of license renewal for meeting 10 CFR 54.4(a)(2) for physical interactions, or justify their exclusion.

NL-08-051 Attachment I Docket Nos. 50-247 & 50-286 Page 18 of 28 RAI 2.3A.3.1-1. Spent Fuel Pit Cooling System (Unit 2)

1. Drawing LRA-9321-2720 (sheet 2) - piping within the spent fuel storage building co-located with safety-related component cooling system piping in the spent fuel building between locations D1 and A3.
2. Drawing LRA-227781 - refueling water purification piping outside the spent fuel storage building co-located with safety-related piping outside the spent fuel building between locations D1 and H1 associated with the spent fuel demineralizers.

Response for RAI 2.3A.3.1-1

1. All piping, piping components, and piping elements in the spent fuel storage building shown on drawing LRA-9321-2720 between locations D1 and A3 are assigned to the spent fuel pit cooling system (SFPC) and are in scope and subject to aging management review based on the criterion of 10 CFR 54.4(a)(2). The component types are evaluated in LRA Table 3.3.2-19-35-1 P2.
2. All piping, piping components, and piping elements outside the spent fuel storage building shown on drawing LRA-227781 between locations D1 and H1 are assigned to the spent fuel pit cooling system (SFPC) and are in scope and subject to aging management review based on the criterion of 10 CFR 54.4(a)(2). The component types are evaluated in LRA Table 3.3.2-19-35-1P2.

RAI 2.3B.3.1-2. Spent Fuel Pit Cooling System (Unit 3)

1. Drawing LRA-9321-27513 (sheet 2) - piping within the spent fuel storage building co-located with safety-related component cooling system piping in the spent fuel storage building between locations El and H6.
2. Drawing LRA-9321-27513 (sheet 2) - piping outside the spent fuel storage building co-located with safety-related safety injection system piping outside the spent fuel storage building at locations F6 and G6 associated with the spent fuel demineralizers.

Response for RAI 2.3B.3.1-2

1. All piping, piping components, and piping elements in the IP3 spent fuel storage building shown on drawing LRA-9321-27513-002 between locations El and H6 are assigned to the spent fuel pit and cooling system (SFPC) and are in scope and subject to aging management review based on the criterion of 10 CFR 54.4(a)(2). The component types are evaluated in LRA Table 3.3.2-19-49-1P3.
2. All piping, piping components, and piping elements outside the spent fuel storage building shown on drawing LRA-9321-27513-002 between locations F6 and G6 are assigned to the spent fuel pit and cooling system (SFPC) and are in scope and subject to aging management review based on the criterion of 10 CFR 54.4(a)(2). The component types are evaluated in LRA Table 3.3.2-19-49-1P3.

NL-08-051 Attachment I Docket Nos. 50-247 & 50-286 Page 19 of 28 RAI 2.3A.3.2-1 Service Water System (Unit 2)

1. Drawing LRA-9321-2028 inch line #1502 city water to the three emergency diesel generator 40 gallon jacket water expansion tanks.
2. Drawing LRA-9321-2722 - instrument air compressor cooling water piping inside the control building that is co-located with the service water system piping between locations G1 and 16.
3. Drawing LRA-9321-2722 inch piping (at location B5) supplying service water to the main turbine lube oil coolers.
4. Drawing LRA-9321-2722 inch piping (at location A4) supplying service water to various conventional plant services.
5. Drawing LRA-9321-2722 inch piping (at location A3) between valves SWN-4 and SWN-5.
6. Drawing LRA-9321-2722 inch piping header # 472 between locations A2 to E2, downstream of valves SWN-591, SWN-593, SWN-595, SWN-597, and SWN-599.
7. Drawing LRA-9321-2722 inch piping header downstream of valves SWN-501, SWN-502, SWN-503, SWN-504, SWN-505' and SWN-506, including connecting piping to and near SWN-507 (at location Fl).
8. Drawing LRA-209762 inch piping upstream of RCV-018 from waste condensate pump discharge via line #260 and #261, (at location H2) inside the Primary Auxiliary Building (PAB).
9. Drawing LRA-235117 inch line #12 inside the service water tunnel (at location C4).
10. Drawing LRA-235117 - 3/4-inch line #1578 from the blowdown tank room to radiation monitor R-49 (at location D4).
11. Drawing LRA-235117 - 3/4-inch line #1577 containing valves MW-594, MW-600, MW-596, together with 3/4-inch line #1577 from radiation monitors R-46 (at location B2) to R-49.
12. Drawing LRA-235117 inch line #1580 from radiation monitors R-46 to R-49 up to sump pump #25 (at location E4).
13. Drawing LRA-235122 inch and 3/4-inch line #1593 between radiation monitors R-47(at.

