ML091180470

Response to Request for Additional Information Regarding the Review of the License Renewal Application-Balance of Plant Scoping and Screening

ML091180470
Person / Time
Site:	Kewaunee
Issue date:	04/27/2009
From:	Hartz L Dominion Energy Kewaunee
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
09-231, FOIA/PA-2010-0209
Download: ML091180470 (52)

Text

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i )orninion Energy Kewaunee, Inc.

'If'l! [)ominion Boulevard. elen Allen. VA.' \<1,. -' Dominion' April 27, 2009 United States Nuclear Regulatory Commission Serial No.: 09-231 Attention: Document Control Desk LR/MWH RO Washington, DC 20555-0001 Docket No.: 50-305 License No.: DPR-43 DOMINION ENERGY KEWAUNEE, INC.

KEWAUNEE POWER STATION RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING THE REVIEW OF THE KEWAUNEE POWER STATION LICENSE RENEWAL APPLICATION -

BALANCE OF PLANT SCOPING AND SCREENING By letter dated April 3, 2009 (Reference 1), the NRC requested additional information regarding the license renewal application (LRA) for Kewaunee Power Station. Specifically, Reference 1 requested additional information regarding the balance of plant scoping and screening. The attachment to this letter contains responses to this request for additional information.

Should you have any questions regarding this submittal, please contact Mr. Paul C. Aitken at (804) 273-2818.

Very truly yours,

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Leslie N. HartV Vice President - Nuclear Support Services COMMONWEALTH OF VIRGINIA COUNTY OF HENRICO The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by Leslie N. Hartz, who is Vice President - Nuclear Support Services of Dominion Energy Kewaunee, Inc.

She has affirmed before me that she is duly authorized to execute and file the foregoing document in behalf of that Company, and that the statements in the document are true to the best of her knowledge and belief.

Acknowledged before me this c2~~ay of ~'(i \ ,2009.

My Commission Expires: -1:\3Jl\:::,

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Serial No.09-231 Docket No. 50-305 Response to Request for Additional Information Page 2 of 3

Reference:

1. Letter from Samuel Hernandez (NRC) to David A. Christian (DEK), "Request for Additional Information for the Review of the Kewaunee Power Station License Renewal Application - Balance of Plant Scoping and Screening (TAC No. MD9408),"

dated April 3, 2009. [ADAMS Accession No. ML090760786]

Attachments:

1. Responses to the Requests for Additional Information Regarding Balance of Plant Scoping and Screening Commitments made in this letter:

None.

Serial No.09-231 Docket No. 50-305 Response to Request for Additional Information Page 3 of 3 cc:

U.S. Nuclear Regulatory Commission Regional Administrator, Region III 2443 Warrenville Road Suite 210 Lisle, IL 60532-4532 Mr. P. S. Tam, Senior Project Manager U.S. Nuclear Regulatory Commission One White Flint, Mail Stop 08-H4A 11555 Rockville Pike Rockville, MD 20852-2738 Ms. S. L. Lopas Environmental Project Manager U.S. Nuclear Regulatory Commission Mail Stop 0-11 F1 Washington, DC 20555-0001 Mr. Q. S. Hernandez License Renewal Project Manager U.S. Nuclear Regulatory Commission Mail Stop 0-11 F1 Washington, DC 20555-0001 NRC Senior Resident Inspector Kewaunee Power Station N490 Highway 42 Kewaunee, WI 54216 Public Service Commission of Wisconsin Electric Division P.O. Box 7854 Madison, WI 53707 Mr. David Zellner Chairman - Town of Carlton N2164 County B Kewaunee, WI 54216

Serial No.09-231 Docket No. 50-305 ATTACHMENT 1 RESPONSES TO THE REQUESTS FOR ADDITIONAL INFORMATION REGARDING BALANCE OF PLANT SCOPING AND SCREENING KEWAUNEE POWER STATION DOMINION ENERGY KEWAUNEE, INC.

Serial No.09-231 Attachment 1 Page 1 of 48 RAI2.2-01

Background:

LRA Section 2.4.2.2, "Administration Building," description states in part: "The Administration Building is a multistory structure that interfaces with the Turbine Building. The basement of the Administration Building is classified as Class I. ..

The remaining areas are Class 111..."

UFSAR Section 9.6.3, "Auxiliary Building Ventilation Systems," Subsection 9.6.3.2 states in part: "The Administration Building is equipped with a multizone-type air conditioning system, arranged to receive outside air for makeup, to recirculate conditioned air, and to exhaust air to the Turbine Building and/or directly to atmosphere."

Issue:

LRA Table 2.2-2, "Systems Not Within the Scope of License Renewal," includes the "Administration Building Air Conditioning" system.

Request:

Provide the reasoning for not including the administration building air conditioning system, which is inside a Class I and Class III structure, in Table 2.2-1, "Systems Within the Scope of License Renewal."

Dominion Response The Administration Building is a multistory structure that interfaces with the Turbine Building. The Administration Building basement is Class I because it houses safety-related components. The two upper levels of the Adminstration Building are Class III and are comprised of office areas. The Administration Building Air Conditioning System provides conditioned air for the Administration Building office areas (i.e., the two upper levels) that are Class III. The Administration Building Air Conditioning System does not provide cooling to the Class I portion of the Administration Building and is not located within the Class I areas of the building. Therefore, the system does not perform a license renewal intended function and has not been included in the scope of license renewal.

Ventilation for the Administration Building basement is provided by the Turbine Building and Screenhouse Ventilation System, which is within the scope of license renewal and is included in LRA Table 2.2-1, "Systems Within the Scope of License Renewal."

Serial No.09-231 Attachment 1 Page 2 of 48 RAI2.3-01

Background:

Section 54.21 (a)(1) of 10 CFR requires applicants to identify and list all components subject to an aging management review (AMR). The staff confirms inclusion of all components subject to AMR by reviewing the component types within the license renewal boundary.

Issue:

During the scoping and screening review process the continuation from one drawing to another could not be established. Drawing numbers and/or locations for the continuations were not identified, or could not be located where identified.

In some cases drawings were not provided.

Request:

Provide additional information to locate the license renewal boundaries.

LRA Section Continuation Location Dominion Response 2.3.3.3 Drawing LRM-209-2, location B- The 2-inch line downstream of check 1, shows a 2" line downstream of valve MU1 008 shown on drawing LRM-check valve MU 1008 in scope in 209-2, at location B-1, continues on accordance with 10CFR drawing LRM-218 at location A-10.

54.4(a)(2). The continuation to the license renewal boundary on drawing LRM-208 at location A-10 could not be located. It appears that the correct location should be drawing LRM-218, location A-1 O.

2.3.3.6 Drawing LRM-202-1, location F- The line at valve SW-28B2 shown on 2, downstream of valve SW- drawing LRM-202-1 , at location F-2, 28B2. continues on drawing LRM-1274 at location A-7.

Drawing LRM-202-1, location F- The line at valve SW-28B1 shown on 4, downstream of valve SW- drawing LRM-202-1 , at location F-4, 28B1. continues on drawing LRM-1274 at location A-7.

Drawing LRM-202-1 , location F- The line at valve SW-28A2 shown on 6, downstream of valve SW- drawing LRM-202-1 , at location F-6, 28A2. continues on drawing LRM-1274 at location A-3.

Serial No.09-231 Attachment 1 Page 3 of 48 LRA Section Continuation Location Dominion Response Drawing LRM-202-1, location F- The line at valve SW-28A1 shown on 8, downstream of valve SW- drawing LRM-202-1 , at location F-8, 28A1. continues on drawing LRM-1274 at location A-3.

Drawing LRM-202-3, location C- The two %-inch lines downstream of 9, two %" lines downstream of valves SW-2010A and SW-2010B valves SW201 OA and SW20108. shown on drawing LRM-202-3, at location C-9, are drain lines from the Electro Hydraulic Control System Oil Coolers. These lines do not continue to another license renewal drawing. The drain lines are within the scope of license renewal for 10 CFR 54.4(a)(2) up to the point where they terminate at a floor drain.

2.3.3.7 Drawing LRXK-1 00-131 , location Additional details of the waste F-7, component cooling water evaporator package are shown on line coming into the waste drawing LRXK-100-829, including evaporator. component cooling water lines. The component cooling water lines to the waste evaporator are also shown on drawing LRXK-100-20 at locations F-1 and F-2.

Drawing LRXK-1 00-131, location Additional details of the waste F-7, component cooling water evaporator package are shown on line going out of the waste drawing LRXK-100-829, including evaporator. component cooling water lines. The component cooling water lines to the waste evaporator are also shown on drawing LRXK-100-20 at locations F-1 and F-2.

2.3.3.8 Drawing LRM-213-4, location H- The instrument air line to the Generator 7, shows a continuation "TO Hydrogen Panel is not continued on GENERATOR HYDROGEN another license renewal drawing, but is PANEL" as in scope for 10 CFR within the scope of license renewal for 54.4(a)(2). 10 CFR 54.4(a)(2) up to the point where it attaches to the panel.

Drawing LRM-213-4, location E- The instrument air line to the Hydrogen 7, shows a continuation "TO Gas Dryer is not continued on another HYDROGEN GAS DRYER" as in license renewal drawing, but is within scope for 10 CFR 54.4(a)(2). the scope of license renewal for 10 CFR 54.4(a)(2) up to the point where it attaches to the dryer.

Serial No.09-231 Attachment 1 Page 4 0 f 48 LRA Section Continuation Location Dominion Response Drawing LRM-213-4, location C- The instrument air line to the Turning 5, shows a continuation "TO Gear is not continued on another TURNING GEAR" as in scope for license renewal drawing, but is within 10 CFR 54.4(a)(2). the scope of license renewal for 10 CFR 54.4(a)(2) up to the point where it attaches to the turning gear.

Drawing LRM-213-5, location B- The instrument air line is not continued 7, shows a continuation "TO on another license renewal drawing, CONTAINMENT AIRLOCK." but is within the scope of license renewal for 10 CFR 54.4(a)(2) up to the point where it attaches to the terminal component.

Drawing LRM-213-5, location F- The instrument air lines shown on 2, shows a continuation "HRSR drawing LRM-213-5, at location F-2, TO SAMPLE ROOM EQUIP." are continued on drawing LRXK-100-44 at locations G-1 0, F-8, and H-6.

These lines were incorrectly not highlighted on drawing LRXK-100-44, but are within the scope of license renewal for 10 CFR 54.4(a)(2) and are included in the component type "Tubing" in LRA Table 2.3.3-8, "Station and Instrument Air."

