Text

NUREG-1928, (1:2) Chpt 3, Section 3.3 - End, Safety Evaluation Report, Related to the License Renewal of Three Mile Island Nuclear Station, Unit 1, Exelon Generation Company, LLC
	ML092950449
Person / Time
Site:	Crane
Issue date:	10/31/2009
From:	; Office of Nuclear Reactor Regulation
To:	;
References
	NUREG-1928
	Download: ML092950449 (328)
	v • d • e

3.3 Management of Auxiliary Aging Management Systems Auxiliary Systems This section of the SER documents documents the staff's review of the applicant's staffs review applicant's AMR results for the the auxiliary systems components auxiliary components and component groups of the:

- Auxiliary Auxiliary and Fuel Handling Handling Building Ventilation Systems Systems

" Auxiliary Steam System

" Circulating Water System

" Closed Cycle Cooling Water System

- Containment Isolation System

- Control Building Ventilation Ventilation System

- Cranes and Hoists Hoists

- Generator Building Ventilation System Diesel Generator

- Emergency Emergency Diesel Generators Generators and Auxiliary Systems Systems

- Fire Protection Protection System

" Fuel Handling and Fuel Storage Storage System

- Fuel Oil System

- Hydrogen Hydrogen Monitoring Monitoring

- Instrument and Control Air System

" Intake Screen and Pump House Ventilation System Intake

- Intermediate Intermediate Building Ventilation Ventilation System

Liquid and Gas Sampling System Liquid

- Miscellaneous Equipment Drains System Miscellaneous Floor and Equipment

Open Cycle Cooling Water System

- Radiation Monitoring System Radiation

- Radwaste System Radwaste

Service Building Chilled Water System Service

- Spent Fuel Cooling System

- Station Blackout and UPS Diesel Generator Generator Systems Systems

- Water Treatment Treatment & & Distribution Distribution System 3.3.1 Summary Information in the Application Summary of Technical Information Section 3.3 provides AMR results for the auxiliary systems components and component LRA Section component groups. LRA Table 3.3.1, Management Programs for Auxiliary Systems," is a 3.3.1, "Summary of Aging Management summary comparison of the applicant's AMRs with those evaluated in the GALL Report summary comparison Report for the the auxiliary components and component groups.

auxiliary systems components The applicant's applicant's AMRs evaluated evaluated and incorporated applicable plant-specific incorporated applicable plant-specific and industry industry operating experience in the determination experience plant-specific evaluation included determination of AERMs. The plant-specific included condition condition reports appropriate site personnel discussions with appropriate reports and discussions AERMs. The applicant's personnel to identify AERMs. applicant's review of industry operating experience included a review of the GALL operating experience GALL Report and operating experience operating experience issues identified since the issuance issuance of the GALL Report.

3-225 3-225

3.3.2 3.3.2 Staff Evaluation Evaluation The staff reviewed determine whether the applicant reviewed LRA Section 3.3 to determine applicant provided sufficient sufficient demonstrate that the effects of aging for auxiliary system components within the information to demonstrate information the scope of license renewal renewal and subject to an AMR, will be adequately adequately managed so that the intended maintained consistent with the CLB for the period of extended intended functions will be maintained extended operation, as required by 10 CFR 54.21 operation, 54.21(a)(3).

(a)(3).

The staff conducted an onsite audit of AMPs to ensure ensure the applicant's claim that certain AMPs AMPs were consistent with the GALL Report. The purpose purpose of this audit was to examine the applicant'sapplicant's AMPs and related documentation documentation and to verify the applicant'sapplicant's claim of consistency with the the corresponding GALL Report corresponding Report AMPs. The staff did not repeat described in matters described repeat its review of the matters the GALL Report. The staff's evaluations of the AMPs are documented documented in SER Section Section 3.0.3.

The staff reviewed the AMRs to confirm the applicant's applicant's claim that certain identified AMRs were consistent with the GALL Report. The staff did not repeat its review of the matters described described in the GALL Report; however, the staff did verify that the material presented presented in the LRA was was

. applicable and that the applicant applicant had identified the appropriate appropriate GALL Report Report AMRs. Details of the the staff's evaluation evaluation are discussed in SER Section 3.3.2.1 and 3.3.2.2.

The staff also reviewed reviewed the AMRs not consistent with or not addressed addressed in the GALL Report. The The review evaluated whether whether all plausible aging effects were identified and whether aging effects whether the aging effects listed were appropriate combination of materials and environments appropriate for the combination specified. Details of the environments specified. the discussed in SER Section 3.3.2.3.

staff's evaluation are discussed For components components which the applicantapplicant claimed were not applicableapplicable or required no agingaging management, the staff reviewed the AMR line items and the plant's operating experience to verify operating experience applicant's claims.

the applicant's Table 3.3-1 summarizes the staff's evaluationevaluation of components, aging effects effects or mechanisms, and AMPs listed in LRA Section 3.3 and addressed addressed in the GALL Report.

Evaluation for Auxiliary System Components Table 3.3-1 Staff Evaluation Components in the GALL Report Report Comonet Goup Aging Effect/,ý AMP in GALL Further, -APiLR, Saff Evalation

,(GALL Repodrt ItmNo.) Mechanism Re ort Evaluatiion in :supp pmens or GA4LL Reor Amedmients Steel cranes - structural Cumulative TLAA to be . Yes TLAA Fatigue is a TLAA exposed to air -

girders exposed fatigue damage damage evaluated for (See SER indoor uncontrolled structural girders of Section 3.3.2.2.1) 3.3.2.2.1)

(extemal) cranes. See the the (3.3.1-1))

(3.3.1-1 SRP-LR, Section 4.7 Section 4.7 for for generic guidance for generic guidance for meeting the meeting the requirements requirements of of 10 CFR 10 CFR 54.21(c)(1).

54.21(c)(1).

3-226 3-226

CmoetGroup AigEft AMP in GALL, .Further' AMP in LRA, Staff Evaluation*

(-GAILL Report Itenm No4,ý Mechan ism Ab" Report GvALLaio, Supp~lemnents, or Repore Amendments K Steel and stainless steel steel Cumulative Cumulative TLAA, evaluated evaluated in Yes TLAA TLAA Fatigue Fatigue is a TLAA piping, piping, piping components, fatigue damage damage accordance with accordance (See SER piping elements, and heat 10 10 CFR 54.21(c) 54.21(c) Section 3.3.2.2.1)

Section 3.3.2.2.1) exchanger components exchanger components exposed exposed to air - indoor uncontrolled, treated uncontrolled, borated water or treated water water (3.3.1-2)

Stainless steel heat heat Reduction of Water Chemistry Water Chemistry Yes Water Chemistry Consistent with exchanger tubes exposed exchanger heat transfer and One-Time One-Time GALL Report to treated water water due to fouling Inspection One-Time One-Time (See SER (3.3.1-3) Inspection Inspection Section 3.3.2.2.2)

Stainless Stainless steel piping, Cracking due to Water Chemistry Yes Not applicable applicable Not applicable to piping components, and stress stress corrosion corrosion and One-Time TMI-1 TMI-1 (See SER SER elements exposed to cracking piping elements cracking Inspection Inspection Section 3.3.2.2.3) sodium pentaborate sodium pentaborate solution solution> > 60°C 60'C (> 140°F)

(3.3.1-4)

Stainless Stainless steel and Cracking Cracking due to A plant specific Yes Not applicable applicable Not applicable to stainless stainless clad steel heat heat stress stress corrosion corrosion management aging management TMI-1 TMI-1 (See SER SER exchanger components exchanger components cracking cracking program is to be Section 3.3.2.2.3) 3.3.2.2.3) exposed exposed to treated water evaluated.

> 60°C (> 140°F) 140°F)

(3.3.1-5)

Stainless Stainless steel diesel Cracking Cracking due to A plant specific specific Yes Inspection Inspection of Consistent with engine exhaust piping, stress stress corrosion management aging management Internal Surfaces in GALL Report piping components, and cracking cracking program is to be Miscellaneous Miscellaneous (See SER piping elements exposed to evaluated.

evaluated. Piping and Ducting Section 3.3.2.2.3) diesel exhaust Components Components (3.3.1-6)

Stainless steel non-non- Cracking due to Water Chemistry Chemistry Yes Not applicable Not applicable Not applicable applicable to regenerative heat regenerative stress corrosion and and a plant-specific plant-specific TMI-1 (See SER SER exchanger exchanger components components cracking and verification program.

verification Section Section 3.3.2.2.4) 3.3.2.2.4) exposed exposed to treated borated cyclic loading acceptable An acceptable water water> > 60°C (> 140°F) 140'F) verification program verification program (3.3.1-7)

(3;3.1-7) include is to include temperature and radioactivity the monitoring of the shell side water, and eddy eddy current testing of tubes.

3-227 3-227

Component Group AgingPin GALL Further AMPtin LRA,/ 'staff Evaluation" Reor iemNo. Mechanis R..

epo Evaluaition, in 'Sppieentr

ýL Repot,11pot Stainless steel regenerative regenerative Cracking due to Chemistry Water Chemistry Yes Not applicable applicable applicable to Not applicable exchanger heat exchanger stress corrosion corrosion and a plant-specific plant-specific TMI-1 (See SER SER components exposed to cracking and verification program.

verification Section 3.3.2.2.4)

Section 3.3.2.2.4) treated borated water cyclic loading The AMP is to be be

> 60*C 60'C (> 140*F) 140'F) augmented by (3.3.1-8) verifying the verifying absence of cracking absence cracking due to stress stress corrosion cracking corrosion cracking and cyclic loading. A specific aging plant specific aging management management program program is to be be evaluated.

evaluated.

Stainless Stainless steel high- Cracking due to Water Chemistry Yes Not applicable applicable to Not applicable pressure pump casing in stress corrosion and a plant-specific plant-specific TMI-1 (See SER TMI-1 chemical and volume PWR chemical cracking and cracking verification program.

verification program. Section 3.3.2.2.4) control system control cyclic loading The AMP is to be (3.3.1-9)

(3.3.1-9) augmented augmented by by verifying the the absence cracking absence of cracking due to stress corrosion cracking and cyclic loading.

loading. A plant specific aging management management program is to be be evaluated.

evaluated.

High-strength steel closure High-strength Cracking due to Bolting Integrity.

Integrity. Yes Applicable Not Applicable Not Applicable Applicable to bolting exposed to air with bolting stress corrosion The AMP is to be TMI-1 (See SER SER steam or water leakage. cracking, cyclic cracking. augmented augmented by Section 3.3.2.2.4)

Section (3.3.1-10) loading appropriate appropriate inspection inspection to detect cracking if the bolts cracking bolts are not otherwise otherwise replaced replaced during maintenance.

maintenance.

Elastomer seals and Elastomer Hardening and Hardening A plant-specific plant-specific Yes Inspection of Consistent with Consistent with components exposed to air loss of strength management aging management Internal Surfaces in Report (See GALL Report

- indoor uncontrolled uncontrolled due to elastomer elastomer program is to be Miscellaneous Miscellaneous SER SER (internal/external)

(internal/external) degradation degradation evaluated. Piping Piping and Ducting 3.3.2.2.5)

Section 3.3.2.2.5)

(3.3.1-11)

(3.3.1-11 ) Components Components Surface External Surface External Monitoring Monitoring Elastomer lining exposed Elastomer exposed to Hardening Hardening and plant-specific A plant-specific Yes Inspection of Inspection Consistent with treated water or treated loss of strength strength aging management management Internal Surfaces in Internal Surfaces GALL Report (See borated water borated due to elastomer elastomer program program is to be Miscellaneous Miscellaneous SER SER (3.3.1-12) degradation degradation evaluated.

evaluated. Piping and Ducting Section Section 3.3.2.2:5)

Components Components 3-228 3-228

'co~~on~nt',G;ou~:;;:.Aging

'Component Group 'Aging 'Eff~~O',

Effectl " ",AMP . AMP in GALL ;of~rl~e~;';>

Further ~;.~tAMPi~.kR~~',:

AMP'in LRA,' .*. . .:. Sta~Evaluatioit Staff Evaluation .'

(GALL Reporttem No.) ItemNo.*Reort (GAl,.tReportlterri,No.jji:Mech~nisrTl:** -,Mechanism " .' ","Report'*.endme Evaluaftindin 'Suppemnts, or EvallJatl()n;II1*~up~le~El.nt~;~.!?r.

L.L'eARepOrt,r '.' .~. ....

':'.':+;~>;,:;~. :L;'::~;1;;:,:**,:;,¥;{;t;:4;f~;~iS;:;.~tl. ;~~(C;~~i; 'i;.;,,1.:;~j::: )~:,;>::;. :/:~ *', *.c~',* >:{ ,/ :~,~~.~,;~~Il~n ~~~:~'l'\~~;~!!!!:.??~~X!;. I<:);;~i;i:~,*:j,.>:):*,. . ;<:,:;;: . . "

Boral, boron steel Boral, steel spent Reduction of Reduction A plant-specific plant-specific Yes Water Chemistry Consistent with fuel storage racks neutron- neutron- neutron-neutron- aging management GALL Report (See absorbing sheets sheets exposed absorbing program is to be SER Section to treated water or treated capacity and evaluated.

evaluated. 3.3.2.2.6) borated water loss of material (3.3.1-13)

(3.3.1-13) due to general corrosion piping, piping Steel piping, material Loss of material Lubricating Oil Lubricating Yes Not applicable applicable Not applicable applicable to component, and piping due to general, Analysis and TMI-1 (See SER SER elements elements exposed to pitting, and One-Time One-Time Section 3.3.2.2.7) lubricating lubricating oil crevice crevice Inspection Inspection (3.3.1-14) corrosion Steel reactor reactor coolant pump pump Loss of material Lubricating Oil Lubricating Yes applicable Not applicable Not applicable to Not applicable oil collection collection system piping, due to general, general, Analysis and '. TMI-1 (See SER tubing, and valve valve bodies pitting, and One-Time One-Time Section Section 3.3.2.2.7) exposed exposed to lubricating lubricating oil crevice Inspection Inspection (3.3.1-15)

(3.3.1-15) corrosion Steel reactor reactor coolant pump pump material Loss of material Lubricating Oil Yes Not applicable applicable Not applicable applicable to oil collection collection system system tank tank due to general, general, Analysis and TMI-1 (See SER exposed to lubricating exposed lubricating oil pitting, and One-Time Section 3.3.2.2.7)

Section 3.3.2.2.7)

(3.3.1-16) crevice Inspection Inspection to corrosion evaluate the the thickness of the thickness the lower portion of the the tank Steel piping, piping piping Loss of material Water Water Chemistry Chemistry Yes Not applicable applicable Not applicable Not applicable to components, and piping due to general, general, and One-Time One-Time TMI-1 (See SER elements exposed to elements pitting, and Inspection Inspection Section Section 3.3.2.2.7) 3.3.2.2.7) treated water water crevice crevice (3.3.1-17) corrosion corrosion Stainless steel and and steelsteel Loss of of' A plant specific Yes Inspection of Consistent Consistent with diesel engine exhaust material/general material/general aging aging management management Surfaces in Internal Surfaces GALL Report piping, piping components, components, (steel only), program is to be program Miscellaneous Miscellaneous (See SER and piping elements elements pitting and evaluated.

evaluated. Piping Piping and Ducting Section 3.3.2.2.7) exposed exposed to diesel exhaust exhaust crevice crevice Components Components (3.3.1-18)

(3.3.1-18) corrosion Steel (with or without material Loss of material Buried Piping and Yes Buried Piping and Consistent with with coating or wrapping) wrapping) piping, piping, due to general, general, Tanks Surveillance Surveillance Tanks Inspection GALL Report (See piping components, and pitting, crevice, program SER Section piping elements exposed to and or or 3.3.2.2.8) soil microbiologically microbiologically (3.3.1-19) -influenced

-influenced Buried Piping Buried Piping and and corrosion corrosion Tanks Inspection Tanks Inspection 3-229 3-229

Comp*0onenhtGroup AginglEffectl- AMP in GALL Further AM LR,

_(GALL Report.Item. No.) MechanismRo..rt Evaluation nSpp ements; o

- e- rt. ~Amen L' RGAL ntsi Steel piping, piping piping Loss of material Fuel Oil Chemistry Yes Yes Fuel Oil Chemistry Consistent with with components, piping piping One-Time due to general, and One-Time One-Time One-Time GALL elements, tanks elements, and tanks pitting, crevice, crevice, Inspection Inspection and (See SER exposed to fuel oil and Inspection of Section 3.3.2.2.9)

(3.3.1-20) microbiologically microbiologically Internal Surfaces in Intemal

-influenced

-influenced Miscellaneous Miscellaneous corrosion, and Piping and Ducting fouling Components Components Steel heat exchanger exchanger Loss of material Lubricating Oil Lubricating Yes Lubricating Oil Lubricating Consistent with Not Consistent components exposed, components exposed to due to general, general, Analysis and*

and Analysis and Report (See GALL Report lubricating oil lubricating pitting, crevice, One-Time One-Time SER (3.3.1-21))

(3.3.1-21 and Inspection Inspection Inspection Inspection Section 3.3.2.2.9) microbiologically microbiologically

-influenced

-influenced corrosion, and fouling fouling elastomer lining Steel with elastomer material Water Chemistry lining Loss of material Chemistry Yes Not applicable applicable Not applicable applicable toto or stainless steel cladding due to pitting and One-Time One-Time TMI-1 (See SER piping, piping components, and crevice Inspection Section 3.3.2.2.10) and piping elements corrosion (only corrosion (only exposed exposed to treated water for steel after and treated treated borated lining/cladding borated water lining/cladding (3.3.1-22)

(3.3.1-22) degradation)..

degradation)

Stainless Stainless steel and steel Loss of material material Water Chemistry Yes Water Chemistry Chemistry Consistent Consistent with with with stainless steel cladding due to pitting One-Time and One-Time and One-Time One-Time GALL Report (See heat exchanger exchanger and crevice crevice Inspection Inspection Inspection SER Section components exposed to components corrosion 3.3.2.2.10) 3.3.2.2.10)'

treated water water (3.3.1-23)

(3.3.1-23)

Stainless Stainless steel and Loss of material Water Water Chemistry Yes Water Chemistry Chemistry Consistent with aluminum piping, piping aluminum due'to due to pitting and One-Time One-Time One-Time and One-Time GALL Report Report (See components, and piping piping and crevice crevice Inspection Inspection Inspection Inspection SER Section elements exposed exposed to corrosion corrosion 3.3.2.2.10) 3.3.2.2.10) treated water water (3.3.1-24)

Copper Copper alloy HVACHVAC piping, Loss of material material A plant-specific plant-specific Yes Inspection of Inspection Consistent with with piping components, components, piping piping due to pitting aging management management Internal Surfaces in Intemal GALL GALL Report elements exposed elements exposed to and crevice program program is to be Miscellaneous Miscellaneous (See SER ilý:

condensation (extemal)

(external) corrosion evaluated.

evaluated. Piping and Ducting Ducting Section 3.3.2.2.10)

Section 3.3.2.2.10)

(3.3.1-25) Components and and Extemal Surfaces External Surfaces MonitOring Monitoring Program 3-230 3-230

'Component Grou u gpng Effctl'.AMP in'GALL Evauaio uri-ther"' Supplments AMP in LRA,:'. or Staff;Ealuation

Er (GALLReport Item, No.) Mechanism Report - EaluatiLneio SupAmenments, or Copper alloy piping, piping Copper piping Loss of material Loss of material Lubricating Lubricating Oil Yes Lubricating Lubricating Oil Consistent with Consistent with components, and components, and piping piping due to pitting due pitting Analysis and Analysis and Analysis and Analysis and GALL Report GALL elements exposed elements exposed to and crevice and crevice One-Time One-Time One-Time One-Time (See SER lubricating oil lubricating corrosion corrosion Inspection Inspection Inspection Inspection Section Section 3.3.2.2.10) 3.3.2.2.10)

(3.3.1-26)

(3.3.1-26) Internal Intemal Surfaces Surfaces in Miscellaneous Miscellaneous Piping and and Ducting Ducting Components Components Stainless steel Stainless steel HVAC HVAC material Loss of material plant-specific A plant-specific Yes Yes Inspection of Inspection Consistent Consistent with with ducting and aluminum ducting aluminum pitting due to pitting aging management aging management Internal Surfaces Internal Surfaces in GALL GALL Report HVAC piping, piping HVAC and crevice program is to be program Miscellaneous Miscellaneous (See SER components components and pipingpiping corrosion evaluated. Piping Piping and Ducting Section Section 3.3.2.2.10) elements exposed to elements exposed Components Components condensation (3.3.1-27)

Copper alloy alloy fire protection protection Loss of material A plant-specific plant-specific Yes Yes Inspection of Inspection Consistent with Consistent with piping, piping piping, piping components, components, due to pitting aging management management Internal Surfaces Internal Surfaces in GALL GALL Report and piping piping elements elements and crevice crevice program is to be program Miscellaneous Miscellaneous (See SER exposed to condensation condensation corrosion evaluated. Piping Piping and Ducting Section 3.3.2.2.10)

Section 3.3.2.2.10)

(intemal)

(internal) Components Components (3.3.1-28) Protection Fire Protection Fire Water System Compressed Compressed Air Air Monitoring Monitoring OneTime One Time Inspection Inspection Stainless steel piping, material Loss of material plant-specific A plant-specific Yes Buried Piping and Buried Consistent with Consistent with piping components, components, and due due to pitting aging management Inspection Tanks Inspection GALL GALL Report Report (See piping elements exposed to and crevice elements exposed be program is to be" program program SER Section soil corrosion evaluated.

evaluated. 3.3.2.2.10.)