location B4), R-39 (at location D4), R-40 (at location B3), and R-48 (at location B2) and from location D2.

14. Drawing LRA-235122 - 3/4-inch line #1592 and 3/4-inch line #1611 from D2 to BI.
15. Drawing LRA-226037 - 2 lines to the Victoreen radiation monitor labeled purge water in, and purge water out including valves FCV-46-2 and FCV-46-3 (at locations D4 and E3, respectively).

NL-08-051 Attachment I Docket Nos. 50-247 & 50-286 Page 20 of 28

16. Drawing LRA-226038 - sample line "B" to and from heat exchanger HTX-49-1 from location A4 to C4.
17. Drawing LRA-226038 - purge water out line "D" and purge water In line "E", and purge water out including valves FCV-49-2 and FCV-49-3 (at locations D4 and E3, respectively).
18. Drawing LRA-242687 - purge water out line "D" and purge water in line "E".

Response for RAI 2.3A.3.2-1

1. The 8-inch city water line #1502 and valve JW-5 shown at coordinates H-6 on drawing LRA-9320-2028 are also shown on at coordinates B-6 on drawing LRA-9321-2018. The piping and valve are in scope and subject to aging management review and evaluated in LRA Table 3.3.2-17-1P2, City Water.
2. All instrument air compressor cooling water piping, piping components, and piping elements inside the control building shown on drawing LRA-9321-2722 between locations G1 and 16 are assigned to the instrument air closed cooling system (IACC) and are in scope and subject to aging management review based on the criterion of 10 CFR 54.4(a)(2). The component types are evaluated in LRA Table 3.3.2-19-19-1P2.
3. The 10-inch piping shown on drawing LRA-9321-2722 at location B5 supplying service water to the main turbine lube oil coolers is assigned to the service water system (SW) and is in scope and subject to aging management review based on the criterion of 10 CFR 54.4(a)(2). The component types are evaluated in LRA Table 3.3.2-19-39-1P2.
4. The 16-inch piping shown on drawing LRA-9321-2722 at location A4 supplying service water to various conventional plant services is assigned to the service water system (SW) and is in scope and subject to aging management review based on the criterion of 10 CFR 54.4(a)(2). The component types are evaluated in LRA Table 3.3.2-19-39-1P2.
5. The 8-inch piping shown on drawing LRA-9321-2722 at location A3 between valves SWN-4 and SWN-5 is assigned to the service water system (SW) and subject to aging management review based on the criterion of 10 CFR 54.4(a)(2). The component types are evaluated in LRA Table 3.3.2-19-39-1P2.
6. The 8-inch piping header #472 shown on drawing LRA-9321-2722 between locations A2 to E2 downstream of valves SWN-591, SWN-593, SWN-595, SWN-597, and SWN-599 is assigned to the service water system (SW) and is in scope and subject to aging management review based on the criterion of 10 CFR 54.4(a)(2). The component types are evaluated in LRA Table 3.3.2-19-39-1P2.
7. The 6-inch piping header downstream of valves SWN-501, SWN-502, SWN-503, SWN-504, SWN-505, and SWN-506, including connecting piping to and near SWN-507 shown on drawing LRA-9321-2722 at location F1 is assigned to the service water system (SW) and is in scope and subject to aging management review based on the criterion of 10 CFR 54.4(a)(2). The component types are evaluated in LRA Table 3.3.2-19-39-1P2.

