ML082630030

Response to NRC Request for Additional Information Related to Three Mile Island Nuclear Station, Unit 1, License Renewal Application

ML082630030
Person / Time
Site:	Three Mile Island
Issue date:	09/16/2008
From:	Gallagher M AmerGen Energy Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
5928-08-20196
Download: ML082630030 (46)

Text

Amer Michael P. GallagheT, PE Telephone 610.765.5958 An Exelon Company Vice President www.exeloncorp.com License Renewal Projects michaelp.gallagher@exeloncorp.com 10 CFR 50 AmrerGen 10 CFR 54 20o Exelon Way KSA/2-E Kennett Square, PA 19348 5928-08-20196 September 16, 2008 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Three Mile Island Nuclear Station, Unit 1.

Facility Operating License No. DPR-50 NRC Docket No.50-289

Subject:

Response to NRC Request for Additional Information related to Three Mile Island Nuclear Station, Unit 1, License Renewal Application

Reference:

Letter from Mr. Jay Robinson (USNRC), to Mr. Michael P. Gallagher (AmerGen)

"Request for additional information for Sections 2.3.3 and 2.3.4 of the Three Mile Island Nuclear Station, Unit 1, License Renewal Application", dated August 2 0 th, 2008. (TAC No. MD7701)

In the referenced letter, the NRC requested additional information related to Sections 2.3.3 and 2.3.4 of the Three Mile Island Nuclear Station, Unit 1, License Renewal Application (LRA).

Enclosed are the responses to this request for additional information.

This letter and its enclosure contain no commitments.

If you have any questions, please contact Fred Polaski, Manager License Renewal, at 610-765-5935.

I declare under penalty of perjury that the foregoing is true and correct.

Respectfully, Executed on pc~.j~ e2OO~

Micdlael P. GallaghCr" Vice President, License Renewal AmerGen Energy Company, LLC A

September 16, 2008 Page 2 of 2 5928-08-20196 Enclosure A: Response to Request for Additional Information for Sections 2.3.3 and 2.3.4 of the Three Mile Island Nuclear Station, Unit 1, License Renewal Application.

cc: Regional Administrator, USNRC Region I, w/Enclosure USNRC Project Manager, NRR - License Renewal, Safety, w/Enclosure USNRC Project Manager, NRR - License Renewal, Environmental, w/o Enclosure USNRC Project Manager, NRR - TMIGS, w/o Enclosure USNRC Senior Resident Inspector, TMIGS, w/o Enclosure File No. 08001

September 16, 2008 Page 1 of 44 5928-08-20196 Enclosure A Enclosure - A Response to Request for Additional Information for Sections 2.3.3 and 2.3.4 of the Three Mile Island Nuclear Station, Unit 1, License Renewal Application.

Note: As a standard convention for AmerGen RAI responses, added text will be shown as bolded italics whereas deleted text will be shown as stuikethleu§ .

September 16, 2008 Page 2 of 44 5928-08-20196 Enclosure A RAI # 2.3.3.4-1

Background:

On license renewal drawing LR-302-175, at locations G-2, F-2, F-3, and F-4, there are five components which appear to be sight flow indicators according to symbol represented on license renewal drawing LR-302-002. These components are highlighted in red, indicating they are in scope for license renewal under 10 CFR 54.4(a)(2) according to Note 1 on license renewal drawing LR-302-003. Typically, this component type "flow indicator" would have a leakage boundary function.

Issue:

Sight flow indicator is not listed in License Renewal Application (LRA) Tables 2.3.3-4 and 3.3.2-4 as a component type with a leakage boundary function.

Request:

Justify the exclusion of the component type "sight flow indicator" from LRA Tables 2.3.3-4 and 3.3.2-4.

AmerGen Response The sight flow indicators (sight glasses), shown in red on drawing LR-302-175 at locations G-2, F-2, F-3, and F-4, are within the scope for license renewal with the intended function of leakage boundary; however they were omitted from Table 2.3.3-4 and Table 3.3.2-4. These components should have been included in Table 2.3.3-4 and Table 3.3.2-4 as shown below.

Glass material should have been included in Section 3.3.2.1.4.

Component information added to Table 2.3.3-4 is shown below:

Table 2.3.3-4 Closed Cycle Cooling Water System Components Subject to Aging Management Review Component Type Intended Functions Sight Glasses Leakage Boundary Material information added to Section 3.3.2.1.4 is shown below:

3.3.2.1.4 Closed Cycle Cooling Water System Material

. Glass Aging management information added to Table 3.3.2-4 is shown as follows:

September 16, 2008 Page 3 of 44 5928-08-20196 Enclosure A Table 3.3.2-4 Closed Cycle Cooling Water System Component Type Intended Material Environment Aging Effect/ Aging NUREG-1801 Table 1 Item Notes Function Mechanism Management Vol. 2 Item Requiring Programs Management Sight Glasses Leakage Glass Air - Indoor None None VII.J-8 3.3.1-93 A Boundary (External)

Sight Glasses Leakage Glass Treated Water None None VII.J-13 3.3.1-93 A Boundary (Internal)

External Sight Glasses Leakage Carbon Air- Indoor Loss of Material/ Surfaces VII.l-8 3.3.1-58 B Boundary Steel (External) General Corrosion Monitoring (B.2.1.21)

Loss of Material/ Closed-Cycle Sight Glasses Leakage Carbon Treated Water General Pitting, Cooling Water VII.C2-14 3.3.1-47 B Boundary Steel (Internal) and Crevice System Corrosion (B.2.1.10)

September 16, 2008 Page 4 of 44 5928-08-20196 Enclosure A RAI # 2.3.3.4-2

Background:

The following coolers are highlighted on their respective drawings as being in scope for license renewal:

Drawing Location Cooler Description LR-302-620 C-3, E-7 IC-C-1A, 1B Intermediate coolers LR-302-620 C-7, D-7, E- 1A, 1B, 1C, 1D Reactor coolant pump thermal 7 barrier heat exchangers LR-302-662 G-4, E-2, G- MU-C-3A, Pump and motor lube oil cooler, 7 MU-C-4A, make-up and purification system MU-C-5A motor air cooler, gear unit oil cooler LR-302-645 E-5, E-6 DH-P-1A, Decay heat removal pumps motor DH-P-1 B and bearing cooling LR-302-181 G-8 SS-C-46 TCU unit LR-302-221 B-8, B-7 SC-C-3A, Isolated phase bus duct coolers, A SC-C-3B and B Issue:

The staff noted that these coolers are not specifically listed in LRA Tables 2.3.3-4 and 3.3.2-4 as being subject to an aging management review (AMR).

Request:

Justify the exclusion of the above-mentioned coolers from LRA Tables 2.3.3-4 and 3.3.2-4.

AmerGen Response:

The listed components are within the scope of license renewal. The evaluation of each component is addressed separately below. The coolers not included in Tables 2.3.3-4 and 3.3.2-4 should have been added as shown in the tables below. The added components have been grouped with coolers of similar design. Additionally, the grouping of the decay heat removal pump bearing cooler has been changed to coolers of similar design.

1) The Intermediate Coolers are safety-related heat exchangers within the scope of license renewal with a heat transfer intended function. Per Section 2.1.6.1 of the LRA, both sides of their heat transfer surfaces have been evaluated for license renewal with the Open Cycle Cooling (OCCW) System, which performs the cooling function for the heat exchangers. These components are included in LRA Tables 2.3.3-19 and 3.3.2-19. The OCCW System is shown on drawing LR-302-202.

2) The Reactor Coolant Pump Thermal Barrier Heat Exchangers are attached to the reactor coolant pumps. They are within the scope of license renewal with a pressure boundary intended function. These heat exchangers are cooled by closed cycle cooling water as shown on drawing LR-302-620. These heat exchangers should have been

September 16, 2008 Page 5 of 44 5928-08-20196 Enclosure A included in Tables 2.3.3-4 and 3.3.2-4 as component type "Heatexchanger components (Reactor Coolant Pump Thermal Barrier)"as shown in the tables below.

3) Makeup and Purification System coolers MU-C-3A/B/C and MU-C-5A/B/C are in scope for license renewal with heat transfer and pressure boundary intended functions. These coolers are cooled by closed cycle cooling water as shown in drawing LR-302-662.

They are included in Tables 2.3.3-4 and 3.3.2-4 as component type "Heatexchanger components (Makeup, Decay Heat Removal, RB Spray Pump & Motor Lube Oil Cooler)." This component type should have read "Heatexchanger components (Makeup, RB Spray Pump & Motor Lube Oil, Gear Unit Oil Cooler)" in Table 3.3.2-4 as shown in the tables below.

4) Makeup and Purification System Motor Air Cooler MU-C-4A/B/C (drawings LR-302-662, LR-302-645) and the Decay Heat Removal Pumps Motor Coolers (LR-302-645) are in scope for license renewal with heat transfer and pressure boundary intended functions.