Drawing LRM-213-5, location F- The instrument air lines to the 5, shows a continuation "TO Radwaste Drumming Station are not RADWASTE DRUMMING continued on another license renewal STATION." drawing, but are within the scope of license renewal for 10 CFR 54.4(a)(2) up to the point where they attach to the radwaste drumming station equipment.

Drawing LRM-213-6, location F- The instrument air line to the Chemical 2, shows a continuation "TO HOT Lab Fume Hood is not continued on CHEM LAB FUME HOOD." another license renewal drawing, but is within the scope of license renewal for 10 CFR 54.4(a)(2) up to the point where it attaches to the fume hood.

Drawing LRM-213-7, location C- The instrument air line to the Caustic 5, shows a continuation "TO Control Station is not continued on CAUSTIC CONTROL STATION." another license renewal drawing, but is within the scope of license renewal for 10 CFR 54.4(a)(2) up to the point where it attaches to the control station.

Serial No.09-231 Attachment 1 Page 5 0 f 48 I LRA Section Continuation Location Dominion Response Drawing LRM-213-7, location B- The instrument air lines to the Water 9, shows a continuation 'TO Treatment Controls are not continued WATER TREATMENT on another license renewal drawing, CONTROLS." but are within the scope of license renewal for 10 CFR 54.4(a)(2) up to the point where they attach to the water treatment controls.

Drawing LRM-213-8, location A- The instrument air line to the Gripper is 8, shows a continuation "TO not continued on another license GRIPPER." renewal drawing, but is within the scope of license renewal for 10 CFR 54.4(a)(3) up to the point where it attaches to the gripper.

Drawing LRM-213-8, location D- The instrument air line to the A S/G 8, shows a continuation "TO A Nozzle Dam Control Panel is not S/G NOZZLE DAM CONTROL continued on another license renewal PANEL." drawing, but is within the scope of license renewal for 10 CFR 54.4(a)(3) up to the point where the portable panel can be connected.

Drawing LRM-213-8, location E- The instrument air line to the B S/G 6, shows a continuation "TO B Nozzle Dam Control Panel is not S/G NOZZLE DAM CONTROL continued on another license renewal PANEL." drawing, but is within the scope of license renewal for 10 CFR 54.4(a)(3) up to the point where the portable panel can be connected.

2.3.3.19 Drawing LRM-220, location C-8, The 1Y2-inch drain line is not continued shows a continuation "1 %" Drain on another license renewal drawing, To Waste (typ)." but is within the scope of license renewal for 10 CFR 54.4(a)(1) up to the point where it terminates at a floor trench.

Serial No.09-231 Attachment 1 I----..,--------------~------------'--'-'--'-------,

Paqe 6 of 48 LRA Section Continuation Location Dominion Response 2.3.3.22 Drawing LRXK-1 00-131, location The continuation of these reactor C-2, show a 3" line from reactor coolant pump #3 seal leakoff lines are coolant pump #3 seal leakoffs as shown on drawing LRXK-100-35 at within scope for license renewal locations E-5 and E-7.

per 10 CFR 54.4(a)(2).

The two leakoff lines shown on drawing LRXK-1 00-131, at location C-2, were incorrectly not highlighted, but are within the scope of license renewal for 10 CFR 54.4(a)(2) and are included in the component type "Pipe" in LRA Table 2.3.3-22, "Liquid Waste Processing and Discharge."

Drawing LRXK-100-400, location The 1%-inch line to the waste holdup H-9, shows a 1%" line "TO tank via the sump tank continues on WASTE HOLDUP TANK VIA drawing LRM-350 at location G-8.

SUMP TANK" within scope for license renewal in accordance with 10 CFR 54.4(a)(2).

Drawing LRM-217, locations E-8 The two lines from containment spray and G-8, shows two %" lines from pumps 1A and 1B mechanical seals to containment spray pumps 1A and waste continue on drawing LRM-539 at 1B mechanical seals to waste as location H-3.

within scope for license renewal in accordance with 10 CFR 54.4(a)(2).

2.3.3.24 Drawing LRXK-1 00-36, location The origination of the line shown on A-12, shows a line coming in drawing LRXK-100-36, at location A-from LRM-209-2, location A-1 0, 12, is the hose connection downstream in scope for license renewal for of valve DW-240 shown on drawing 10 CFR 54.4(a)(2). The location LRM-209-2, at location A-10, which of this line on the drawing LRM- provides demineralized water to the 209-2 could not be located. resin fill tank.

Drawing LRM-209-2, location B- Drawing LRM-209-2, at location B-1, 1, shows a 2" line going to LRM- incorrectly referenced LRM-208, at 208, location A-1 0, in scope for location A-1 0, for the continuation of license renewal for 10 CFR the 2-inch line. The 2-inch line to the 54.4(a)(2). The location of this spent fuel pool shown on drawing line on drawing LRM-208 could LRM-209-2 continues on drawing LRM-not be located. 218 at location A-10.

Serial No.09-231 Attachment 1 Paqe 7 0 f 48 LRA Section Continuation Location Dominion Response Drawing LRM-209-2, location B- The 2-inch line to the new chemistry 5, downstream of valve DW51 00- lab is not continued on another license 33 "TO NEW CHEM LAB." (Note: renewal drawing, but is within the valve number provided but the scope of license renewal for 10 CFR valve is not shown on drawing.) 54.4(a)(2) up to the point where it exits the Turbine Building. Valve DW51 00-33 was incorrectly omitted from drawing LRM-209-2, at location B-5, but is within the scope of license renewal for 10 CFR 54.4 (a)(2) and is included in the component type "Valves" in LRA Table 2.3.3-24, "Makeup and Demineralized Water".

Drawing LRM-209-2, location B- The %-inch line to the instrument lab 7, downstream of valve DW128 sink is not continued on another "TO INSTRU. LAB. SINK." license renewal drawing, but is with the scope of license renewal for 10 CFR 54.4 (a)(2) up to the point where it attaches to the sink.

Drawing LRM-209-2, location A- The %-inch line to sample room 7, downstream of valve OW 123 equipment is not continued on another "TO SAMPLE ROOM EQUIP." license renewal drawing, but is within the scope of license renewal for 10 CFR 54.4 (a)(2) up to the point where it attaches to the equipment.

Drawing LRM-209-2, location A- The %-inch line to hot chemical lab 7, downstream of valve OW 125 equipment is not continued on another "TO HOT CHEM. LAB. EQUIP." license renewal drawing, but is within the scope of license renewal for 10 CFR 54.4 (a)(2) up to the point where it attaches to the equipment.

Drawing LRM-209-2, location A- The 3,4-inch line to fume hood in the hot 7, downstream of valve OW 126 chemical lab is not continued on "TO FUME HOOD IN HOT. another license renewal drawing, but is CHEM. LAB." within the scope of license renewal for 10 CFR 54.4(a)(2) up to the point where it attaches to the fume hood.

Drawing LRM-209-2, location A- The %-inch line to the hot instrument 7, downstream of valve OW 127 lab sink is not continued on another "TO HOT INSTRU. LAB. SINK." license renewal drawing, but is within the scope of license renewal for 10 CFR 54.4(a)(2) up to the point where it attaches to the sink.

Serial No.09-231 Attachment 1 Page 8 0 f 48 LRA Section Continuation Location Dominion Response Drawing LRM-209-2, location E- The %-inch line to the waste 11 , downstream of valve DW280 evaporator concentrates pump sample "TO WASTE EVAP. CONC. trough is not continued on another PUMP SAMPLE TROUGH." license renewal drawing, but is within the scope of license renewal for 10 CFR 54.4(a)(2) up to the point where it empties into the trough.

2.3.3.26 Drawing LRM-350, location G-9, As shown in Detail "A" of drawing LRM-shows continuation of a 2" line 350 at location A-11, the 2-inch line downstream of relief valve WG- downstream of relief valve WG-305A 305A off of Deaerated Drain continues on drawing LRXK-1 00-132 at Tanks "TO WASTE GAS COMPo location C-1 .

PKGS."

I Drawing LRM-539, location C-2, The 2-inch line down/up stream of shows 2" line, down/up stream of valve WG-320A on drawing LRM-539, valve WG-320A, as in scope for at location C-2, continues as shown license renewal for 10 CFR through the Reactor Building Shield 54.21 (a)(1). However this 2" line Wall and is open-ended between the continues into the reactor Reactor Containment Vessel and the building wall and a continuation Shield Wall.

was not provided.

Drawing LRM-202-2, location F- The 6-inch roof drain line to the gage 1, 6" roof drain coming in to gage glass is not continued on another glass. license renewal drawing, but is within the scope of license renewal for 10 CFR 54.4(a)(2) up to the point where it penetrates the roof.

Drawing LRM-202-2, location G- The 1-inch drain line to the Turbine 3, 1" DRAIN DOWNSTREAM OF Building sump is not continued on SW(R20)-5 "TO DRAINS (TURB. another license renewal drawing, but is BKDG. SUMP)." within the scope of license renewal for 10 CFR 54.4(a)(2) up to the point where it terminates at the floor drain.

Drawing LRM-211, location H-1, The two lines for "Miscellaneous Floor "MISC. FLOOR DRAINS" coming Drains" do not continue to another in to turbine building sump. drawing. These lines indicate general floor drains to the sump that are embedded in the Turbine Building basement concrete floor. These two miscellaneous floor drain lines were incorrectly identified as within the scope of license renewal for 10 CFR 54.4(a)(2) and should not have been highlighted on the drawing.

Serial No.09-231 Attachment 1 P aqe 9 0 f 48 I

i LRA

! Section Continuation Location Dominion Response I Drawing LRM-219, location H-9, The 2-inch drain line to the Turbine "2" DRAIN TO TURBINE BLDG Building sump is not continued on SUMP." another license renewal drawing, but is within the scope of license renewal for 10 CFR 54.4(a)(2) up to the point where it penetrates the Turbine Building basement floor.

Drawing LRM-539, location 0-9, The 3-inch line downstream of relief 3" line downstream of relief valve valve WG-305B is not continued on WG-305B "TO WASTE." another license renewal drawing, but is within the scope of license renewal for 10 CFR 54.4(a)(2) up to where it ends, about 6-inches off the floor.

Drawing LRM-539, locations G-4 The charging pump leak-off lines are and G-5, lines coming in from not continued on another license "CHARGING PUMPS 1A, 1B & renewal drawing, but are within the 1C STUFFING BOX LEAK- scope of license renewal for 10 CFR OFFS." 54.4(a)(2) up to the point where they attach to the pumps.