NL-08-051 Attachment I Docket Nos. 50-247 & 50-286 Page 21 of 28

8. The 2-inch piping upstream of RCV-018 from waste condensate pump discharge via line
  1. 260 and #261 inside the Primary Auxiliary Building (PAB) shown on drawing LRA-209762 (H-2) and continued on LRA-9321-2719 (G-4) is assigned to the wastedisposal system (WDS) and is in scope and subject to aging management review based on the criterion of 10 CFR 54.4(a)(2). The component types are evaluated in LRA Table 3.3.2-19-42-1P2.
9. The 2-inch piping line #12 inside the service water tunnel shown on drawing LRA-235117 (C-4) and continued on LRA-209762 (G-4) is assigned to the service water system (SW) and is in scope and subject to aging management review based on the criterion of 10 CFR 54.4(a)(1). The component types are evaluated in LRA Table 3.3.2-2-1P2.
10. The 3/4-inch line #1578 from the blowdown tank room to the radiation monitor R-49 shown on drawing LRA-235117 at location D4 is assigned to the service water system (SW) and is in scope and subject to aging management review based on the criterion of 10 CFR 54.4(a)(2). The component types are evaluated in LRA Table 3.3.2-19-39-1P2.,
11. The 3/4-inch line #1577 containing valves MW-594, MW-600, MW-596, together with 3/4-inch line #1577 from radiation monitors R-46 to R-49 shown on drawing LRA-235117 at location B2 is assigned to the city water system (CYW) and is in scope and subject to aging management review based on the criterion of 10 CFR 54.4(a)(2). The component types are evaluated in LRA Table 3.3.2-19-7-1P2.
12. The 1-inch line #1580 from radiation monitors R-46 to R-49 up to sump pump #25 shown on drawing LRA-235117 at location E4 is assigned to the waste disposal system (WDS) and is in scope and'subject to aging management review based on the criterion of 10 CFR 54.4(a)(2). The component types are evaluated in LRA Table 3.3.2-19-42-1P2.
13. The 1-inch and 3/4-inch line #1593 between radiation monitors R-47, R-39, R-40, and R-48 located at B4, D4, B3, and B2 respectively shown on drawing LRA-235122 is assigned to the radiation monitoring system (RMS) and is in scope and subject to aging management review based on the criterion of 10 CFR 54.4(a)(2). The component types are evaluated in LRA Table 3.3.2-19-31-1P2.
14. The 3/4-inch lines #1592 and #1611 from D2 to B1 shown on drawing LRA-235122 are assigned to the waste disposal system (WDS) and are in scope and subject to aging management review based on the criterion of 10 CFR 54.4(a)(2). The component types are evaluated in LRA Table 3.3.2-19-42-1P2.
15. The lines to the Victoreen radiation monitor labeled purge water in, and purge water out including valves FCV-46-2 and FCV-46-3 shown at locations D4 and E3, respectively on drawing LRA-226037 are assigned to the radiation monitoring system (RMS) and are in scope and subject to aging management review based on the criterion of 10 CFR 54.4(a)(2). The component types are evaluated in LRA Table 3.3.2-19-31-1P2.

NL-08-051 Attachment I Docket Nos. 50-247 & 50-286 Page 22 of 28

16. Sample line "B" to and from heat exchanger HTX-49-1 from location A4 to C4 shown on drawing LRA-226038 is assigned to the steam generator blowdown system (SGBD) and is in scope and subject to aging management review based on the criterion of 10 CFR 54.4(a)(2). The component types are evaluated in LRA Table 3.3.2-19-36-1P2.
17. Purge line "D" and line "E" including valves FCV-49-2 and FCV-49-3 at locations D4 and E3 shown on drawing LRA-226038 are assigned to the steam generator blowdown system (SGBD) and are in scope and subject to aging management review based on the criterion of 10 CFR 54.4(a)(2). The component types are evaluated in LRA Table 3.3.2-19-36-IP2.
18. Purge line "D" shown on drawing LRA-242687 is assigned to the service water system (SW) and is in scope and subject to aging management review based on the criterion of 10 CFR 54.4(a)(2). The component types are evaluated in LRA Table 3.3.2-19-36-1P2.