They are cooled by closed cycle cooling water. These coolers should have been included in Table 2.3.3-4 as component type "Heatexchanger components (Reactor Building Fan Motor, Decay Heat Removal & Makeup Motor Air Coolers)." These coolers should have been included in Table 3.3.2-4 as component types "Heatexchanger components (ReactorBuilding Fan Motor, Decay Heat Removal & Makeup Motor Air Coolers)" and "Heatexchangercomponents (Decay Heat Removal & Makeup Motor Air Coolers)" as shown in the tables below.

5) Decay Heat Removal Pumps Bearing Coolers (LR-302-645) are in scope for license renewal with heat transfer and pressure boundary intended functions. They are cooled by closed cycle cooling water. These coolers should have been included in Table 2.3.3-4 as component types "Heatexchangercomponents (Control Rod Drive Cooling Coils, Decay Heat Removal Pumps Bearing Cooling)" and "Heatexchanger components (Reactor Coolant Drain Tank, Decay Heat Removal Pumps Bearing Cooling)." These coolers should have been included in Table 3.3.2-4 as component types "Heat exchangercomponents (Control Rod Drive Cooling Coils, Decay Heat Removal Pumps Bearing Cooling)", "Heatexchangercomponents (ReactorCoolant Drain Tank, Decay Heat Removal Pumps Bearing Cooling)" and "Heatexchangercomponents (Decay Heat Removal Pumps Bearing Cooling)" as shown in the tables below.

6) The TCU Unit (Temperature Control Unit), SS-C-46, is a skid-mounted chiller unit that cools feedwater samples prior to entering sample racks. This chiller unit is within the scope for license renewal with a leakage boundary intended function. It is cooled by closed cycle cooling water. The TCU Unit should have been included in Tables 2.3.3-4 as component type "Heatexchangercomponents (Auxiliary Boiler Sample Rack, TCU Unit)." It should have been included in Table 3.3.2-4 as component types "Heat exchangercomponents (Auxiliary Boiler Sample Rack, TCU Unit)" and "Heatexchanger components (Primaryand Secondary Cooling Coils, TCU Unit)" as shown in the tables below.

7) The Isolated Phase Bus Duct Coolers are part of the Closed Cycle Cooling Water System. They are shown on drawing LR-302-221. These heat exchangers perform a leakage boundary intended function and are within the scope for license renewal. They are cooled by the closed cycle cooling water and should have been included as component type "Heatexchangercomponents (Control Building Air Conditioning,

September 16, 2008 Page 6 of 44 5928-08-20196 Enclosure A Isolated Phase Bus Duct Coolers)" in Tables 2.3.3-4 and 3.3.2-4 as shown in the associated tables shown below.

The table below shows the component types and intended functions that should have been included in Table 2.3.3-4.

Table 2.3.3-4 Closed Cycle Coolinq Water System Components Subject to Aging Management Review Component Type Intended Functions Heat exchanger components (ReactorCoolant Pump PressureBoundary Thermal Barrier)

Heat exchanger components (Makeup, DeGay-Heat Heat Transfer Removal, RB Spray Pump & Motor Lube Oil, Gear Unit Oil Cooler)

Heat exchanger components (Makeup, DeGay-1eat Pressure Boundary Remeval, RB Spray Pump & Motor Lube Oil, Gear Unit Oil Cooler)

Heat exchanger components (Reactor Building Fan Heat Transfer Motor, Decay Heat Removal & Makeup Motor Air Coolers)

Heat exchanger components (Reactor Building Fan Pressure Boundary Motor, Decay Heat Removal & Makeup Motor Air Coolers)

Heat exchanger components (Control Rod Drive Cooling Heat Transfer Coils, Decay Heat Removal Pumps Bearing Cooling)

Heat exchanger components (Reactor Coolant Drain Tank Pressure Boundary Heat Exchanger, Decay Heat Removal Pumps Bearing Cooling)

Heat exchanger components (Auxiliary Boiler Sample Leakage Boundary Rack Coolers, TCU Unit)

Heat exchanger components (Control Building Air Leakage Boundary Conditioning, Isolated Phase Bus Duct Coolers)

The table below shows the aging management information that should have been included in Table 3.3.2-4.

September 16, 2008 Page 7 of 44 5928-08-20196 Enclosure A Table 3.3.2-4 Closed Cycle Cooling Water System Component Type Intended Material Environment Aging Effect Requiring Aging NUREG- Table I Notes Function Management Management 1801 Vol. 2 Item Programs Item Heat exchanger Air with components Pressure Stainless Borated (Reactor Coolant Boundary Steel Water None None VII.J-16 3.3.1-99 C Pump Thermal Leakage Barrier) (External)

Heat exchanger Treated Water components Pressure Stainless >140 F Cracking/StressCorrosion Water Chemistry Pump Coolal Boundary Steel (External! Cracking (B.2.1.2)

Pump Thermal Barrier) Internal)

Heat exchanger Treated Water components Pressure Stainless >140 F Cracking/Stress Corrosion One-Time (ReactorCoolant Boundary Steel (External! Cracking Inspection VIII.F-3 3.4.1-14 B Pump Thermal Internal) (B.2.1.18)

Barrier)

Heat exchanger components Pressure Stainless Treated Water Loss of Material/Pittingand Water Chemistry (Reactor Coolant Boundary Steel (External! Crevice Corrosion (B.2.1.2) VII.A4-2 3.3.1-23 A Pump Thermal Internal)

Barrier)

Heat exchanger components Pressure Stainless Treated Water Loss of Material/Pittingand One-Time (ReactorCoolant Peure (ExternalM of atenao/Pion Inspection VII.A4-2 3.3.1-23 B PumpBoundary Steel Internal) Crevice Corrosion (B.2.1.18)

Barrier)

Heat exchanger Closed Cycle Closed-Cycle components Pressure Stainless Cooling Water Cracking/StressCorrosion CoolingCWate (ReactorCoolant Boundary Steel > 140 F Cracking Cooling Water VII.E3-2 3.3.1-46 B Pump Thermal System (B.2.1.10)

Barrier) (Internal)

September 16, 2008 Page 8 of 44 5928-08-20196 Enclosure A Component Type Intended Material Environment Aging Effect Requiring Aging NUREG- Table I Notes Function Management Management 1801 Vol. 2 Item Programs Item Heat exchanger components Pressure Stainless Closed Cycle Loss of Material/Pittingand Closed-Cycle (Reactor Coolant Cooling Water Cooling Water VII.C2-10 3.3.1-50 B Pump Thermal (Internal) Crevice Corrosion System (B.2.1.10)

Barrier)

Heat exchanger components (Makeup,-DeGay Copper Alloy Closed Cycle Closed-Cycle HaRoo.lRB Heat CpeAlo CosdyceReduction of Heat Coe-yl Spay Pump & Tran with 15% Cooling Water Rer/Fon Cooling Water VII.C2-2 Spray Pum p & Transfer z n orM e (i t na)Transfer/Fouling ( ... 0 3.3.1-52 B MtrLbOiZinc Motor Lube Oil, or More (Internal) (B.2.1.10)

Gear Unit Oil Cooler)

Heat exchanger components (Makeup,-DeGay Copper Alloy wite15 Lurictin Ol Rducionofaea Hott Remval, RB Heat hLubricating Oil VIII.G-8 3.4.1-10 B Spray Pump & Transfer Zinc or More (External) Transfer/Fouling Analysis (B.2.1.23)

Motor Lube Oil, Gear Unit Oil Cooler)

Heat exchanger components (Makeup,-DeGay Copper Alloy One-Time Heat R RB Heat Lubricating Oil Reduction of HeatInspection VIII.G-8 3.4.1-10 Spray Pump & Transfer Zinc or (External) Transfer/Fouling Iptn.134-0 MtrLbOiZinc Motor Lube Oil, or More (B.2.1.18)

Gear Unit Oil Cooler)

September 16, 2008 Page 9 of 44 5928-08-20196 Enclosure A Component Type intended Material Environment Aging Effect Requiring Aging NUREG- Table I Notes Function Management Management 1801 Vol. 2 Item Programs Item Heat exchanger components (Makeup,-DeGay Air with Heat Removal, RB Pressure Carbon Borated Water Loss of Material/Boric Acid Boric Acid Spray Pump & Boundary Steel Leakage Corrosion Corrosion (B.2.1.4)

Motor Lube Oil, (External)

Gear Unit Oil Cooler)

Heat exchanger components (Makeup,-DeGay Air with External Surfaces Heat Removal, RB Pressure Carbon Borated Water Loss of Material/General, Pitting Monitoring VII.I-4 3.3.1-43 E, 1 Spray Pump & Boundary Steel Leakage and Crevice Corrosion (B.2.1.21)

Motor Lube Oil, (External)

Gear Unit Oil Cooler)

Heat exchanger components (Makeup, Debay Loss of Material/General, Pitting, Lubricating Oil Heat Removal, RB Pressure Carbon Lubricating Oil Crevice, and Microbiological ly Anrialyis g OilB.2.1.23..1-2 Spray Pump & Boundary Steel (Internal) Influenced Corrosion Analysis (B.2.1.23)