Drawing LRM-539, locations H-5 The safety injection pump leak-off lines and H-6, lines coming in from shown on drawing LRM-539, at "SAFETY INJECTION PUMPS locations H-5 and H-6, were incorrectly 1A, & 1B SEAL LEAKOFFS." not highlighted, but are within the scope of license renewal for 10 CFR 54.4(a)(2) and are included in the component type "Pipe" in LRA Table 2.3.3-26, "Miscellaneous Drains and Sumps." These lines are not continued on another license renewal drawing, but are within the scope of license renewal for 10 CFR 54.4(a)(2) up to the point where they attach to the pumps.

Drawing LRM-539, location H-3, The containment spray leak-off lines lines coming in from shown on drawing LRM-539, at "CONTAINMENT SPRAY 1A, & location H-3, were incorrectly not 1B SHAFT SEAL LEAKOFFS." highlighted, but are within the scope of license renewal for 10 CFR 54.4(a)(2) and are included in the component type "Pipe" in LRA Table 2.3.3-26, "Miscellaneous Drains and Sumps."

The leak-off lines continue on drawing LRM-217 at locations E-8 and G-8.

Serial No.09-231 Attachment 1 Page 10 of 48 LRA Section Continuation Location Dominion Response Drawing LRM-539, location H-4, The 1-inch line downstream of control 1" line downstream of control valve MD(R) 280A is not continued on valve MD(R) 280A "TO WASTE." another license renewal drawing, but is within the scope of license renewal for 10 CFR 54.4(a)(2) up to the point where it penetrates the basement floor in the charging pump room.

2.3.3.27 Drawing LRXK-1 00-37, locations The three lines to the plant vent shown B-1, B-3, and B-4, show lines to on drawing LRXK-1 00-37, at locations the plant vent within scope for 10 B-1, B-3, and B-4, combine into a CFR 54.4(a)(1). The continuation single 2-inch line that continues on to the LRA boundary could not be drawing LRM-601 at location F-9.

located. However, a flanged connection was incorrectly shown on drawing LRM-601, at location F-9, instead of the incoming 2-inch line continuation.

2.3.4.1 Drawing LRM-202-3, location 0- As indicated in LR Note 17 on drawing 4, shows a continuation of a pipe LRM-202-3, the pipe downstream of section (SW-31 00) in scope for valve SW-31 00 is within the scope of 10 CFR 54(a)(2) belonging to the license renewal up to the point where it service water system to drawing enters the Auxiliary Building at the OPERM-209-5, location A-1. mezzanine level south end where there Drawing OPERM-209-5 was not are no safety-related components submitted as a part of the LRA. located. The in-scope portion of the pipe is not continued on another license renewal drawing.

Drawing LRM-206, location A-9, The 2Y2-inch line upstream of valve shows a continuation of in scope MS-310 continues on drawing LRXK-2%" 10 CFR 54.4(a)(2) pipe 101-17 at location F-4.

(without identification number)

"FROM TURBINE GLAND STEAM HDR."

Serial No.09-231 Attachment 1 Page 11 0 f 48 LRA Section Continuation Location Dominion Response Drawing LRXK-101-24-1, The oil drain lines shown on drawing locations D-9, F-9, F-10, H-9, and LRXK-1 01-24-1, at locations D-9, F-9, H-10 show continuations of in F-10 and H-10, are not continued on scope 10 CFR 54.4(a)(2) pipe another license renewal drawing. The lines. drain line at location D-9 is within the scope of license renewal for 10 CFR 54.4 (a)(2) to the point where it empties into the governor pedestal catch basin.

The drain lines at locations F-9 and F-10 are within the scope of license renewal for 10 CFR 54.4 (a)(2) to the point where they empty into the turbine pedestal catch basin. The drain line at location H-10 is within the scope of license renewal for 10 CFR 54.4 (a)(2) to the end of the pipe which opens to the room atmosphere.

Drawing LRXK-1 01-24-2, location The drain return line shown on drawing F-9, shows continuation of in LRXK-1 01-24-2, at location F-9, is a scope 10 CFR 54.4(a)(2) pipe common Electro Hydraulic (EH) line from "DRAIN RETURN." System drain return line. The EH System drains are shown on drawing LRXK-101-24-1 at locations C-1 , C-4, E-1, E-4 and F-5, as indicated by the EH System drain symbol, which is provided in the drawing legend.

Drawing LRXK-1 01-24-1, location The oil to generator bearings line is not H-10, shows continuation of in continued on another license renewal scope 10 CFR 54.4(a)(2) pipe drawing, but is within the scope of line to "OIL TO GEN BRGS." license renewal for 1a CFR 54.4(a)(2) up to the point where it attaches to the generator.

Drawing LRXK-1 01-24-1, location The high pressure seal oil back up line H-10, shows continuation of in shown on drawing LRXK-1 01-24-1, at scope 10 CFR 54.4(a)(2) pipe location H-10, continues on drawing line to "HP SEAL OIL BACK UP." LRXK-1 01-64 at location E-8.

2.3.4.2 Drawing LRM-211, location C-12, The piping shown on drawing LRM-shows continuation of a 10 CFR 211, at location C-12, continues on 54.4(a)(1) pipe "10" EXHAUST drawing LRM-203 at location H-3.

STM FROM TURB DRIVEN AUX F. W. STEAM RING DRAIN."

Serial No.09-231 Attachment 1 P aQe 12 0 f 48

!I LRA I

I Section Continuation Location Dominion Response Drawing LRM-211 locations B-4 Drawing LRM-211, locations B-4 through B-6, C-4 through C-6, through B-6, shows the turbine slop and A-6 show continuations of 10 drains piping. The slop drain piping is CFR 54.4(a)(2) pipe sections also shown on drawing LRXK-101-17 from drawings X-K101-17 and X- at locations B-2, B-5, B-6 and B-9.

K1 01-17A, respectively, without These lines are located inside the grid locations. turbine exhaust casing/condenser neck and their failure could not affect safety-related SSCs. Therefore, these lines are not within the scope of license renewal and were incorrectly highlighted on drawing LRM-211.

Drawing LRM-211, location C-4 through C-6, shows the turbine gland steam supply lines and strainers.

These lines are continued on drawing LRXK-101-17 at locations 0-2,0-5,0-6, and 0-9 and on drawing LRXK-101-16 at locations 0-1 and 0-5.

Drawing LRM-211, location A-6, shows the Turbine Connection 38. This connection is also shown on drawing LRXK-101-17A at locations F-3.

Serial No.09-231 Attachment 1 Page 13 0 f 48 LRA Section Continuation Location Dominion Response Review of drawings X-K101-17 The following provides additional and X-K101-17A could not locate continuations to/from drawings LRXK-the continuations to drawing 101-17 and LRXK-101-17A.

LRM-211. Also, note at location A-6 refers to drawing X-K101- Drawing LRXK-101-17, location E-7, 174. Drawing X-K101-174 was line downstream of MS-322 continues not submitted with the LRA. on drawing LRM-207 at location H-8.

Drawing LRXK-101-17, location E-7, line upstream of MS-301 continues on drawing LRM-203 at location A-g.

Drawing LRXK-101-17, locations C-1 and C-11 , exhaust hood spray lines continue on LRM-204 at locations C-4 and C-8, respectively.

The reference to drawing XK-101-174 on Drawing LRM-211 , location A-6, is a typographical error and the referenced drawing should have been XK-101-17A. The corresponding license renewal drawing is LRXK-101-17A.

Drawing LRM-211, location A-7, Drawing X-K1 01-15 is not a license shows continuation of 10 CFR renewal drawing. This piping on 54.5(a)(2) pipe sections drawing LRM-211 at location A-7 is not "TURBINE CONNECTION 28" continued on a license renewal from drawing X-K101-15. drawing, but is within the scope of license renewal for 10 CFR 54.4(a)(2) up to the point where it connects to the turbine.

Drawing LRM-211, locations B-6 The drain lines shown on drawing and B-7, show continuations of LRM-211, locations B-6 and B-7, 10 CFR 54.4(a)(2) pipe sections continue on drawing LRXK-101-17A at "DRAINS FROM CYLINDER locations C-3 and C-7.

HEATING STEAM SUPPLY SYSTEM."

Drawing LRM-212, locations C- The "GLAND STEAM SUPPLY" line 11 through C-12, show shown on drawing LRM-212, location continuation of 10 CFR 54.4(a)(2) C-11 through C-12, is continued on "GLAND STEAM SUPPLY" pipe. drawing LRXK-1 01-17, location E-12.

Serial No.09-231 Attachment 1 PaQe 14 0 f 48 I

LRA Section Continuation Location Dominion Response 2.3.4.3 Drawing LRM-206, location E-3, The 1Y2-inch drain line is not continued "1 W' DRAIN TO TURBINE RM. on another license renewal drawing, SUMP" downstream of 14" but is within the scope of license piping. renewal for 10 CFR 54.4(a)(2) up to the point where it enters a Turbine Building floor drain funnel.

Drawing LRM-206, location E-3, The 1Y2-inch drain line is not continued "1W' DRAIN TO TURBINE RM. on another license renewal drawing, SUMP" downstream of 10" but is within the scope of license piping. renewal for 10 CFR 54.4(a)(2) up to the point where it enters a Turbine Building floor drain funnel.

Drawing LRM-206, location B-1, The 2-inch drain line is not continued "2" DRAIN TO TURBINE BLDG on another license renewal drawing, SUMP" downstream of valve but is within the scope of license HRS100B3. renewal for 10 CFR 54.4(a)(2) up to the point where it enters a Turbine Building floor drain funnel.

Drawing LRM-206, location B-1, The 2-inch drain line is not continued "2" DRAIN TO TURBINE BLDG on another license renewal drawing, SUMP" downstream of valve but is within the scope of license HRS100B2. renewal for 10 CFR 54.4(a)(2) up to the point where it enters a Turbine Building floor drain funnel.

Drawing LRM-206, location B-1, The 2-inch drain line is not continued "2" DRAIN TO TURBINE BLDG on another license renewal drawing, SUMP" downstream of valve but is within the scope of license HRS100B1. renewal for 10 CFR 54.4(a)(2) up to the point where it enters a Turbine Building floor drain funnel.

Drawing LRM-206, location B-1, The 2-inch drain line is not continued "2" DRAIN TO TURBINE BLDG on another license renewal drawing, SUMP" downstream of valve but is within the scope of license HRS100A1. renewal for 10 CFR 54.4(a)(2) up to the point where it enters a Turbine Building floor drain funnel.

Drawing LRM-206, location B-1, The 2-inch drain line is not continued "2" DRAIN TO TURBINE BLDG on another license renewal drawing, SUMP" downstream of valve but is within the scope of license HRS100A2. renewal for 10 CFR 54.4(a)(2) up to the point where it enters a Turbine Building floor drain funnel.