Purge line "E" shown on drawing LRA-242687 is assigned to the radiation monitoring system (RMS) and is in scope and subject to aging management review based on the criterion of 10 CFR 54.4(a)(2). The component types are evaluated in LRA Table 3.3.2-19-31-1P2.

RAI 2.3B.3.2-1. Service Water System (Unit 3)

1. Drawing LRA-9321-20283 - 3/4-inch line #1033 city water to the three emergency diesel generator 40 gallon jacket water expansion tanks.
2. Drawing LRA-9321-20333 inch and 16-inch lines originating at valves SWN-6 and SWN-7 (at location F4) and FCV-1 111 and FCV-1 112 (at location F4).
3. Drawing LRA-9321-20333 - piping associated with service water strainer blowdown valves SWN 64-1 (at location C2), SWN-64-2 (at location C3), SWN-64-3 (at location C4), SWN 64-4 (at location C5), SWN 64-5 (at location C6), and SWN 64-6 (at location C7) up to its anchor.
4. Drawing LRA-9321-20333 inch and 8-inch lines originating between valves SWN-4 and SWN-5 (at location D-5), in their entirety.

Response for RAI 2.3B.3.2-1

1. The 3/4-inch line #1033 city water to the three emergency diesel generator 40 gallon jacket water expansion tanks shown on drawing LRA-9321-20283 is assigned to the city water makeup system (CWM) and is in scope and subject to aging management review based on the criterion of 10 CFR 54.4(a)(2). The component types are evaluated in LRA Table 3.3.2-19-13-1P3.
2. The 10-inch and 16-inch lines originating at valves SWN-6 and SWN-7 and FCV-1 111 and FCV-1 112 shown on drawing LRA-9321-20333 at location F-4 are assigned to the service water system (SWS) and are in scope and subject to aging management review based on the criterion of 10 CFR 54.4(a)(2). The component types are evaluated in LRA Table 3.3.2-19-56-IP3.

NL-08-051 Attachment I Docket Nos. 50-247 & 50-286 Page 23 of 28

3. The piping and valves associated with service water strainer blowdown valves SWN 64-1, SWN-64-2, SWN-64-3, SWN 64-4, SWN 64-5, and SWN 64-6 as shown on drawing LRA-9321-20333 are assigned to the service water system (SWS) and are in scope and subject to aging management review based on the criterion of 10 CFR 54.4(a)(2). The component types are evaluated in LRA Table 3.3.2-19-56-1P3.
4. The 3-inch and 8-inch lines originating between valves SWN-4 and SWN-5, in their entirety, shown on drawing LRA-9321-20333 are assigned to the service water system (SWS) and are in scope and subject to aging management review based on the criterion of 10 CFR 54.4(a)(2). The component types are evaluated in LRA Table 3.3.2-19 IP3.

RAI 2.3A.3.3-1 Component Cooling Water System (Unit 2)

Drawing LRA-9321-2730 - lines surrounding component cooling supply to #21 and #22 waste gas compressors.

Response for RAI 2.3A.3.3-1 The lines surrounding the component cooling supply to #21 and #22 waste gas compressors as shown on LRA-9321-2730 at coordinates B-4 and B-6.are assigned to the waste disposal system (WDS) and are in scope and subject to aging management review based on the criterion of 10 CFR 54.4(a)(2). The component types are evaluated in LRA Table 3.3.2-19-42-1P2.

RAI 2.3B.3.3-1 Component Cooling Water System (Unit 3)

Drawing LRA-9321-27303 - lines surrounding component cooling supply to #31 and #32 waste gas compressors.