Motor Lube Oil, Gear Unit Oil Cooler)

Heat exchanger components (Makeup- DePay Loss of Material/General, Pitting, One-Time Heat Removal, RB Pressure Carbon Lubricating Oil Crevice, and Microbiologically Inspection VIII.G-6 3.4.1-12 B Spray Pump & Boundary Steel (Internal) Influenced Corrosion (B.2.1.18)

Motor Lube Oil, Gear Unit Oil Cooler)

September 16, 2008 Page 10 of 44 5928-08-20196 Enclosure A Component Type Intended Material Environment Aging Effect Requiring Aging NUREG- Table 1 Notes Function Management Management 1801 Vol. 2 Item Programs Item Heat exchanger components (Makeupmoval, R Peau Copper Alloy Closed Cycle Closed-Cycle H-;tRmoMIRB Pressure Loss Los of o Material/ Pitting, al!aPit Crevice, Spayeup with 15% Cooling Water Crevice Cooling Water VII.E1-2 3.3.1-51 B Spray Pump & Boundary ZnorMe (Itna)and Galvanic Corrosion (210 Motor Lube Oil, Zinc or More (Internal) (B.2.1.10)

Gear Unit Oil Cooler)

Heat exchanger components (Makeup,-DeCay Heat Removal, RB Pressure Copper Alloy Closed Cycle Loss of Material/ Selective Selective Leaching Spray Pump & Boundary with 15 CoolInter Leaching (B.2.1.19)

Motor Lube Oil, Zinc or More (Internal)

Gear Unit Oil Cooler)

Heat exchanger components (Makeup,-Decay Copper Alloy Lubricating Oil Loss of Material!Pitting and Lubricating Oil Heat Removal, RB Pressure with 15% Analysis VII.C1-8 3.3.1-26 D Spray Pump & Boundary Zinc or More (External) Crevice Corrosion (B.2.1.23)

Motor Lube Oil, Gear Unit Oil Cooler)

Heat exchanger components (Makeup,-DeGay Copper Alloy One-Time Heat Removal RB Pressure with Lubricating Oil Loss of MaterialInspection VII.C1-8 3.3.1-26 Spray Pump & Boundary Zinc or (External) Crevice Corrosion Iptn.133-6 Motor Lube Oil, Zinc or More (B.2.1.18)

Gear Unit Oil Cooler)

September 16, 2008 Page 11 of 44 5928-08-20196 Enclosure A Component Type intended Material Environment Aging Effect Requiring Aging NUREG- Table I Notes Function Management Management 1801 Vol. 2 Item Programs Item Heat exchanger components Copper (Makeup, RB Pressure Alloy with Lubricating Loss of Material! LubricatingOil Spray Pump & Alloy with Lubricating MicrobiologicallyInfluenced Analysis H, 5 Motor Lube Oil, Boundary 15% Zinc or Oil (External) Corrosion (B.2.1.23)

Gear Unit Oil Cooler)

Heat exchanger components Copper (Makeup, RB Pressure Alloy with Lubricating Loss of Materialu One-Time Spray Pump & MicrobiologicallyInfluenced Inspection H, 5 Motor Lube Oil, Boundary 15% Zinc or Oil (External) Corrosion (B.2.1.18)

Gear Unit Oil Cooler)

Heat exchanger components Air with (Reactor Building Pressure Copper Alloy Borated Water Loss of Material/Boric Acid Boric Acid Fan Motor, Decay Boundary with 15% Leakage Corrosion Corrosion (B.2.1.4) Vl1.l-12 3.3.1-88 C Heat Removal & Zinc or More Leakr Makeup Motor (External)

Air Coolers)

Heat exchanger components (Reactor Building Pressure Copper Alloy Closed Cycle Loss of Material/ Pitting, Crevice, Closed-Cycle Fan Motor, Decay Boundary with 15% Cooling Water Cooling Water VII.E1-2 3.3.1-51 B Heat Removal & Zinc or More (internal) (B.2.1.10)

Makeup Motor Air Coolers)

Heat exchanger components (Reactor Building Pressure Copper Alloy Closed Cycle Loss of Material/Selective Selective Leaching Fan Motor, Decay Boundary with 15% Cooling Water Leaching (B.2.1.19)3.2.1-41 A Heat Removal & Zinc or More (Internal)

Makeup Motor Air Coolers)

September 16, 2008 Page 12 of 44 5928-08-20196 Enclosure A Component Type Intended Material Environment Aging Effect Requiring Aging NUREG- Table I Notes Function Management Management 1801 Vol. 2 Item Programs Item Heat exchanger Inspection of componentscmoetCopr Copper Borated Air with Internal in Surfaces Miscellaneous (Decay Heat Heat Alloy with Water Reduction of Heat in andou Removal & Transfer Zinc or 15%More Leakage Transfer/Fouling Ducing Makeup Motor LageDucting Air Coolers) (External) Components (B.2.1.22)

Heat exchanger components Copper Closed Cycle Closed-Cycle (Decay Heat Heat Alloy with Reduction of Heat ClosedCyce Removal & Transfer 15% Zinc or (Internal) Transfer/Fouling (B. 2. 1. 10)

Makeup Motor More Air Coolers)

Heat exchanger components (Control Rod Drive Heat Stainless Closed Cycle Reduction of Heat Closed-Cycle Cooling Coils, Transfer Steel Cooling Water Transfer/Fouling Cooling Water VII.C2-3 3.3.1-52 B Decay Heat (Internal) (B.2.1.10)

Removal Pumps Bearing Cooling)

Heat exchanger components (R e a cto Drain r C o Heat Tank o la ntCl Pressure Stainless Clings d C c elo Wate Loss of Material/Pitting and Closed-Cycle d- y e (RatrCoatClosedg Cycler Ls fMtra/itnn Cooling Water V.D1-4 3.2.1.28 B Exchanger Boundary Steel lCrevice Corrosion Decay Heat (Internal) (8.2.1.10)

Removal Pumps Bearing Cooling)

Heat exchanger components Heat Stainless Lubricating Reduction of Heat LubricatingOil (DecayHeat Transfer Steel Analysis VIII.G-12 3.4.1-10 B Removal Pumps Oil (External) Transfer/Fouling (B.2.1.23)

Bearing Cooling)

September 16, 2008 Page 13 of 44 5928-08-20196 Enclosure A Component Type Intended Material Environment Aging Effect Requiring Aging NUREG- Table 1 Notes Function Management Management 1801 Vol. 2 Item Programs Item Heat exchanger components Heat Stainless Lubricating Reduction of Heat One-Time (Decay Heat T Inspection VIII.G-12 3.4.1-10 B Removal Pumps Remoal Pmps Transfer Steel Oil (External) Transfer/Fouling,(.. (B.2.1.18) 18 Bearing Cooling)

Heat exchanger Air with components Pressure Stainless Borated (Decay Heat Boundary Steel Water None None VII.J-16 3.3.1-99 A Removal Pumps Leakage Bearing Cooling) (External))

Heat exchanger components Pressure Stainless Lubricatin Loss of Material/Pitting, LubricatingOil (Decay Heat O Crevice, and Microbiologically Analysis VII.H2-17 3.3.1-33 B Removal Pumps Boundary Steel Oil (External) Influenced Corrosion (B.2.1.23)

Bearing Cooling)

Heat exchanger components Pressure Stainless Lubricatin Loss of Material/Pitting, One-Time (DecayBounda Steel Oil (External) Crevice, and Microbiologically Inspection VII.H2-17 3.3.1-33 B Removal Pumps Influenced Corrosion (B.2.1.18)

Bearing Cooling)

Heat exchanger components (Auxiliary Boiler Leakage Stainless Treated Water Loss of Material/Pitting and Water Chemistry VII.A4-2 3.3.1-23 A Sample Rack Boundary Steel (Internal) Crevice Corrosion (B.2.1.2)

Coolers, TCU Unit)

Heat exchanger components One-Time (Auxiliary Boiler Leakage Stainless Treated Water Loss of Material/Pitting and Inspection VII.A4-2 3.3.1-23 B Sample Rack Boundary Steel (Internal) Crevice Corrosion Iptn.A 3313 Coolers, TCU (B.2.1.18)

Unit)

September 16, 2008 Page 14 of 44 5928-08-20196 Enclosure A Component Type Intended Material Environment Aging Effect Requiring Aging NUREG- Table 1 Notes Function Management Management 1801 Vol. 2 Item Programs Item Heat exchanger components (Primary and Leakage Stainless Air - Indoor None None VII-15 3.3.1-94 C Secondary Boundary Steel (External)

Cooling Coils, TCU Unit)

Heat exchanger components Closed Cycle Closed-Cycle (Primary and Leakage Stainless Close Cyce Loss of Material/Pitting and ClosedCyce Secondary Boundary Steel (internal) Cooling Water V.D1-4 3.2.1.28(B Cooling Coils, TCU Unit)

Heat exchanger components (Control Building Leakage Copper Alloy Air - Indoor Air Conditioning, Boundary with 15% (External) None None V.F-3 3.2.1-53 C IsolatedPhase Zinc or More Bus Duct Coolers)