(3.3.1-29)

Stainless steel piping, Loss of material Water Chemistry Yes Not applicable applicable Not applicable to Not piping components, and due to pitting and One-Time TMI-1 (See SER piping elements exposed to and crevice Inspection Section 3.3.2.2.10) pentaborate sodium pentaborate corrosion solution (3.3.1-30)

Copper alloy piping, piping Loss of material Water Chemistry Yes Notapplicable Not applicable Not applicable to Not components, and piping due to pitting, and One-Time TMI-1 (See SER elements exposed to crevice, and Inspection Inspection 3.3.2.2.11)

Section 3.3.2.2.11) treated water galvanic (3.3.1-31))

(3.3.1-31 corrosion 3-231

Component Grou'U7 Agng, Efet' AM nGLL FrhAMPI inLRA,ý' .Staff'Evaljuation-..

'(GALL Report Item No.) Mechanism Report Evluatini upeeto

- ~GALL 4pr &4ý,z, Amendments Stainless steel, aluminum Loss of material Fuel Fuel Oil Chemistry Yes Fuel Oil Chemistry Consistent with Fuel and copper alloy piping, due to pitting, and One-Time One-Time GALL Report (See piping components, piping components, and and crevice, and Inspection Inspection Inspection Inspection SER Section piping elements exposed to piping microbiologically microbiologically 3.3.2.2.12) .

oil fuel oil -influenced

-influenced (3.3.1-32) corrosion Stainless steel piping, Lubricating Oil Loss of material Lubricating Yes Inspection of Consistent with Consistent piping components, and due to pitting, Analysis and Surfaces in Internal Surfaces GALL Report piping elements exposed exposed to crevice, and One-Time One-Time Miscellaneous Miscellaneous (See SER (See lubricating oil lubricating microbiologically Inspection microbiologically Inspection Piping and Ducting_

Ducting Section 3.3:2.2.12) 3.3.2.2.12)

(3.3.1-33) -influenced Components Components corrosion External Surfaces External Surfaces Monitoring Monitoring Program Program Lubricating Lubricating Oil Analysis Analysis One-Time One-Time Inspection Inspection Elastomer seals and Elastomer material Loss of material plant-specific A plant-specific Yes Not applicable applicable applicable to Not applicable components components exposed exposed to air due to wear wear aging management management TMI-1 (See SER SER

-- indoor uncontrolled indoor uncontrolled program is to be Section Section 3.3.2.2.13) 3.3.2.2.13)

(internal (internal or extemal) extemal) evaluated.

(3.3.1-34)

Steel with stainless steel Loss of material A plant-specific plant-specific Yes applicable Not applicable Not applicable to Not applicable cladding cladding pumppump casing due to cladding cladding aging management aging management TMI-1 (See SER (See'SER exposed exposed to treated treated borated borated breach program program is to be Section Section 3.3.2.2.14) 3.3.2.2.14) water water evaluated.

evaluated.

(3.3.1-35)

Reference Reference NRCNRC IN IN 94-63, 94-63, "Boric "Boric Acid Acid Corrosion Corrosion ofof Charging Pump Charging Pump Casings Caused Caused by by Cladding Cracks."

Cladding Boraflex Boraflex spent fuel storage storage Reduction of Reduction of Boraflex Monitoring Boraflex Monitoring No Not applicable applicable Not applicable applicable to racks neutron-absorbing neutron-absorbing neutron-neutron- TMI-1 (See SER sheets exposed to treated sheets absorbing absorbing Section 3.3.2.1.1) 3.3.2.1.1) water water capacity capacity due to to (3.3.1-36)

(3.3.1-36) boraflex boraflex degradation degradation 3-232 3-232

Component Group AgingEffectd AMP, ini GALL Furhe AMPiný -RA*;., Staff Evaluatibrun.

"(GALL Report Item No.). Mechanism Repo. Evlain in 'SupIeets or S GAý!LLReport -Amendrnents.

Stainless Stainless steel piping, piping, Cracking due to BWR Cracking BWR Reactor Reactor Water Water No Not Not applicable applicable Not Not applicable applicable to piping piping components, and stress stress corrosion corrosion Cleanup Cleanup System System TMI-1 (See SER SER piping elements exposed piping elements exposed to cracking, cracking, Section Section 3.3.2.1.1) 3.3.2.1.1) treated water treated water> 60°C

> 60°C intergranular intergranular

(> 140'F)

(> 140°F) stress stress corrosion (3.3.1-37)

(3.3.1-37) cracking cracking Stainless Stainless steel piping, piping, Cracking Cracking due to BWR BWR Stress No Not Not applicable applicable Not Not applicable applicable to piping components, components, and stress stress corrosion Corrosion Corrosion Cracking Cracking TMI-1 (See SER SER piping elements elements exposed exposed to to cracking cracking and Water Water Section Section 3.3.2.1.1) 3.3.2.1.1) treated treated water water> > 60°C Chemistry

(> 140°F) 140°F)

(3.3.1-38)

Stainless steel steel BWR spent spent Cracking Cracking duedue to Water Chemistry No Not Not applicable Not applicable to Not applicable to fuel fuel storage racks exposed exposed stress corrosion corrosion TMI-1 (See SER to treated treated water water> > 60°C 60'C cracking Section 3.3.2.1.1)

Section 3.3.2.1.1)

(> 140°F) 140°F)

(3.3.1-39)

Steel tanks in in diesel fuel oil Loss of Aboveground Steel of material Aboveground Steel No Aboveground Steel Consistent Aboveground Consistent with with system exposed exposed to air - due to general, general, Tanks Tanks GALL Report (external) outdoor (extemal) pitting, and (3.3.1-40)

(3.3.1-40) crevice crevice corrosion High-strength steel closure High-strength Cracking due to Bolting Integrity Integrity No Not applicable Not applicable to Not applicable bolting exposed exposed to air with cyclic loading, TMI-1 (See SER SER steam or water water leakage leakage stress corrosion corrosion Section 3.3.2.1.1)

Section 3.3.2.1.1)

(3.3.1-41)

(3.3.1-41 ) cracking Steel closure bolting Loss of material Bolting Integrity Integrity No Not applicable Not applicable applicable to Not applicable to exposed to air with steam due to general general TMI-1 (See SER or water leakage corrosion Section 3.3.2.1.1)

Section 3.3.2.1.1)

(3.3.1-42)

Steel bolting and closure material Bolting Integrity Loss of material No External Surfaces Extemal Consistent with bolting exposed to air - due to general, Monitoring GALL Report uncontrolled indoor uncontrolled pitting, and Program Program (See SER (external)

(extemal) or air - outdoor crevice crevice Bolting Integrity Bolting Integrity Section 3.3.2.1.2)

Section 3.3.2.1.2)

(external)

(extemal) corrosion corrosion Program (3.3.1-43)

(3.3.1-43)

Steel compressed compressed air Loss of material Bolting Integrity No Not applicable applicable Not applicable to system closure bolting due to general, SER TMI-1 (See SER exposed to condensation pitting, and 3.3.2.1.1)

Section 3.3.2.1.1)

(3.3.1-44) crevice corrosion 3-233

.Componnt G'up Ag..ing Effectl '.AMP'in GALL -- :."Further AMP inA"StaffEvaluation S(GA4LLReport Item No.) Mechanism Report

Evaluati.ni inýSupplements, or

......... GALL Report ,Amendments -

Steel closure bolting Steel Loss of preload Bolting Integrity No Integrity Bolting Integrity Consistent with exposed to air - indoor exposed due to thermal thermal Program Program GALL Report Report uncontrolled uncontrolled (external) effects, gasket gasket Inspection Inspection of (See SER Section (3.3.1-45)

(3.3.1-45) creep, and and self- Overhead Heavy 3.3.2.3.7) loosening Load and Load Light and Light Load Handling Load Handling Systems Systems Stainless steel Stainless steel and Cracking due to Cracking Closed-Cycle to Closed-Cycle No Closed-Cycle Closed-Cycle Consistent Consistent with stainless stainless clad steel piping, stress corrosion Cooling Water Water Water Cooling Water GALL GALL Report piping components, piping piping cracking System System elements, and heat heat components exchanger components exchanger exposed to closed cycle cycle cooling cooling water > 60'C (> 140TF) water> 140'F)

(3.3.1-46)

Steel piping, piping Loss of material Closed-Cycle Closed-Cycle No Closed-Cycle Closed-Cycle Consistent with components, piping due to general, general, Cooling Water Cooling Water Water GALL Report elements, tanks, and heat pitting, and System System exchanger components exchanger crevice exposed to closed cycle corrosion cooling water water (3.3.1-47)

(3.3.1-47)

Steel piping, piping Loss of material material Closed-Cycle Closed-Cycle No Closed-Cycle Closed-Cycle Consistent with components, piping due to general, Cooling Water Cooling Water Report (See GALL Report elements, tanks, and heat pitting, crevice, System System SER Section exchanger components exchanger components and galvanic 3.3.2.1.15) exposed to closed closed cycle corrosion corrosion cooling water (3.3.1-48)

Stainless steel; steel with Loss of material Closed-Cycle Closed-Cycle No Not applicable applicable applicable to Not applicable stainless steel cladding cladding due to Cooling Water TMI-1 (See SER heat exchanger exchanger microbiologically System microbiologically Section 3.3.2.1.1)

Section 3.3.2.1.1) components exposed to -influenced closed cycle cooling water corrosion (3.3.1-49)

(3.3.1-49)

Stainless steel piping, Stainless Closed-Cycle Loss of material Closed-Cycle No No Closed-Cycle Closed-Cycle Consistent with piping components, and due to pitting Cooling Water Cooling Water Report GALL Rep<;>rt piping elements exposed to and crevice System System closed cycle cooling water corrosion corrosion (3.3.1-50) 3-234 3-234

") Component Gro - Aging'Efct.M..L. '...ther

AMP in LRA, ., Staff Evaluation

'echnis 1ýý.(GLLReprt temNo., Reort Evaluation in Spplements, or (GALL~~~GLL Repor ItmN.oehnseotr~t Amendments.

Copper alloy piping, Copper piping, piping Loss of material Closed-Cycle Closed-Cycle No Closed-Cycle Closed-Cycle Consistent with piping components, piping due to pitting, Cooling Water Cooling Water GALL Report (See elements, and heat heat crevice, and and System System SER Section exchanger components exchanger galvanic 3.3.2.1.16) exposed to closed cycle exposed corrosion cooling water (3.3.1-51))

(3.3.1-51 Steel, stainless steel, and Reduction Reduction of Closed-Cycle Closed-Cycle No Closed-Cycle Closed-Cycle Consistent with copper alloy heat heat heat transfer Cooling Water Cooling Water GALL Report exchanger exposed exchanger tubes exposed due to fouling System System to closed cycle COOling cooling water (3.3.1-52)

(3.3.1-52)

Steel compressed compressed air Loss of material material Compressed Compressed Air No Not appiicable applicable Not applicable to Not applicable system piping, piping due to general due Monitoring TMI-1 (See SERSER components, and piping and pitting Section Section 3.3.2.1.1) 3.3.2.1.1) erements exposed to efements corrosion corrosion (internal) condensation (intemal)

(3.3.1-53)

Stainless steel compressed Stainless compressed Loss of material Compressed Compressed Air No Inspection of Inspection Consistent Consistent with air system piping, piping, piping due to pitting Monitoring Monitoring Surfaces in Internal Surfaces Intemal GALL Report components, and piping components, and crevice Miscellaneous Miscellaneous (See SER elements exposed to elements corrosion corrosion Piping and Ducting Ducting Section 3.3.2.1.3)

Section internal condensation intemal Components Components (3.3.1-54) Protection Fire Protection Fire Water Fire System Water System Compressed Air Compressed Air Monitoring Monitoring Steel ducting closure Steel External Surfaces Loss of material Extemal Surfaces No External Surfaces Extemal Surfaces Consistent Consistent with bolting exposed to air - due to general general Monitoring Monitoring Monitoring Monitoring GALL Report uncontrolled indoor uncontrolled corrosion (external)

(extemal)

(3.3.1-55)

Steel HVAC ducting and Loss of material External Surfaces material Extemal No External Surfaces Extemal Surfaces Consistent with with components extemal external due to general general Monitoring Monitoring Monitoring GALL Report exposed to air -

surfaces exposed corrosion uncontrolled indoor uncontrolled (external)

(extemal)

(3.3.1-56)

Steel piping and and Extemal Surfaces Loss of material External Surfaces No External Surfaces Extemal Consistent with components extemal components external due to general Monitoring Monitoring Monitoring Monitoring GALL Report surfaces exposed to air -

surfaces corrosion uncontrolled indoor uncontrolled (external)

(extemal)

(3.3.1-57) 3-235 3-235

Componient'Group. Aging Effect. AMP in GL hstaffEvaluation (GALL Report Item No.), Mechanism, Report Evaluation in upplements, or, GALLReport Amenndment& >.

Steel external Steel extemal surfaces surfaces Extemal Surfaces material External Loss of material Surfaces No Fire Protection Fire Protection Consistent with exposed to airair - indoor due to general general Monitoring Monitoring Extemal Surface External Surface GALL Report Report (See (See uncontrolled (extemal), air uncontrolled (external), air - corrosion Monitoring Monitoring SER Section outdoor (external),

(extemal), and and 3.3.2.1.4) condensation (external) condensation (extemal)

(3.3.1-58)

Steel heat exchanger Steel exchanger Extemal Surfaces material External Loss of material Surfaces No External Extemal Surfaces Surfaces Consistent with Consistent components exposed components exposed to air due to general, Monitoring due Monitoring Monitoring Monitoring GALL Report indoor uncontrolled

- indoor uncontrolled pitting, and pitting, and (extemal) or (external) or air -outdoor

-outdoor crevice crevice (extemal)

(external) corrosion corrosion (3.3.1-59)

St~el piping, piping Steel Loss Surfaces External Surfaces Loss of material Extemal No Fire Protection Protection Consistent Consistent with components, and piping general, Monitoring due to general, Monitoring Extemal Surfaces External Surfaces GALL GALL Report elements exposed to air -

elements pitting, and pitting, Monitoring Monitoring (See SER SERI1 outdoor (external) outdoor (extemal) crevice crevice Inspection Inspection ofof Sections Sections 3.3.2.1.5, (3.3.1-60)

(3.3.1-60) corrosion Overhead Heavy Overhead 3.3.2.3.7) 3.3.2.3.7)

Load and Light Light (Related to Load (Related to Refueling)

Refueling)

Handling Systems Systems Elastomer fire barrier Elastomer Increased Increased Fire Protection Protection No No Fire Protection Consistent Consistent with penetration seals exposed exposed hardness, GALL GALL Report to shrinkage andand air - outdoor or loss of strength indoor uncontrolled air - indoor uncontrolled due to (3.3.1-61 (3.3.1-61)) weathering Aluminum piping, piping Loss of material material Fire Protection No Fire Water Water System Consistent :with Consistent with components, and piping due to pitting Structures GALL Report GALL elements exposed exposed to raw and crevice Monitoring (See SER water corrosion Program 3.3.2.1.6)

Section 3.3.2.1.6)

(3.3.1-62)

Steel fire rated doors Loss of material Fire Protection Protection No Fire Protection Consistent with Consistent.,with I,

exposed to air - outdoor or due to wear Inspection of GALL Report (See air - indoor uncontrolled Overhead Heavy Overhead SER Section (3.3.1-63) Load and Light 3.3.2.3.7) .

Load (Related Load to (Related to Refueling)

Refueling)

Systems Handling Systems Handling Steel Steel piping, piping, piping material Fire Protection and Loss of material No No applicable Not applicable Not applicable to components, and piping Chemistry due to general, Fuel Oil Chemistry TMI-1 (See SER SER elements exposed exposed to fuel pitting, and 3.3.2.1.1)

Section 3.3.2.1.1) oil crevice (3.3.1-64) corrosion 3-236

Compon-enrt, Group AgiriEffectI.ý AMP--in GALL. :Further AMPý fin LRA,-: SffEauati"'ni-(GALL Report Item No.) Mechanisml,ý Report Evaluation in 'Supplements, or G6ALL; Report Amnendments.

Reinforced Reinforced concrete Concrete Concrete Fire Protection Protection and No Fire Protection Consistent with with structural fire barriers barriers - cracking and Structures Structures Structures Report GALL Report walls, ceilings walls, ceilings and and floors spalling due to Monitoring Monitoring Program Program Monitoring exposed to air - indoor aggressive aggressive Program Program uncontrolled uncontrolled chemical attack, (3.3.1-65) and reaction with aggregates aggregates Reinforced concrete Reinforced Concrete Fire Protection and No Fire Protection Consistent with structural fire barriers - cracking and Structures Structures Structures Structures GALL Report walls, ceilings ceilings and floors spalling spalling due to Monitoring Program Monitoring Monitoring exposed exposed to air - outdoor freeze thaw, Program Program (3.3.1-66)

(3.3.1-66) aggressive aggressive i~ chemical chemical attack, and reaction reaction with aggregates aggregates Reinforced Reinforced concrete Loss of material Fire Protection Protection and No Fire Protection Consistent with structural structural fire barriers barriers - due to corrosion Structures Structures Structures Structures GALL Report walls, ceilings and floors of embedded embedded Monitoring Program Monitoring Program Monitoring Monitoring exposed exposed to to air -- outdoor or steel Program Program air - indoor uncontrolled uncontrolled (3.3.1-67)

Steel piping, Steel piping piping, piping Loss of material Fire Water System No Inspection of Inspection Consistent with components, and piping components, piping due to general, due Internal Surfaces in Internal in GALL Report elements exposed to raw elements pitting, crevice, Miscellaneous Miscellaneous (See SER water and Piping and Ducting Section 3.3.2.1.7)

(3.3.1-68) microbiologically microbiologically Components Components

-influenced

-influenced and corrosion, and External Surfaces Extemal Surfaces fouling Monitoring Monitoring Program (8.2.1.21)

(B.2.1.21)

Fire Water Water System Stainless steel piping, Loss of material material Fire Water Water System No Fire Water Water System Consistent with piping components, piping components, and due to pitting GALL Report piping elements elements exposed to and crevicecrevice raw water corrosion, corrosion, and (3.3.1-69) fouling fouling Copper alloy Copper alloy piping, piping piping Loss of material material Fire Water System No Fire Water System System Consistent with components, and piping components, due due to pitting, GALL Report elements exposed to raw crevice, and water microbiologically microbiologically (3.3.1-70) -influenced

-influenced corrosion, andand fouling fouling 3-237

Component Group': Aging Effectl AMPin GALL Further AMPin LRA, StaffEvaluatiOn (GALL Report Item No.) Mechanism Report Evaluation in Suppleements-,or GALL Repor Aýmenidments Steel piping, piping Steel Loss of material Loss material Inspection of No Fire Protection Fire Consistent with components, and piping components, due to general, in Internal Surfaces in Compressed Air Compressed GALL Report elements exposed to moist elements pitting, and pitting, Miscellaneous Miscellaneous Monitoring Monitoring SER (See SER or condensation air or crevice Piping and Piping and Ducting Ducting Inspection of Inspection of Section 3.3,:2.1.8)

Section 3.32.1.8)

(internal)

(internal) corrosion Components Components Internal Surfaces Internal Surfaces in in (3.3.1-71))

(3.3.1-71 Miscellaneous Miscellaneous Piping and Ducting Piping Ducting Components Steel HVAC ducting and Loss of of material Inspection of Inspection No Compressed Air Air Consistent with components internal due to to general, general, Surfaces in Internal Surfaces in Monitoring Report (See GALL Report surfaces exposed to pitting, crevice, Miscellaneous Miscellaneous Inspection of SER Section condensation (internal) and (for drip Piping and Ducting Internal Surfaces in Intemal in 3.3.2.1.9) I (3.3.1-72) pans and drain Components Miscellaneous Miscellaneous lines) lines) Piping and Piping Ducting and Ducting microbiologically microbiologically Components Components

-influenced

-influenced corrosion corrosion Steel crane structural Inspection of Loss of material Inspection No Inspection of Consistent with girders inin load handling due to general Overhead Heavy Overhead Heavy Overhead Heavy Overhead GALL Report system exposed to air - corrosion Load and Light Load Load and Light indoor uncontrolled uncontrolled (Related to Load (Related to (external) Refueling)

Refueling) Handling Refueling)

Refueling)

(3.3.1-73) Systems Handling Handling Systems Systems Program Program Steel cranes - rails exposed Loss of material material Inspection of*

Inspection of' No Inspection Inspection of with Consistent with to air - indoor uncontrolled uncontrolled due to Wear Overhead Heavy Overhead Heavy Overhead Heavy Overhead Heavy GALL Report (external) Load and Light Load Load and Light Light (3.3.1-74) (Related to Load (Related (Related to Refueling) Handling Refueling) Handling Refueling)

Refueling)

Systems Handling Systems Systems Program Program Elastomer Elastomer seals and and Hardening Hardening and Open-Cycle Cooling and Open-Cycle Cooling No No Not applicable applicable Not applicable applicable to components components exposed to loss of strength Water SystemSystem TMI-1 TMI-1 (See SER SER raw water water due to elastomer Section 3.3.2.1.1)

Section 3.3.2.1.1)

(3.3.1-75) degradation; loss of loss material of material due to due to erosion erosion Steel piping, piping, piping Loss Loss of material material Open-Cycle Cooling Cooling No Inspection Inspection of Consistent Consistent with components, and piping due to general, Water Water System Internal Surfaces in Intemal Surfaces GALL Report Report elements (without lining/

lining/ pitting, pitting, crevice, Miscellaneous Miscellaneous (See SER SER coating coating or with degraded degraded and Piping and Ducting Sections Sections 3.3.2.1.10, 3.3.2.1.10, lining/coating) lining/coating) exposed exposed to microbiologically microbiologically Components Components 3.3.2.1.17) 3.3.2.1.17) raw raw water -influenced