Serial No.09-231 Attachment 1 Page 15 0 f 48 II LRA Section Continuation Location Dominion Response Drawing LRM-206, location B-1, The 2-inch drain line is not continued "2" DRAIN TO TURBINE BLDG on another license renewal drawing, SUMP" downstream of valve but is within the scope of license HRS100A3. renewal for 10 CFR 54.4(a)(2) up to the point where it enters a Turbine Building floor drain funnel.

Drawing LRM-206, location B-3, The 1Y2-inch drain line is not continued "1 W' DRAIN TO TURBINE RM. on another license renewal drawing, SUMP" downstream of 14" but is within the scope of license piping. renewal for 10 CFR 54.4(a)(2) up to the point where it enters a Turbine Building floor drain funnel.

Drawing LRM-206, location B-3, The 1Y2-inch drain line is not continued "1 W' DRAIN TO TURBINE RM. on another license renewal drawing, SUMP" downstream of 10" but is within the scope of license piping. renewal for 10 CFR 54.4(a)(2) up to the point where it enters a Turbine Building floor drain funnel.

Drawing LRM-206, locations G-5 The vent lines downstream of valves and G-7, condenser "VENT BS244 and BS 144 end as shown on BLOW-OFF TO ATMOS.", drawing LRM-206, location G-5 and G-upstream of valves BS244 and 7, and vent directly to the Turbine BS144. Building.

2.3.4.4 Drawing LRM-205, locations E- The 1-inch drain lines downstream of 10 and F-10, show 10 CFR valves FW202A and FW202B are not 54.4(a)(2) 1" drain lines from the continued on another license renewal condensate pump warm-up drawing, but are within the scope of piping downstream of valves license renewal for 10 CFR 54.4(a)(2)

FW202A and FW202B to up to the point where the lines enter a continuations labeled as "DRAIN Turbine Building floor drain funnel.

TO WASTE".

2.3.4.5 Drawing LRM-204, locations D-9 The drain lines downstream of the and E-9, show 10 CFR 54.4(a)(2) feedwater pump relief valves are not drain lines downstream from the continued on another license renewal feedwater pump relief valves drawing, but are within the scope of C18A and C18B to continuations license renewal for 10 CFR 54.4(a)(2) labeled as "TO WASTE". up to the point where they end, about 12 inches above the Turbine Building basement floor.

Serial No.09-231 Attachment 1 Page 16 0 f 48 LRA Section Continuation Location Dominion Response Drawing LRM-204, locations 0-3, The 6-inch condensate storage tank shows 6" drain line downstream drain line shown on drawing LRM-204, from the condensate storage location 0-3, is not within the scope of tanks 1A and 1B continuation license renewal. Drawing OPERM-labeled as "6" DRAIN TO CIRC. 209-1 is not a license renewal drawing.

WATER DISCH. SEE OPERM-209-1." OPERM-209-1 was not provided with the LRA.

2.3.4.6 Drawing LRM-436, location A-3, The 1-inch piping downstream of relief 1" piping downstream of relief valve BT 1055A is not continued on valve BT 1055A "To Waste." another license renewal drawing, but is within the scope of license renewal for 10 CFR 54.4(a)(2) up to the point where it penetrates the floor.

Drawing LRM-436, location B-4, The 1-inch piping downstream of relief 1" piping downstream of relief valve C 1055A1 is not continued on valve C 1055A1 To Waste." another license renewal drawing, but is within the scope of license renewal for 10 CFR 54.4(a)(2) up to the point where it penetrates the floor.

Drawing LRM-436, location B-5, The 1-inch piping downstream of relief 1" piping downstream of relief valve C 1055A2 is not continued on valve C 1055A2 "To Waste." another license renewal drawing, but is within the scope of license renewal for 10 CFR 54.4(a)(2) up to the point where it penetrates the floor.

Drawing LRM-436, location A-7, The 2-inch piping downstream of relief 2" piping downstream of relief valve BT 1065A is not continued on valve BT 1065A "To Waste." another license renewal drawing, but is within the scope of license renewal for 10 CFR 54.4(a)(2) up to the point where it penetrates the floor.

Drawing LRM-436, location F-4, The 1-inch piping downstream of relief 1" piping downstream of relief valve BT 1055B is not continued on valve BT 1055B "To Waste." another license renewal drawing, but is within the scope of license renewal for 10 CFR 54.4(a)(2) up to the point where it penetrates the floor.

Drawing LRM-436, location G-4, The 1-inch piping downstream of relief 1" piping downstream of relief valve C 1055B1 is not continued on valve C 1055B1 "To Waste." another license renewal drawing, but is within the scope of license renewal for 10 CFR 54.4(a)(2) up to the point where it penetrates the floor.

Serial No.09-231 Attachment 1 P aQe 17 0 f 48 I

LRA Section Continuation Location Dominion Response Drawing LRM-436, location G-5, The 1-inch piping downstream of relief 1" piping downstream of relief valve C 1055B2 is not continued on valve C 1055B2 "To Waste." another license renewal drawing, but is within the scope of license renewal for 10 CFR 54.4(a)(2) up to the point where it penetrates the floor.

Drawing LRM-436, location F-7, The 2-inch piping downstream of relief 2" piping downstream of relief valve BT 1065B is not continued on valve BT 1065B "To Waste." another license renewal drawing, but is within the scope of license renewal for 10 CFR 54.4(a)(2) up to the point where it penetrates the floor.

Drawing LRM-436, location F-10, The 3/4-inch piping downstream of 3/4" piping downstream of valve valve BT 52A-3 is not continued on BT 52A-3 to "D." another license renewal drawing, but is within the scope of license renewal for 10 CFR 54.4(a)(2) up to the point where it enters an Auxiliary Building floor drain funnel.

Drawing LRM-436, location G-10, The 3/4-inch piping downstream of 3/4" piping downstream of valve valve BT 52A-1 is not continued on BT 52A-1 to "D." another license renewal drawing, but is within the scope of license renewal for 10 CFR 54.4(a)(2) up to the point that it enters an Auxiliary Building floor drain funnel.

Drawing LRM-436, location G-10, The 3/4-inch piping downstream of 3/4" piping downstream of valve valve BT 52B-1 is not continued on BT 52B-1 to "D." another license renewal drawing, but is within the scope of license renewal for 10 CFR 54.4(a)(2) up to the point that it enters an Auxiliary Building floor drain funnel.

Drawing LRM-436, location H-10, The 3/4-inch piping downstream of 3/4" piping downstream of valve valve BT 52B-3 is not continued on BT 52B-3 to "D." another license renewal drawing, but is within the scope of license renewal for 10 CFR 54.4(a)(2) up to the point that it enters an Auxiliary Building floor drain funnel.

Serial No.09-231 Attachment 1 Page 18 of 48 LRA Section Continuation Location Dominion Response Drawing LRM-436, location F-11 , The 3/4-inch piping downstream of 3/4" piping downstream of valve valve BT 54A-1 is not continued on BT 54A-1 to "D." another license renewal drawing, but is within the scope of license renewal for 10 CFR 54.4(a)(2) up to the point that it enters an Auxiliary Building floor drain funnel.

Drawing LRM-436, location G-11 , The 3/4-inch piping downstream of 3/4" piping downstream of valve valve BT 54A-3 is not continued on BT 54A-3 to "D." another license renewal drawing, but is within the scope of license renewal for 10 CFR 54.4(a)(2) up to the point that it enters an Auxiliary Building floor drain funnel.

Drawing LRM-436, location G-11 , The 3/4-inch piping downstream of 3/4" piping downstream of valve valve BT 55-1 is not continued on BT 55-1 to "D." another license renewal drawing, but is within the scope of license renewal for 10 CFR 54.4(a)(2) up to the point that it enters an Auxiliary Building floor drain funnel.

Drawing LRM-436, location G-11 , The 3/4-inch piping downstream of 3/4" piping downstream of valve valve BT 54B-3 is not continued on BT 54B-3 to "D." another license renewal drawing, but is within the scope of license renewal for 10 CFR 54.4(a)(2) up to the point that it enters an Auxiliary Building floor drain funnel.

Drawing LRM-436, location H-11, The 3/4-inch piping downstream of 3/4" piping downstream of valve valve BT 54B-1 is not continued on BT 54B-1 to "D." another license renewal drawing, but is within the scope of license renewal for 10 CFR 54.4(a)(2) up to the point that it enters an Auxiliary Building floor drain funnel.

Drawing LRM-436, location H-8, The 3/4-inch piping downstream of 3/4" piping downstream of valve valve BT 65 is not continued on BT 65 to "D." another license renewal drawing, but is within the scope of license renewal for 10 CFR 54.4(a)(2) up to the point that it enters an Auxiliary Building floor drain funnel.

Serial No.09-231 Attachment 1 P age 19 0 f 48 LRA Section Continuation Location Dominion Response Drawing LRM-436, location F-10, The 1/2-inch piping downstream of 1/2" piping downstream of valve valve BT 52A-2 ends as shown on the BT 52A-2 to "V." drawing and vents directly to the Auxiliary Building.

Drawing LRM-436, location G-10, The 1/2-inch piping downstream of 1/2" piping downstream of valve valve BT 54B-2 ends as shown on the BT 52B-2 to "V." drawing and vents directly to the Auxiliary Building.

Drawing LRM-436, location F-11, The 1/2-inch piping downstream of 1/2" piping downstream of valve valve BT 54A-2 ends as shown on the BT 54A-2 to "V." drawing and vents directly to the Auxiliary Building.

Drawing LRM-436, location G-11 , The 3/4-inch piping downstream of 3/4" piping downstream of valve valve BT 54B-2 ends as shown on the BT 54B-2 to "V." drawing and vents directly to the Auxiliary Building.

Drawing LRM-436, location G-8, The 8-inch vent piping is not continued 8" piping downstream of valve BT on another license renewal drawing, 75 "Vent to Atmosphere." but is within the scope of license renewal for 10 CFR 54.4(a)(2) up to the point that it exits through the Auxiliary Building roof.

2.3.4.7 Drawing LRM-204,locations A-5, The 2V2-inch lines are not continued on A-7 and A-8 show 10 CFR another license renewal drawing, but 54.4(a)(2) pipe lines continued to are within the scope of license renewal "2W' TO WASTE." The for 10 CFR 54.4(a)(2) up to the point continuation was not provided where they discharge to a trench near and could not be located. the auxiliary feedwater pumps.

2.3.4.8 Drawing LRM-203, location C-12, The relief line continues on drawing 10 CFR 54.4(a)(2) piping to the LRM-212, location 0-4.