Heat exchanger components (Control Building Leakage Copper Alloy Closed Cycle Loss of Material/General, Pitting, Closed-Cycle Air Conditioning, Boundary with 15% Cooling Water Crevice, and Galvanic Corrosion Cooling Water VII.E1-2 3.3.1-51 B Isolated Phase Zinc or More (internal) (B.2.1.10)

Bus Duct Coolers)

Heat exchanger components (Control Building Leakage Copper Alloy Closed Cycle Loss of Material/Selective Selective Leaching Air Conditioning, Boundary with 15% Cooling Water Leaching V.A-6 3.2.1-41 A Isolated Phase Zincundar Leaching (B.2.1 .19)

Bus Duct Coolers)

September 16, 2008 Page 15 of 44 5928-08-20196 Enclosure A Component Type Intended Material Environment Aging Effect Requiring Aging NUREG- Table I Notes Function Management Management 1801 Vol. 2 Item Programs Item Piping and Copper fittings Leakage Alloy with Air - Indoor None None VIII.1-2 3.4.1-41 A Boundary 15% Zinc or (External)

More Piping and Copper fittings Leakage Alloy with Treated Water Loss of Material/Pittingand One-Time Boundary 15% Zinc or (Internal) Crevice Corrosion Inspection VIII.A-5 3.4.1-15 B More (B.2.1.18)

Piping and Copper fittings Leakage Alloy with Treated Water Loss of Material/Pittingand Water Chemistry Viii.A-5 3.4.1-15 A Boundary 15% Zinc or (Internal) Crevice Corrosion (B.2.1.2)

More Piping and Copper Selective fittings Leakage Alloy with Treated Water Loss of Material/Selective Leaching of Boundary 15% Zinc or (Internal) Leaching Materials More (B.2.1.19)

Piping and Copper Closed Cycle Closed-Cycle fittings Leakage Alloy with Loss of Material/Pittingand Cooling Water VIIC24 3.3.1-51 I,3 Boundary 15% Zinc or CingeWater Crevice Corrosion (B.2.1.10)

More (Internal)

Pipingand Copper Closed Cycle Selective fittings Leakage Alloy with Cooling Cce Loss of MateriaWr/Selective Leaching of VII.C2-6 3.3.1-84 A Boundary 15% Zinc or Leaching Materials More (Internal) (B.2.1.19)

Valve Body Copper One-Time Leakage Alloy with Treated Water Loss of Material/Pittingand Boundary 15% Zinc or (Internal) Crevice Corrosion Inspection VIII.A-5 3.4.1-15 B More (B.2.1.18)

Valve Body Copper Leakage Alloy with Treated Water Loss of Material/Pittingand Water Chemistry Viii.A-5 3.4.1-15 A Boundary 15% Zinc or (Internal) Crevice Corrosion (B.2.1.2)

More

September 16, 2008 Page 16 of 44 5928-08-20196 Enclosure A Component Type Intended Material Environment Aging Effect Requiring Aging NUREG- Table I Notes Function Management Management 1801 Vol. 2 Item Programs Item Valve Body Copper Selective Leakage Alloy with Treated Water Loss of Material/Selective Leaching of VII.C2-7 3.3.1-84 A Boundary 15% Zinc or (Internal) Leaching Materials More (B.2.1.19)

Plant Specific Notes:

5. The aging effects/mechanisms of copper alloy in a lubricatingoil environment include loss of materialdue to microbiologicallyinfluenced corrosion. These aging effects/mechanisms are managed by the LubricatingOil Analysis and One-Time Inspection Programs.

September 16, 2008 Page 17 of 44 5928-08-20196 Enclosure A RAI # 2.3.3.9-1

Background:

On license renewal drawing LR-302-351, the emergency diesel generator (EDG), air start system, air compressor has a standby diesel engine to drive the compressor in the event of a failure of the motor shown as not included in scope for license renewal. The standby diesel engine includes a tank and lines containing diesel fuel.

In accordance with LRA Section 2.1.5.2, the applicant used the preventive option approach, as described in NEI 95-10, to scope nonsafety-related components with a potential for physical or spatial interaction with safety-related SSCs. Potential spatial interaction is assumed in any structure that contains active or passive safety-related SSCs. Nonsafety-related systems and components that contain water, oil, or steam, and are located inside structures that contain safety-related SSCs, are included in scope for potential spatial interaction under criterion 10 CFR 54.4(a)(2), unless located in an excluded room.

Issue:

The standby diesel engine to the EDG air start compressor includes lines containing diesel fuel.

In accordance with the applicant's methodology as described in LRA Section 2.1.5.2, this component should be included in scope under 10 CFR 54.4(a)(2).

Request:

Justify the exclusion of the fluid-filled tank and lines on the standby diesel engine for the EDG air start system air compressor from the scope of license renewal under 10 CFR 54.4(a)(2).

AmerGen Response The fuel tank for the standby diesel engine is in scope and subject to aging management review and should have been included in Table 2.3.3-9 and Table 3.3.2-9 as shown below. The standby diesel engine fuel lines (piping and fittings, hoses), fuel filters, and fuel pump casing are included in scope and subject to aging management review and are included in LRA Tables 2.3.3-9 and 3.3.2-9 under the following component types: "Filter Housing", "Hoses", "Piping and fittings", and "Pump Casing (Engine-driven Fuel Oil Pump)".

Drawing LR-302-351 should have shown the standby diesel engine component as in-scope for license renewal.

The component type of "Tank (Standby Diesel Engine)" should have been included in LRA Table 2.3.3-9 as follows:

Table 2.3.3-9 Emergency Diesel Generators and Auxiliary Systems Components Subject to Aging Management Review Component Type Intended Functions Tank (Standby Diesel Engine) Leakage Boundary

September 16, 2008 Page 18 of 44 5928-08-20196 Enclosure A The component type of "Tank (Standby Diesel Engine)" should have been included in LRA Table 3.3.2-9 as follows:

September 16, 2008 Page 19 of 44 5928-08-20196 Enclosure A Table 3.3.2-9 Emergency Diesel Generators and Auxiliary Systems Component Type Intended Material Environment Aging Effect/ Aging NUREG-1801 Table I Item Notes Function Mechanism Management Vol. 2 Item Requiring Programs Management Tank (Standby Leakage Carbon Fuel Oil (Internal) Loss of Inspection of VII.HI-1O 3.3.1-20 E, 6 Diesel Engine) Boundary Steel Material/General, Internal Pitting,Crevice, Surfaces in and Miscellaneous Microbiologically Pipingand Influenced Ducting Corrosion,and Components Fouling (B.2.1.22)

Tank (Standby Leakage Carbon Air - Indoor Loss of External VII.I-8 3.3.1-58 B Diesel Engine) Boundary Steel (Exterior) Material/General Surfaces Corrosion Monitoring (B.2.1.21)

September 16, 2008 Page 20 of 44 5928-08-20196 Enclosure A RAI # 2.3.3.14-1

Background:

On license renewal drawing LR-302-276, the instrument air (IA) system has a two-hour backup instrument air charging compressor. The charging compressor is not included in scope for license renewal. The charging compressor includes an oil pump and piping containing oil that operates up to 1500 psi. This charging compressor is located in the emergency diesel generator (EDG) room, next to the EDG.

Similar to the discussion in RAI# 2.3.3.9-1, nonsafety-related systems and components that contain water, oil, or steam, and are located inside structures that contain safety-related SSCs, are included in scope for potential spatial interaction under criterion 10 CFR 54.4(a)(2), unless located in an excluded room.

Issue:

The backup instrument air charging compressor includes components containing oil. In accordance with the applicant's methodology as described in LRA Section 2.1.5.2, this component should be included in scope under 10 CFR 54.4(a)(2).

Request:

Justify the exclusion of the backup instrument air charging compressor from the scope of license renewal under 10 CFR 54.4(a)(2).

AmerGen Response The oil lines associated with the Two Hour Backup Instrument Air Charging Compressor are included in the scope of license renewal and should have been shown as leakage boundary piping on the license renewal drawing LR-302-276.

Table 2.3.3-14 should have included the component type and intended function that follows:

Table 2.3.3-14 Instrument and Control Air System Components Subject to Aging Management Review Component Type Intended Functions Piping & Fittings (Two HourBackup Instr Leakage Boundary Air ChargingCompressor)

The components listed in the following table should have been included in the LRA Table 3.3.2-14 as follows:

September 16, 2008 Page 21 of 44 5928-08-20196 Enclosure A Table 3.3.2-14 Instrument and Control Air System Component Intended Material Environment Aging Effect Aging NUREG-1801 Table 1 Item Notes Type Function Requiring Management Vol. 2 Item Management Programs Piping & Fittings Leakage Stainless Lubricating Oil Loss of Material! Inspection of VIII.E-26 3.4.1-19 E, 8 (Two Hour Backup Boundary Steel (Internal) Pitting,Crevice & InternalSurfaces Instr Air Charging Microbiologically in Miscellaneous Compressor) Influenced Pipingand Corrosion Ducting Components (B.2.1.22)

Piping & Fittings Leakage Stainless Air-Indoor(External) None None VII.J-15 3.3.1-94 A (Two Hour Backup Boundary Steel Instr Air Charging Compressor)

Plant Specific Notes

8. This component, materialand environment combination is associatedwith the interiorlubricationsystem on the Two Hour Charging Compressor.