-influenced Open Open Cycle Cycle (3.3.1-76) corrosion, Cooling Cooling Water Water fouling, fouling, andand System System lining/coating lining/coating degradation degradation 3-238 3-238

Component Group Aging Effect/. AMP in GALL Further. AMP in LRA,, .,StiffEvaluation

.(GALL R eport Item No'.)_ Mechanism, Report, EvISIuation in or GALL anm Sorot exchanger Steel heat exchanger Loss of material Open-Cycle Open-Cycle Cooling No applicable Not applicable Not applicable to components components exposed to due to general, Water System TMI-1 (See SER raw water pitting, crevice, Section 3.3.2.1.1)

Section 3.3.2.1.1)

(3.3.1-77)

(3.3.1-77) galvanic, and microbiologically microbiologically

-influenced

-influenced corrosion, andand fouling fouling Stainless steel, nickel alloy, Loss of material Open-Cycle Open-Cycle Cooling No Inspection of Consistent Consistent with with and copper copper alloy alloy piping, due due to pitting pitting Water Water System Internal Surfaces Intemal Surfaces in GALL Report piping components, and and crevice crevice Miscellaneous Miscellaneous (See SER piping elements elements exposed exposed to corrosion corrosion Piping Piping and Ducting Section 3.3.2.1.11)

Section 3.3.2.1.11) raw water Components Components (3.3.1-78) Open-Cycle Open-Cycle Cooling Water System Stainless steel piping, Loss of material material Open-Cycle Open-Cycle Cooling No Not applicable Not applicable to piping components, and due to pitting Water System TMI-1 (See SER piping elements exposed to elements exposed and crevice 3.3.2.1.1)

Section 3.3.2.1.1) raw water corrosion, corrosion, andand (3.3.1-79) fouling Stainless Stainless steel and copper copper Loss of material Open-Cycle Open-Cycle Cooling No Open-Cycle Open-Cycle Consistent with alloy piping, piping due to pitting, Water System Cooling Water GALL Report components, and piping crevice, and System (See SER elements elements exposed exposed to raw microbiologically microbiologically Fire Water Water System Section 3.3.2.1.12) water -influenced

-influenced (3.3.1-80)

(3.3.1-80) corrosion Copper Copper alloy piping, piping Loss of material Open-Cycle Open-Cycle Cooling No Inspection of Inspection Consistent with Consistent components, and piping due to pitting, Water System Internal Surfaces in Internal GALL Report elements, exposed to raw crevice, and Miscellaneous Miscellaneous (See SER water microbiologically microbiologically Piping and Ducting Section 3.3.2.1.13)

(3.3.1-81)

(3.3.1-81) -influenced

-influenced Components Components corrosion, and Open Cycle Cycle fouling Cooling Water System Copper alloy heat Loss of material Open-Cycle Cooling No material Open-Cycle Open-Cycle Open-Cycle Consistent with exchanger components components due to pitting, pitting, Water System System Cooling Water Water GALL Report Report (See exposed to raw water crevice, crevice, System SER Section (3.3.1-82) galvanic, and 3.3.2.1.18) microbiologically microbiologically

-influenced

-influenced corrosion, and and fouling Stainless steel and copper Reduction of copper Reduction Open-Cycle Cooling No Open-Cycle Open-Cycle Open-Cycle Consistent Consistent with alloy heat exchanger tubes heat transfer heat exchanger transfer Water System Cooling Water GALL Report exposed to raw water due to fouling System (3.3.1-83) 3-239

t4~~~~~I~~~: l~r~A~~~t~\~1~!; :~~~~ilt{~I~~~~ t\ta\~~~~~t~,'

Component Group Aging Effectl - AMP in GALL Further; AMP in LRA, Staff Evalu~ation (GALL Report Item No.) Mechanism R.port Evaluation in Supplements, or, -

~GALL Report Aendments Copper alloy Copper alloy>> 15% Zn Loss of material material Selective Leaching Leaching No No Selective Leaching Selective Leaching Consistent with with piping, piping, piping piping components, due to selective Materials selective of Materials GALL Report piping elements, and heat leaching exchanger components exchanger components exposed exposed to raw water, treated water, or closed cycle cooling water water (3.3.1-84)

Gray cast iron piping, Loss of material Selective Leaching Selective Leaching No Selective Leaching Leaching Consistent Consistent with piping components, and due to selective of Materials GALL Report piping elements elements exposed to leaching soil, raw water, treated water, or closed-cycle closed-cycle cooling water (3.3.1-85)

Structural steel (new fuel Loss of material Structures Structures No Fire Protection Consistent with storage rack assembly) due to general, Monitoring Program GALL GALL Report exposed exposed to air - indoor indoor pitting, pitting, and (See SER Section uncontrolled (external)

(extemal) crevice crevice 3.3.2.1.14)

(3.3.1-86)

(3.3.1-86) corrosion Boraflex spent fuel storage Reduction Reduction of Boraflex Monitoring No Not applicable Not applicable Not applicable to Not neutron-absorbing racks neutron-absorbing neutron-neutron- TMI-1 (See SER sheets exposed to treated absorbing absorbing Section 3.3.2.1.1)

Section 3.3.2.1.1) borated borated water capacity due to (3.3.1-87)

(3.3.1-87) boraflex boraflex degradation degradation Aluminum and coppercopper alloy Loss of material Boric Acid Corrosion No Boric Acid Acid Consistent ,with Consistent with

>> 15%

15% Zn piping, piping due to boric acid Corrosion GALL Report components, and and piping corrosion elements elements exposed exposed to air air leakage with borated water leakage (3.3.1-88)

(3.3.1-88)

Steel bolting bolting and external Loss of material Boric Acid Corrosion No Boric Acid Consistent with surfaces exposed to air surfaces due to boric acid Corrosion GALL Report with borated borated water water leakage corrosion (3.3.1-89)

(3.3.1-89)

Stainless steel andand steel Cracking Cracking due to Water Water Chemistry Chemistry No Water Chemistry, Consistent with with stainless steel cladding cladding stress corrosion or Water Chemistry Chemistry GALL Report Report (See piping, piping components, cracking cracking One-Time and One-Time SER SER Section Section piping elements, tanks, and Inspection Inspection 3.3.2.1.19) 3.3.2.1.19) fuel storage racks exposed exposed to treated borated borated water

>> 60°C 140 0 F) 60*C (> 140*F)

(3.3.1-90)

(3.3.1-90) 3-240

ComonntGrop~~ Agng ff'cP AMP in GALL .Further AMP in LRA~, Staf t' Evluti (GALL Report Item No.) -Mechanism' Report .Evaluation in, Supplements, or-

- :'

'~~..' GALL ReportAedmns Stainless Stainless steel and steel Loss of material material Water Chemistry No Water Chemistry, Consistent with cladding with stainless steel cladding due to pitting or Water Chemistry GALL Report (See piping, piping components, and crevice and One- SER Section and piping elements corrosion Inspection Inspection 3.3.2.1.19) 3.3.2.1.19) exposed to treated borated water water (3.3.1-91))

(3.3.1-91 Galvanized steel piping, Galvanized None None No None None the Consistent with the piping components, and GALL Report piping elements exposed to uncontrolled air - indoor uncontrolled (3.3.1-92)

Glass piping piping elements elements None None None None No None Consistent with the the exposed to air, air - indoor GALL Report uncontrolled (external), fuel uncontrolled lubricating oil, raw oil, lubricating water, treated water, and treated borated water water (3.3.1-93)

Stainless steel and nickel None None None None No None Consistent with the the alloy piping, piping GALL Report components, and pipingpiping elements exposed to air --

indoor uncontrolled uncontrolled (external)

(3.3.1-94) piping, None Steel and aluminum piping, None None No None Consistent with the the piping components, and GALL Report exposed to piping elements exposed air - indoor controlled controlled (external)

(3.3.1-95)

Steel and stainless steel None None No None Consistent with the the piping, piping components, GALL Report elements in and piping elements in concrete concrete (3.3.1-96)

Steel, stainless steel, None None None No None Consistent with the the aluminum, and copper alloy aluminum, GALL Report piping, piping components, and piping elements elements exposed to gasgas (3.3.1-97) 3-241

Compnonen~t:G~roup). Aging Effctl AMP in, GALL- F ýStaff Evaluation

,ý(GALL RIeport Item No.),I Mechanism, Report, IEval I JGAL Steel, stainless Steel, stainless steel, andand None None None None No None Consistent Consistent with with the the copper alloy piping, copper piping, piping piping GALL GALL Report components, and piping components, piping elements exposed elements exposed to dried dried air air (3.3.1-98)

Stainless steel and Stainless steel and copper copper None None None None No None Consistent ~ith the Consistent with the 15% Zn piping, alloy << 15% piping, GALL GALL Report piping components, components, and and piping elements elements exposed exposed to air with borated water air water leakage leakage (3.3.1-99)

(3.3.1-99)

The staff's staffs review review of the auxiliary auxiliary systems component groups systems component groups followed several approaches.

approaches.: One One approach, documented in SER Section approach, documented SER Section 3.3.2.1, discusses 3.3.2.1, discusses the staffs staffs review of AMR results for components components the applicant applicant indicated are are consistent with the GALL GALL Report and require require no further further evaluation. Another Another approach, discusses the staffs review of documented in SER Section 3.3.2.2, discusses approach, documented AMR results for components components the applicant applicant indicated are consistent consistent with the GALL GALL Report and for .

which which further evaluation evaluation is recommended.

recommended. A third approach, documented documented in SER Section 3.13.2.3, 3Ji3.2.3, discusses the staffs review of AMR results for components the applicant indicated indicated are not consistent with or not addressedaddressed in the GALL Report. The staffs staffs review of AMPs credited to to manage manage or monitor aging effects of the auxiliary systems components is documented documented in SER Section 3.0.3. .

3.3.2.1 3.3.2.1 AMRAMR Results That Are Consistent Consistentwith the GALL GALL Report LRA Section Section 3.3.2.1 identifies identifies the materials, environments, following prog~ams environments, AERMs, and the following programs that manage aging effects for the auxiliary systems components:

- Aboveground Steel Tanks Aboveground

- Bolting Integrity

- Boric Acid Corrosion Corrosion

- Buried Piping and Tanks InspectionInspection

" Closed Cycle Cooling Water System

- Compressed Air Monitoring Monitoring

- Monitoring External Surfaces Monitoring

- Fire Protection

- Water System Fire Water 3-242

0 Flow-Accelerated Corrosion Flow:'Accelerated Corrosion

- Fuel Oil Chemistry

Inspection of Overhead Inspection Overhead Heavy (Related to Refueling)

Heavy Load and Light Load (Related Refueling) Handling Handling Systems Systems

- Inspection of Internal Surfaces Surfaces in Miscellaneous Miscellaneous Piping and Ducting Components Components

- Lubricating Oil Analysis Analysis

" One-Time Inspection One-Time Inspection

" Open Open Cycle Cooling Water System

- Selective Materials Selective Leaching of Materials

- Structures Structures Monitoring Monitoring Program Program

- TLAA TLAA

0 Water Chemistry LRA Tables 3.3.2-1 through 3.3.2-25 summarize AMRs for the auxiliary systems 3.3.2-25 summarize components and systems components indicate claimed to be consistent with the GALL Report.

indicate AMRs claimed Report .

. For component groups evaluated in the GALL component groups GALL Report applicant had claimed Report for which the applicant claimed consistency consistency and for which the GALL Report does does not recommend recommend further evaluation, evaluation, the staff staff performed determine whether performed an audit and review to determine plant-specific components in these GALL whether the plant-specific Report Report component groups were bounded by the GALL Report Report evaluation.

evaluation.

applicant provided a note for each AMR line item. The notes The applicant describe how the information notes describe information in information in the GALL Report. The staff audited those AMRs the tables aligns with the information AMRs with through E, which indicate how the AMR was consistent Notes A through Report.

consistent with the GALL Report:

indicates that the AMR line item is consistent with the GALL Report Note A indicates Report for component, consistent with the GALL Report material, environment, and aging effect. In addition, the AMP is consistent consistency with the GALL Report and the AMP. The staff audited these line items to verify consistency the validity of the AMR for the site-specific site-specific conditions.

indicates that the AMR Note B indicates item is consistent with the GALL AMR line item component, .

GALL Report for component,*

material, environment, and aging exceptions to the AMP aging effect. In addition, the AMP takes some exceptions AMP identified in the GALL Report. The staff audited these line items to verify consistency consistency with the the GALL Report and confirmed that itit had reviewed GALL reviewed and accepted the identified exceptions to the and accepted the GALL GALL Report AMPs. The staff also determined whether the AMP identified by the applicant determined whether applicant was was consistent with the AMP identified consistent GALL Report and whether the AMR was valid for the identified in the GALL the site-specific conditions.

site-specific .

Note Note C indicates component for the AMR indicates that the component different from, is consistent AMR line item, although different with the GALL Report for material, environment, and aging effect. In addition, the AMP is identified by the GALL Report. This note indicates consistent with the AMP identified applicant was indicates that the applicant was 3-243

unable to find a listing of some system components components in the GALL applicant GALL Report; however, the applicant identified a different component in the GALL different component GALL Report that had the same material, environment, component under review. The staff audited aging effect, and AMP as the component audited these line items to verify consistency with the GALL Report. The staff also determined determined whether the AMR line item of the the different component applied different component the component under review and whether applied to the-component whether the AMR was valid for the site-specific conditions.

Note D indicates that the component for the AMR line item, although consistent although different from, is consistent material, environment, and aging effect. In addition, the AMP take~

GALL Report for material, with the GALL takes some exceptions GALL Report. The staff audited identified in the GALL exceptions to the AMP identified items to audited these line items to verify consistency with the GALL ReportReport and confirmed whether whether the AMR different AMR line item of the different component under review. The staff confirmed component was applicable to the component component confirmed whether whether it had reviewed and accepted reviewed exceptions to the GALL Report accepted the exceptions Report AMPs. It determined whether It also determined whether the the AMP identified by the applicant applicant was consistent identified in the GALL Report consistent with the AMP identified and Report and.

site-specific conditions.

whether the AMR was valid for the site-specific .

consistent with the GALL Report Note E indicates that the AMR line item is consistent Report for material, different AMP is credited. The staff audited environment, and aging effect, but a different audited these line items items consistency with the GALL to verify consistency GALL Report and determined identified AMP would determined whether the identified would manage the aging effect consistent with the AMP identified manage GALL Report and whether identified in the GALL whether the the AMR was valid for the site-specific site-specific conditions. .

described in the GALL Report; however, itit did The staff did not repeat its review of the matters described did presented verify that the material presented in the LRA was applicable and that the applicant identified the the appropriate GALL Report AMRs. The staffs appropriate GALL evaluation is discussed staff's evaluation discussed below.

The staff reviewed applicant: (a) provided reviewed the LRA to confirm that the applicant: description of the provided a brief description the environments; (b) system, components, materials, and environments; (b) stated that the applicable effects applicable aging effects reviewed and evaluated were reviewed evaluated in the GALL Report; and (c) identifiedidentified those aging effects the effects for the components that are subject to an AMR.

auxiliary systems components determines that, for AMRs not requiring On the basis of its audit and review, the staff determines requiring further evaluation, evaluation, as identified in LRA Table 3.3.1, 3.3.1, the applicant's references to the GALL Report are applicant's references acceptable and no further staff acceptable staff review is required.

3.3.2.1.1 ARM Results Identified as Not ApplicableApplicable determine the specific reason why the applicant Based on its initial review, the staff could not determine applicant considered LRA Table 3.3.1, line items 41, Table 3.3.1, 41, 42, 44, 49, 53, 64, 75, 77, 79, and 87 to be not not RAI-AMR-GENERIC-1, dated applicable. In RAI-AMR-GENERIC-1,. dated October October 16,16, 2008, the staff requested the requested that the applicant additional information regarding applicant provide additional regarding.these applicable items so the staff could these not applicable.items could.

complete complete its evaluation.

In its response dated October 30, 2008, the applicant stated response to the RAI dated stated that "Not Applicable" has been used when the component, material and environment environment combination does not exist in the the identified identified GALL system grouping and also when the component, material material and environment, environment I!

combination does exist but the LRA Table 3.x.1 item was not used because a different Table 3.x.1 combination 3.x.1 item was selected to manage effect/mechanism.

manage the identified aging effect/mechanism.

applicant's response Based on its review, the staff finds the applicant's Based RAI-AMR-GENERIC-1 response to RAI-AMR-GENERIC-1 unacceptable because the applicant unacceptable provide the specific reasons itit used to consider the applicant did not provide the items in LRA Table 3.1.1 not applicable and the staff could not complete its review.

subject line items 3-244

RAI-AMR-GENERIC-2, dated In RAI-AMR-GENERIC-2, dated January January 5, 2009, 2009, the staff requested that the staff requested the applicant applicant indicate indicate each of the LRA for each LRA Table Table 3.x. 1 items applicable" is listed items where "not applicable" in the "discussion" column, listed in column, the specific the specific reason reason why the item item is considered considered notnot applicable applicable to TMI-1. The to TMI-1. The staff also requested requested that if the component, material and that if environment does and environment exist but the LRA Table 3.x.1 item does exist item was not not used, that the the applicant indicate what other applicant indicate selected to other 3.x.1 item was selected to manage manage the identified identified aging aging effect/mechanism.

effect/mechanism.

response to the RAI dated In its response January 12, 2009, the dated January the applicant applicant provided provided a table identifying the table identifying the specific reason(s) why specific Table 3.x.1 item is not why aa Table not considered applicable to TMI-1.

considered applicable TMI-1.

Based on its review, the staff Based applicant's response staff finds the applicant's response to RAI AMR-GENERIC-2 acceptable RAI AMR-GENERIC-2 acceptable because the applicant because applicant provided provided the basis for LRA identified as "not LRA Table 3.x.1 line items identified applicable." The staffs concern applicable." concern described described in RAI AMR-GENERIC-2 AMR-GENERIC-2 is is resolved.

resolved.

LRA LRA Table 3.3.1, 3.3.1, line items 36 - 39, discusses the applicant's determination on GALL AMR applicant's determination AMR lineline items that are are applicable only to BWR-designed BWR-designed reactors. In the applicant applicant AMR discussions discussions for for line items 36 - 39, no additional information provided. The information is provided. The staff confirmed that AMR AMR line items line items 36 - 39, in Table 1 of the GALL GALL Report, Volume 1 are only applicable applicable to BWR designeddesigned reactors, pressurized water reactor with a dry ambient and that TMI-1 is aa pressurized ambient containment. Based on this this determination, the staff finds that AMR determination, AMR line items 36 - 39, in Table 1 of the GALL Report, Volume Volume 1 are not applicable applicable to TMI-I.

TMI-1.

LRA LRA Table Table 3.3.1, addresses high strength steel closure 3.3.1, line item 41 addresses closure bolting exposed exposed to air with with steam or water leakage. The GALL Report recommends recommends the Bolting Integrity AMP to manage manage cracking due to cyclic loading, stress corrosion corrosion cracking in this component group. In the the RAI-AMR-GENERIC-2, the applicant stated that this line item is not applicant's response to RAI-AMR-GENERIC-2, applicant's applicable because there is no high-strength applicable because high-strength steel closure bolting exposed to air with steam or water leakage in auxiliary reviewed LRA Sections 2.3.3 and 3.3 and confirmed auxiliary systems. The staff reviewed confirmed that TMI-1 does not have support support systems that are part of the auxiliaryauxiliary systems with-in the scope scope oflicense of license renewal contain the high strength closure bolting fabricated from steel exposed renewal that contain exposed to air with steam or water leakage. Based Based on its review of the LRA, the staff confirmed confirmed that there is no high-strength steel closure bolting exposed exposed to air with steam or water leakage in auxiliary systems and, th~refore, therefore, finds the applicant's determination acceptable~

acceptable.

LRA Table 3.3.1, 3.3.1, line item 42 addresses steel closure bolting exposed exposed to air with steam or water leakage. The GALL Report recommends recommends the Bolting Integrity AMP to manage loss of material material due due to general corrosion in this component group. In the applicant's response to RAI-AMR-GENERIC-applicant's response RAI-AMR-GENERIC-applicable because there is no steel closure bolting applicant stated that this line item is not applicable 2, the applicant bolting exposed to air with steam.

exposE;ld steam or water teC3!<~ge or watElr auxiliary systems. The staff in auxiliary leakage in ~taff r~yiewed reviewed -LRA LRA Sections Sections 2.3.3 and 3.3 and confirmed that TMI-1 does not have support systems that are part of the the auxiliary systems with-in the scope of license renewal that contain the closure bolting fabricated from steel exposed to air with steam or water leakage. Based on its review of the LRA, the staff staff confirmed that there is no steel closure bolting exposed to air with steam or water leakage leakage in in auxiliary auxiliary systems and, therefore, finds the applicant's determination determination acceptable.

acceptable.

LRA Table 3.3.1, 3.3.1, line item 44 addresses steel compressed air system closure bolting exposed to .

condensation. The GALL Report recommends the Bolting Integrity AMP to manage condensation. manage loss of material due to general, pitting, and crevice corrosion in this component group. In In the applicant's applicant's response to to RAI-AMR-GENERIC-2, RAI-AMR-GENERIC-2, the applicant stated that there is no steel compressed air system closure bolting exposed to condensation in auxiliary systems. The staff reviewed reviewed LRA 3-245

Sections 2.3.3 and 3.3 and confirmed that TMI-1 does not have support systems Sections systems that are part of the auxiliary systems with-in the scope of license renewal that contain the compressed compressed air system exposed to condensation. Based on its review closure bolting fabricated from steel exposed review of the LRA, the staff confirmed that there is no steel compressed compressed air system closure closure bolting exposed exposed to to condensation condensation in auxiliary auxiliary systems and, therefore, finds the applicant's determination determination acceptable.