Response for RAI 2.3B.3.3-1 The lines surrounding the component cooling supply to #31 and #32 waste gas compressors as shown on LRA-9321-27303 at coordinates D-7 and F-7 are assigned to the gaseous waste disposal system (GWD) and are in scope and subject to aging management review based on the criterion of 10 CFR 54.4(a)(2). The component types are evaluated in LRA Table 3.3.2 25-1P3.

RAI 2.3A.3.5-1 Gas System (Unit 2)

Drawing LRA-9321-2723 line 1"-CH-151 R-LINE#1 15 that is directly connected to the volume control tank.

NL-08-051 Attachment I Docket Nos. 50-247 & 50-286 Page 24 of 28 Response for RAI 2.3A.3.5-1 Line 1"-CH-151 R-LINE#115 directly connected to the volume control tank as shown on LRA-9321-2723 at coordinate B-6 is assigned to the gas system (GAS) and is in scope and subject to aging management review based on the criterion of 10 CFR 54.4(a)(2). The component types are evaluated in LRA Table 3.3.2-19-14-1P2.

RAI 2.3A.3.18-1 Plant Drains System - Waste Disposal System (Unit 2)

Drawing LRA-9321-2719 - containment penetrations Y and Z outside of the safety-related boundary that is structurally attached to the containment penetration piping both inside and outside containment at locations C1 and C2, respectively.

Response for RAI 2.3A.3.18-1 Piping, piping components, and piping elements connected to containment penetrations Y and Z outside of the safety-related boundary connected to the containment penetration piping both inside and outside containment as shown on drawing LRA-9321-2719 at locations C1 and C2 are conservatively assumed to be fluid-filled. These components are assigned to the waste disposal system (WDS) and are in scope and subject to aging management review based on the criterion of 10 CFR 54.4(a)(2). The component types are evaluated in LRA Table 3.3.2 42-1P2.

RAI 2.3B.3.18-1 Plant Drains System - Liquid Waste Disposal System (Unit 3)

Drawing LRA-9321-27193 (sheet 1) - containment penetrations Y and Z outside of the safety-related boundary that is structurally attached to the containment penetration piping both inside and outside containment (at locations C3 and D3, respectively).

Response for RAI 2.3B.3.18-1 Piping, piping components, and piping elements connected to containment penetrations Y and Z outside of the safety-related boundary that is structurally attached to the containment penetration piping both inside and outside containment as shown on drawing LRA-9321-27193-001 at locations C3 and D3 are conservatively assumed to be fluid-filled. These components are assigned to the liquid waste disposal system (LWD) and are in scope and subject to aging management review based on the criterion of 10 CFR 54.4(a)(2). The component types are evaluated in LRA Table 3.3.2-19-33-1P3.

RAI 2.3A.3.13-1 Fuel Oil System (Unit 2)

1. Drawing LRA-9321-2030 - 3/4-inch line from 21 diesel generator fuel oil drip tank drain pump 21 and associated valves structurally attached to fuel oil day tank No. 21 between locations G2 and G4.
2. Drawing LRA-9321-2030 - 3/4-inch line from 22 diesel generator fuel oil drip tank drain pump 22 and associated valves structurally attached to fuel oil day tank no. 22 between locations D2 and D4.

NL-08-051 Attachment I Docket Nos. 50-247 & 50-286 Page 25 of 28

3. Drawing LRA-9321-2030 - 3/4-inch line from 23 diesel generator fuel oil drip tank drain pump 23 and associated valves structurally attached to fuel oil day tank no. 23 between locations B2 and B4.

Response for RAI 2.3A.3.13-1 The 3/4-inch lines from 21, 22, and 23 diesel generator fuel oil drip tank drain pumps and associated valves to fuel oil day tank No. 21, 22, and 23 shown on drawing LRA-9321-2030 are assigned to the emergency diesel generator system (EDG) and are in scope and subject to aging management review based on the criterion of 10 CFR 54.4(a)(2). The component types are evaluated in LRA Table 3.3.2-19-9-1P2.