As such, the Lubricating Oil Analysis and One-Time Inspection programsdo not apply. The aging effects/mechanisms will be managed by the Inspection of InternalSurfaces in Miscellaneous Piping and Ducting Components Program.

September 16, 2008 Page 22 of 44 5928-08-20196 Enclosure A The Environments List in Section 3.3.2.1.14 should have shown the following:

3.3.2.1.14 Instrument and Control Air System Materials

• Lubricating Oil The Aging Management Programs List in Section 3.3.2.1.14 should have shown the following:

Aging Management Programs

• Inspection of InternalSurfaces in Miscellaneous Piping and Ducting Components (B.2.1.22)

September 16, 2008 Page 23 of 44 5928-08-20196 Enclosure A RAI # 2.3.3.14-2

Background:

On license renewal drawing LR-302-271, at location D-7, the piping up to a temperature instrument connected to instrument air aftercooler IA-C-1A, is highlighted in green, indicating that it is in the scope of license renewal for 10 CFR 54.4 (a)(1) or (a)(3) criteria according to note on license renewal drawing LR-302-003. On the same license renewal drawing LR-302-271, at location D-6, the piping to a similar temperature instrument connected to instrument air after-cooler IA-C-1 B, is not highlighted, indicating that it is not in the scope of license renewal.

Issue:

The IA piping from the instrument air after-cooler IA-C-1 B to the temperature sensor is part of the pressure boundary of the IA system and should be included in the scope of license renewal in accordance with 10 CFR 54.4 (a)(1).

Request:

Justify the exclusion of the piping to the temperature instrument connecting to instrument air after-cooler IA-C-1 B from the scope of license renewal.

AmerGen Response The piping up to and including the temperature instrument located on the instrument air after-cooler IA-C-1 B at location D-6 on drawing LR-302-271 is included in the scope of license renewal and should have been shown as in scope on the drawing.

September 16, 2008 Page 24 of 44 5928-08-20196 Enclosure A RAI # 2.3.3.17-1

Background:

On license renewal drawing LR-302-181, at locations F-2 through F-8 and G-7, the primary sampling coolers tube side components are highlighted in red, indicating that they are within the scope of license renewal under 10 CFR 54.4 (a)(2), according to Note 1 on drawing LR-302-003.

On license renewal drawing LR-302-181, at location G-9, the condensate pump sample cooler tube side components are highlighted in red, indicating that they are within the scope of license renewal under 10 CFR 54.4 (a)(2), according to Note 1 on license renewal drawing LR-302-003.

Issue:

Note 3 on license renewal drawing LR-302-181 reads: "The tube side of the Sample Coolers is evaluated for aging management with the LGS System. The shell side of the coolers is evaluated for aging management with the CCCW System." However, LRA Table 2.3.3-17, Liquid and Gas Sampling System, Components Subject to Aging Management Review, does not list these coolers as subject to an AMR.

Note 4 on license renewal drawing LR-302-181 reads: "The tube side of the Condensate Pump Sample Cooler is evaluated for aging management with the LGS System. The shell side of the cooler is evaluated for aging management with the CCCW System." However, LRA Table 2.3.3-17 does not list this cooler as subject to AMR.

Request:

a) Justify the exclusion of the tube side of the primary sampling coolers from Table 2.3.3-17 as a component subject to an AMR.

b) Justify the exclusion of the tube side of the condensate pump sample cooler from Table 2.3.3-17 as a component subject to an AMR.

AmerGen Response a) The Primary Sample Coolers located at F-2 through F-8 and G-7 on LR-302-181 are tube in tube coolers. The inner tubes, which were incorrectly shown as red, are contained within the outer tubes. The nonsafety-related inner tube side of the coolers are not connected to safety-related piping, do not have a spatial relationship such that their failure could adversely impact on the performance of a safety-related SSC intended function, and are not credited for any regulatory events; therefore, they do not perform any intended functions and are not in scope. LR-302-181 should have depicted the inner tube side of the coolers as black, indicating the inner tube side is not in scope for license renewal. Note 3 should have read, "The Primary Sample Coolers are evaluated for aging management with the CCCW System." The Primary Sample Coolers are not listed in Table 2.3.3-17 because the inner tube side of the coolers do not perform any intended function and the outer tube side, which performs a leakage boundary intended function, is evaluated with Closed Cycle Cooling Water. Refer to Table 2.3.3-4 for a list of Closed Cycle Cooling Water components subject to Aging Management Review.

September 16, 2008 Page 25 of 44 5928-08-20196 Enclosure A b) Condensate Pump Sample Cooler located at G-9 is a tube in tube cooler. The outer tube of the cooler performs a leakage boundary intended function and is correctly shown as red; however, it was omitted from Table 2.3.3-17 and Table 3.3.2-17. The inner tube, which is not in scope and was incorrectly shown as red, is contained within the outer tube. The nonsafety-related inner tube side of the cooler is not connected to safety-related piping, does not have a spatial relationship such that its failure could adversely impact on the performance of a safety-related SSC intended function, and is not credited for any regulatory events; therefore, the inner tube side does not perform any intended functions and is not in scope. LR-302-181 should have depicted the inner tube side of the cooler as black, indicating the inner tube side is not in scope for license renewal.

Note 4 should have read, "The Condensate Pump Sample Cooler is evaluated for aging management with the LGS System." Table 2.3.3-17 should have included the component type and intended function as follows:

Table 2.3.3-17 Liquid and Gas Sampling System Components Subject to Aging Management Review Component Type Intended Functions Heat exchanger components Leakage Boundary (CondensatePump Sample Cooler)

The External Surfaces Monitoring program, B.2.1.21, will be used to manage loss of material due to general corrosion of the Condensate Pump Sample Cooler; therefore, Table 3.3.1 Item Number 3.3.1-58 should have included the Liquid and Gas Sampling System in the Discussion list of applicable systems for the External Surfaces Monitoring program. The cooler should have been included in LRA Table 3.3.2-17 as follows:

September 16, 2008 Page 26 of 44 5928-08-20196 Enclosure A Table 3.3.2-17 Liquid and Gas Sampling System Component Type Intended Material Environment Aging Effect Requiring Aging Management NUREG- Table I Notes Function Management Programs 1801 Vol. 2 Item Item Heat exchanger Leakage Carbon Air - Indoor Loss of Material/General External Surfaces VII.I-8 3.3.1-58 B components Boundary Steel (External) Corrosion Monitoring (B.2.1.21)

(Condensate Pump Sample Cooler)

Heat exchanger Leakage Carbon Treated Water Loss of Water Chemistry VIII.E-37 3.4.1-3 A components Boundary Steel (Internal) Material/General,Pitting, (B.2.1.2)

(Condensate and Crevice Corrosion Pump Sample Cooler)

Heat exchanger Leakage Carbon Treated Water Loss of One-Time Inspection VIII.E-37 3.4.1-3 B components Boundary Steel (Internal) Material/General,Pitting, (B.2.1.18)

(Condensate and Crevice Corrosion Pump Sample Cooler)

September 16, 2008 Page 27 of 44 5928-08-20196 Enclosure A RAI 2.3.3.17-2

Background:

On license renewal drawing LR-302-182, at locations C-2 and E-2, the chillers are highlighted in red, indicating that they are within the scope of license renewal under 10 CFR 54.4 (a)(2) criteria according to Note 1 on drawing LR-302-003.

Issue:

Note 3 on license renewal drawing LR-302-182 reads: "The tube side and shell side of the Chillers are evaluated for Aging Management with the LGS System." However, LRA Table 2.3.3-17, Liquid and Gas Sampling System, Components Subject to Aging Management Review, does not list these chillers as subject to an AMR.

Request:

Justify the exclusion of the tube side and shell side of the chillers from Table 2.3.3-17 as a component subject to an AMR.