3.3.1, line item 49 addresses Table 3.3.1, LRA Table stainless steel; steel with stainless steel cladding addresses stainless cladding heat heat exchanger exchanger components exposed exposed to closed cycle cooling water. The GALL Report recommends Report recommends the Closed Cycle Cycle Cooling Water System System AMP to manage loss of material material due to microbiologically-microbiologically-influenced RAI-AMR-GENERIC-2, the applicant applicant's response to RAI-AMR-GENERIC-2, influenced corrosion. In the applicant's applicant stated that this component, material, environment, and aging effect/mechanism combination does not effect/mechanism combination exist in auxiliary predicted in closed cycle applicant also stated that MIC is not predicted auxiliary systems. The applicant cycle cooling water due due to the lack of a MICMIC source. The staff reviewed reviewed LRA Sections 2.3.3 and 3.3 and confirmed that TMI-1 does not have support auxiliary systems with-in support systems that are part of the auxiliary the scope of license renewal that contain the heat exchanger exchanger components fabricated from components fabricated stainless steel or steel with stainless cladding exposed to closed cycle cooling water. li3ased stainless steel cladding Based confirmed that this component, material, on its review of the LRA, the staff confirmed environment, and material,environment, aging effect/mechanism aging effect/mechanism combination does not exist in auxiliary systems and also that MIC MIC is not cooling water due to the lack of a MIC source. The staff finds the predicted in closed cycle cooling the !I determination acceptable.

applicant's determination LRA Table 3.3.1, 3.3.1, line item 53 addresses compressed air system piping, piping components, addresses steel compressed components, elements exposed and piping elements exposed to condensation condensation (internal). The GALL Report recommends recommends the the Compressed Compressed Air Monitoring manage loss of material Monitoring AMP to manage material due due to general and pitting corrosion.

RAI-AMR-GENERIC-2, the applicant stated that this component, applicant's response to RAI-AMR-GENERIC-2, In the applicant's environment combination material, and environment addressed by Item combination is addressed 3.3.1-71 since Item 3.3.1-53 does Item 3.3.1-71 does include crevice corrosion, which is predicted not include TMI-1 for this component, material, and predicted for TMI-1 environment combination.

environment combination. The applicant discussed in the "Discussion'"

further stated that as discussed applicant further "Discussion';

column for Item 3.3.1-71 in LRA Table 3.3.1, the Compressed Air Monitoring AMP has been Table 3.3.1, substituted for the Inspection of Internal Surfaces substituted Miscellaneous Piping and Ducting Surfaces in Miscellaneous Ducting 'I Components AMP and that in this case, the Table 2 AMR line item was identified identified with an "E" Standard Note and a plant specific Standard specific note stating: "The aging effects of carbon steel in an air/gas -

environment include (internal) environment wetted (internal) material due to general, pitting, and crevice include loss of material crevice corrosion. These corrosion. These aging effects/mechanisms managed by the Compressed Air Monitoring effects/mechanisms are managed Monitoring program." Based on its review LRA, the staff confirmed review of the LRA' material, and confirmed that this component, materia:I, environment combination environment addressed by item 3.3.1-71 combination is addressed 3.3.1-53 3.3.1-71 since item 3.3.1-53 does not include include crevice corrosion, which is predicted for this component, material, and environment combination. combination.

The staff also confirmed confirmed that the Compressed Monitoring AMP has been substituted for!the Compressed Air Monitoring for!!the Inspection of Internal Surfaces in Miscellaneous Internal Surfaces Components AMP. The staff Piping and Ducting Components Miscellaneous Piping staff applicant's determination finds the applicant's determination acceptable.

3.3.1, line item 64 addresses steel piping, piping components, and piping elements LRA Table 3.3.1, elements exposed to fuel oil. The GALL Report recommendsrecommends the Fire Protection Protection and Fuel Oil Chemistry manage loss of material due to general, pitting, and crevice corrosion. In AMPs to manage In the applicant's appli~ant's response to RAI-AMR-GENERIC-2, RAI-AMR-GENERIC-2, the applicant aging applicant stated that it predicts the additional agingl mechanisms of MIC and fouling for steel components in fuel oil and that this component, material, mechanisms effect/mechanism combination is addressed environment, and aging effect/mechanism environment, addressed by item 3.3.1-20. Based Based on on its review of the LRA, the staffstaff confirmed applicant predicts the additional confirmed that the applicant aging additional aging mechanisms of MIC and fouling for steel components mechanisms components in fuel oil and and that this component, material, material, effect/mechanism combination environment, and aging effect/mechanism is addressed combination addressed by item 3.3.1-20. The "'staff

'staff finds the applicant's determination determination acceptable.

3-246 3-246

LRA Table LRA Table 3.3.1, 3.3.1, line line item 75 addresses elastomer seals and components addresses elastomer components exposed exposed to raw water.

The The GALL GALL Report Report recommends recommends the Open Cycle Cycle Cooling Water Water System System AMP AMP to manage manage hardening hardening and loss of of strength strength due due toto elastomer elastomer degradation; degradation; loss loss of material material duedue to erosion.

erosion. In applicant's response the applicant's RAI-AMR-GENERIC-2, the applicant response to RAI-AMR-GENERIC-2, applicant stated stated that there there are no are no elastomer elastomer seals seals and components components exposed to raw water water in auxiliary auxiliary systems. The staffstaff reviewed reviewed LRA Sections Sections 2.3.3 and 3.3 3.3 and confirmed confirmed that TMI-1 TMI-1 does does not have support support systems systems that areare part of the auxiliary auxiliary systems systems with-in with-in the scope of license renewal that contain the seals and license renewal components components fabricated from elastomers elastomers exposed exposed to raw water. Based Based onon its review review of the LRA, the staff confirmed confirmed that therethere are no no elastomer elastomer seals and and components components exposed exposed to raw raw water in auxiliary auxiliary systems, and, therefore, the the staff finds the applicant's determination acceptable.

applicant's determination acceptable.

LRA LRA Table 3.3.1, line item Table 3.3.1, item 77 addresses addresses steel heatheat exchanger exchanger components components exposed exposed to raw raw water.

The GALL Report Report recommends recommends the Open Open Cycle Cooling Cooling Water Water System AMP AMP to manage manage loss of material material duedue to pitting andand crevice crevice corrosion corrosion in this component component group. In the applicant's response applicant's response to RAI-AMR-GENERIC-2, RAI-AMR-GENERIC-2, the applicant applicant stated that this component, material, material, environment, and and aging aging effect effect combination addressed by items 3.2.1-35,3.3.1-68, combination is addressed 3.2.1-35, 3.3.1-68, and and 3.3.1-76 3.3.1-76 since galvanic galvanic corrosion identified in Item 3.3.1-77 does corrosion as identified does not apply to these heat exchanger components. The heat exchanger The applicant applicant alsoalso stated that the component, material,material, environment, and and aging effect effect combination combination addressed addressed by items 3.2.1-35 and 3.3.1-76 are managed managed by the Open-Cycle Open-Cycle Cooling Water Water System System AMP and that the raw water water environment environment associated associated with floor and equipment equipment draindrain systems and addressed addressed by item item 3.3.1-68 are managed managed by the Inspection Inspection of Internal Surfaces in Internal Surfaces Miscellaneous Miscellaneous PipingPiping and and Ducting Components AMP since Ducting Components since Open-Cycle Open-Cycle Cooling Water System AMP activities activities do do not address waste raw water. Based on its review of the LRA, the staff staff confirmed confirmed that this component, material, material, environment, and aging combination is addressed aging effect combination by items 3.2.1-35,3.3.1-68, 3.2.1-35, 3.3.1-68, and 3.3.1-76 3.3.1-76 since galvanic galvanic corrosion as identified identified in item 3.3.1-77 3.3.1-77 does not apply to these heat exchanger exchanger components. The staff also confirmed that the the component, material, environment, and aging effect combination combination addressed addressed by items 3.2.1-35 3.2.1-35 and 3.3.1-76 3.3.1-76 are managed by the Open-Cycle Cooling Cooling Water Water System AMP and that the raw water environment associated with floor and equipment environment equipment drain systems and addressedaddressed by item 3.3.1-68 3.3.1-68 are managed Inspection of Internal managed by the Inspection Internal Surfaces in Miscellaneous Miscellaneous Piping and DuctingDucting Components Components AMP since Open-Cycle Open-Cycle Cooling Water System AMP activities activities do not address address waste raw waters. The staff finds the applicant's applicant's determination determination acceptable.

LRA Table 3.3.1,3.3.1, line item 79 addresses stainless steel piping, piping components, and piping piping elements exposed to raw water. The GALL Report recommends recommends the Open Cycle Cooling Water System AMP to manage manage loss of material due to pitting and crevice corrosion, and fouling in this this component group. In the applicant's response to RAI-AMR-GENERIC-2, component RAI-AMR-GENERIC-2, the applicant stated that itit predicts the additional aging mechanism mechanism of MIC for stainless steel components exposed to raw

. water and that this component, material, environment, and aging effect/mechanism effect/mechanism combination is addressed by Items 3.2.1-38 and 3.4.1-33. The applicant also stated that circulating circulating water system components in raw water are managed managed by the Open-Cycle Open-Cycle Cooling Water System AMP and that components exposed to waste raw water environments are managed by the Inspection Inspection of Internal Surfaces in Miscellaneous Miscellaneous Piping and Ducting Components AMP since the Open Cycle Cooling Water System AMP activities db do not address waste raw water. Based Based on its review of of the LRA, the staff confirmed that the applicant predicts the additional aging mechanism of MIC MIC for stainless steel components exposed to raw water and that this component, material, environment, and effect/mechanism combination aging effect/mechanism combination is addressed addressed by by Items 3.2.1-38 and 3.4.1-33. The staff also confirmed confirmed that circulating water system components in raw water are managed managed by the Open-Cycle Cooling Water System AMP and that components exposed to waste raw water environments are managed by the Inspection environments Inspection of Internal Surfaces Surfaces in Miscellaneous Miscellaneous Piping and 3-247 3-247

Components AMP since the Open Cycle Cooling Water Ducting Components System AMP activities Water System activities do not address waste raw water. The staff finds the applicant's determination determination acceptable.

acceptable.

LRA Table 3.3.1, addresses boraflex spent fuel storage racks neutron 3.3.1, line item 87 addresses neutron absorbing sheets exposed to treated borated water. The GALL Boraflex Monitoring recommends the Boraflex GALL Report recommends Monitoring AMP to manage reduction of neutron absorbing absorbing capacity due degradation in this due to boraflex degradation this, component applicant's response to RAI-AMR-GENERIC-2, component group. In the applicant's applicant stated that RAI-AMR-GENERIC-2, the applicant boraflex spent fuel storage racks neutron-absorbing there are no boraflex exposed to treated neutron-absorbing sheets exposed auxiliary systems and that the borated water in auxiliary borated fuel storage storage racks are Boral and are addre~sed Boral addressed by item 3.3.1-13. Based on its review of the LRA, the staff confirmed confirmed that there are no boraflex neutron-absorbing sheets exposed spent fuel storage racks neutron-absorbing auxiliary exposed to treated borated water in auxil'jary systems and that the fuel storage racks are Boral and are addressed addressed by item 3.3.1-13. The staff staff finds the applicant's determination acceptable.

applicant's determination acceptable.

Material Due To General, Pitting, And Crevice Corrosion 3.3.2.1.2 Loss Of Material addresses loss of material due to general, pitting and crevice 3.3.1, Item 3.3.1-43 addresses LRA Table 3.3.1, crevic~

corrosion for steel components with its external surfaces exposed surfaces exposed to outdoor air in the auxiliary and fuel handling building ventilation system.

The LRA credits credits the External Surfaces Surfaces Monitoring manage this aging effect for ~,teel Monitoring Program to manage steel outdoor air (external) environment only. The components in an outdoor piping, fittings and valve body components The GALL Report Report recommends recommends GALL AMP XI.M XI.M18, 18, "Bolting Integrity," to manage this aging effect.

AMR line items The AMR reference this line item in GALL Report Table 1 cite Generic items that reference Generic Note E, indicating that the AMR line items are consistent with GALL indicating GALL Report material, environment, a'nd and aging effect, but a different management program different aging management program is credited.

credited.

The staff reviewed the applicant's applicant's External Surfaces Monitoring program and its evaluation Surfaces Monitoring evaluation i,s is documented in SER Sections 3.0.3.2.16. The staff noted from its review that all but one AMR line documented line referenced line item 3.3.1-43 and credited the External Surfaces item that the referenced Surfaces Monitoring Monitoring Program are not bolting components components with an intended intended function function for mechanical closure. The staff further further referenced Item 3.3.1-43 of LRA Table 3.3.1 because there was not noted that the applicant referenced another another applicable corresponded to the same applicable Table 1 line item in LRA Table 3.3.1 that corresponded same material, material, environment and aging effect combination. The staff confirmed that for the one AMR line item in environment this review that is a bolting component mechanical closure that was component with an intended function for mechanical was listed, the applicant also credited the Bolting Integrity Program for managing listed, managing loss of material material due due to general, pitting and crevice corrosion, which is consistent with the GALL GALL Report. The staff staff applicant took a conservative noted that the applicant noted approach by crediting the GALL conservative approach recommended GALL recommended program, Bolting Integrity Program, and the External program, External Surfaces Surfaces Monitoring Monitoring Program for periodic periodic inspections of the components.

visual inspections .

determined that the External Surfaces The staff determined Program, which includes periodic Surfaces Monitoring Program, periodic inspections of external visual inspections surfaces performed during system walkdowns, is adequate external surfaces adequate to to general, pitting and crevice corrosion for steel components material due to general, manage loss of material manage components .

addressed by this AMR. On the basis of periodic exposed to outdoor air (external) addressed periodic visual .

performed during system walkdowns of these components, the staff finds, inspections being performed finds* thethe applicant's use of the External Surfaces applicant's Surfaces Monitoring Monitoring program acceptable.

LRA Table 3.2.1-23, and LRA Table 3.3.1, 3.2.1, Item 3.2.1-23, Table 3.2.1, 3.3.1, Item 3.3.1-43 material due 3.3.1-43 address loss of material due general, pitting and crevice to general, components with their external surfaces crevice corrosion for steel components surfaces exposed to outdoor air or uncontrolled auxiliary and fuel handling indoor air in the auxiliary uncontrolled indoor handling building building ventilation ventilation 3-248

system, the auxiliary auxiliary steam system, closed cycle cooling water system, containment containment isolation system, instrument and control control air system, miscellaneous miscellaneous floor and equipment equipment drains system and the radwaste system. The staff noted that for those AMR lirW line items in LRA Section 3.3, in which LRA Section which the applicant references Item 3.2.1-23 and Item 3.3.1-43, the applicant listed the environment environment as as air with borated borated water leakage, which is a more aggressive environment, compared compared to outdoor air or uncontrolled indoor air. The staff confirmed in LRA Section 3.3, that for the same system, component, material and environment environment combination, the applicant manages loss of material due to boric acid corrosion with the Boric Acid Corrosion Corrosion Program, as recommended recommended by the GALL Report.

The LRA credits the External External Surfaces Surfaces Monitoring Program Program to manage this aging effect for steel bolting, damper damper housing, ducting, filter housing, flow device, heat exchanger exchanger components, piping, fittings, pump casings, regulator, sight glass, spectacle blind, steam trap, strainer body and tank components in an air with boratedborated water water leakage environment only. The GALL leakage environment GALL Report recommends GALL AMP XI.M18, XI.M18, "Bolting Integrity,"

Integrity," to manage manage this aging effect. The AMR line line items that reference this line item in GALL Report Table 1 cite Generic Note E, indicating that the the AMR line items are consistent consistent with GALL Report material, environment, and aging effect, but a different different aging management program aging management program is credited.

The staff reviewed the applicant's applicant's External Surfaces Monitoring Program Program and its evaluation evaluation is documented documented in SER Sections 3.0.3.2.16.

3.0.3.2.16. The staff noted noted from its review that all but one AMR lineline item that the applicant referenced Item 3.2.1-23 applicant referenced 3.2.1-23 and Item 3.3.1-43 3.3.1-43 and credited credited the External Surfaces Surfaces Monitoring Program are not bolting components Monitoring Program components with an intendedintended function for mechanical mechanical closure. The staff further noted noted that the applicant referenced Item 3.2.1-23 of LRA applicant referenced Table 3.2.1 and Item 3.3.1-43 of LRA Table 3.3.1 because there was not another applicable Table another applicable Table 1 line item in LRA Table 3.2.1 and LRA Table corresponded to the same material, Table 3.3.1 that corresponded material, environment and aging effect combination. The staff confirmed environment confirmed that for the one AMR line item in this review that aa bolting component with an intended function for mechanical mechanical closure was listed, applicant also credited the Bolting the applicant Bolting Integrity Program, which is recommended recommended by the GALL Report. The staff noted noted that the applicant was taken a conservative approach by crediting the the GALL recommended program, Bolting Integrity GALL recommended Integrity Program, and the External Surfaces Surfaces Monitoring Monitoring Program for periodic Program periodic visual inspections of the components components for this aging effect.

staff determined The staff determined that the External Surfaces Surfaces Monitoring program, program, which periodic which includes periodic visual inspections inspections of external surfaces surfaces performed during system walkdowns, is adequate to manage loss of material material due to general, pitting and crevice corrosion for steel componentscomponents exposed to to air with borated borated water leakage leakage environment addressed by this AMR. On the basis of environment addressed inspections being periodic visual inspections being performed during system walkdownswalkdowns of these components components by the External Surfaces Monitoring Program, and the applicant Surfaces Monitoring applicant monitoring these components components with the Boric Acid Corrosion Corrosion Program, Program, for loss of material material due to boric boric acid corrosion, the staff findsfinds the applicant's applicant's use of the External Surfaces Monitoring Monitoring program acceptable.

program acceptable.

Based on a review of the programs programs identified identified above, the staff determines that the applicant'sapplicant's proposed proposed programs are acceptable acceptable for managing managing the aging effects in the applicable components.

applicable The staff concludes concludes that the applicant has demonstrated demonstrated that the effects of aging for these these components will be adequately adequately managed so that their intendedintended function(s) will be maintained consistent with the CLB during the period of extended operation, operation, as required by 10 CFR 54.21 (a)(3).

54.21(a)(3).

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3.3.2.1.3 Loss Of Material Material Due To Pitting And Crevice Corrosion LRA Table 3.3.1, addresses loss of material 3.3.1, Item 3.3.1-54 addresses material due to pitting and crevice corrosion for crevice corrosion stainless stainless steel components components with its internal surfaces exposed to wetted air/gas in the emergency surfaces exposed emergency diesel diesel generators generators and auxiliary auxiliary systems, miscellaneous miscellaneous floor and equipment drains system and the radwaste system.

The LRA credits the Inspection Inspection of Internal Surfaces in Miscellaneous Miscellaneous Piping and DuctingDucting Components Program, to manage manage this aging effect for stainless steel piping, fittings, pump pump casings, tanks and valve body components components in a wetted air/gasair/gas environment only. The GALL recommends GALL AMP XI.M24, "Compressed Air Monitoring,"

Report recommends Monitoring," to manage this aging effect. The AMR line items that reference reference this line item in GALLGALL Report Table 1 cite Generic Note Note E, indicating indicating that the AMR line items are consistent with GALL GALL Report material, environment, and aging effect, but a different aging management management program is credited.

The staff reviewed the Inspection Inspection of Internal Surfaces Miscellaneous Piping and Ducting Surfaces of Miscellaneous Ducting Components Program and its evaluation is documented documented in SER Section Section 3.0.3.2.17. The staffstaff noted that the wetted wetted air/gas air/gas environment environment is not the same as a compressed compressed air environment environment for which GALL GALL AMP XI.M24 is intended to manage, and thus cannot be used for aging .

management.

management. The staff determined staff determined that the Inspection Inspection of Internal Surfaces in Miscellaneous Surfaces Miscellaneous Piping and Ducting Components Program, Program, which include include periodic inspections and periodic visual inspections and volumetric testing, when appropriate, appropriate, during periodic periodic system and component surveillance component surveillance activities or during maintenance activities maintenance activities activities when the internal internal surface surface is accessible for visual inspections, inspections, is adequate adequate to manage loss of material material due to pitting and crevice corrosion corrosion for for' stainless steel components components exposed exposed to wetted air/gas (internal) addressed by this AMR. On the the basis of periodic visual inspections, inspections, the staff finds the applicant's applicant's use of the Inspection Inspection of Internal Surfaces in Miscellaneous Surfaces Miscellaneous Piping and Ducting Components Program acceptable.

In LRA Table Table 3.3.2-10, the applicant applicant stated that loss of material material due to pitting and crevice crevice corrosion corrosion of stainless steel sprinkler heads exposed to wetted air in the fire protection protection system is managed managed by the Fire Water System Program. Program.

The staff noted that the applicant applicant applied note E to this item. The applicant referenced referenced LRA Table Table 3.3-1, 3.3-1, item 3.3.1-54 3.3.1-54 and GALL Report Volume 2, item VII.D-4. The staff reviewed reviewed the AMR results AMR iresults lines that reference reference Generic Note E and finds that the component type, material, environment, and aging effect are consistent consistent with the GALL Report. However, the staff noted that where the the GALL Report Report recommends recommends AMP XI.M24, "Compressed Air Monitoring," Monitoring," the applicant proposed proposed using the Fire Water System Program. The staff noted that these components are in the fire fire protection system and therefore, will not be in the scope of the Compressed Monitoring Compressed Air Monitoring.