RAI 2.3B.3.13-1 Fuel Oil System (Unit 3)-

1. Drawing LRA-9321-20303 - 3/4-inch line # 1103 near 31 diesel generator fuel oil drip tank drain pump 31 discharge and associated valves structurally attached to fuel oil day tank no.

31 between locations B4 and E3.

2. Drawing LRA-9321-20303 - 3/4-inch line # 1106 near diesel generator fuel oil drip tank drain pump 32 discharge and associated valves structurally attached to fuel oil day tank no. 32 between locations B6 and E5.
3. Drawing LRA-9321-20303 - 3/4-inch line # 1106 near diesel generator fuel oil drip tank drain pump 33 discharge and associated valves structurally attached to fuel oil day tank no. 33 between locations B7 and E7.

Response for RAI 2.3B.3.13-1 The 3/4-inch lines from 31, 32, and 33 diesel generator fuel oil drip tank drain pumps and associated valves to fuel oil day tank No. 31, 32, and 33 shown on drawing LRA-9321-20303 are assigned to the emergency generator system (EG) and are in scope and subject to aging management review based on the criterion of 10 CFR 54.4(a)(2). The component types are evaluated in LRA Table 3.3.2-19-17-1P3.

RAI 2.3A.3.14-2 Emergency Diesel Generators (Unit 2)

Drawing LRA-9321-2028 - 3/4-inch line from city water system (for makeup) structurally attached to 21, 22, and 23 jacket water expansion tanks, including valves and LCV-5004, LCV-5005, and LCV-5006, located between B5/6 and H5/6 and in the EDG room.

NL-08-051 Attachment I Docket Nos. 50-247 & 50-286 Page 26 of 28 Response for RAI 2.3A.3.14-2 The 3/4-inch piping and associated valves structurally attached to 21, 22, and 23 jacket water expansion tanks are assigned to the emergency diesel generator system (EDG) and are in scope and subject to aging management review based on the criterion of 10 CFR 54.4(a)(2).

The component types are evaluated in LRA Table 3.3.2-19-9-1P2. Valves LCV-5004, LCV-5005, and LCV-5006 are in scope and subject to aging management review based on the criterion of 10 CFR 54.4(a)(1) and evaluated in LRA Table 3.3.2-14-1P2.

RAI 2.3B.3.14-2 Emergency Diesel Generators (Unit 3)

Drawing LRA-9321-20283 - 3/4-inch line #1033 from city water system (for makeup) structurally attached to 31 (3/4-inch line #1033), 32 (3/4-inch line #1034), and 33 (3/4-inch line #1035) jacket water expansion tanks, including valves and associated level control valves located between D2 and D7 and in the EDG room.

Response for RAI 2.3B.3.14-2 The 3/4-inch lines (#1033, #1034, #1035) supplying makeup water to each emergency diesel generator jacket water expansion tank shown on drawing LRA-9321-20283 are assigned to the city water makeup system (CWM) and are in scope and subject to aging management review based on the criterion of 10 CFR 54.4(a)(2). The component types are evaluated in LRA Table 3.3.2-19-13-1P3. The expansion tank level control valves are in scope and subject to aging management review based on the criterion of 10 CFR 54.4(a)(1) and evaluated in LRA Table 3.3.2-14-1P3.

Fire Protection RAI 3.0.3.2.7-1 LRA Table 2.4-4 lists fire stops and fire wrap as bulk commodities that perform an intended function of fire barrier. LRA Table 3.5.2-4, "Bulk Commodities," identifies the material, environment and aging effect requiring aging management for these two commodities. The Fire Protection Program is identified as the aging management program along with Note J which indicates that neither the component nor the material and environment combination is evaluated in NUREG-1801. However, in LRA Section B.1.13, "Fire Protection," there is no indication that fire stops and fire wrap are included as commodities whose aging effects will be managed by the AMP. Describe how the aging effects of cracking/delamination, separation (for fire stops),

and loss of material (for fire wrap) will be managed under the Fire Protection. AMP.