"M212 RELIEF TO ATMOS."

Drawing LRXK-1 01-17, location The piping downstream of the air F-2, piping downstream of air exhausters continues on drawing LRM-exhauster AR-300A & AR-300B 212, location C-4.

to the "Air Exhauster."

2.3.4.9 Drawing LRM-219, location A-1O, The piping associated with "Heater 10 CFR 54.4(a)(2) piping from Drain Pumps Discharge" continues on the "HEATER DRAIN PUMPS LRM-207, location H-1. The discharge DISCHARGE." line from the heater drain pumps is also shown on drawing LRM-204, location B-12.

Serial No.09-231 Attachment 1 Page 20 0 f 48 LRA Section Continuation Location Dominion Response 2.3.4.10 Drawing LRM-605-1, location A- The lines downstream of valves HS-2, after valve HS406, shows a 406 and HS-403, and the vent from the continuation to drawing LRM- Boric Acid Evaporator Condensate 601, location G-9, TO VENT Return Tank are not continued on DUCT." However, review of another license renewal drawing, but drawing LRM-601 could not are within the scope of license renewal locate the continuation from for 10 CFR 54.4(a)(2) up to the point LRM-605-1. Also, similar where they discharge into the vent duct extensions "TO VENT DUCT" at from the Boric Acid Evaporator Vault.

location A-3 after valve HS403 to The vent duct from the Boric Acid LRM- 601, location G-9, and at Evaporator Vault is shown on LRM-location B-3 after the boric acid 601, location G-9.

evaporator condensate return tank to LRM-601, location G-8, could not be located.

Drawing LRM-605-1, location E- There is no license renewal drawing 7, shows a continuation of 10 LRM-505. Drawing LRM-605-1 CFR 54.4(a)(2) 3" pipe section incorrectly identified a continuation of after valve HS590 to drawing the in-scope portion of the 3-inch line LRM-505, location A-1 O. downstream of valve HS590 on However, drawing LRM-505 was drawing LRM-505. LR Note 3, shown not provided as a part of LRA. A on LRM-605-1 , should have been similar reference to LRM-505, applied at location E-7 to indicate that location E-8, at location E-5 could the license renewal boundary for the 3-not be located. inch line ends where the line exits the Turbine Building.

2.3.4.12 Drawing LRM-219, location C-1, The 1-inch piping downstream of valve 1" line attached to valve MU500- MU500-3 is an open-ended grab 3 in-scope for 10 CFR 54.4(a)(2). sample point and ends as shown on drawing LRM-219 at location C-1.

Drawing LRM-204, location 0-3, The line downstream of MU200 is a %-

shows a 2" line downstream of inch line and continues on drawing valve MU200 in scope for 10 LRM-219 at location G-10.

CFR 54.4(a)(2). The continuation to the LRA boundary on Drawing The 2-inch line downstream of MU1 00 LRM-605-2, location 0-10, could on drawing LRM-204, location 0-3, is not be located. not within the scope of license renewal and continues on drawing LRM-605-2 at location 0-10.

Serial No.09-231 Attachment 1 Page 21 0 f 48 LRA Section Continuation Location Dominion Response 2.3.4.14 Drawing LRM-211, locations H-1 The two lines for "Miscellaneous Floor and H-3, 10CFR54.4(a)(2) pipes Drains" do not continue to another from "MISCELLANEOUS FLOOR drawing. These lines indicate general DRAINS" and "%" SAMPLE floor drains to the sump that are CONNECTION" respectively. embedded in the Turbine Building basement concrete floor. These two miscellaneous floor drain lines were incorrectly identified as within the scope of license renewal for 10 CFR 54.4(a)(2) and should not have been highlighted on the drawing.

The %-inch sample connection is an open-ended grab sample point and ends as shown on drawing LRM-211, location H-3.

Drawing LRM-211, location C7, These turbine gland sealing steam 10 CFR 54.4(a)(2) pipes lines are continued on drawing LRXK-

"TURBINE CONNECTION 25 101-17 at location F-6.

FOR CONT. SEE TO DWG. X-K101-17."

Serial No.09-231 Attachment 1 Page 22 of 48 RAI 2.3.3.6-01

Background:

LRA Section 2.3.3.6, "Service Water System," states that components are within the scope of license renewal per 10 CFR 54.4(a)(1) and 10 CFR 54.4(a)(2) and have intended functions of providing a pressure boundary and filtration.

Issue:

License renewal drawing LRM-202-3, location F-11 , shows the 12" line out of the turbine oil cooler as in scope for license renewal for 10 CFR 54.4 (a)(2) , whereas the 3" line connected to this line and going to the fan coil units is shown as not in scope. However, the continuation of this 3" line on drawing LRM-606, location A8, shows this line is in scope for 10 CFR 54.4(a)(2).

Request:

Provide additional information explaining why there is a difference in scope classification between drawing LRM-202-3 and LRM-606.

Dominion Response The 3-inch line downstream of the turbine lube oil cooler on license renewal drawing LRM-606 (location A-8) is correctly shown as being within the scope of license renewal for 10 CFR 54.4(a)(2). The continuation of this 3-inch line on license renewal drawing LRM-202-3 was incorrectly not highlighted, but is within the scope of license renewal for 10 CFR 54.4(a)(2) and is included in the component type "Pipe" in LRA Table 2.3.3-6, "Service Water."

Serial No.09-231 Attachment 1 Page 23 of 48 RAI 2.3.3.6-02

Background:

LRA Section 2.3.3.6, "Service Water System," states that components are within the scope of license renewal per 10 CFR 54.4(a)(1) and 10 CFR 54.4(a)(2) and have intended functions of providing a pressure boundary and filtration.

Issue:

License renewal drawing LRM-202-2, location H-9, shows valve SW(T)251 in scope for 10 CFR 54.4(a)(1). However, the same valve on drawing LRM-394, location E-7, is shown in scope for 10 CFR 54.4(a)(2).

Request:

Provide additional information explaining why there is a difference in scope classification between drawings LRM-202-2 and LRM-394.

Dominion Response LRA Section 2.3.3.6, "Service Water System," states that components are within the scope of license renewal per 10 CFR 54.4(a)(1), 10 CFR 54.4(a)(2), and 10 CFR 54.4(a)(3).

Valve SW(T)251 performs a pressure boundary function for the cooling water supply to the instrument air compressor, which is included within the scope of license renewal for 10 CFR 54.4(a)(3) in support of 10 CFR 50.48 fire protection regulations. Valve SW(T)251 is within the scope of license renewal per 10 CFR 54.4(a)(3) since it supports the function of the instrument air compressor. As indicated in LRA Section 2.1.3.8, components included within the scope of license renewal per 10 CFR 54.4(a)(1) and (a)(3) are highlighted blue on the license renewal drawings. Therefore, license renewal drawing LRM-202-2 (location H-9) correctly shows valve SW(T)251 highlighted blue. Valve SW(T)251 should also be highlighted blue on LRM-394 (location E-7), but was incorrectly highlighted orange.

Serial No.09-231 Attachment 1 Page 24 of 48 RAI 2.3.3.6-03

Background:

LRA Section 2.3.3.6, "Service Water System," states that components are within the scope of license renewal per 10 CFR 54.4(a)(1) and 10 CFR 54.4(a)(2) and have intended functions of providing a pressure boundary and filtration.

Issue:

License renewal drawing LRM-202-2, locations 0-9 and 0-10, shows 1Y2" lines downstream of valves SW1260 and SW1263 as in scope for 10 CFR 54.4(a)(2).

However, the continuations of these 1112" lines on drawing LRM-606, locations G-10 and G-11, are shown in scope for 10 CFR 54.4(a)(1).

Request:

Provide additional information explaining why there is a difference in scope classification between drawings LRM-202-2 and LRM-606.

Dominion Response LRA Section 2.3.3.6, "Service Water System," states that components are within the scope of license renewal per 10 CFR 54.4(a)(1), 10 CFR 54.4(a)(2), and 10 CFR 54.4(a)(3).

The 1Y2-inch lines downstream of valve SW 1260 and upstream of valve SW 1263 are cooling water supply and return lines for the component cooling pump 1B fan coil unit, which is included within the scope of license renewal per 10 CFR 54.4(a)(3) in support of 10 CFR 50.48 fire protection regulations. The cooling water lines are within the scope of license renewal per 10 CFR 54.4(a)(3) since they support the function of the fan coil unit. As indicated in LRA Section 2.1.3.8, components included within the scope of license renewal per 10 CFR 54.4(a)(1) and (a)(3) are highlighted blue on the license renewal drawings. Therefore, license renewal drawing LRM-606 (locations G-1 0 and G-11) correctly shows the 1Y2-inch lines highlighted blue. The continuations of the 1Y2-inch lines on license renewal drawing LRM-202-2 (locations 0-9 and 0-10) should also be highlighted blue, but were incorrectly highlighted orange.

Serial No.09-231 Attachment 1 Page 25 of 48 RAI 2.3.3.6-04

Background:

LRA Section 2.3.3.6, "Service Water System," states that components are within the scope of license renewal per 10 CFR 54.4(a)(1) and 10 CFR 54.4(a)(2) and have intended functions of providing a pressure boundary and filtration.

Issue:

License renewal drawing LRM-202-2, locations C-5 and C-6, shows 1Y2" lines downstream of valves SW850 and SW853 as in scope for 10 CFR 54.4(a)(2).

However, the continuations of these 1Y2" lines on drawing LRM-606, locations B-5 and B-6, are shown in scope for 10 CFR 54.4(a)(1).

Request:

Provide additional information explaining why there is a difference in scope classification between drawings LRM-202-2 and LRM-606.

Dominion Response LRA Section 2.3.3.6, "Service Water System," states that components are within the scope of license renewal per 10 CFR 54.4(a)(1), 10 CFR 54.4(a)(2), and 10 CFR 54.4(a)(3).

The 1Y2-inch lines downstream of valve SW850 and upstream of valve SW853 are cooling water supply and return lines for charging pump 1C fan coil unit, which is included within the scope of license renewal for 10 CFR 54.4(a)(3) in support of 10 CFR 50.48 fire protection regulations. The cooling water lines are within the scope of license renewal for 10 CFR 54.4(a)(3) since they support the function of the fan coil unit. As indicated in LRA Section 2.1.3.8, components included within the scope of license renewal for 10 CFR 54.4(a)(1) and (a)(3) are highlighted blue. Therefore, license renewal drawing LRM-606 (locations B-5 and B-6) correctly shows the 1Y2-inch lines highlighted blue. The continuations of the 1Y2-inch lines on license renewal drawing LRM-202-2 (locations C-5 and C-6) should also be highlighted blue, but were incorrectly highlighted orange.