AmerGen Response The Secondary Sample Chillers, SS-C-1 and SS-C-2, are in scope for License Renewal as depicted on LR-302-182, but were omitted from Table 2.3.3-17 and Table 3.3.2-17. LRA Table 2.3.3-17 should have included component type and intended function as follows:

Table 2.3.3-17 Liquid and Gas Samplinq System Components Subject to Aging Management Review Component Type Intended Functions Heat exchangercomponents Leakage Boundary (SecondarySample Chillers)

The External Surfaces Monitoring program, B.2.1.21, will be used to manage loss of material due to general corrosion of the Secondary Sample Chillers; therefore, Table 3.3.1 Item Number 3.3.1-58 should have included the Liquid and Gas Sampling System in the Discussion list of applicable systems for the External Surfaces Monitoring program. The chillers should have been included in LRA Table 3.3.2-17 as follows:

September 16, 2008 Page 28 of 44 5928-08-20196 Enclosure A Table 3.3.2-17 Liquid and Gas Sampling System Component Type Intended Material Environment Aging Effect Requiring Aging Management NUREG- Table 1 Notes Function Management Programs 1801 Vol. 2 Item Item Heat exchanger Leakage Carbon Air - Indoor Loss of Material/General External Surfaces VII.l-8 3.3.1-58 B components Boundary Steel (External) Corrosion Monitoring (B.2.1.21)

(Secondary Sample Chillers)

Heat exchanger Leakage Carbon Treated Water Loss of Water Chemistry VIII.E-37 3.4.1-3 A components Boundary Steel (Internal) Material/General,Pitting, (B.2.1.2)

(Secondary and Crevice Corrosion Sample Chillers)

Heat exchanger Leakage Carbon Treated Water Loss of One-Time Inspection VIII.E-37 3.4.1-3 B components Boundary Steel (Internal) Material/General,Pitting, (B.2.1.18)

(Secondary and Crevice Corrosion Sample Chillers) I I I

September 16, 2008 Page 29 of 44 5928-08-20196 Enclosure A RAI 2.3.3.17-3

Background:

On various license renewal drawings, the applicant shows the piping leading up to and out of an enclosure, such as a sampling panel, highlighted in red, indicating that the components are within the scope of license renewal under 10 CFR 54.4 (a)(2) criteria according to Note 1 on drawing LR-302-003. Yet, the piping inside the panel and the panel enclosure walls are not shown as in scope. Examples of this condition can be found on license renewal drawing LR-302-181, at location E-9; the iron sampler housing, the sampling rack just below the iron sampler, and the piping inside these enclosures are all shown in black, not highlighted.

Issue:

The piping in the room up to the sampling rack and iron sampler housing is highlighted in red, indicating it is within the scope of license renewal under 10 CFR 54.4(a)(2). The staff would expect either the internal components or the panel to be included within scope of license renewal.

Request:

Justify the exclusion of the housing panels and their internal piping and components from being in scope for an AMR in accordance with 10 CFR 54.4(a)(2). In addition, provide a general explanation of how piping and components inside enclosures, as illustrated above, are evaluated for inclusion in scope under 10 CFR 54.4(a)(2).

AmerGen Response These enclosures are in scope and evaluated for license renewal in Section 2.4.13, Structural Commodities as commodity type Cabinets, Enclosures and Panels for Electrical Equipment and Instrumentation. AmerGen's practice was to not highlight structural components on mechanical drawings.

As indicated on the drawing, piping up to the enclosure is required to perform a leakage boundary function; therefore, it is subject to AMR for 10 CFR 54.4(a)(2) due to the potential of spatial interaction with safety-related equipment. Piping inside the enclosure does not have a potential for spatial interaction with safety-related equipment, because the enclosure protects the safety-related equipment from spray originating from the nonsafety-related components.

Refer to Table 2.4-13 and AMR Table 3.5.2-13.

September 16, 2008 Page 30 of 44 5928-08-20196 Enclosure A RAI # 2.3.3.19-1

Background:

On license renewal drawing LR-302-203 at locations C-3 through C-5 and B-3 through B-5, the traveling water screens and auto bar rakes are highlighted in green, indicating that they are within the scope of license renewal under 10 CFR 54.4 (a)(1) or (a)(3) according to Note 1 on license renewal drawing LR-302-003. The traveling water screens and debris bars (bar racks, not the automatic rakes) have a passive intended function of filter. LRA Section 2.3.3.19, Open Cycle Cooling Water System (OCCWS), on page 2.3-139 in the last paragraph, states that the OCCWS System boundary begins at the intake screen and pump house bar racks.

Issue:

The staff noted that, in LRA Table 2.3.3-19, Open Cycle Cooling Water System, Components Subject to Aging Management Review, the traveling water screens and debris bars have not been listed. A review of LRA Section 2.4.8, Intake Screen and Pump House, indicates the traveling water screens and debris bars have also not been included in this building system.

Request:

Justify the exclusion of the components bar racks and traveling screens for the intended function of filter from Table 2.3.3-19.

AmerGen Response The bar racks are passive components within the scope of license renewal with a filter intended function. The bar racks are subject to aging management and should have been included in Table 2.3.3-19. The traveling screens are also within the scope of license renewal with a filter intended function, but are active components and not subject to aging management review.

Due to their active intended function, the traveling screens were excluded from Table 2.3.3-19.

Additionally, bar grids are located at the outermost portion of the intake structure. The bars grids are 2-foot by 2-foot stainless steel grids that prevent large debris from entering the intake.

They perform a filter passive intended function similar to the function of the bar racks. These bar grids are not shown on drawing LR-302-203.

Paragraphs one and two of "System Operation" in LRA Section 2.3.3.19 on page 2.3-138 should have read as follows:

The OCCW System is comprised of bar grids, bar rakes, bar racks, traveling screens, river water pumps, strainers, piping and components, heat exchangers, and instrumentation and control. The river water pumps are the Decay Heat River, Nuclear Service River Water, Secondary Service Cooling Water, and Screen House Ventilation Cooling Water Pumps.

Automatic Bar Rakes remove the initial large debris from the river water at the eRn*ance to the Intake Screen and Pump House (ISPH). Stainless steel bar grids, with a 2-foot horizontalspacing and a 3.5-foot vertical spacing,are located on the inlet openings of the Intake Screen and Pump House (ISPH)

September 16, 2008 Page 31 of 44 5928-08-20196 Enclosure A to prevent large river debris from entering the ISPH. Downstream of the bar grids, carbon steel bar racks are positionedto provide a 1- inch clearance for a finer passive filtering of river debris. Collected debris is removed automatically by a power driven Fake bar rakes, which lifts trash up the front of the vertical bars bar racks and dumps the trash into a trough. Traveling screens are located just after the autemiati bar Fakes racks. Small size 3/8-inch openings in the traveling screens catch debris that has passed through the bar rakes racks. The traveling screens are cleaned by pumped river water that is strained and then sprayed on the screens. The bar grids, bar rakes, bar racks, and travelingscreens together perform a filtering function that assures a highly reliable, screenedsupply of river water at the suction of the Nuclear Services and Decay Heat River Water Pumps, allowing them to perform their nuclearsafety-relatedfunction. Based on this filter function, these components are included the OCCW System scope requiredfor License Renewal. The bar rakes and traveling screens are consideredactive components and are not subject to aging management review.

Paragraphs one and two of "System Boundary" in LRA Section 2.3.3.19 on page 2.3-139 should read as follows:

The OCCW System boundary begins at the ISPH bar Frak-s grids. The system continues through the barrakes, bar racks, traveling screens, river water pumps, and strainers and then runs underground into the Heat Exchanger Vault and Turbine Building. The system then passes through the heat exchangers and leads to the common river discharge line. The system then passes through the river discharge line in both directions to the East Dike and through the MDCT basin, radiation monitor pit, and to discharge at the river. The OCCW boundary also includes the radiation monitor pit pump, associated piping and valves, and radiation monitor. The boundary includes discharge piping through, but not including, the East Dike.

The boundary includes the Screen House Ventilation Equipment pumps, strainers, piping, through the vent equipment, to the ISPH. The Screen House Ventilation cooling coils are evaluated with the Intake Screen and Pump House Ventilation System. The boundary also includes the Screen Wash pumps and continues through the pump discharge strainers, traveling water screens, and auto bar rakesT to the sluice canal. The boundary includes the river pump strainer backwash, which discharges to the river.

System Intended Function #2 in LRA Section 2.3.3.19 on page 2.3-141 should have read as follows:

2. Resist nonsafety-related SSC failure that could prevent satisfactory accomplishment of a safety-related function. 10 CFR 54.4(a)(2). The bar grids, barrakes, bar racks, and traveling screens together perform a filtering function that assures a highly reliable,screened supply of river water at the suction of the Nuclear Service and Decay Heat River Water Pumps, allowing them to perform their nuclearsafety-relatedfunction.

The OCCW System also contains nonsafety-ratedwater-filled lines,

September 16, 2008 Page 32 of 44 5928-08-20196 Enclosure A which have the potentialfor spatialinteraction(sprayor leakage) with safety-relatedSSC's.

Table 2.3.3-19 should have included the component type of "strainer element" and intended function of "filter" for the ISPH bar grid and bar racks as shown below.

Table 2.3.3-19 Open Cycle Cooling Water System Components Subject to Aging Management Review Component Type Intended Functions StrainerElement (ISPH Bar Grids, ISPH Bar Filter Racks)

LRA Section 3.3.2.1.19, as shown below, includes the Structures Monitoring (B.2.1.28) aging management program.

3.3.2.1.19 Open Cycle Cooling Water System Aging Management Programs 0 Structures Monitoring(B.2.1.28)

Table 3.3.2.19, as shown below, includes the aging management for the ISPH bar grids and bar racks.