Program.

The staff reviewed reviewed the Fire Water System program, which manages manages aging effect of loss *of of material for the water-based water-based fire protection protection system and associated associated components, through the use use of periodic inspections, inspections, monitoring, monitoring, and performance performance testing, and is consistent with the GALL AMP XI.M27, Fire Water recommended by the GALL Water System. As recommended GALL AMP XI.M27, the applicaht applicant has has committed committed to testing or replacement replacement of sprinkler heads in service for 50 years. The staff's staffs review of the Fire Water System program and its evaluation evaluation is documented documented in SER SER Section Section 3.0.3.2.10.

On the basis that periodic periodic inspections, monitoring and performance performance testing will be performed, performed, the the staff finds that the Fire Water System program will adequately adequately manage loss of material material due to pitting and crevice corrosion of stainless stainless steel sprinkler sprinkler heads exposed exposed to wetted air in the fire fire protection system through the period of extended protection extended operation.

3-250 3-250

In LRA Table 3.3.2-10, the applicant statedstated that loss of material material due to pitting and crevice crevice corrosion of stainless steel spray nozzles exposed to wetted wetted air in the fire protection protection system is managed by the Fire Protection Program.

managed Program. The staff noted that the applicant applicant applied this applied note E to this item. The applicant referenced 3.3-1, item 3.3.1-54 and GALL Report Volume 2, item referenced LRA Table 3.3-1, VIL.D-4.

VII.D-4. The staff reviewed the AMR results lines lines that reference reference note E and determines determines that the the component type, material, environment, and aging effect are consistent with the GALL Report.

However, the staff noted that where the GALL Report Report recommends recommends AMP XI.M24, "Compressed Air Monitoring,"

Monitoring," the applicant applicant proposed proposed using using the Fire Protection program. The staff noted that these these components components are in the fire protection protection system and therefore, therefore, will not be in the scope of thethe Compressed Compressed Air Monitoring Program.

Monitoring Program.

The staff reviewed the Fire Protection program, which includes monitoring, testing, and inspection inspection activities activities including low-pressure low-pressure carbon carbon dioxide fire suppression suppression system flow testing to verify flow flow from each nozzle. The staff also noted that that any adverse adverse conditions such as excessive excessive dirt or debris, or other degrading condition are required to be reported reported for corrective corrective action evaluation.

staffs review The staff's review of the Fire Protection Program and its evaluation is documented documented in SER Section 3.0.3.2.9.

3.0.3.2.9. On the basis that monitoring monitoring and testing on a periodic periodic interval will be be performed, the staff finds that the Fire Protection performed, Protection Program Program will adequately adequately manage manage loss of material due to pitting and crevice crevice corrosion corrosion of stainless stainless steel spray nozzles nozzles exposed exposed to wetted air in the the fire protection protection system through the period of extended operation.

period extended operation.

LRA Table 3.3.1, 3.3.1, line item 3.3.1-54 addresses addresses loss of material due to pitting and crevicecrevice corrosion for stainless steel components with their internal surfaces exposed to wetted air/gas in the the condensers &

condensers & air removal removal system. The staff noted that the applicantapplicant referenced referenced line item 3.3.1-54 3.3.1-54 of LRA Table 3.3.1 because because there was not an applicable Table 1 line item in LRA Table 3.4.1 that corresponded to the same material, environment corresponded environment and aging effect combination.

combination. .

The LRA credits the Inspection Inspection of Internal Surfaces in Miscellaneous Miscellaneous Piping and Ducting Components Program, to manage Components manage this aging effect for stainless steel thermowells thermowells and valve body body components in a wetted air/gas environment environment only. The GALL GALL Report recommends recommends GALL AMP AMP XI.M24, XI.M24, "Compressed Air Monitoring,"

Monitoring," to-manage to-manage this agingaging effect. The AMR line items that reference this line item reference item in GALL GALL Report Table Table 1 cite Generic Generic Note E, indicating indicating that the AMR line line items are consistent consistent with the GALL Report material, environment, and aging effect, but a different Report material, different aging management management program is credited.

credited.

The staff reviewed the applicant's applicant's Inspection Inspection of Internal Internal Surfaces in Miscellaneous.

Miscellaneous Piping and Ducting Components Program and its evaluation Components Program evaluation is documented documented in SER Section 3.0.3.2.17. The The staff noted that the wetted air/gas environment environment is not the same as a compressed compressed air environment environment for which GALL AMP XI.M24 is intendedintended to manage, manage, and thus GALL AMP XI.M24 cannot be used for aging management. The staff staff determined Inspection of Internal Surfaces determined that the Inspection Surfaces in Miscellaneous Miscellaneous Piping and Ducting Components Program, which includes periodic visual inspections inspections and volumetric volumetric testing, when appropriate, during periodic system system and component component surveillance activities surveillance activities or during maintenance activities maintenance activities when the internal surface is accessible for visual inspections, is adequate to manage loss of material due to pitting and crevice corrosion for stainless steel components components exposed to wetted air/gas (internal) (internal) addressed addressed by this AMR. On the the basis of periodic basis periodic visual inspections, the staff finds the applicant's use of the Inspection Inspection of Internal Surfaces in Surfaces in Miscellaneous Piping and Ducting Components Program Miscellaneous Piping Program acceptable.

acceptable.

3.5.1, Items LRA Table 3.5.1, Items 3.5.1-47 and 3.5.1-50, 3.5.1-50, address loss of material material due to pitting and crevice crevice corrosion for copper alloys (with 15% zinc or more and with less than 15% 15% zinc) and stainless stainless 3-251

steel components, respectively, with their external surfaces exposed exposed to outdoor air in in the fire fire protection system and the auxiliary and fuel handling building ventilation system. The staff noted protection that the applicant referenced Item 3.5.1-47 and Item 3.5.1-50 of LRA Table 3.5.1 because applicant referenced because there was not an applicable applicable Table Table 1 line item in in LRA Table that corresponded to the same Table 3.3.1 that same I' material, environment environment and aging effect combination.

The LRA credits the External Surfaces Monitoring Monitoring Program to manage this aging effect for coppery alloys (with 15% 15% zinc or more and with less than 15% 15% zinc) sprinkler and valve bodybody components and stainless piping, fittings, valve body, sprinkler and spray nozzle componentscomponents in in an outdoor outdoor air (external)'environment (external}environment only. The GALL Report recommends recommends GALL AMP XLS6, XI.S6, "Structures Monitoring manage this aging effect. The AMR line items that reference Monitoring Program," to manage reference this line item in in GALL Report Table 1 cite Generic Generic Note E, indicating that the AMRAMR line items are consistent with GALL Report material, environment, and aging effect, but a different GALL Report different aging management management program program is credited.

The staff reviewed the External Surfaces Surfaces Monitoring Program and its evaluation evaluation is documented documented in in SER Sections Sections 3.0.3.2.16. The staff determined Surfaces Monitoring determined that the External Surfaces Monitoring Program, which includes periodic periodic visual inspections of external external surfaces surfaces performed performed during system walkdowns, is adequate to managemanage loss of material due to pitting and crevice crevice corrosion for copper copper alloys (with 15% zinc or more and with less than 15% zinc) and stainless steel components components exposed to outdoor air (external) addressed addressed by this AMR. On the basis of periodic visual inspections being performed inspections performed during system walkdowns of these components, the staff finds the the applicant's use of the External applicant's External Surfaces Monitoring Monitoring Program Program acceptable.

Based on a review of the programs identified, identified, the staff determines determines that the applicant's proposed programs are acceptable programs acceptable for managing managing the aging effects in in the applicable components. The" staff The:' staff concludes that the applicant has demonstrated demonstrated that the effects effects of aging for these components components will be adequately adequately managed so that their intended function(s) will be maintained consistentconsistent with the with' the CLB during the period of extended operation, as required by 10 CFR 54.21(a)(3).

3.3.2.1.4 Loss Of Material 3.3.2.1.4 Material Due To General Corrosion In LRA Table 3.3.2-10, the applicant stated that loss of material due to general In general corrosion of firefire protection system steel fire barrier barrier doors and penetration penetration seals in an external environment environment of air-managed by the Fire Protection indoor is managed Protection Program.

Program.

The staff noted that the applicant applied note E to this item. The applicant applicant referenced referenced LRALRA Table Table 3.3-1, item 3.3.1-58 3.3-1, 3.3.1-58 and GALL Report Volume 2, item VIU-8. VII.I-8. The staff reviewed the AMR results results lines that reference reference Generic Note E and determines that the componentcomponent type, material, environment, and aging effect are consistent with the GALL Report. However, the staff noted noted that where the GALL Report recommends recommends AMP Xi.M36,XLM36, "External Surface Monitoring," the applicant applicant*

proposed using the Fire Protection Program.

Program.

GALL AMP XLM36 XI.M36 recommends recommends periodic visual inspection of the external external surface surface of components.

The staff reviewed reviewed the Fire Protection Program, which providesprovides for periodic visual inspecticm inspection of fire barrier penetration penetration seals; fire barrier walls, ceilings and floors; and fire doors for managing loss of material material due to corrosion and finds that itit is consistent consistent with GALL XI.M26, "Fire GALL AMP XLM26, "Fire Protection." The staffs review of the Fire Protection Protection." evaluation is documented Protection Program and its evaluation documented in in SER Section 3.0.3.2.9. On the basis that periodic periodic visual inspection is performed, performed, the staff finds finds that the Fire Protection Program will adequately adequately manage manage loss of material material due to general corrosion corrosion 3-252

of fire protection protection system steel fire barrier doors and penetration penetration seals in an external environment external environment of air-indoor.

Based on a review review of the program identified above, the staff determines that the applicant's applicant's proposed programs programs are acceptable for managing managing the aging effects effects in the applicable components.

The staff concludes demonstrated that the effects concludes that the applicant has demonstrated effects of aging for these these components components will be adequately managed managed so that their intended intended function(s) will be maintained maintained consistent with the CLB during the period of extended operation, operation, as required by 10 CFR 54.21 (a)(3).

3.3.2.1.5 3.3.2.1.5 Loss Of Material Material Due To General, General, Pitting, And Crevice Corrosion Corrosion In LRA Table Table 3.3.2-10, the applicant applicant stated stated that loss of material due to general, pitting and crevicecrevice corrosion corrosion of fire protection protection system steel fire barrier doors exposed exposed to outdoor air environment is managed managed by the Fire Protection Protection Program.

Program.

The staff noted that the applicant applicant applied applied Generic Generic Note Note E to this item. The applicant referenced LRA Table 3.3-1, 3.3-1, item 3.3.1-60 3.3.1-60 and GALL Report Report Volume 2, item VII.H1-8. The staff reviewedreviewed the the AMR results lines that reference reference note E and finds that the component type, material,material, environment, environment, and aging effect effect are consistent consistent with the GALL Report. However, the staff noted that where the the GALL Report Report recommends recommends AMP XI.M36, "External Surface Surface Monitoring,"

Monitoring," the applicant applicant proposed proposed using Protection Program.

using the Fire Protection GALL AMP XI.M36 recommends recommends periodic visual inspection inspection of the external surface surface of components.

The staff reviewed the Fire Protection Protection Program, which provides provides for periodic periodic visual inspection of penetration seals; fire barrier walls, ceilings and floors; and fire doors for managing fire barrier penetration managing loss of material due to corrosion and finds that itit is consistent with GALL AMP XI.M26, "Fire XI.M26, "Fire Protection."

Protection." The staffs review of the Fire Protection Protection Program and its evaluation is documented documented in SER Section Section 3.0.3.2.9. On the basis that periodic periodic visual inspection performed, the staff finds inspection is performed, finds that the Fire protection Program Program will adequately adequately manage manage loss of material material due to general, pitting pitting and crevice corrosion of fire protection protection system steel fire barrier doors in an outdoor air environment environment during the period of extended extended operation.

operation.

Based on a review review of the program identified identified above, the staff determines applicant's determines that the applicant's proposed acceptable for managing the aging effects in the applicable proposed programs are acceptable applicable components.

The staff concludes that the applicant applicant has demonstrated demonstrated that the effects effects of aging aging for these components will be adequately components adequately managed so that their intended function(s) will be maintained maintained consistent with the CLB during the period of extended extended operation, as required by 10 10 CFR CFR 54.21 (a)(3).

3.3.2.1.6 Material Due To Pitting And Crevice 3.3.2.1.6 Loss Of Material Crevice Corrosion Corrosion In LRA Table Table 3.3.2-10, the applicant applicant stated that loss of material due to pitting and crevice crevice corrosion corrosion of aluminum components exposed to raw water in the fire protection aluminum piping components protection system is managed managed by the Fire Water System Program.

The staff noted that the applicant Generic Note E applicant applied Generic E to this item. The applicant referenced referenced LRA LRA Table 3.3-1, 3.3-1, item 3.3.1-62 3.3.1-62 and GALL GALL Report Report Volume 2, item VII.G-8. The staff reviewed reviewed the the AMR results lines that reference Generic reference Generic Note E and finds that the component component type, material, environment, and aging effect are consistent consistent with the GALL Report. However, the staff noted noted that where the GALL Report recommends AMP XI.M26, XI.M26, "Fire Protection," the applicant proposed 3-253 3-253

using the Fire Water System System Program.

Program. The staff noted noted that these components components are in water-based water-based protection system and therefore are not in the scope of the Fire Protection Program.

fire protection The staff reviewed the Fire Water System Program,Program, which manages manages identified identified aging effects for for the water-based protection system and associated water-based fire protection associated components, through the use of periodic peri6dic inspections, monitoring, inspections, performance testing, and finds that itit is consistent with the GALL monitoring, and performance AMP XI.M27, XI.M27, "Fire Water Water System." The staffs staffs review of the Fire Water System Program and its evaluation is documented evaluation documented in SER Section 3.0.3.2.10.

3.0.3.2.10. On the basis that periodic periodic inspections, monitoring performance testing will be performed, monitoring and performance performed, the staff finds that the Fire Water System I:

Program Program will adequately manage loss of material adequately manage material due to pitting and crevice crevice corrosion of aluminum aluminum piping components components exposed to raw water in the fire protection protection system through the period of extended operation. .

Based on a review of the program Based determines that the applicant's' program identified above, the staff determines applicant's ,

proposed programs proposed programs are acceptable acceptable for managing managing the aging aging effects effects in the applicable applicable components.

The staff concludes concludes that the applicant applicant has demonstrated demonstrated that the effectseffects of aging for these these il adequately managed so that their intended components will be adequately intended function(s) will be maintained maintained consistent with the CLB during the period of extended extended operation, as required by 10 10 CFR 54.21(a)(3).

3.3.2.1.7 Loss Of Material Microbiologically-influenced Material Due To General, Pitting, Crevice, And Microbiologically-influenced Corrosion, Fouling Corrosion, And Fouling LRA Table 3.3.1, 3.3.1, Item 3.3.1-68 3.3.1-68 addresses addresses loss of material due to general, pitting, crevice, and microbiologically-influenced microbiologically-influenced corrosion, and fouling for steel components with its external and anp internal surfaces surfaces exposed exposed to raw water in the Miscellaneous Miscellaneous Floor and Equipment Drains System and the Closed Cycle Cooling Water System.

The LRA credits the AMP B.2.1.22, "Inspection of Internal Internal Surfaces in Miscellaneous Miscellaneous Piping and Ducting Components," to managemanage this aging effect for steel flow devices, heat exchangerexchanger I components, pump casings, spectacle spectacle blinds, strainer strainer body, piping, fittings, tanks and valve body components in aa raw water (internal) environment only. The LRAcredits LRA credits the AMP B.2.1.21 .

"External Surfaces Monitoring" to manage Surfaces Monitoring" manage this aging effect for steel pump casings components components in a raw water (external) environment environment only. The GALL Report recommends GALL Report recommends GALL AMP XI.M27, XI.M27, "Fire Water System," to manage manage this aging effect. The AMR line items items that reference reference this line item item in GALL Report Report Table 1 cite Generic Note E, indicating that the AMR AMR line items items are consistent consistent with the GALL Report material, environment, environment, and aging effect, but a different aging management management program program is credited. The staff confirmed that only piping, piping components components and piping elements elehlents align to GALL Item VII.G-24 Item VII.G-24 and are fabricated fabricated from steel materials materials that are applicable applicable TMI.

to The staff reviewed the applicant's Inspection of Internal applicant's Inspection Surfaces in Miscellaneous Internal Surfaces Miscellaneous Piping and Ducting Components program and External Components program External Surfaces Monitoring Monitoring program and its evaluatio!i;ls evaluations are documented in SER Sections 3.0.3.2.16 3.0.3.2.16 and 3.0.3.2.17, respectively. The staff noted that the the program that is recommended recommended by the GALL GALL Report was meant meant to specifically specifically address address this aging effect effect for Fire Protection Systems Systems that are tested in accordance accordance with NFPA codes and and standards.

However, the staff further noted that the applicant referenced applicant referenced Item 3.3.1-68 of LRA Table 3.3.1 because because there was not another applicable Table 1 line item in LRA Table another applicable that corresponded Table 3.3.1 tliat corresponded to the same material, environment environment and aging effect combination. The systems in which the! the' applicant's applicant's AMR Line items that are discussed in this section are not Fire Protection Systems; Protection Systerps; they are the Miscellaneous Miscellaneous Floor and Equipment Equipment Drains System and the Closed Cycle Cooling CoOling Water System.

3-254 3-254

The staff determined determined that the Inspection of Internal Surfaces Surfaces in Miscellaneous Miscellaneous Piping and DuctingDucting Components program, which includes periodic visual inspections which includes inspections and volumetric volumetric testing, when appropriate, appropriate, during periodic system and component maintenance component surveillance activities or during maintenance activities activities when the internal surface accessible for visual inspections, is adequate surface is accessible adequate to manage manage microbiologically-influenced corrosion, and loss of material due to general, pitting, crevice, and microbiologically-influenced fouling for steel components exposed to raw water (internal) addressed by this AMR. The staff (internal) addressed staff determined determined that the External Surfaces Monitoring Monitoring program, program, which includes includes periodic visual inspections of external surfaces performed during system walkdowns, is adequate surfaces performed adequate to manage loss loss of material due to general, pitting, crevice, and microbiologically-influenced microbiologically-influenced corrosion, and foulingfouling for steel components components exposed to raw water (internal)

(internal) addressed by this AMR.

On the basis of periodic visual inspections and volumetric testing, when appropriate, the staff staff finds the applicant's applicant's use of the Inspection Inspection of Internal Internal Surfaces Surfaces in Miscellaneous Miscellaneous Piping and Ducting Components program acceptable. On the basis of periodic visual inspections, the staff staff finds the applicant's use of the External Surfaces Monitoring program program acceptable.

Based on aa review of the programs identified, identified, the staff determines determines that the applicant's applicant's proposed programs are acceptable programs acceptable for managing managing the aging aging effect in the applicable components. The staff staff concludes that the applicant has demonstrated demonstrated that the effects of aging for these components components will adequately managed be adequately managed so that their intended function(s) will be maintained maintained consistent consistent with the the CLB during the period of extended operation, extended operation, as required by 10 CFR 54.21(a)(3).

54.21 (a)(3).

3.3.2.1.8 3.3.2.1.8 Loss Of Material Due To General, Pitting, And Crevice Corrosion In LRA Table 3.3.2-10, the applicant applicant stated that loss of material due to general, general, pitting and crevice crevice corrosion protection system steel spray nozzles exposed to air-gas wetted internal corrosion of fire protection environment environment is managed by the Fire Protection Protection Program.

Program.

The staff noted that the applicant applicant applied Generic Generic Note E to this item. The applicant referenced referenced 3.3-1, item 3.3.1-71 and GALL Report LRA Table 3.3-1, Report Volume 2, item VII.G-23. The staff reviewedreviewed the the AMR results lines that reference Generic reference Generic Note E and determines determines that the component component type, material, environment, and aging effect are consistent with the GALL Report. However, the staff staff noted noted that where the GALL Report recommends recommends AMP XI.M38, "Inspection of Internal Internal Surfaces Surfaces in in Miscellaneous Piping and Ducting Components," the applicant proposed Miscellaneous proposed using the Fire Protection Protection Program.

GALL GALL AMP XI.M38 recommends recommends periodic periodic visual inspection inspection of the internal surface of components components when accessible accessible during performance performance of maintenance maintenance or surveillance surveillance activities. The staff noted that these spray spray nozzles are in the halon and carbon carbon dioxide fire protection system. The staff staff reviewed reviewed the Fire Protection Protection Program, which provides for periodic visual inspection and and performance testing of halon and carbon dioxide system components, performance components, including spray nozzles, nozzles, which atmosphere, for managing loss of material due to corrosion and finds that it is which are open to atmosphere, consistent with GALL GALL AMP XI.M26, XI.M26, "Fire Protection."

Protection." The staff's review of the Fire Protection Protection Program and its evaluation is documented documented in SER SER Section 3.0.3.2.9. On the basis that periodicperiodic visual visual inspection is performed, the staff finds that the Fire protection Program Program will adequately adequately manage loss of material manage material due to general, pitting and crevice corrosion corrosion of fire protection system steel spray nozzles exposed exposed to air-gas wetted internal environment during during the period of extended extended operation.

operation.