Serial No.09-231 Attachment 1 Page 26 of 48 RAI2.3.3.7-01

Background:

LRA Section 2.3.3.7, "Cooling Water System," states that components are within the scope of license renewal per 10 CFR 54.4(a)(1), 10 CFR 54.4(a)(2), and 10 CFR 54.4(a)(3) and have intended functions of providing a pressure boundary, restricting flow, and heat transfer.

Issue:

License renewal drawing LRXK-100-20, location E-2, shows the distillate cooler and evaporator condenser in scope for 10 CFR 54.4(a)(2) while the pipelines entering and leaving the distillate cooler and evaporator condenser are shown in scope for 10 CFR 54.4(a)(1) or 10 CFR 54.4(a)(3).

Request:

1. Confirm the piping attached to the distillate cooler and evaporator condenser is in scope for 10 CFR 54.4(a)(1) or 10 CFR 54.4(a)(3), or

2. Provide additional information explaining why there is a difference in scope classification between the attached piping and the distillate cooler and evaporator condenser.

Dominion Response The distillate cooler and evaporator condenser, shown on license renewal drawing LRXK-100-20 (location E-2), are subcomponents of the waste evaporator, which is no longer in operation as described in LRA Section 2.3.3.22, "Liquid Waste Processing and Discharge System." Component cooling water flow through the piping shown on license renewal drawing LRXK-100-20 at location E-2 to the waste evaporator equipment is isolated by closed valves that are under administrative control. Although component cooling water flow is isolated, the component cooling piping shown on license renewal drawing LRXK-100-20 at location E-2 is safety-related and is within the scope of license renewal for 10 CFR 54.4(a)(1). The non-safety-related distillate cooler and evaporator condenser shells are included within the scope of license renewal for 10 CFR 54.4(a)(2) since they are relied on to provide structural seismic support for the attached safety-related component cooling piping as described in LRA Section 2.3.3.22.

Serial No.09-231 Attachment 1 Page 27 of 48 RAI 2.3.3.8-01

Background:

LRA Section 2.3.3.8, "Station and Instrument Air System," states that components are within the scope of license renewal per 10 CFR 54.4(a)(1), 10 CFR 54.4(a)(2), or 10 CFR 54.4(a)(3) and have intended functions of providing a pressure boundary, filtration, and heat transfer.

Issue:

LRA drawing LRM-213-4, location G-4, shows a continuation "To pas. FOR GV-31396 SHEET 301" as in scope for 10 CFR 54.4(a)(2). The continuation on LRM-213-3, location 0-1, does not show this section of piping to be in scope.

Request:

Provide additional information to clarify the scoping classification of this section of piping.

Dominion Response License renewal drawing LRM-213-4 (location G-4) correctly shows the line to the positioner for CV-31396 within the scope of license renewal for 10 CFR 54.4(a)(2). The continuation of this line on license renewal drawing LRM-213-3 (location 0-1) was incorrectly not highlighted, but is within the scope of license renewal for 10 CFR 54.4(a)(2) and is included in the component type "Tubing" in LRA Table 2.3.3-8, "Station and Instrument Air."

Serial No.09-231 Attachment 1 Page 28 of 48 RAI 2.3.3.8-02 8ackground:

LRA Section 2.3.3.8, "Station and Instrument Air System," states that components are within the scope of license renewal per 10 CFR 54.4(a)(1), 10 CFR 54.4(a)(2), and 10 CFR 54.4(a)(3) and have intended functions of providing a pressure boundary, filtration, and heat transfer.

Issue:

LRA drawing LRM-213-3, location A-3, downstream of valve SA-201 shows a continuation to LRM-213-1, location 8-5, as in scope for 10 CFR 54.4(a)(2). The continuation on LRM-213-1, location 8-5, is not in scope.

Request:

Provide additional information to clarify the scoping classification for this section of piping.

Dominion Response The Station Air System pressure sensing line from the station air piping shown on license renewal drawing LRM-213-1 (location 8-5), through valve SA-201, to the positioner for CV-31308 was incorrectly highlighted on license renewal drawing LRM-213-3 (location A-3). The continuation of this sensing line on license renewal drawing LRM-213-1 (location 8-5) correctly shows the station air sensing line as not within the scope of license renewal.

During the preparation of this response, it was identified that the valve positioner output line to the CV-31308 valve actuator, shown on license renewal drawing LRM-213-1 (location 8-5), was incorrectly not highlighted, but is within the scope of license renewal for 10 CFR 54.4(a)(2) and is included in the component type "Tubing" in LRA Table 2.3.3-8, "Station and Instrument Air."

Serial No.09-231 Attachment 1 Page 29 of 48 RAI 2.3.3.8-03

Background:

LRA Section 2.3.3.8, "Station and Instrument Air System," states that component are within the scope of license renewal per 10 CFR 54.4(a)(1), 10 CFR 54.4(a)(2), or 10 CFR 54.4(a)(3) and have intended functions of providing a pressure boundary, filtration, and heat transfer.

Issue:

LRA drawing LRM-213-5, location A-12, shows a continuation "To pas. FOR CV-31120 SHT 206" as in scope for 10 CFR 54.4(a)(2). The continuation on LRM-213-2, location 0-6, shows this section of piping to be in scope for 10 CFR 54.4(a)(1) or 10 CFR 54.4(a)(3).

Request:

Provide additional information to clarify the scoping classification of this section of piping.

Dominion Response License renewal drawing LRM-213-5 (location A-12) correctly shows the instrument air line to the positioner for CV-31120 within the scope of license renewal for 10 CFR 54.4(a)(2). The continuation of this line on license renewal drawing LRM-213-2 (location 0-6) was incorrectly not highlighted, but is within the scope of license renewal for 10 CFR 54.4(a)(2) and is included in the component type "Tubing" in LRA Table 2.3.3-8, "Station and Instrument Air." The line from the positioner to CV-31120 shown on LRM-213-2 (location 0-6) is within the scope of license renewal for 10 CFR 54.4(a)(3) in support of 10 CFR 50.48 fire protection regulations and is correctly highlighted blue.

Serial No.09-231 Attachment 1 Page 30 of 48 RAI 2.3.3.19-01

Background:

LRA Section 2.1.3.6.2, "NS Piping Attached to SR Piping," states in part "The NS piping up to and including the structural anchors were included in scope per 10 CFR 54.4(a)(2). In the event an equipment connection is credited for providing restraint in one or more of the orthogonal directions, the credited component and its associated supports were included in the scope of license renewal per 10 CFR 54.4(a)(2)."

Issue:

License renewal drawing LRM-213-9, locations B-1, B-2, B-3, B-4, B-5, B-7, B-8, B-10, B-11, and B-12, show non-safety related piping connected to safety-related components at valves SA2020A-1, SA2020A-2, SA2020A-3 SA2020A-4, SA2020B-1, SA2020B-2, SA2020B-3, and SA2020B-4 and traps downstream of After Coolers 166-021 and 166-022 to floor drains.

Request:

Provide the location of the seismic anchor for the non safety related %" lines connected to the safety-related valves and traps.

Dominion Response The controlled drawing for this system does not identify structural anchors for the non-safety-related %-inch drain lines downstream of the safety-related drain valves. Therefore, the bounding scoping methodology as described in LRA Section 2.1.3.6.2, "NS Piping Attached to SR Piping," was applied and the entire drain line sections from the safety-related valves to the floor drain were included in scope under 10 CFR 54.4(a)(2). Consequently, it was not necessary to identify the location of structural anchors in the non-safety related portion of the piping.

The traps, after coolers, and air dryers shown on LRM-213-9 are not safety-related. These components were included within the scope of license renewal for 10 CFR 54.4(a)(3) in support of 10 CFR 50.48 fire protection regulations.

The drain lines downstream of the after coolers and air dryers are not considered to be NS piping attached to SR piping. These drain lines are within the scope of license renewal for 10 CFR 54.4(a)(2) based on their spatial orientation to safety-related equipment as described in LRA Section 2.1.3.6.1, "Spatially Oriented NS SSCs Not Directly Attached to SR SSCs."

Serial No.09-231 Attachment 1 Page 31 of 48 RAI 2.3.3.22-01

Background

LRA Section 2.3.3.22, "Liquid Waste Processing and Discharge System," states that components are within the scope of license renewal per 10 CFR 54.4(a)(1),

10 CFR 54.4(a)(2), and 10 CFR 54.4(a)(3) and have an intended function of providing a pressure boundary.

Issue LRA drawing LRXK-1 00-131, location A-7, shows the laundry and hot shower tank 1A within scope for license renewal per 10 CFR 54.4(a)(2). The attached blind flange on the overflow connection near Note 14 is shown as not in scope (the same flange on tank 1B is shown as in-scope).

Request Provide a justification for not including the blind flange on laundry and hot shower tank 1A within scope for license renewal.

Dominion Response The blind flange on laundry and hot shower tank 1A on license renewal drawing LRXK-100-131 (location A-7) was incorrectly not highlighted, but is within the scope of license renewal for 10 CFR 54.4(a)(2) and is included in the component type "Pipe" in LRA Table 2.3.3-22, "Liquid Waste Processing and Discharge."

Serial No.09-231 Attachment 1 Page 32 of 48 RAI 2.3.3.22-02

Background

Section 54.21 (a) of 10 CFR requires applicants to list all component types subject to an AMR. The staff confirms inclusion of all component types subject to an AMR by reviewing components within the license renewal boundary.

Issue LRA drawing LRXK-100-44, location E-8, shows a sample sink and a line to the fume hood sampler (Hi-RAD RC sample) as not within scope for license renewal.

All piping entering and exiting the sink, including the drain to the waste holdup tank which is shown as belonging to the liquid waste processing and discharge system, is shown as within scope for 10 CFR 54.4(a)(2).

Request Explain why the sample sink and sample line to the fume hood sampler are not in scope for 10 CFR 54.4(a)(2).

Dominion Response The sample line to the fume hood sampler is incorrectly shown on drawing LRXK-100-44. This line is no longer installed in the plant.

The sample sink is not within the scope of license renewal because the sink does not perform an intended function in accordance with 10 CFR 54.4(a). The methodology for determining SSCs within the scope of license renewal is described in LRA Section 2.1, "Scoping and Screening Methodology" and further discussed for 10 CFR 54.4(a)(2) in LRA Section 2.1.3.6, "10 CFR 54.4(a)(2)

REPORT."

The sample sink does not provide structural support for NS piping attached to SR piping and is not required to support the function of safety-related SSCs.