September 16, 2008 Page 33 of 44 5928-08-20196 Enclosure A Table 3.3.2.19 Open Cycle Cooling Water System ComponentMaterial Environment Aging Effect Aging Management NUREG-1801 Table 1 Notes Function aRequiring Programs Vol. 2 Item Item Type Management Strainer Loss of Element (ISPH Filter Carbon Steel Air- Indoor Material/General StructuresMonitoring VII.1-8 3.3.1-58 E, 4 Bar Grids, ISPH (External) Corrosion Program(B.2.1.28)

Bar Racks)

Loss of Material/

General,Pitting, Crevice, and Strainer Element (ISPH Filter Carbon Steel Raw Water Microbiologically Structures Monitoring VII.C1-19 3.3.1-76 E, 3 (Internal) Influenced Program(B.2.1.28)

Bar Grids, ISPH Bar Racks) Corrosion,fouling, and lining/coating degradation Strainer Loss of Element (ISPH Filter Stainless Air- Outdoor Material/Pittingand Structures Monitoring III.B4-7 3.5.1-50 C Bar Grids, ISPH Steel (External) Crevice Corrosion Program(B.2.1.28)

Bar Racks)

Loss of Strainer Stainless Raw Water Material/Pittingand Structures Monitoring VII.CI-15 3.3.1-79 E, 2 Element (ISPH Filter Steel (Internal) Crevice Corrosion, Program(B.2.1.28)

Bar Grids, ISPH and fouling Bar Racks) __________________________________________

Plant Specific Notes:

2. The aging effects/mechanisms of stainlesssteel in a raw waterenvironment include loss of materialdue to pitting, crevice, and microbiologicallyinfluenced corrosion,and fouling. These aging effect mechanisms are managedby the StructuresMonitoring Program.

3. The aging effects/mechanisms of carbon steel in a raw water environment include loss of material/general,pitting, crevice,and microbiologicallyinfluenced corrosion,fouling, and lining/coatingdegradation. These aging effect mechanisms are managed by the Structures Monitoring Program.

4. The aging effects/mechanisms of carbon steel in an indoor airenvironment include generalcorrosion. This agingeffect mechanism is managed by the Structures Monitoring Program.

September 16, 2008 Page 34 of 44 5928-08-20196 Enclosure A RAI # 2.3.3.19-2

Background:

On license renewal drawing LR-302-202 at locations C-5 and D-5, two restricting orifices are highlighted in red, indicating that they are within the scope of license renewal under 10 CFR 54.4 (a)(2) according to Note 1 on drawing LR-302-003.

Issue:

The staff noted that, LRA Table 2.3.3-19, Open Cycle Cooling Water System, Components Subject to Aging Management Review, shows restricting orifices with a pressure boundary function only, indicting they are in scope based on 10 CFR 54.4(a)(1) or (a)(3) criteria. Since the components are highlighted in red, the appropriate function for (a)(2) components would be leakage boundary; however, this function is not included in Table 2.3.3-19 for restricting orifices.

Request:

Justify the exclusion of the leakage boundary function for the restricting orifices from Table 2.3.3-19.

AmerGen Response Restricting orifices in the Open Cycle Cooling Water System perform both pressure and leakage boundary functions. The restricting orifices shown on drawing LR-302-202 at locations C-5 and D-5 are within the scope for license renewal with the intended function of leakage boundary, but their intended function of leakage boundary was omitted from Tables 2.3.3-19 and 3.3.2-19.

Table 2.3.3-19 should have included the intended function of leakage boundary for the restricting orifices as follows:

Table 2.3.3-19 Open Cycle Cooling Water System Components Subject to Aging Management Review Component Type Intended Functions Restricting Orifices Leakage Boundary Table 3.3.2.19, should have included the leakage boundary function for the restricting orifices as follows:

September 16, 2008 Page 35 of 44 5928-08-20196 Enclosure A Table 3.3.2.19 Open Cycle Cooling Water System Component Intended Aging Effect Aging Management NUREG-1801 Table 1 Material Environment Requiring Programs Vol. tem Notes Type Function Management Programs Vol. 2 Item Item Restricting Leakage Stainless Air- Indoor None None VIIJ-15 3.3.1-94 A Orifices Boundary Steel (External)

Loss of Restricting Leakage Stainless Raw Water Material/Pitting, Crevice, and Open-Cycle Cooling Water VIH-8 3318 Orifices Boundary Steel (Internal) Microbiologically System (B.2.1.9)

Influenced Corrosion

September 16, 2008 Page 36 of 44 5928-08-20196 Enclosure A RAI # 2.3.3.20-1

Background:

On license renewal drawing LR-302-833, sheet 1, location G-7, an isokinetic nozzle (RE-A14) is highlighted in green, indicating it is within the scope of license renewal under 10 CFR 54.4 (a)(1) according to Note 1 on license renewal drawing LR-302-003. The nozzle is associated with the radiation monitor RM-A14 and has an intended function of pressure boundary and direct flow.

Issue:

LRA Table 2.3.3-20, Radiation Monitoring System, Components Subject to Aging Management Review, does not show the nozzle as a component with an intended function of pressure boundary or direct flow.

Request:

Justify the exclusion of the isokinetic nozzle from LRA Table 2.3.3-20.

AmerGen Response The isokinetic nozzle shown on drawing LR-302-833, at location G-7, is within the scope for license renewal; however, it was omitted from Tables 2.3.3-20 and Table 3.3.2-20. The nozzle has the intended functions of direct flow and pressure boundary. The nozzle directs flow to the RM-A-14 manual sampling rack and penetrates surrounding ductwork. This component should have been included in Tables 2.3.3-20 and Table 3.3.2-20 as follows:

Table 2.3.3-20 Radiation Monitoring System Components Subject to Aging Management Review Component Type Intended Functions Nozzle (Isokinetic Nozzle) Direct Flow PressureBoundary Aging management information for Table 3.3.2-20 is shown as follows:

September 16, 2008 Page 37 of 44 5928-08-20196 Enclosure A Table 3.3.2-20 Radiation Monitoring System Component Type Intended Material Environment Aging Management Effect Requiring AgingPrograms Management NUREG-1801 Table Function Vol. 2 Item Item 1 Notes Nozzle (Isokinetic Direct Flow Stainless Air/Gas Wetted Loss of Material/Pitting One-Time Nozzle) Steel (External) and Crevice Corrosion Inspection (B.2.1.18) VII.F2-1 3.3.1-27 E, 1 Nozzle)

Nozzle Stainless Air/Gas Wetted Loss of Material/Pitting One-Time (Isokinetic Direct Flow Steel (Internal) and Crevice Corrosion Inspection (B.2.1.18) VII.F2-1 3.3.1-27 E, 1 Nozzle)

(Isokinetic Pressure Stainless Air/Gas Wetted Loss of Material/Pitting One-Time Nozzle) Boundary Steel (External) and Crevice Corrosion Inspection (B.2.1.18) VII.12-1 3.3.1-27 E, 1 Nozzle)

Nozzle Pressure Stainless Air/Gas Wetted Loss of Material/Pitting One-Time Nozzle) Boundary Steel (Internal) and Crevice Corrosion Inspection (B.2.1.18) VIIF21 3.3.1-27 E, 1

September 16, 2008 Page 38 of 44 5928-08-20196 Enclosure A RAI 2.3.3.22-1

Background:

On license renewal drawing LR-302-846, at location D-3, level indicator LI-1007 is highlighted in red, indicating that it is within the scope of license renewal for 10 CFR 54.4 (a)(2) according to Note 1 on drawing LR-302-003. This component type typically includes a sight glass, which would have a leakage boundary function.

Issue:

Sight glass is not listed in Tables 2.3.3-22, Service Building Chilled Water System, Components Subject to Aging Management Review, and 3.3.2-22, Service Building Chilled Water System, Summary of Aging Management Evaluation, as a component type with a leakage boundary function.

Request:

Justify the exclusion of the component type "sight glass" from LRA Tables 2.3.3-22 and 3.3.2-22.

AmerGen Response The sight glass, LI-1 007, is in scope for License Renewal as depicted on LR-302-846, but was omitted from Table 2.3.3-22 and Table 3.3.2-22. Table 2.3.3-22 should have included component type and intended function as follows:

Table 2.3.3-22 Service Building Chilled Water System Components Subject to Aging Management Review Component Type Intended Functions Sight glass Leakage Boundary The component is comprised of carbon steel, which is already in Section 3.3.2.1.22, and glass.