3-255 3-255

In LRA Table 3.3.2-14, 3.3.2-14. the applicant applicant stated that loss of material material due to general.

general, pitting and crevice crevice corrosion of instrument corrosion instrument and control air system steel piping and fittings. fittings, heat exchanger exchanger components, filter housing.

components. housing, pump casing, tanks and valve bodies exposed to air/gas wetted internal environment managed by the Compressed environment is managed Compressed Air Monitoring Monitoring Program.

The staff noted that the applicant applied Generic Note E to this item. The applicant applied Generic referenced applicant referenced LRA Table 3.3-1, 3.3-1. item 3.3.1-71 and GALL GALL Report Report Volume 2, 2. item VII.G-23.

VII.G-23. The staff reviewed reviewed thethe AMR results lines that reference reference Generic Generic Note Note E and finds that the component type, material, component type. material, environment, and aging effect are consistent with the GALL Report. However. However, the staff note~

noted that where the GALLGALL Report recommends AMP XI.M38, XI.M38, "Inspection of Internal Surfaces in in Miscellaneous Piping and Ducting Components,"

Miscellaneous Components," the applicant proposed using the Compressed Air Monitoring Program.

Program.

GALL AMP XI.M38XI.M38 recommends recommends periodic periodic visual visual inspection of the internal internal surface of components when accessible accessible during performance performance of maintenance maintenance or surveillance activities. Since these Since these components are in the instrument instrument and control air system, the applicant has proposed the the .

Compressed Compressed Air Monitoring Monitoring Program. The staff reviewed the Compressed Compressed Air Monitoring Monitoring Program, which includes includes periodic visual inspection of internal surfaces of piping and heat exchanger components for loss of material exchanger components material and fouling, fouling, monitoring monitoring of system air quality in II accordance with industry accordance standards and guidelines, industry standards guidelines, and finds that itit is consistent consistent with the GALL AMP XI.M24, XI.M24. "Compressed Air Monitoring."

Monitoring." The staff's review of the Compressed Compressed Air Monitoring Monitoring Program and its evaluation documented in SER Section 3.0.3.2.8. On the basis that periqdic evaluation is documented periodic visual inspection of internal surfaces of piping and heat exchanger exchanger components components performed. the is performed, Monitoring program staff finds that the Compressed Air Monitoring adequately manage program will adequately manage loss of material general, pitting and crevice corrosion of instrument due to general. instrument and and control air system steel piping and fittings, heat exchanger fittings. exchanger components, filter housing, pump casing, casing. tanks and valve bodies exposed to air/gas air/gas wetted internal internal environment environment through through the period of extended operation.

Based Based on a review of the programs identified above, above. the staff determines determines that the applicant's applicant's proposed programs acceptable for managing the aging effects in the applicable proposed programs are acceptable applicable components.

The staff concludes that the applicant has demonstrated demonstrated that the effects effects of aging for these these components will be adequately managed components managed so that their intended function(s) will be maintained maintained consistent with the CLB during the period extended operation, period of extended operation, as required by 10 CFR 54.21 (a)(3).

3.3.2.1.9 Loss Of Material Due To General. General, Pitting.

Pitting, Crevice, Crevice. And (For (For Drip Pans And Drain Lines) Lines)

Microbiologically-influenced Microbiologically-influenced Corrosion In LRA Table 3.3.2-14.

3.3.2-14, the applicant stated that loss of material material due to general.

general, pitting, crevice crevice and microbiologically-influenced microbiologically-influenced corrosion corrosion of control building ventilation ventilation system steel air dryerdryer exposed exposed to air/gas wetted internal internal* environment managed by the Compressed Air Monitoring environment is managed Monitoriing Program.

The staff noted that the applicant applied applied Generic Note E to this item. The applicant referenced applicant referer)ced LRA Table 3.3-1, Table 3.3-1. item 3.3.1-72 and GALL Report Volume 2,

2. item VII.F1-3. The staff reviewed revie""ed thethe AMR results lines that reference reference Generic Generic Note E and finds that the component component type, material, material.

environment, and aging effect environment. effect are are consistent consistent with the GALL GALL Report. However.However, the staff noted that where the GALL Report recommends recommends AMP XI.M38, XI.M38. "Inspection of Internal Internal Surfaces in ,

Miscellaneous Piping and Ducting Components."

Miscellaneous Components," the applicant proposed using the Compressed Air Monitoring Monitoring Program.

3-256

GALL AMP XI.M39 GALL XI.M39 recommends recommends periodic visual inspection of the internal internal surface of components components when accessible performance of maintenance accessible during performance maintenance or surveillance surveillance activities.

activities. Since Since the the component is an air dryer, the applicant component applicant has proposed using usirng the Compressed Compressed Air Monitoring Monitoring Program. The staff reviewed the Compressed Air Monitoring Monitoring Program, which includes includes periodic periodic visual inspections inspections of internal surfaces internal surfaces of piping and heat exchanger exchanger components components for loss of material and fouling and monitoring of system air quality in accordance accordance with industry standards standards and guidelines, and finds that it is consistent with the GALL AMP XI.M24, "Compressed Air Air Monitoring." The staff's review of the Compressed Monitoring." Monitoring Program Compressed Air Monitoring Program and its evaluation is documented documented in SER Section 3.0.3.2.8. On the basis that periodic inspection of internal periodic visual inspection surfaces of piping and heat exchanger exchanger components components is performed, performed, the staff finds that the the Compressed Air Monitoring Monitoring Program will adequately manage adequately manage loss of material due to general, pitting, crevice and microbiologically-influenced microbiologically-influenced corrosion corrosion of control building ventilation ventilation system steel air dryer exposed to air/gas wetted internal internal environment environment through the period of extendedextended operation.

operation:

Based on a review of the program identified above, the staff determines program identified determines that the applicant's applicant's proposed acceptable for managing proposed program is acceptable managing the aging effects in the applicable applicable components.

The staff concludes that the applicant has demonstrated demonstrated that the effects of aging for these components components will be adequately adequately managed so that their intended function(s) will be maintained maintained consistent with the CLB during the period of extended extended operation, as required by 10 CFR 54.21 (a)(3).

3.3.2.1.10 Material Due To General, Pitting, Crevice, 3.3.2.1.10 Loss Of Material Crevice, And Microbiologically-influenced Microbiologically-influenced Corrosion, Lining/Coating Degradation Corrosion, Fouling, And Lining/Coating Degradation LRA Table 3.3.1, 3.3.1, Item 3.3.1-76 addresses loss of material material due to general, pitting, crevice, and microbiologically-influenced microbiologically-influenced corrosion, and fouling for steel components with their internal surfaces surfaces exposed to raw water water in the water treatment and distribution system.

The LRA credits the Inspection Internal Surfaces Inspection of Internal Surfaces in Miscellaneous Miscellaneous Piping and DuctingDucting Components Program, to manage this aging effect Components Program, effect for steel piping, piping and flow components, pump casings, tanks and valve body components components in a raw water (internal)

(internal) environment environment only. The GALL recommends GALL AMP XI.M20, "Open-Cycle GALL Report recommends "Open-Cycle Cooling Cooling Water System," to manage manage this aging effect. The AMR AMR line items that reference reference this line item in GALL ReportReport Table 1 cite cite Generic Generic Note E, indicating indicating that the AMR line items are consistent consistent with the GALL Report material, environment, and aging effect, but a different different aging management management program is credited. The staff staff confirmed that only piping, piping components and piping elements elements align to GALL Item VII.C1-19 VII.C1-19 and are fabricated fabricated from steel materials materials that are applicable to TMI. TMI.

Inspection of Internal The staff reviewed the Inspection Internal Surfaces Surfaces of Miscellaneous Miscellaneous Piping and DuctingDucting Components Program Components Program and its evaluation evaluation is documented documented in SER Section 3.0.3.2.17. The staff staff determined determined that the Inspection Inspection of Internal Internal Surfaces Surfaces in Miscellaneous Miscellaneous Piping and Ducting Ducting Components Components Program, Program, which includes includes periodic visual inspections and volumetric volumetric testing, when when appropriate, during periodic appropriate, during periodic system and component surveillance activities component surveillance activities or during maintenance maintenance activities activities when the internal surface is accessible for visual inspections, is adequate adequate to manage manage loss of material due to general, general, pitting, crevice, microbiologically-influenced corrosion, and crevice, and microbiologically-influenced fouling for steel components components exposed exposed to raw water water (internal)

(internal) addressed addressed by this AMR. On the basis basis of periodic periodic visual inspections, inspections, the staff finds the applicant's use of the InspectionInspection of Internal Surfaces in Miscellaneous Surfaces Miscellaneous Piping and Ducting Components Program acceptable.

Ducting Components 3-257 3-257

Based on a review of the programs programs identified above, the staff determines determines that the applicant's applicant's proposed programs are acceptable acceptable for managing managing the aging effect aging effect in the applicable components.

applicable componehts.

demonstrated that the effects of aging for these concludes that the applicant has demonstrated The staff concludes components will be adequately adequately managed intended function(s) managed so that their intended function(s) will be maintained consistent with the CLB during the period of extended extended operation, operation, as required by 10 CFR 54.21 (a)(3).

3.3.2.1.11 Material Due To Pitting And Crevice Loss Of Material Crevice Corrosion Item 3.3.1-78 addresses loss of material 3.3.1, Item LRA Table 3.3.1, material due to pitting and crevice crevice corrosion corrosion for components with internal surfaces exposed to raw water in the stainless steel and nickel alloy components stainless the miscellaneous floor and equipment drains miscellaneous drains system and radwaste radwaste system. '

Inspection of Internal The LRA credits the Inspection Internal Surfaces Miscellaneous Piping Surfaces in Miscellaneous Ducting Piping and Ducting Components Program, to manage manage this aging effect for nickel alloy and stainless steel piping, components in an internal raw water environment only. The fittings and various floor sump tank components The GALL Report GALL recommends GALL AMP XI.M20, "Open-Cycle Cooling Report recommends Cooling Water manage Water System," to manage this aging aging effect. The AMR line items that referencereference this line item in GALL ReportReport Table 1 citecite Generic Note Generic indicating that the AMR line items Note E, indicating items are consistent consistent with GALL material, GALL Report material, environment, and aging effect, but a different management program is credited.

different aging management credited. The staff noted that these AMR Line items in the reactor building sump and drain system are not in the the open-cycle cooling water system as described scope of an open-cycle described in GL 89-13, and therefore is not not within the scope of GALL AMP XI.M20, XI.M20, "Open-Cycle Cooling Water System."

Miscellaneous Piping and Ducting Inspection of Internal Surfaces of Miscellaneous The staff reviewed the Inspection Components Components Program and its evaluation evaluation is documented staff 3.0.3.2.17. The staff documented in SER Section 3.0.3.2.17.

determined determined that the Inspection of Internal Miscellaneous Piping and Ducting Internal Surfaces in Miscellaneous Ducting Components Components Program, which includes includes periodic visual inspections and volumetric testing, w~en visual inspections when appropriate, during periodic component surveillance activities or during periodic system and component maintenance during maintenance activities activities when the internal surface is accessible for visual inspections, is adequate to manage internal surface manage loss of material material due to pitting and crevice corrosion corrosion for stainless stainless steel and nickel alloy components exposed to raw water environment (internal) components (internal) addressed addressed by this AMR. On the basis II of periodic visual inspections, the staff finds the applicant's periodic Internal Surfaces applicant's use of the Inspection of Internal Surfaces in Miscellaneous Miscellaneous Piping and Ducting ComponentsComponents program acceptable.

Based on a review of the programs identified above, the staff determines programs identified applicant's determines that the applicant's acceptable for managing the aging effects in the applicable components.

proposed programs are acceptable staff concludes The staff demonstrated that the effects of aging for these concludes that the applicant has demonstrated adequately managed components will be adequately intended function(s) will be maintained managed so that their intended consistent with the CLB during the period of extended consistent extended operation, as required by 10 CFR CFR 54.21 (a)(3).

3.3.2.1.12 Loss Of Material Due To Pitting, Crevice, And Microbiologically-influenced 3.3.2.1.12 Corrosion Microbiologically-influenced Corrosion In LRA Table 3.3.2-10, the applicant stated stated that loss of material due to pitting, crevice, crevice, and microbiologically-influenced corrosion microbiologically-influenced corrosion of fire protection system protection system stainless steel piping, flow elements, restricting orifices, sprinkler heads, strainer strainer element and valve body in an internal environment of raw water is managed environment managed by the Fire Water System System Program.

Program.

,

staff noted The staff noted that the applicant applied Generic referenced Generic Note E to this item. The applicant referenced 3.3-1, item 3.3.1-80 and GALL Report Volume 2, item VII.H2-18. The staff reviewed LRA Table 3.3-1, reviewed 3-258

the AMR results lines that reference reference Generic Generic Note E and finds that the component component type, material, environment, environment, and aging effect are consistentconsistent with the GALL Report. However, the staff noted noted that where the GALL GALL Report recommends AMP XI.M20, Report recommends XLM20, "Open-Cycle Cooling Cooling Water System," the the applicant proposed using the Fire Water System program.

applicant proposed program. The staff noted that these components components are in the fire protection system and will not be in the scope of the GL 89-13 program program as dictated Open-Cycle Cooling Water Program.

by the Open-Cycle GALL GALL AMP XLM20,XI.M20, "Open-Cycle Cooling Water System" recommends performance testing and recommends performance inspection inspection to manage the effects effects of loss of material. The staff reviewed the Fire Water System Program, Program, which which manages identified aging effects for the water-based water-based fire protection system and associated associated components, through the use of periodic monitoring, and performance periodic inspections, monitoring, performance testing and provides for preventive preventive measures measures and inspection inspection activities activities to detect aging effects prior prior to loss of intended intended functions, and finds that itit is consistent with the GALL AMP XLM27, XI.M27, "Fire "Fire Water System." The staffs staff's review of the Fire Water System Program Program and its evaluation evaluation is documented in SER Section 3.0.3.2.10. On the basis that periodic inspection, monitoring and

. documented performance testing will be performed, performance performed, the staff finds that the Fire Water System Program will adequately manage loss of material due to pitting, adequately pitting, crevice, crevice, and microbiologically-influenced microbiologically-influenced corrosion of stainless steel piping, flow elements, restricting orifices, sprinkler heads, strainer element and valve body in an internal environment environment of raw water water in the fire protection protection system through through the period period of extended extended operation.

Based on a review of the programsprograms identified, the staff determines determines that the applicant's applicant's proposed proposed acceptable for managing programs are acceptable managing the aging effect in the applicable components. The staff staff concludes that the applicant has demonstrated demonstrated that the effectseffects of aging aging for these components will adequately managed be adequately managed so that their intended function(s) will be maintained maintained consistent with the the CLB during during the period of extended extended operation, as required by 10 CFR 54.21(a)(3). 54.21 (a)(3).

3.3.2.1.13 Loss Of Material Due To Pitting, 3.3.2.1.13 Pitting, Crevice, And Microbiologically-influenced Microbiologically-influenced Corrosion, Corrosion, And Fouling Fouling LRA Table 3.3.1, 3.3.1, Item 3.3.1-81 addresses addresses loss of material due to pitting, crevice, and microbiologically-influenced corrosion, and fouling for copper alloy (with 15%

microbiologically-influenced 15% zinc or more and with less than 15% zinc) components with its internal surfaces exposed exposed to raw water in the the miscellaneous floor and equipment drains system and the water treatment and distribution miscellaneous distribution system.

The LRA credits the Inspection Inspection of Internal Surfaces Surfaces in Miscellaneous Miscellaneous Piping and Ducting Components Program, to manage manage this aging effect for copper copper alloy (with 15% 15% zinc or more and with less than 15%

15% zinc) piping, piping, fittings, tanks and valve body components in a raw water (internal) environment only. The GALL Report (internal) environment Report recommends GALL AMP XLM20, XI.M20, "Open-Cycle "Open-Cycle Cooling Water System," to manage manage this aging effect. The AMR line items items that reference this line line item in GALL Report Table 1 cite Generic Generic Note E, indicating indicating that the AMR line items are consistent consistent with the GALL GALL Report material, material, environment, and aging effect, but a different different aging aging management program management program is credited. The staff confirmed that only piping, piping components and piping elements align to GALL GALL Item VII.C1-9 VII.C1-9 and are fabricated from copper alloy materials materials that applicable to TMI.

are applicable TMI.

reviewed the Inspection The staff reviewed Inspection of Internal Surfaces of Miscellaneous Miscellaneous Piping and Ducting Components Program and its evaluation is documented Components documented in SER Section 3.0.3.2.17. The staff staff determined determined that the Inspection Inspection of Internal Surfaces in Miscellaneous Internal Surfaces Miscellaneous Piping and Ducting Ducting Components Program, which includes Components includes periodic visual inspections inspections and volumetric volumetric testing, when 3-259 3-259

appropriate, during periodic periodic system and component component surveillance activities maintenance activities or during maintenance activities when the internal surface is accessible accessible for visual inspections, is adequate to manage visual inspections, manage loss of material material due to pitting, crevice, and microbiologically-influenced corrosion, and fouling for microbiologically-influenced corrosion, copper alloy (with 15% zinc or more and with less than 15% zinc) components exposed to raw (with 15% raw water (internal)

(internal) addressed addressed by this AMR. On the basis of periodic visual inspectionsinspections and volumetric volumetric testing, when appropriate, appropriate, the staff finds the applicant's use of the Inspection Inspection of Internal Internal Surfaces Surfaces Miscellaneous Piping and Ducting Components in Miscellaneous Components Program acceptable.

Program acceptable.

Based on a review of the programs identified above, the staff determines programs identified determines that the applicant's applicant's programs are acceptable proposed programs acceptable for managing the aging effect in the applicable applicable components.

The staff concludes that the applicant applicant has demonstrated demonstrated that the effects of aging for these these components will be adequately components managed so that their intended adequately managed intended function(s) function(s) will be maintained maintained consistent with the CLB during the period of extended operation, as required by 10 CFR CFR !

54.21(a)(3).

54.21 (a)(3).

3.3.2.1.14 Loss Of Material Due To General, Pitting, And Crevice Corrosion 3.3.2.1.14 In LRA Table 3.3.2-10, the applicant applicant stated that loss of material due to general, pitting and crevice crevice corrosion of fire protection protection system steel fire barrier barrier doors and penetration penetration seals exposed exposed to air air with borated borated water leakage leakage external environment are managed by the Fire Protection environment Protection Program.

The staff noted that the applicant applied Generic Generic Note E to this item. The applicant referencedreferenced LRA Table 3.3-1, item 3.3.1-86 and GALL Report Volume 2, item VII.A1-1.

Table 3.3-1, VII.A1-1. The staff reviewed reviewed the the AMR results lines that reference Generic determines that the component type, I Generic Note E and determines consistent with the GALL Report. However, the staff material, environment, and aging effect are consistent noted that where where the GALL Report recommends recommends AMP XI.S6, "Structures Monitoring Program," the the applicant applicant proposed using the Fire Protection Program.

Program.

3.3.2-10-1, dated October 16, 2008, the staff requested In RAI 3.3.2-10-1, requested that the applicant provide applicant provide additional information information to explain why GALL GALL Report item VII.A1-1 was used, since this item is for steel components components in an air-indoor environment, and not an air with borated water leakage leakage environment.

environment. The staff staff noted that the applicant referenced GALL Report item III.B5-8 applicant referenced I1.B5-8 for fire fire doors doors in LRALRA Tables 3.5.2-2 and 3.5.2-7. The staff also asked the applicant to justify why it used Protection Program and not the Boric Acid the Fire Protection Acid Corrosion Program, and which program program Ilwill

,will be be evaluate and control boric acid leakage.

used to evaluate In its response to the RAI dated November November 12, 2008, the applicant stated that in its aging management review process, for steel components management components in air with borated water leakage leakage environment, it considered loss of material due to boric acid leakage, and due to general, general, pitting pitting and crevice corrosion.

corrosion. The applicant also mentioned mentioned that GALL GALL Report item VII.A1-1 VII.A1-1 was was referenced for loss of material referenced material due due to general, pitting and crevice corrosion, and item VI/.I-tO VII.l-10 waswas referenced for loss of material due to boric acid leakage because referenced because the fire protection protection systemi system!' is included in GALLGALL Report Chapter VII, Auxiliary Systems VI/, Auxiliary Systems and not in Chapter Chapter III,III, which is for structures.

The applicant further stated that both the Fire Protection Protection Program and the Boric Acid Corrosion Program are credited in the LRA. The Fire Protection Program Program is credited credited for managing managing loss of material due to general, pitting and crevice material crevice corrosion, whereas the Boric Acid Corrosion Program is credited for managing loss of material material due to boric acid leakage. In all cases, the applicant applicant stated, the Boric Acid Corrosion Corrosion Program is used to evaluate evaluate and control boric acid acid leakage.

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Based on its review, the staff finds the applicant's applicant's response to the RAI acceptable because the acceptable because the applicant has credited the Boric Acid Corrosion Program manage loss of material Program to manage material due to boric boric acid leakage Protection Program to manage leakage and is using the Fire Protection manage loss of material due to general, pitting and crevice corrosion. Furthermore, the staff finds the use of GALL Report item VII.A1-1 VII.A1-1 to acceptable be acceptable since the fire protection protection system is part of the GALL Report Chapter VII, Auxiliary VII, Auxiliary Systems. The staff reviewed reviewed the Fire Protection Program, Program, which provides provides for periodic periodic visual barrier walls, ceilings and floors; and fire doors for penetration seals; fire barrier inspection of fire barrier penetration managing managing lossJoss of material corrosion and is consistent with GALL material due to corrosion GALL AMP XI.M26, "Fire Protection." The staffs review of the Fire*Protection program and its evaluation is documented in Fire Protection program SER Section 3.0.3.2.9. On the basis that periodic visual inspection inspection is performed, the staff finds finds Protection Program will adequately that the Fire Protection adequately manage loss of materialmaterial due to general, general, pitting pitting protection system steel fire barrier crevice corrosion of fire protection and crevice barrier doors and penetration seals penetration seals exposed to air with borated water leakage external exposed external environment during the period of extended extended operation.