Response for RAI 3.0.3.2.7-1 As stated in LRA Section B.1.13, the fire protection program is an existing program that includes fire barrier inspections. The commodities fire stops and fire wraps are considered to be fire barriers which are included in the scope of the Fire Protection Program. Fire stops (penetration seals) are visually inspected for cracking, delaminating, separation, and change in material properties at least once every seven operating cycles (15% every 24 months). Fire wraps are visually inspected at least once every 24 months for loss of material and any other indications of degradation or damage.

NL-08-051 AttachmentI Docket Nos. 50-247 & 50-286 Page 27 of 28 Nickel Alloy RAI 3.0.3.3.5-1 The Nickel Alloy Inspection Program for the monitoring and trending program element states that records of the inspection program, examination and test procedures, exam ination/test data, and corrective actions taken or recommended are maintained in accordance with the requirements of ASME Section Xl, Subsection IWA.

The Standard Review Plan for License Renewal (SRP-LR) Section A.1.2.3.5, and SRP-LR Table A. 1-1 state that:

Monitoring and trending activities should be described, and they should provide' predictability of the extent of degradation and thus effect timely corrective or mitigative actions. Plant-specific and/or industry-wide operating experience may be considered in evaluating the appropriateness of the technique and frequency. This program element describes "how" the data collected are evaluated and may also include trending for a forward look. This includes an evaluation of the results against the acceptance criteria and a prediction regarding the rate of degradation in order to confirm that timing of the next scheduled inspection will occur before a loss of SC intended function. Although aging indicators may be quantitative or qualitative, aging indicators should be quantified, to the extent possible, to allow trending. The parameter or indicator trended should be described. The methodology for analyzing the inspection or test results against the acceptance criteria should be described. Trending is a comparison of the current monitoring results with previous monitoring results in order to make predictions for the future.

Please describe how the monitoring and trending program elements will be addressed in the Nickel Alloy Inspection Program.

Response for RAI 3.0.3.3.5-1 The Nickel Alloy Inspection Program manages the effects of aging on Alloy 600/82/1 82 components by utilizing elements of the Boric Acid Corrosion Control and ISI Programs.

Alloy 600/82/1 82 locations are documented with unique component identification numbers with applicable data maintained for monitoring and trending. Inspections are performed using industry guidance and site-specific operating experience and produce quantitative data through eddy current, ultrasonic, and visual inspections. Inspection findings are evaluated using previous inspection results through the corrective action program. If evidence of PWSCC is discovered, a repair is performed. Since unacceptable findings are repaired or replaced, use of past inspections to predict the extent of future degradation is not applicable.

The monitoring and trending element of the Nickel Alloy Inspection Program relies on the site corrective action program to assure timely corrective and mitigative actions.

NL-08-051 Attachment I Docket Nos. 50-247 & 50-286 Page 28 of 28 RAI 3.0.3.3.5-2 LRA Table 3.1.1, Item 3.1.1-31 is applicable to NUREG-1801, Rev. 1, Items IV.A2-12, IV.A2-19, and IV.C2-13, which specify that an acceptable aging management program is to comply with applicable NRC Orders and provide a commitment in the FSAR supplement to implement applicable (1) Bulletins and Generic Letters and (2) staff-accepted industry guidelines.

The statement in the Nickel Alloy Inspection Program states that Indian Point will "continue to" implement commitments associated with (1) NRC Orders, Bulletins and Generic Letters associated with nickel alloys and (2) staff accepted industry guidelines.

The intent of this statement is unclear. Please clarify that the applicant commits to comply with applicable Bulletins, Generic Letters and staff-accepted industry guidelines.

Response for RAI 3.0.3.3.5-2 For clarification, IPEC commits to comply with future applicable (1) NRC Orders. In addition, IPEC commits to implement applicable (1) Bulletins and Generic Letters associated with nickel alloys and (2) staff accepted industry guidelines associated with nickel alloys.

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