Although the sink is in the vicinity of safety-related SSCs, its failure could not affect the function of safety-related SSCs. The sample sink may contain fluids during sampling operations, but is maintained at atmospheric pressure and there are no safety-related SSCs located such that they could be impacted by leakage from the sink. Therefore, the sample sink is not within the scope of license renewal for 10 CFR 54.4(a)(2) per LRA Section 2.1.3.6.1, "Spatially Oriented NS SSCs Not Directly Attached to SR SSCs."

In addition, the sample sink drain piping below the sample sink within the sample room, shown on drawing LRXK-100-44 at location E-8, is similarly maintained at atmospheric pressure and its failure could not impact safety-related SSCs. This

Serial No.09-231 Attachment 1 Page 33 of 48 piping is not within the scope of license renewal, but was incorrectly highlighted on the drawing.

The sample lines entering and exiting the sample sink contain fluid during sampling operations and are within the scope of license renewal for 10 CFR 54.4(a)(2) as indicated on drawing LRXK-1 00-44.

Serial No.09-231 Attachment 1 Page 34 of 48 RAI 2.3.3.24-01

Background:

LRA Section 2.3.3.24, "Makeup and Demineralized Water System," states that components are within the scope of license renewal per 10 CFR 54.4(a)(1), 10 CFR 54.4(a)(2), and 10 CFR 54.4(a)(3) and have an intended function of providing a pressure boundary.

Issue:

License renewal drawing LRM-209-2 sheet 1, location B-1, shows a 1Y2" line in scope for license renewal for 10 CFR 54.4(a)(2). However, the continuation of this 1Y2" line on drawing LRM-385, location G7, shows this line is not in scope for license renewal.

Request:

Provide additional information to clarify the scoping classification for this pipe section.

Dominion Response License renewal drawing LRM-209-2 (location B-1) correctly shows a portion of the 1Y2-inch line to the waste solidification mixer/feeder as being within the scope of license renewal for 10 CFR 54.4(a)(2) based on its spatial orientation to safety-related equipment. This 1Y2-inch line is only within the scope of license renewal up to the point where it enters the Solid Radioactive Waste Processing Cubicle, since there are no safety-related SSCs within the cubicle. The continuation of the line on license renewal drawing LRM-385 (location G-7) is within the Solid Radioactive Waste Processing Cubicle and is not within the scope of license renewal. A note identifying the in-scope boundary is normally added to the license renewal drawing as described in LRA Section 2.1.3.6.1, "Spatially Oriented NS SSCs Not Directly Attached to SR SSCs," but was incorrectly omitted.

Serial No.09-231 Attachment 1 Page 35 of 48 RAI 2.3.3.25-01

Background:

LRA Section 2.3.3.25, "Service Water Pretreatment System," states that component types are within the scope of license renewal per 10 CFR 54.4(a)(1) and 10 CFR 54.4(a)(2) and have intended functions of providing a pressure boundary and filtration.

Issue:

License renewal drawing LRM-394, location F-10, shows a 4" line downstream of valve SW(T)404 as not in scope for license renewal for 10 CFR 54.4(a).

However, the continuation of this 4" line on drawing LRM-211, location G-1, is shown as in scope for license renewal for 10 CFR 54.4(a)(2).

Reguest:

Provide additional information explaining why there is a difference in scope classification between drawings LRM-394 and LRM-211.

Dominion Response A portion of the 4-inch Service Water Pretreatment System line downstream of valve SW(T)404 is shown within the scope of license renewal for 10 CFR 54.4(a)(2) on both license renewal drawings LRM-394 (location F-10) and LRM-211 (location G-1). As indicated by LR Note 1 on license renewal drawing LRM-394, the piping immediately downstream of valve SW (T)404 is not within the scope of license renewal because this piping, located in the east/southeast side of the Turbine Building basement, is not spatially oriented near safety-related components.

Serial No.09-231 Attachment 1 Page 36 of 48 RAI 2.3.3.25-02

Background:

LRA Section 2.3.3.25, "Service Water Pretreatment System," states that components are within the scope of license renewal per 10 CFR 54.4(a)(1) and 10 CFR 54.4(a)(2) and have intended functions of providing a pressure boundary and filtration.

Issue:

License renewal drawing LRM-394, location E-4, shows the valve SW(T)242 as in scope for license renewal for 10 CFR 54.4(a)(2). However, the same valve on drawing LRM-202-2, location H8, is shown in scope for 10 CFR 54.4(a)(1).

Request:

Provide additional information explaining why there is a difference in scope classification between drawings LRM-394 and LRM-202-2.

Dominion Response Components in the Service Water Pretreatment System are also within the scope of license renewal for 10 CFR 54.4(a)(3). During the review of this request it was identified that the following statement was omitted from the LRA Section 2.3.3.25, "Service Water Pretreatment System," system description:

"The system meets 10 CFR 54.4 (a)(3) because the system includes components that support fire protection."

Valve SW(T)242 is a non-safety-related valve that performs a pressure boundary function for the cooling water line to the instrument air compressor, which is included within the scope of license renewal for 10 CFR 54.4(a)(3) in support of 10 CFR 50.48 fire protection regulations. As indicated in LRA Section 2.1.3.8, components included within the scope of license renewal for 10 CFR 54.4(a)(1) and (a)(3) are highlighted blue. Therefore, license renewal drawing LRM-202-2 (location H-8) correctly shows valve SW(T)242 highlighted blue. Valve SW(T)242 on license renewal drawing LRM-394 (location E-4) should also be highlighted blue, but was incorrectly highlighted orange.

Serial No.09-231 Attachment 1 Page 37 of 48 RAI 2.3.3.26-01

Background:

LRA Section 2.1.3.6.2, "NS Piping Attached to SR Piping," states in part "The NS piping up to and including the structural anchors were included in scope per 10 CFR 54.4(a)(2). In the event an equipment connection is credited for providing restraint in one or more of the orthogonal directions, the credited component and its associated supports were included in the scope of license renewal per 10 CFR 54.4(a)(2)."

Issue:

License renewal drawing LRM-350, locations 0-5, 0-6, and 0-10, show non-safety-related piping connected to safety-related piping components at valves MO(R)-250A&B, MO(R)-251A&B, MO(R)-260, MO(R)-261, MO(R)-270, MO(R)-

271, MO(R)-272, MO(R)-273, and MO(R)-262.

Request:

Provide the location of the seismic anchor for the non-safety-related 1" lines connected to the safety-related residual heat exchangers #1 A and #1 B, the letdown exchanger, and seal water heat exchanger piping.

Dominion Response The controlled drawings did not identify structural anchors for the NS 1-inch drain lines associated with these heat exchangers. Therefore, the bounding scoping methodology was applied as described in LRA Section 2.1.3.6.2, "NS Piping Attached to SR Piping." The entire drain line sections from the safety-related drain isolation valves to the sludge interceptor tank (license renewal drawing LRM-350, location F-7) were included within the scope of license renewal for 10 CFR 54.4.(a)(2). Consequently, it was not necessary to identify the location of structural anchors in the non-safety related portion of the piping.

Serial No.09-231 Attachment 1 Page 38 of 48 RAI 2.3.3.26-02

Background:

Section 54.21 (a) of 10 CFR requires applicants to list all component types subject to an AMR. The staff confirms inclusion of all component types subject to an AMR by reviewing components within the license renewal boundary.

Issue:

License renewal drawing LRM-350, locations H-6 and H-7, shows the 3" and 2" lines, downstream of the residual heat removal (RHR) pump flushing outlets, as in scope for license renewal for 10 CFR 54.21 (a)(2). However part of the 2" line is shown as not in scope for license renewal.

The 2" line upstream of valve MD(R) 280B, location H-7, is continued to LRM-539, location H-5, where it is shown as in scope for license renewal while it is shown as not in scope for license renewal on LRM-350.

Request:

Provide additional information to establish the license renewal boundary for the 3" and 2" lines shown as not in scope for license renewal.

Provide additional information explaining why there is a difference in scope classification between the main drawing LRM-350 and the continuation on LRM-539 for the 2" line upstream of valve MD(R) 280B.

Dominion Response License renewal drawing LRM-539 correctly shows valve MD(R)-280B and the associated 2-inch line within the scope of license renewal for 10 CFR 54.4(a)(2).

On license renewal drawing LRM-350 (location H-7), this same valve and a portion of the associated 2-inch line were incorrectly not highlighted, but are within the scope of license renewal for 10 CFR 54.4(a)(2) and are included in the component types "Valves" and "Pipe" in LRA Table 2.3.3-26, "Miscellaneous Drains and Sumps."

Serial No.09-231 Attachment 1 Page 39 of 48 RAI 2.3.4.1-01

Background:

LRA Section 2.3.4.1, "Turbine System," states that components are within the scope of license renewal per 10 CFR 54.4(a)(1), 10 CFR 54.4(a)(2), and 10 CFR 54.4(a)(3) and have an intended function of providing a pressure boundary.

Issue:

License renewal drawing LRM-202-3, location H-7, shows a continuation of in scope 2" 10 CFR 54.4(a)(2) pipe from drawing LRM-204, location A5. Review of drawing LRM-204 found a continuation (2" to standpipe) at A5, however, this line is included in scope for 10 CFR 54.4(a)(1).

Request:

Confirm that the located continuations are correct and provide additional information to justify the different criteria for the continuing sections of the same pipe.

Dominion Response The continuation of the 2-inch auxiliary feedwater pump recirculation line to the standpipe on license renewal drawing LRM-202-3 (location H-7) is correctly shown as within the scope of license renewal for 10 CFR 54.4(a)(2). This line is continued from the 2-inch line downstream of valve AFW-120 on license renewal drawing LRM-204 (location A-5), which is also within the scope of license renewal for 10 CFR 54.4(a)(2), and should be highlighted orange, but was incorrectly highlighted blue. Normally closed valve AFW-120 and the portion of this line upstream of the valve shown on license renewal drawing LRM-204 (location A-5) is within the scope of license renewal for 10 CFR 54.4(a)(3) in support of 10 CFR 50.48 fire protection and 10 CFR 50.63 station blackout regulations, and is correctly highlighted blue.

Serial No.09-231 Attachment 1 Page 40 of 48 RAI 2.3.4.2-01

Background:

LRA Section 2.3.4.2, "Main Steam and Steam Dump System," states that components are within the scope of license renewal per 10 CFR 54.4(a)(1), 10 CFR 54.4(a)(2), and 10 CFR 54.4(a)(3) and have intended functions of providing a pressure boundary, restricting flow, equipment qualification (EO) barrier, and jet impingement shield.