Based Based on a review of the programs identified identified above, the staff determines determines that the applicant's applicant's proposed programs proposed acceptable for managing the aging effect programs are acceptable effect in the applicable applicable components.

components.

The staff concludes demonstrated that the effects of aging for these concludes that the applicant has demonstrated these components adequately managed so that their intended function(s) will be maintained components will be adequately maintained consistent with the CLB during the period period of extended required by 10 extended operation, as required 10 CFR CFR 54.21 (a)(3).

3.3.2.1.15 Loss of Material due to General, 3.3.2.1.15 Pitting, Crevice, and Galvanic Corrosion General, Pitting, 3.3.1, item 3.3.1-48, the applicant stated In LRA Table 3.3.1, stated that the AMR AMR result is not consistent consistent with the GALL GALL Report. LRA Tables 3.3.2-9 and 3.3.2-22 3.3.2-22 include AMR result lines referencing referencing 3.3.1-48 where item 3.3.1-48 components in a closed-cycle cooling water where carbon steel components water environment environment have have an aging effect of loss of material due to general, pitting and crevice corrosion and the the recommended Cooling Water System program.

Closed-Cycle Cooling recommended AMP is the Closed-Cycle program. For these AMR result lines the applicant cited generic note I,I, indicating that the aging effect in the GALL GALL Report for the the combination is not applicable. The applicant also included material and environment combination component, material a plant-specific note stating that loss of material due due to galvanic corrosion corrosion is not predicted because because materials cause galvanic corrosion are not in contact materials that cause contact with the component.

The staff noted noted that the applicant appeared to be citing Generic applicant appeared Generic Note II to indicate that the aging aging effect due to one mechanism, galvanic corrosion, is not present, rather than to indicate that the the 3.3.2-48-1, dated October aging effect is not present at all. In RAI 3.3.2-48-1, October 16, 2008, the staff requested requested that the applicant provide additional information to clarify the meaning of Generic additional information Note I,I, as used Generic Note for these AMR result lines.

In its response to the RAI dated November 12, 2008, the applicant stated dated November stated that Generic Note I in the LRA 3.x.2 AMRAMR tables is applied when the component, material and environment environment combination exists but the aging effect, or any of the identified aging mechanisms mechanisms associated with the aging aging effect, in the GALL Report Report is not predicted. The applicant stated that in these cases, the GALL identified in the LRA 3.x.1 aging management summary Report Table 1 item number is identified summary tables as as predicted is identified effect/mechanism that is not predicted being applicable and the specific aging effect/mechanism identified in thethe item discussion evaluation paragraph where the GALL discussion column or in the evaluation GALL Report specifies further specifies further evaluation. The applicant further stated that in accordance evaluation. accordance with EPRI Report 1010639, "Non-Implementation Guidelines and Mechanical Mechanical Implementation Class 1 Mechanical Mechanical Tools," Revision 4, galvanicgalvanic predicted for component, material, and environment combinations when the corrosion is not predicted the 3-261

subject to AMR is not in contact with a material of different electrochemical material subject electrochemical potential, and that in these cases the Table 3.x.2 AMR AMR line items are identified with genericgeneric note I. I.

Because the applicant cited Generic Note I for AMR results where one aging mechanism, rather than the aging effect due to all mechanisms, mechanisms, does does not occur, the staff finds that the applicant's applicant's use of generic note I does not indicate an inconsistency comparable AMR results in the inconsistency with comparable the GALL Report. Because Because the component, material, environment and aging effect combination material, environment combination

. (except for one aging mechanism) consistent with the GALL Report mechanism) is consistent Report and the AMP proposed by by the applicant applicant is the same as the AMP recommended recommended in the GALL Report, the staff finds that the that"the applicant's AMR results are consistent applicant's consistent with the GALL Report and are acceptable.

applicant's response to RAI 3.3.2-48-1 Based on its review, the staff finds the applicant's 3.3.2-48-1 acceptable because acceptable because Generic Note II does not indicate an inconsistency with comparable applicant's use of Generic the applicant's comparable AMR AMR results in the GALL Report. The staff also finds that because because the component, material, combination (except for one aging mechanism) environment and aging effect combination environment mechanism) is consistent With with the GALL Report, and the AMP proposed by the applicant applicant is the same as the AMP recommended recommended GALL Report, the AMR results are consistent in the GALL consistent with the GALL Report. The staff's concern described described in RAI 3.3.2-48-1 is resolved.

Based identified, the staff concludes Based on the programs identified, applicant's proposed concludes that the applicant's proposed programs programs are acceptable acceptable for managing the aging aging effect in the applicable determine s that applicable components. The staff determine's the LRA is consistent with the GALL GALL Report and that the applicant has demonstrateddemonstrated that the the effects of aging will be adequately managed so that the intended function(s) will be maintained adequately managed consistent with the CLB during during the period of extended operation, as required by extended operation, by 10 CFR 54.21(a)(3).

Material due to Pitting, Crevice, 3.3.2.1.16 Loss of Material Crevice, and Galvanic Galvanic Corrosion In LRA Table 3.3.1, 3.3.1-51, the applicant stated that the AMR result is not consistent 3.3.1, item 3.3.1-51, consistent with the GALL Report. LRA Tables Tables 3.3.2-4, 3.3.2-6, 3.3.1-9, 3.3.2-223.3.2-22 and 3.3.2-24 3.3.2-24 include AMR AMR results results referencing*

referencing item 3.3.1-51 where copper alloy components components in aa closed-cycle closed-cycle cooling water .

environment have environment have an aging material due to pitting and crevice corrosion aging effect of loss of material corrosion ana and the the recommended AMP recommended is the Closed-Cycle Closed-Cycle Cooling Water System program. For these AMR results applicant cited generic note the applicant indicating that the aging effect note I,I, indicating effect in the GALL GALL Report for the. the component, material and environment environment combination applicable. The applicant also included combination is not applicable. included plant-specific note stating that loss of material due to galvanic corrosion is not predicted a plant-specific predicted because materials that cause galvanic corrosion are not in contact with the component.

galvanic corrosion The staff staff noted noted that the applicant appeared to be citing note II to indicate that the aging effect due applicant appeared due to one mechanism, mechanism, galvanic corrosion, corrosion, is not present, rather rather than to indicate indicate that the aging effect aging~ffect dated October letter dated In aa letter 16, 2008, staff issued RAI 3.3. 1-48-1 and the staff present at all. In is not present October 16, 2008, the issued RAI 3.3. f-48-1 and .

requested requested that the applicant information to clarify the meaning applicant provide additional information meaning of genericinote generic!note I,I, as used for these AMR result lines.

In its response to the RAJ RAI dated November November 12,2008, applicant stated that generic notelI 12, 2008, the appJicantstated note,J in the the LRA 3.x.2 AMR tables is applied when the component, material and environment combination and environment combination exists but the aging effect, or any of the identified mechanisms associated identified aging mechanisms associated with the aging effect in the GALL Report is not predicted.predicted. The applicant applicant stated that in these cases, the GALL Report Table 1 item number is identified identified in the LRA 3.x.1 aging management summary tables as management summary and the specific applicable and being applicable specific aging effect/mechanism that is not predicted agIng effect/mechanism predicted is identified identified in thethe item discussion column or in the evaluation evaluation paragraph where the GALL Report specifies specifies further further 3-262 3-262

applicant further evaluation. The applicant evaluation. accordance with EPRI Report 1010639, "Non-further stated that in accordance Class 1 Mechanical Mechanical Implementation Mechanical Tools," Revision 4, galvanic Guidelines and Mechanical Implementation Guidelines galvanic combinations when the predicted for component, material, and environment combinations corrosion is not predicted the material subject to AMR is not in contact material electrochemical potential, and contact with a material of different electrochemical identified with generic note I.I.

that in these cases the Table 3.x.2 AMR line items are identified Based on its review, the staff finds the applicant's response to RAI 3.3.1-48-1 acceptable acceptable because because the applicant cited generic generic note note II for AMR results where one aging mechanism, rather than the the aging effect effect due to all mechanisms, does not occur which inconsistency with which does not indicate an inconsistency with comparable AMR results in the GALL Report. Because comparable Because the component, material, material, environment environment and aging effect effect combination combination (except for one aging mechanism) mechanism) is consistent with the GALL Report and the AMP proposed proposed by the applicant is the same as the AMP recommended recommended in the GALL consistent with the GALL Report applicant's AMR results are consistent Report, the staff finds that the applicant's Report and and are acceptable. concern in RAI 3.3.1-48-1 acceptable. The staffs concern 3.3.1-48-1 is resolved.

Based applicant's proposed programs Based on the programs identified, the staff concludes that the applicant's programs are acceptable applicable components. The staff determines acceptable for managing the aging effect in the applicable determines that the LRA is consistent with the GALL demonstrated that the GALL Report and that the applicant has demonstrated the effects of aging managed so that the intended function(s) aging will be adequately managed maintained function(s) will be maintained consistent with the CLB during the period extended operation, as required by period of extended 10 10 CFR 54.21(a)(3).

Material due to General, Pitting, Crevice, and Microbiologically-influenced 3.3.2.1.17 Loss of Material Microbiologically-influenced Corrosion, Fouling, and Lining/Coat Corrosion, Lining/Coat Degradation LRA Table 3.3.2-25 includes AMR results for carbon steel, ductile ductile cast iron and gray cast iron iron components in a raw water environment in the water treatment water environment distribution system where the treatment and distribution the aging effect of loss of material managed by the Inspection material is managed Inspection of Internal Miscellaneous Internal Surfaces in Miscellaneous Components AMP. For these AMR results, the applicant referred Ducting Components Piping and Ducting referred to LRA recommended by the GALL 3.3.1-76, where the AMP recommended 3.3.1, item 3.3.1-76, Table 3.3.1, GALL Report is the Open-Cycle Open-Cycle Cooling Water System program, and cited generic note E indicating indicating that the result is consistent different aging environment and aging effect, but a different with the GALL Report for material, environment management program is used.

management In a letter letter dated 16, 2008, the staff issued RAI 3.3.2-25-1 dated October 16,2008, requesting that the applicant 3.3.2-25-1 requesting applicant provide additional information to explain additional information recommended in the different from the one recommended explain why an AMP different the GALL Report is being being used used for these components.

November 12, 2008, the applicant stated that the raw water In its response to the RAI dated November water treatment and distribution environment in the water treatment environment includes domestic water, filtered distribution system includes non-demineralized water water, and other non-demineralized water sources. The applicant stated that these environments environments are not considered raw cooling water and, as such, are not addressed addressed by the activities of the the .

Open-Cycle Cooling Water System AMP. The applicant Open-Cycle applicant further stated that these environments environments Chemistry AMP.

addressed by the activities of the Water ChemistryAMP.

are not addressed Miscellaneous Piping and Ducting Inspection of Internal Surfaces in Miscellaneous The applicant stated that the Inspection Ducting Components AMP includes Components inspections that are performed includes internal inspections during periodic system and component inspections component activities when the surfaces maintenance activities inspections and during the performance of maintenance surfaces accessible for inspection.

are made accessible program includes visual inspection. The applicant stated that the program inspections to assure that environmental inspections degradation such environmental conditions are not resulting in material degradation microbiologically-influenced corrosion and material due to general, pitting, crevice, and microbiologically-influenced as loss of material 3-263 3-263

fouling and that material degradation identified during the inspections material degradation inspections will be entered into the the corrective corrective action process for further evaluation.

further evaluation.

The staff reviewed reviewed the applicant's applicant's RAI response and the Inspection Inspection of Internal Internal Surfaces in in Miscellaneous Piping and Ducting Components Miscellaneous Components program. The staffs staffs evaluation of this program, which documented in SER Section 3.0.3.2.17, determined which is documented determined that the Inspection Inspection of Internal Miscellaneous Piping and Ducting Components Surfaces in Miscellaneous Surfaces Components program, with an acceptable acceptable exception, is consistent with GALL XI.M38, "Inspection of Internal Surfaces GALL AMP XI,M38, Miscellaneous Surfaces in Miscellaneous Piping and Ducting Components," and provides for visual inspections of internal surfaces of iblant internal surfaces plant components to be performed maintenance or surveillance performed during maintenance including visible surveillance activities, including visible.

evidence corrosion to indicate possible loss of materials. The staff noted that the Inspection evidence of corrosion Inspection of Internal Surfaces Internal Miscellaneous Piping and Ducting Components program Surfaces in Miscellaneous program includes evaluation evaluation indications of corrosion or fouling to determine whether of indications intended function is component intended whether component affected and requires corrective actions in accordance affected corrective action program accordance with the site's corrective program quality assurance and quality procedures.

assurance procedures. The staffs concern staffs concern in RAI 3.3.2-25-1 3.3.2-25-1 is resolved.

applicant's response to RAI 3.3.2-25-1 Based on its review, the staff finds the applicant's acceptable because 3.3.2-25-1 acceptable because the Inspection of Internal Miscellaneous Piping and Ducting Components Internal Surfaces in Miscellaneous Components program includes detection of loss of material includes appropriate corrective material and requires appropriate corrective actions ifif loss of material affecting component affecting component intended intended function is found. The staff finds that the applicant's applicant's use of the the Miscellaneous Piping and Ducting Components program to Surfaces in Miscellaneous Inspection of Internal Surfaces manage loss of material in carbon manage carbon steel, ductile components in a raw ductile cast iron and gray cast iron components a water environment environment in the water treatment distribution system to be acceptable.

treatment and distribution staff s acceptable. The staffs described in RAI 3.3.2-25-1 is resolved.

concern described concern identified, the staff concludes that the applicant's proposed programs are Based on the programs identified, Based acceptable managing the aging effect in the applicable acceptable for managing applicable components. The staff determinesdetermines that the LRA is consistent with the GALL Report and that the applicant demonstrated that the applicant has demonstrated the effects of aging will be adequately managed so that the intended function(s) adequately managed function(s) will be maintained maintained consistent with the CLB during the period of extended extended operation, as required by 10 CFR 54.21(a)(3).

Material due to Pitting, Crevice, Galvanic 3.3.2.1.18 Loss of Material 3.3.2.1.18 Microbiologically-influenced Galvanic and Microbiologically-influenced Corrosion and Fouling In LRA Table Table 3.3.1, applicant stated that the AMR result is not consistent with 3.3.1, Item 3.3.1-82, the applicant the GALL GALL Report. LRA Table 3.2.2-4 includes includes AMR result Iines referring to Table 3.3.1, lines referring 3.3.1, Item Item 3.3.1-82, where the coppercopper alloy components components in a raw water environment have an aging environment material due to pitting, crevice effect of loss of material microbiologically-influenced corrosion crevice and microbiologically-influenced corrosion and recommended AMP is the Open-Cycle fouling and the recommended Open-Cycle Cooling Water System System program. For these For:these AMR result lines the applicant AMR cited generic Note I,I, indicating that the aging effect applicant cited effect in the GALL Report for the component, material and environment Report combination is not applicable. The applicant environment combination applicant plant-specific note stating that the aging mechanism also included a plant-specific mechanism of galvanic galvanic corrosion does does material is not in contact with material higher in galvanic series.

not apply since the material The staff noted appeared to be citing note II to indicate that the aging effect due noted that the applicant appeared due corrosion, is not present, rather mechanism, galvanic corrosion, to one mechanism, indicate that the aging ~effect rather than to indicate effect is not present at all. In a letter letter dated October 16, 2008, the staff issued RAI 3.3.1-48-1 requesting provide additional that the applicant provide information to clarify the meaning additional information meaning of generic generic note I,I, as used for these AMR AMR result lines.

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November 12, 2008 the applicant In its response to the RAI dated November applicant stated that generic generic note I in the the LRA 3.x.2 AMRAMR tables is applied applied when the component, environment combination material and environment exists but the aging effect, or any of the identified identified aging mechanisms mechanisms associated with the aging aging effect, in the GALL GALL Report is not predicted. The applicant applicant stated that in these cases, the GALL Report Report Table 1 item number is identified identified in the LRA 3.x.1 aging management summary tables as aging management being being applicable applicable and the specific aging effect/mechanism effect/mechanism that is not predicted is identified in the the item discussion column or in the evaluation paragraph paragraph where the GALL Report Report specifies further evaluation. The applicant further further stated that in accordance accordance with EPRI Report Report 1010639, "Non-1010639, "Non-Mechanical Implementation Class 1 Mechanical Implementation Guidelines and Mechanical Mechanical Tools," Revision Revision 4, galvanic galvanic corrosion is not predicted for component, material, and environment environment combinations when the the material subject to AMR is not in contact with a material material material of different different electrochemical potential, and electrochemical potential, that in these cases the Table 3.x.2 AMR line items are identified with generic generic note I.

I. .

Based on its review, the staff finds the applicant's applicant's response to the RAI acceptable acceptable because because the the applicant cited generic note II for AMR results where where one aging mechanism, mechanism, rather than the aging aging effect due due to all mechanisms, mechanisms, does not occur, which does not indicate indicate an inconsistency inconsistency with with comparable comparable AMR AMR results in the GALL Report. Because the component, material, environment environment and aging effect effect combination combination (except for one aging mechanism) is consistent consistent with the GALL Report and the AMP proposed by the applicant applicant is the same as the AMP recommended recommended in the GALL Report, the staff finds that the applicant's applicant's AMR results are consistent with the GALL GALL Report and are acceptable. The staff's concern concern described described in RAI 3.3.1-48-1 is resolved.

Based on the programs programs identified, the staff concludes that the applicant's proposed proposed programs are acceptable acceptable for managing managing the aging effect in the applicable determines that applicable components. The staff determines that the LRA is consistent with the GALL GALL Report and that the applicant applicant has demonstrated demonstrated that the the effects of aging effects adequately managed aging will be adequately managed so that the intended intended function(s) will be maintained maintained consistent with the CLB during the period of extended extended operation, as required required by 10 CFR 54.21(a)(3).

3.3.2.1.19 Cracking due 3.3.2.1.19 Cracking due to Stress Corrosion Cracking, or Loss of Material Material due to Pitting and Crevice Corrosion Corrosion LRA Table 3.2.2-21 includes includes AMR result lines referring to Table 3.3.1, 3.3.1, Items 3.3.1-90 3.3.1-90 or 3.3.1-91, 3.3.1-91, for stainless steel components in a treated borated water environment in the radwaste radwaste system having aging effects of cracking due to stress corrosion cracking or loss of material material due to pitting pitting and crevice corrosion. For these components components the applicant credited the One-Time Inspection Inspection program in addition to the Water Chemistry program program for managing the aging effects effects in the the components. For the AMR result lines using the One-Time One-Time Inspection Inspection Program, the applicant applicant cited generic generic note E, indicating that the result line is consistent with the GALL Report for material, material, environment, environment, and aging effect, but a different different AMP is credited. The applicant also cited a plant-specific specific note stating that for portions of the radwaste system which receive drainage of reactor and spent fuel pool grade borated borated treated treated water, plant operating experience experience is that aging effects effects progress environments may be more adverse than the general progress very slowly but local environments general environment; applicant states that the One-Time the applicant One-Time Inspection program will augment the Water Chemistry program by verifying the absence of aging effects.

program The staff reviewed the applicant's One-Time Inspection program.

One-Time Inspection program. The staff's staffs evaluation evaluation of this this program, which is documented program, documented in SER Section 3.0.3.2.14, determineddetermined that the One-Time One-Time Inspection Inspection program is consistent with GALL AMP XI.M32, "One-Time Inspection," Inspection," and is adequate adequate to detect detect the presence presence or note the absence absence of cracking due to SCC or of loss of material due to pitting and crevice corrosion.

corrosion. Because the One-Time InspectionInspection program is used as an 3-265

recommended in the GALL report and provides added assurance that augmentation of the AMP recommended augmentation the aging effects are not present or are progressing slowly, the staff finds the AMPs specified by by the applicant for these AMR result lines to be acceptable.

acceptable.

Based on a review of the programs identified above, the staff concludes that the applicant's*

programs identified applicant's acceptable for managing proposed programs are acceptable applicable components.

managing the aging effect in the applicable determines that the LRA is consistent with the GALL Report The staff determines Report and that the applicant hashas adequately managed so that the intended demonstrated that the effects of aging will be adequately demonstrated maintained consistent with the CLB during the period function(s) will be maintained period of extended as operation, as extended operatiqn, 54.21 (a)(3).

required by 10 CFR 54.21(a)(3). .

3.3.2.2 3.3.2.2 AMR AMR Results That Are Consistent Consistent with the GALL Further Report, for Which Further GALL Report, Evaluation is Recommended Evaluation 3.3.2.2 provides further evaluation LRA Section 3.3.2.2 recommended by the management, as recommended evaluation of aging management, the GALL Report, for the auxiliary systems systems components.

components. The applicant information applicant provided information concerning how itit will manage concerning manage the following agingaging effects:

" Cumulative Damage Cumulative Fatigue Damage

- Reduction of Heat Transfer Due to FoulingFouling

- Cracking due to SCC

- Cracking due to SCC and Cyclic Loading Cracking Loading

- Elastomer Degradation Hardening and Loss of Strength due to Elastomer Degradation

- Neutron-Absorbing Capacity and loss of material due to General Reduction of Neutron-Absorbing Reduction General Corrosion

- Material due to General, Pitting, and Crevice Loss of Material Crevice Corrosion Corrosion

- due to General, Pitting, Material due Loss of Material MIC Pitting, Crevice, and MIC

- general, Pitting, Crevice, MIC and Fouling Material due to general, Loss of Material Fouling

- Material due to Pitting and Crevice Loss of Material Crevice Corrosion

Loss of Material Galvanic Corrosion Material due to Pitting, Crevice, and Galvanic Corrosion D° Crevice, and MIC Material due to Pitting, Crevice, Loss of Material MIC Do Material due to Wear Loss of Material Wear

- Material due Loss of Material due to Cladding Breach For component evaluated in the GALL Report for which the applicant claimed consistency groups evaluated component groups with the GALL GALL Report and for which which the GALL Report recommends evaluation, the staff recommends further evaluation, audited and reviewed the applicant's evaluations determine whether they adequately evaluations to determine address adequately address evaluations against the criteria those issues. In addition, the staff reviewed the applicant's further evaluations qiteria in SRP-LR SRP-LR Section 3.3.2.2. The staffs review of the applicant's further evaluation follows.