Additional material of glass should be included in Section 3.3.2.1.22 as follows:

3.3.2.1.22 Service Building Chilled Water System Materials Glass The sight glass should have been included in LRA Table 3.3.2-22 as follows:

September 16, 2008 Page 39 of 44 5928-08-20196 Enclosure A Table 3.3.2-22 Service Building Chilled Water System Component Type Intended Material Environment Aging Effect Requiring Aging Management NUREG- Table I Notes Function Management Program 1801 Vol. 2 Item Item Sight glass Leakage Carbon Air - Indoor Loss of Material/General External Surfaces VII.I-8 3.3.1-58 B Boundary Steel (External) Corrosion Monitoring (B.2.1.21)

Sight glass Leakage Carbon Closed Cycle Loss of Closed-Cycle Cooling VII.C2-14 3.3.1-47 B Boundary Steel Cooling Water Material/General,Pitting, Water System (B.2. 1.10) and Crevice Corrosion Sight glass Leakage Glass Air- Indoor None None VII.J-7 3.3.1-93 A Boundary (External)

Sight glass Leakage Glass Closed Cycle None None G, 3 Boundary Cooling Water Plant Specific Notes

3. There are no aging effects for glass in a closed cycle cooling water environment.

September 16, 2008 Page 40 of 44 5928-08-20196 Enclosure A RAI # 2.3.3.25-1

Background:

The staff noted that on license renewal drawing LR-302-162, at location G-1, a vacuum degasifier tank is highlighted in red, indicating that it is within the scope of license renewal for 10 CFR 54.4 (a)(2) according to Note 1 on drawing LR-302-003. This component type "tank" would have a leakage boundary function.

Issue:

LRA Table 2.3.3-25, Water Treatment & Distribution System, Components Subject to Aging Management Review, includes "tank" as a component type and itemizes which tanks are included; however, the table does not show "tank (vacuum degasifier)" as a component subject to an AMR.

Request:

Justify the exclusion of "tank (vacuum degasifier)" from LRA Table 2.3.3-25.

AmerGen Response The drawing is correct. The vacuum degasifier tank is in scope for leakage boundary. This tank was omitted from LRA Table 2.3.3-25 Water Treatment & Distribution System Components Subject to Aging Management Review and LRA Table 3.3.2-25 Water Treatment & Distribution System Summary of Aging Management Evaluation.

As also indicated on drawing LR-302-162, the degasifier booster pumps are in scope for leakage boundary. The degasifier booster pumps were also omitted from LRA Tables 2.3.3-25 and 3.3.2-25.

LRA Table 2.3.3-25 should have included the following component types and their intended functions:

Table 2.3.3-25 Water Treatment & Distribution System Components Subject to Aging Management Review Component Type Intended Functions Pump Casing(DegasifierBooster Pumps) Leakage Boundary Tanks (Vacuum DegasifierTank) Leakage Boundary LRA Table 3.3.2-25 should have included the following:

September 16, 2008 Page 41 of 44 5928-08-20196 Enclosure A Table 3.3.2-25 Water Treatment & Distribution System Summary of Aging Management Evaluation Component Type Intended Material Environment Aging Effect Aging NUREG- Table 1 Notes Function Requiring Management 1801 Vol. 2 Item Management Programs Item Pump Casing Leakage Ductile Cast Air - Indoor Loss of External VII.D-3 3.3.1-57 B (DegasifierBooster Boundary Iron (External) Material/General Surfaces Pumps) Corrosion Monitoring (B.2.1.21)

Pump Casing Leakage Ductile Cast Raw Water Loss of Inspection of VI1.C1-19 3.3.1-76 E, 1 (DegasifierBooster Boundary Iron (Internal) Material/General, Internal Pumps) Pitting,Crevice, Surfaces in and Miscellaneous Microbiologically Piping and Influenced Ducting Corrosion,and Components Fouling (B.2.1.22)

Tanks (Vacuum Leakage Carbon Air- Indoor Loss of External VII.D-3 3.3.1-57 B DegasifierTank) Boundary Steel (External) Material/General Surfaces Corrosion Monitoring (B.2.1.21)

Tanks (Vacuum Leakage Carbon Raw Water Loss of Inspection of VII.C1-19 3.3.1-76 E, I DegasifierTank) Boundary Steel (Internal) Material/General, Internal Pitting,Crevice, Surfaces in and Miscellaneous Microbiologically Piping and Influenced Ducting Corrosion,and Components Fouling (B.2.1.22)

September 16, 2008 Page 42 of 44 5928-08-20196 Enclosure A RAI # 2.3.4.4-1

Background:

LRA Section 2.3.4.4, Extraction Steam System, states that the extraction steam system meets 10 CFR 54.4(a)(1) because it is a system that is relied upon to remain functional during and following design basis events.

Issue:

The staff could not identify the 10 CFR 54.4(a)(1) functions provided by the extraction steam system in order to verify the applicant did not omit any components.

Request:

Provide the functions that support the 10 CFR 54.4(a)(1) designation provided by the extraction steam system and identify the components that perform these functions.

AmerGen Response The extraction steam system performs no 10 CFR 54.4(a)(1) intended functions. LRA Section 2.3.4.4, Reason for Scope Determination, incorrectly stated that extraction steam system meets 10 CFR 54.4(a)(1). The extraction steam system is in scope for license renewal because it meets 10CFR 54.4(a)(2).

LRA Section 2.3.4.4, "Reason for Scope Determination" should have read as follows:

The Extraction Steam System is not in scope under 10 CFR 54.4(a)(1) because no portions of the system are safety-related and relied upon to remain functional during and following design basis events. It meets 10 CFR 54.4(a)(2) because failure of nonsafety-related portions of the system could prevent satisfactory accomplishment of function(s) identified for 10 CFR 54.4(a)(1). The Extraction Steam System is not in scope under 10 CFR 54.4(a)(3) because it is not relied upon in safety analyses or plant evaluations to perform a function that demonstrates compliance with the Commission's regulations for Fire Protection (10 CFR 50.48), Environmental Qualification (10 CFR 50.49),

Pressurized Thermal Shock (10 CFR 50.61), Anticipated Transient Without Scram (10 CFR 50.62), and Station Blackout (10 CFR 50.63).

September 16, 2008 Page 43 of 44 5928-08-20196 Enclosure A RAI # 2.3.4.8-1

Background:

On license renewal drawing LR-302-141, at location G-5, a turbine gland seal atmospheric drain tank is highlighted in red, indicating that it is within the scope of license renewal under 10 CFR 54.4 (a)(2) according to Note 1 on drawing LR-302-003. Typically, this component type "tank" has a leakage boundary function.

Issue:

LRA Table 2.3.4-8, Steam Turbine and Auxiliary Systems, Components Subject to Aging Management Review, includes "tank" as a component type and itemizes which tanks are included. However, the table does not show "tank (turbine gland seal)" as a component subject to an AMR.

Request:

Justify the exclusion of the turbine gland seal atmospheric drain tank from LRA Table 2.3.4-8.

AmerGen Response The Turbine Gland Seal Atmospheric Drain Tank, GS-T-1, is a nonsafety-related tank within the scope of license renewal. It has a leakage boundary function and is subject to aging management review. This tank is part of the Condensate System and should have been

-included in LRA Tables 2.3.4-1 and 3.4.2-1 as shown below.

Boundary flags on drawings LR-302-141 and LR-302-172 incorrectly indicate that the turbine gland seal atmospheric drain tank and associated piping is part of the Steam Turbine &

Auxiliaries System (STA). These flags should have been removed from the drawings. They are located at valves GS-V-14 (LR-302-141, G-5) and CO-V-60 (LR-302-172, D-4). Additionally, on drawing LR-302-141 at G-4, the STA flag should have been replaced by a Condensate System (CO) flag.

Table 2.3.4-1 Condensate System Components Subject to Aging Management Review Component Type Intended Functions Tanks (Condensate Seal Water Head Tank, Leakage Boundary MiscellaneousDrains Collection Tank, Turbine Gland Seal Atmospheric Drain Tank)

Table 3.4.2-1, as shown below, should have included the name and function of the Turbine Gland Seal Atmospheric Drain Tank as follows:

September 16, 2008 Page 44 of 44 5928-08-20196 Enclosure A Table 3.4.2-1 Condensate System Aging Effect Aging NUREG- Table I Component Type Intended Function Material Environment Requiring Management 1801 Vol. Item Notes Management Programs 2 Item Tanks (Condensate Seal Water Head Tank, Loss of External Miscellaneous Drains Leakage Boundary Carbon Steel Material/General Surfaces VIII.H-7 3.4.1-28 B Collection Tank, Turbine (External) Corrosion Monitoring Gland Seal Atmospheric (B.2.1.21)

Drain Tank)

Tanks (Condensate Seal Loss of Water Head Tank, Material/General, One-Time Miscellaneous Drains Treated Water Mtra/eea, OeTm Collection Tank, Turbine Leakage Boundary Carbon Steel (Internal) Pitting and Inspection VIII.E-40 3.4.1-6 B Coletin an, urin (ntrnl)Crevice (B.2.1.18)

Gland Seal Atmospheric Corrosion Drain Tank)

Tanks (Condensate Seal Loss of Water Head Tank, Material/General, Water Miscellaneous Drains Treated Water MaeilGnr, Wtr Collection Tank, Turbine Leakage Boundary Carbon Steel (Internal) Pitting and Chemistry VIII.E-40 3.4.1-6 A Coletin an, urin (ntrnl)Crevice (B.2.1.2)

Gland Seal Atmospheric Corrosion Drain Tank)