Issue:

License renewal drawing LRM-203 location H-3, shows a section of safety-related 10 CFR 54.4(a)(1) pipe connecting tachometer element readout and the turbine driven auxiliary feedwater pump both of which are in the scope for 10 CFR 54.4(a)(1). However, this connecting pipe section is not included in scope.

Request:

Provide additional information explaining why this section of safety-related piping is not within the scope of license renewal.

Dominion Response The tachometer element and readout instrument shown on license renewal drawing LRM-203 (location H-3) senses the shaft speed of the turbine-driven auxiliary feedwater pump, but does not penetrate the system pressure boundary.

The shaft is represented on the drawing by the line that runs from the turbine to the pump. The tachometer element and readout instrument and the shaft are active components and do not require aging management review. Therefore, these components have not been highlighted on license renewal drawing LRM-203.

Serial No.09-231 Attachment 1 Page 41 of 48 RAI 2.3.4.5-01

Background:

LRA Section 2.3.4.5, "Condensate System," states that component types are within the scope of license renewal per 10 CFR 54.4(a)(2) or 10 CFR 54.4(a)(3) and have an intended function of providing a pressure boundary.

Issue:

LRA drawing LRM-204, locations B-1 and B-2, show partially highlighted 10 CFR 54.4(a)(3) sampling line downstream from condensate storage tanks 1Al1 B to valves MU40AlB. This drawing does not match the partially highlighted 10 CFR 54.4(a)(3) section of piping on drawing LRM-219, location B-1.

Request:

Provide additional information to clarify the scoping classification for these pipe sections.

Dominion Response License renewal drawing LRM-219 (locations B-1) correctly shows valves MU40AlB and the associated upstream piping as being within the scope of license renewal for 10 CFR 54.4(a)(3). These same valves and associated upstream piping on license renewal drawing LRM-204 (locations B-1 and B-2) were incorrectly not highlighted, but are within the scope of license renewal for 10 CFR 54.4(a)(3) and are included in the component types "Valves" and "Pipe" in LRA Table 2.3.4-5, "Condensate."

Serial No.09-231 Attachment 1 Page 42 of 48 RAI 2.3.4.6-01

Background:

LRA Section 2.3.4.6, "Steam Generator Blowdown Treatment System," states that components are within the scope of license renewal per 10 CFR 54.4(a)(1),

10 CFR 54.4(a)(2), and 10 CFR 54.4(a)(3) and have intended functions of providing a pressure boundary, spray pattern, restricting flow, filtration, and heat transfer.

Issue:

LRA drawing LRM-368, location H-7, shows 2" piping downstream of valve WD41 as in scope for 10 CFR 54.4(a)(2). This drawing does not match the same section of piping on drawing LRXK-1 00-131, location H-1 O.

Request:

Provide additional information to clarify the scoping classification for this pipe section.

Dominion Response License renewal drawing LRM-368 (location H-7) correctly shows the piping downstream of valve WD41 as being within the scope of license renewal for 10 CFR 54.4(a)(2). This same piping on license renewal drawing LRXK-100-131 (location H-10) was incorrectly not highlighted, but is within the scope of license renewal for 10 CFR 54.4(a)(2) and is included in the component type "Pipe" in LRA Table 2.3.3-22, "Liquid Waste Processing and Discharge."

Serial No.09-231 Attachment 1 Page 43 of 48 RAI2.3.4.7-01

Background:

LRA Section 2.3.4.7, "Auxiliary Feedwater System," states that components are within the scope of license renewal per 10 CFR 54.4(a)(1), 10 CFR 54.4(a)(2),

and 10 CFR 54.4(a)(3) and have intended functions of providing a pressure boundary, heat transfer, flow restriction, and filtration.

Issue:

Drawing LRM-204, location A-5, shows a 10 CFR 54.4(a)(1) pipe line continued to 2" to standpipe on LRM-202-3, location H-7. The continuation on LRM-202-3, location H-7, shows this section of pipe as in scope for 10 CFR 54.4(a)(2).

Request:

Provide additional information to clarify the scoping classification for this pipe section.

Dominion Response The continuation of the 2-inch auxiliary feedwater pump recirculation line to the standpipe on license renewal drawing LRM-202-3 (location H-7) is correctly shown as within the scope of license renewal for 10 CFR 54.4(a)(2). This line is continued from the 2-inch line downstream of valve AFW-120 on license renewal drawing LRM-204 (location A-5), which is also within the scope of license renewal for 10 CFR 54.4(a)(2), and should be highlighted orange, but was incorrectly highlighted blue. Normally closed valve AFW-120 and the portion of this line upstream of the valve shown on license renewal drawing LRM-204 (location A-5) is within the scope of license renewal for 10 CFR 54.4(a)(3) in support of 10 CFR 50.48 fire protection and 10 CFR 50.63 station blackout regulations, and is correctly highlighted blue.

Serial No.09-231 Attachment 1 Page 44 of 48 RAI2.3.4.7-02

Background:

LRA section 2.3.4.7, "Auxiliary Feedwater System," states that components are within the scope of license renewal per 10 CFR 54.4(a)(1), 10 CFR 54.4(a)(2), 10 CFR 54.4(a)(3) and have intended functions of providing a pressure boundary, heat transfer, flow restriction, and filtration.

Issue:

Drawing LRM-205, location G-6 shows a 10 CFR 54.4(a)(1) pipe line continued to 1Y2" "Recirc. Line (typ)" on LRM-204, location A-6. The continuation on LRM-204, location A-6, shows this section of pipe as not in scope. This is typical for all three AFW pumps.

Request:

Provide additional information to clarify the scoping classification for this pipe section.

Dominion Response The 1Y2-inch auxiliary feedwater pump recirculation line (with valve AFW-100B) on license renewal drawing LRM-205 (location G-6) is correctly highlighted as being within the scope of license renewal for 10 CFR 54.4(a)(1). The continuation of this 1Y2-inch line is shown on license renewal drawing LRM-204 (location A-6) by the horizontal line to the left of the pump discharge line (with valve AFW-100B) and is also highlighted as being within the scope of license renewal for 10 CFR 54.4(a)(1). The vertical line immediately to the left of valve AFW-100B on license renewal drawing LRM-204 is a marker and is not intended to indicate a pipe line. The arrow and note associated with this vertical line indicate that the components to the right of the marker are also shown on LRM-205 at location G-6.

Serial No.09-231 Attachment 1 Page 45 of 48 RAI 2.3.4.8-01

Background:

LRA Section 2.3.4.8, "Air Removal System," states that components are within the scope of license renewal per 10 CFR 54.4(a)(2) and have an intended function of providing a pressure boundary.

Issue:

License renewal drawing LRM-204 location G-1, shows a section of air removal system 3" piping, not included in scope, continuing from drawing LRM-212, location 0-6, where it was included in scope for 10 CFR 54.4(a)(2).

Request:

Provide additional information to clarify the scoping classification for this pipe section.

Dominion Response The 3-inch piping (drain line to the condensate start-up dump line to the 24-inch Turbine Building standpipe) on license renewal drawing LRM-212 (location 0-6) is correctly shown as being within the scope of license renewal for 10 CFR 54.4(a)(2). The continuation of this drain line on license renewal drawing LRM-204 (location G-1) was incorrectly not highlighted up to the check valve MD10, but is within the scope of license renewal for 10 CFR 54.4(a)(2) and is included in the component type "Pipe" in LRA Table 2.3.4-8, "Air Removal." Valve MD10 and the downstream piping are separated from safety-related components by major plant equipment and are not within the scope of license renewal consistent with the methodology described in LRA Section 2.1.3.6.1 "Spatially Oriented NS SSCs Not Directly Attached to SR SSCs."

Serial No.09-231 Attachment 1 Page 46 of 48 RAI 2.3.4.9-01

Background:

LRA Section 2.3.4.9, "Heater and Moisture Separator Drains System," states that components are within the scope of license renewal per 10 CFR 54.4(a)(2) and have an intended function of providing a pressure boundary.

Issue:

Drawing LRM-207, locations C-1 and 0-1, show two instruments lines (DPS 16431 and DPS 16432) not in scope continued to instrument lines on feedwater heater 15B on LRM-206, location H-2. The continuation on LRM-206, location H-2, shows this section of instrument lines as in scope for 10 CFR 54.4(a)(2).

Request:

Provide additional information to clarify the scoping classification for this pipe section.

Dominion Response The instrument tubing to DPS 16431 and DPS 16432 on license renewal drawing LRM-206 (location H-2) is correctly shown as being within the scope of license renewal for 10 CFR 54.4(a)(2). The continuation of this tubing on license renewal drawing LRM-207 (locations C-1 and 0-1) was incorrectly not highlighted, but is within the scope of license renewal for 10 CFR 54.4(a)(2) and is included in the component type "Tubing" in LRA Table 2.3.4-9, "Heater and Moisture Separator Drains."

Serial No.09-231 Attachment 1 Page 47 of 48 RAI 2.3.4.10-01

Background:

LRA Section 2.3.4.10, "Heating Steam System," states that components are within the scope of license renewal for 10 CFR 54.4(a)(2) and have an intended function of providing a pressure boundary.

Issue:

License renewal drawing LRM-605-1, location A-1, shows a section of heating steam pipe to/from a control valve (31105/HS476) within scope for 10 CFR 55.4(a)(2). However, the same section of pipe is not included in scope on drawing LRXK-1 00-38, location 0-8.

Request:

Provide additional information to clarify the scoping classification for this pipe section.

Dominion Response License renewal drawing LRM-605-1 (location A-1) incorrectly shows a heating steam line to/from the actuator for control valve TCV-100 (311 05/HS-476). The configuration on license renewal drawing LRXK-100-38 (location D-8) correctly shows an instrument air control signal line from TIC 100 (26317) to HS-476.

Serial No.09-231 Attachment 1 Page 48 of 48 RAI 2.3.4.10-02

Background:

LRA Section 2.3.4.10, "Heating Steam System," states that components are within the scope of license renewal for 10 CFR 54.4(a)(2) and have an intended function of providing a pressure boundary.

Issue:

License renewal drawing LRM-605-1, location E-8, shows the caustic dilution water heat exchanger as not in scope. Failure of this heat exchanger casing may affect the intended function of providing a pressure boundary.

Request:

Provide additional information explaining why the caustic dilution water heat exchanger is not included in scope per 10 CFR 54.4(a)(2).

Dominion Response The caustic dilution water heat exchanger is located in an area of the Auxiliary Building where there is no potential for spatial interaction with safety-related SSCs. As such, since the failure of its pressure boundary could not affect safety-related SSCs, the heat exchanger is not within the scope of license renewal for 10 CFR 54.4(a)(2).