Cumulative Fatigue Damage 3.3.2.2.1 Cumulative Damage age-related degradation Fatigue is an age-related degradation mechanism compon~nt by stressing of a component mechanism caused by cyclic stressing either mechanical or thermal stresses. SRP-LR Section 3.3.2.2.1 states that fatigue is a TLAA either TLM as as defined in 10 CFR 54.3 and that TLAAs are required defined required to be evaluated accordance with 10 evaluated in accordance 10 CFR CFR addressed separately in Section 4.3, "Metal Fatigue Analysis" or Sebion 54.21(c). This TLAA is addressed 54.21(c). Section Plant-Specific Time-Limited Aging Analyses" of the SRP-LR.

4.7, "Other Plant-Specific 3-266

LRA LRA Section 3.3.2.2.1 3.3.2.2.1 states that TLAAs TLMs are evaluated in accordance accordance with 10 10 CFR 54.21(c) and that the evaluations evaluations of this TLM TLAA are addressed in Sections Sections 4.3 and 4.6. This is consistent with SRP-LR 3.3.2.2.1 and is, therefore, acceptable.

SRP-LR Section 3.3.2.2.1 acceptable.

3.3.2.2.2 Reduction 3.3.2.2.2 Reduction of Heat Transfer Transfer due to Fouling The staff reviewed reviewed LRA Section Section 3.3.2.2.2 3.3.2.2.2 against against the criteria in SRP-LR Section 3.3.2.2.2.

LRA Section 3.3.2.2.2 3.3.2.2.2 states that TMI-1 will implement a One-TimeOne-Time Inspection Inspection Program, Program, to verify the effectiveness effectiveness of the Water Chemistry Program, to manage manage the reduction reduction of heat transfer due transfer due to fouling in stainless steel heat exchanger exchanger components exposed to treated water in the closed cycle cooling water system.

The staff reviewed LRA Section 3.3.2.2.2 against against the criteria in SRP-LR Section 3.3.2.2.2, 3.3.2.2.2, which states that reduction of heat transfer transfer due to fouling could occur for stainless steel heat heat exchanger tubes exposed to treated treated water. The existing program relies on control of water water chemistry to to manage reduction reduction of heat transfer due to fouling.

fouling. However, the GALL Report recommends that Report recommends that the effectiveness effectiveness of the water chemistry control program should be verified to ensure ensure that reduction of heat heat transfer transfer due to fouling is not occurring. A one-time inspection inspection is an acceptable acceptable method to ensure that reduction reduction of heat transfer is not occurring and that the component's component's intended function function will be maintained maintained during the period of extended extended operation.

SRP-LR SRP-LR Section 3.3.2.2.2 3.3.2.2.2 invokes invokes AMR Item 3 in Table 3 of the GALL Report, Volume 1, and AMR Item VII.A4-4 VII.A4-4 in the GALL Report, Volume 2, as applicableapplicable to stainless steel heat exchanger exchanger tubes that are exposed to treated treated water.

The applicant stated that the Water Chemistry Chemistry Program is consistent with EPRI 1002884, 1002884, Pressurized Water Chemistry Guidelines, Revision 5 and Plant Technical Water Reactor Primary Chemistry Specification limits for fluorides, chlorides, and dissolved oxygen Specification oxygen and is consistent with GALL Report AMP XI.M2. The applicant applicant also stated that the One-Time Program will be used One-Time Inspection Programwill to confirm the effectiveness effectiveness of the Water Chemistry Program to manage manage the loss of material, cracking, and the reduction of heat transfer transfer aging effects and is consistent consistent with GALL Report AMP Report AMP XI.M32. The staffs review of the Water ChemistryChemistry program and the One-Time Inspection program One-Time Inspection evaluation is documented and its evaluation documented in SER Sections 3.0.3.2.2 3.0.3.2.2 and 3.0.3.2.14 3.0.3.2.14 respectively.

respectively.

On the basis that the Water Chemistry Program Program maintains maintains water chemistry within acceptable acceptable limits, and the One-Time Inspection One-Time Inspection Program performs performs visual inspection to confirm the the effectiveness effectiveness of the Water Chemistry Program, Program, the staff finds that the Water Chemistry Program One-Time Inspection and the One-Time Program will adequately Inspection Program adequately manage manage reduction of heat heat transfer transfer due toto fouling for stainless stainless steel steel heat exchanger exchanger tubes exposed to treatedtreated water through the period of extended operation.

extended Based on aa review of the programs identified, the staff concludesconcludes that the applicant's programs applicant's programs meet SRP-LR SRP-LR Section 3.3.2.2.2 criteria. For those line items that apply to LRA Section 3.3.2.2.2, the staff determines determines that the LRA is consistent with the GALL Report and that the applicant has has demonstrated demonstrated that the effects of aging will be adequately adequately managed managed so that the intended function(s) function(s) will be maintained maintained consistent with the CLB during the period of extended extended operation, as as required by 1010 CFR 54.21 54.21(a)(3).

(a)(3).

3-267 3-267

3.3.2.2.3 Cracking Cracking due to SCC The staff reviewed LRA Section 3.3.2.2.3 against against the criteria criteria in SRP-LR Section 3.3.2.2.3.

(1) LRA Section 3.3.2.2.3 addresses addresses cracking agingeffect is not cracking due to SCC, stating that this aging.effect applicable applicable to TMI-1, which is a PWR.

TMI-1, which SRP-LR SRP-LR Section 3.3.2.2.3 states that cracking due to SCC could occur in the stainless 3.3.2.2.3 states stainless steel piping, piping components, and piping elementselements of the BWR standby liquid liquid control system that are exposed to sodium pentaborate sodium penta borate solution greater than 60°C 60 0C (140 (140 OF).

°F).

TMI-1 because TMI-1 is a PWR. On this basis, the staff This line item is not applicable to TMI-1 staff finds that the SRP-LR TMI-1.

SRP-LR criteria do not apply to TMI-1.

(2) LRA Section Section 3.3.2.2.3.2 3.3.2.2.3.2 refers to LRA Table 3.3.1, line item 5, and addresses crackir:lg Table 3.3.1, cracking due due to stress corrosion cracking in stainless stainless steel and stainless stainless clad steel heat exchanger exchanger components components exposed to treated greater than 60 treated water greater 60°C0C (greater than 140 OF). The !! i applicant stated applicant effect/mechanism stated that the component, material, environment, and aging effect/mechanism does not apply to auxiliary systems.

reviewed LRA Section The staff reviewed 3.3.2.2.3.2 against the criteria Section 3.3.2.2.3.2 SRP-LR criteria in SRP-LR Section Section 3.3.2.2.3.2, which states that cracking due to SCC could occur occur in stainless steel stainless steel and stainless clad steel heat exchanger exchanger components components exposed exposed to treated water greater greater than 60°C 60 0C (greater than 140 °F). GALL Report recommends OF). The GALL further evaluation of a recommends further plant-specific aging plant-specific management program aging management ensure that these aging effects program to ensure effects are I adequately managed.

adequately SRP-LR Section 3.3.2.2.3.2 invokes AMR Item 5 in Table 3 of the GALL Report, SRP-LR Section Volume 1, and AMR Items VIIE3-3 Volume VII.E3-3 and VII.E3-19 GALL Report, Volume 2, as VIIE3-19 in the GALL aS li applicable to stainless steel and stainless clad steel heat exchanger applicable components exposed exchanger components to treated water 60 °C (greater than 140 OF).

water greater than 60°C OF).

In the applicant's response to RAI-AMR-GENERIC-2, RAI-AMR-GENERIC-2, the applicant stated that line item item 3.3.1-5 is not applicable because this component, material, environment, and aging :i applicable because effect/mechanism combination effect/mechanism addressed by item 3.4.1-14 from the steam and power combination is addressed grouping and item 3.3.1-90. The applicant also stated that item 3.3.1-conversion systems grouping 3.3.1-5 specifies a plant specific specific AMP which which is satisfied by item 3.4.1-14, which specifies the the Water Water Chemistry One-Time Inspection Chemistry and One-Time applicant also stated that thi~

Inspection AMPs. The applicant this combination is satisfied by item 3.3.1-90, which specifies the Water Chemistry combination Chemistry AMP and augmented in the aging management that item 3.3.1-90 has been augmented management reviews to also include include the One-Time Inspection Inspection AMP.

Based on its review of the LRA, the staff confirmed Based confirmed this component, material, environment, addressed by item 3.4.1-14 from the steam effect/mechanism combination is addressed and aging effect/mechanism conversion systems grouping and also addressed by item 3.3.1-90. The staff and power conversion staff confirmed that item 3.3.1-5 also confirmed specifies a plant specific 3.3.1-5 specifies specific AMP which is satisfied by i,tem item 3.4.1-14, which specifies the Water Chemistry One-Time Inspection AMPs and by Chemistry and One-Time item 3.3.1-90, which specifies Chemistry AMP. The staff confirmed specifies the Water Chemistry confirmed that item 3.3.1-90 has been augmented augmented in the aging management management reviews to also include include the One-Time Inspection AMP. The staff finds the applicant's determination determination acceptable.

acceptable.

(3) LRA Section 3.3.2.2.3 3.3.2.2.3 addresses addresses cracking cracking due to stress corrosion cracking in stainlessstainless steel diesel engine exhaust components and piping elements exposed exhaust piping, piping components exposed to 3-268 3-268

diesel exhaust. The applicant stated that the Inspection of Internal Internal Surfaces in Miscellaneous Piping and Ducting Components Miscellaneous Components program will manage manage this aging effect in stainless internal surfaces exposed to diesel exhaust. The staff reviewed stainless steel internal reviewed LRA Section 3.3.2.2.3 3.3.2.2.3 against against the criteria in SRP-LR Section 3.3.2.2.3, which states states that that cracking due to stress stress corrosion corrosion cracking may occur in stainless steel diesel engine engine exhaust piping, piping component component and piping elements exposed exposed to diesel diesel exhaust. The The GALL GALL Report, under Item VII.H2-1 recommends that a plant-specific VII.H2-1 recommends plant-specific program be credited credited to manage manage this aging effecteffect for stainless steel piping, components and piping piping, piping components piping elements in the Auxiliary Systems.

The staff confirmed that only expansion expansion joints that align to GALL GALL AMRs VII.H2-1 VII.H2-1 for thethe Emergency Emergency Diesel Generators Generators and Auxiliary System and the Station Blackout and UPS UPS Generator System that are fabricated Diesel Generator fabricated from stainless steel materials are applicable applicable to TMI that credit credit the Inspection Inspection of Internal Internal Surfaces in Miscellaneous Miscellaneous Piping and Ducting Ducting Components program.

program.

The staff reviewed the Inspection of Internal Internal Surfaces of Miscellaneous Miscellaneous Piping and Ducting Ducting Components Components Program Program and its evaluation evaluation is documented in SER Section 3.0.3.2.17. The The staff noted that the applicant's applicant's proposed proposed program will supplement supplement its period period visual inspections inspections with volumetric volumetric testing to specifically manage manage cracking cracking due to stress corrosion cracking cracking in stainless steel components for indications indications of degradation. The staff finds that degradation.

Inspection of Internal the Inspection Internal Surfaces in Miscellaneous Miscellaneous Piping and Ducting Components Ducting Components Program inspections of internal surfaces of components Program requires visual inspections components during periodic periodic system and component surveillance surveillance activities or during during maintenance maintenance activities activities when the the internal internal surface becomes becomes accessible for visual inspectionsinspections and volumetric volumetric testing for for stainless steel to detect cracking due to stress corrosion corrosion cracking that could result in aa loss of the component's intended function. The staff further noted that volumetric testing to detect detect cracking due to stress corrosion cracking cracking is consistent with the inspection inspection techniques techniques recommended recommended by the GALL AMP XI,M32 XI.M32 "One-Time Inspection," to detect detect the the aging effect effect of cracking due to stress corrosion corrosion cracking. The staff finds that the the applicant's applicant's use of volumetric testing to be consistent with the inspection techniques techniques recommended recommended by the GALL Report to detect this aging effect. The staff finds that this this program activities that are consistent with the recommendations program includes activities recommendations in the GALL adequate to manage cracking due to stress corrosion Report, and that itit is adequate corrosion cracking in stainless steel diesel diesel exhaust piping, piping, piping components components and piping elements exposed to diesel exhaust on the internal internal surface.

Based on a review of the programs programs identified identified above, the staff concludes concludes that the applicant's applicant's program program meets SRP-LR Section Section 3.3.2.2.3. For those line items that apply to LRA Section 3.3.2.2.3, 3.3.2.2.3, the staff determines that the LRA is consistent consistent with the GALL Report Report and that the applicant has demonstrated demonstrated that the effectseffects of aging will be adequately adequately managed so that the the intended function(s) will be maintained intended maintained consistent with the CLB during the period period of extended operation, as required required by 10 CFR 54.21(a)(3).

3.3.2.2.4 Cracking Cracking due to SCC and Cyclic Loading Cyclic Loading The staff reviewed LRA Section 3.3.2.2.4 against the criteria in SRP-LR SRP-LR Section 3.3.2.2.4.

(1) LRA Section 3.3.2.2.4 refers refers to LRA Table 3.3.1, line item 7.

Table 3.3.1, 7, and addresses cracking cracking duedue cracking and cyclic loading to stress corrosion cracking loading in stainless steel PWR non-regenerative non-regenerative exchanger components heat exchanger components exposedexposed to treated treated borated water water greater than 60°C 60 °C (greater 3-269 3-269

than 140 than OF) in 140 OF) in the the chemical chemical and and volume volume control control system.

system. The The applicant applicant stated that the the component, material, environment, material, environment, and and aging effect/mechanism effect/mechanism does not apply apply to auxiliary aClxiliary systems.

The The staff reviewed reviewed LRA LRA Section Section 3.3.2.2.4 3.3.2.2.4 against against the the criteria criteria in in SRP-LR SRP-LR Section Section 3.3.2.2.4, which which states thatthat cracking cracking due due toto SCC and and cyclic loading loading may occuroccur in stainless stainless steel PWR non-regenerative non-regenerative heat heat exchanger exchanger components components exposed exposed to treated borated water water greater greater than 140 OF 140 of in the CVCS. The existing AMP monitors existing AMP monitors and controls primary water chemistry chemistry in PWRs to manage manage the aging aging effects of cracking cracking duedue to to SCC. However, However, control of water water chemistry chemistry does not not preclude preclude cracking cracking due due to SCC and cycliccyclic loading; therefore, therefore, effectiveness of water the effectiveness water chemistry chemistry control control programs should should be verified verified to ensure ensure that cracking cracking does does not occur. The GALL GALL Report Report recommends recommends that aa plant-specific plant-specific AMP be be evaluated evaluated to verify verify the absence absence of cracking cracking due to SCC and and cyclic loading loading to ensurethat ensure.! that these aging aging effects effects are are adequately managed. An acceptable adequately managed. acceptable verification program program is to to include temperature include temperature and radioactivity monitoring radioactivity monitoring of the shell side water and eddy current current testing of tubes.

SRP-LR Section SRP-LR Section 3.3.2.2.4.1 invokes AMR AMR Item Item 7 in Table 3 of the GALL Report, Volume 1, andand AMR Item Item VII.E1-9 VII.E1-9 in in the GALL GALL Report, Volume Volume 2, as applicable applicable to to stainless steel PWR non-regenerative non-regenerative heat exchanger exchanger components exposed to treated components exposed treated borated water greater greater than 140 OF. of. .

In RAI AMR-Generic-2, AMR-Generic-2, dated dated January January 5, 2009, the staff requested that the applicant applicant information to justify why LRA Table provide additional information Table 3.3.1, 3.3.1, Item 3.3.1-7 is not applicable.

In its response to the RAI RAI dated January January 12, 2009, the applicant stated stated that this line, item is linei,item from GALL Section VII.E1 for PWR Chemical and and Volume Control system stainless stainless steel non-regenerative non-regenerative heat exchangers exchangers exposed to borated borated treated water environment environment greater than 140 of.OF. The applicant indicated that this GALL system has been included in the TMI- TMI-1 makeup makeup and purification license license renewal system. The applicant further stated that that the the subject heat exchangers are the letdown coolers and the RC pump seal coolers and the heat exchangers the LRA treated treated water environment greater than 140 of environment greater OF should have been applied to these components.

The applicant revised LRA Section 3.3.2.2.4.1 3.3.2.2.4.1 to state the following:

TMI-1 will implement a One-TimeOne-Time Inspection Inspection program, 8.2.1.18, B.2.1.18, to verify the effectiveness effectiveness of the Water Chemistry program, B.2.1.2, 8.2.1.2, to manage cracking due to stress corrosion cracking in stainless steel PWR non-regenerative non-regenerative heat exchanger components exposed to treated borated water greater than 140 of components OF in the clo.~ed closed cycle cooling water system. Cracking Cracking due to cyclic loading does not apply since these components components are continuously in service and not subject to cyclic loading. loading.

The GALL recommended verification program for temperature GALL recommended temperature and radioactivity monitoring of the shell side water, and eddy current testing of tubes for managing cyclic loading is therefore not not applicable. The Water Chemistry and One-Time One-Time Inspection programs are described in Appendix 8.

Inspection B.

The applicant also revised the discussion column in LRA Table 3.3.1, 3.3.1, line item3.3.1-7 item 3.3.1-7 to state the following:

Not consistent with NUREG-1801.

Not NUREG-1801. The One-Time One-Time Inspection program, B.2.1.18, B.2.1,.18, effectiveness of the Water Chemistry program, B.2:1.2, to will be used to verify the effectiveness 3-270 3-270

manage cracking due to stress corrosion manage cracking in stainless steel corrosion cracking nonregenerative heat exchanged nonregenerative exchanged components exposed to treated components exposed treated borated water water greater 60 0C (greater than 140 OF).

greater than 60°C °F). Cracking due due to cyclic loading does not not apply since these components continuously in service and not subject to cyclic components are continuously cyclic loading.

The applicant included four additional line items in LRA Table 3.3.2-4, closed-cycle closed-cycle cooling water cooling water system to address these heat exchanger components exchanger components as follows follows (columns 1 to 9, from left to right respectively):

(1) Heat exchange exchange components components (letdown Coolers); Pressure Pressure Boundary; Stainless Steel; Treated Water (Internal)

Stainless (Internal) greater than 140 of;OF; Cracking/Stress Corrosion Cracking; One-Time Cracking/Stress One-Time Inspection Inspection (B.2.1.18);

VII.El-9; 3.3.1-7; VII.E1-9; 3.3.1-7; and, I,I, 5.

(2) exchange components Heat exchange components (letdown (letdown Coolers);

Coolers); Pressure Boundary; Stainless Steel; Treated Water (Internal)

(Internal) greater greater than 140 140 OF; of; Cracking/Stress Corrosion Cracking; Cracking/Stress Corrosion Cracking; Water Chemistry (B.2.1.2); VII.E1-9; VII.El-9; 3.3.1-7; and, I,I, 5.

(3) Heat exchange exchange components components (RC (RC Pump Seal Return Coolers);

Coolers); Pressure Boundary; Boundary; Stainless Steel; Treated Water (Internal) (Internal) greater greater than 140 140 °F; of; Cracking/Stress Corrosion Cracking/Stress Corrosion Cracking; Cracking; One-Time Inspection (B.2.1.18);

One-Time Inspection VII.El-9; 3.3.1-7; and, I,I, 5.

VII.E1-9; (4) Heat Heat exchange components (RC Pump Seal Return Return Coolers); Pressure Pressure Boundary; Stainless Stainless Steel; Treated Treated Water Water (Internal)

(Internal) greater than 140 of;

°F; Cracking; Water Chemistry (B.2.1.2);

Cracking/Stress Corrosion Cracking; (B.2.1.2); VII.El-9; VII.E1-9; 3.3.1-7; and, I, 5.

1,5.

The staff staff reviewed the Water Chemistry Program, which is consistent consistent with GALL GALL AMP AMP XI.M2, "Water Chemistry," and is also consistentconsistent with EPRI 1002884, "Pressurized Water Water Reactor Reactor Primary Primary Chemistry Chemistry Guidelines,"

Guidelines," Revision 5 and Plant TS limits for fluorides, chlorides, and dissolved dissolved oxygen. The staff also reviewedreviewed the One-Time One-Time Inspection Inspection Program, which is consistent Program, which consistent with GALL AMP XI.M32, XI.M32, "One-Time Inspection," and uses Inspection,"

enhanced VT-3 enhanced recommended by GALL AMP XI.M32 to detect VT-3 as recommended detect cracking. The staffs staffs evaluation is of the Water Chemistry Program and the One-Time evaluation One-Time Inspection Program is documented in SER Sections 3.0.3.2.2 3.0.3.2.2 and 3.0.3.2.14 3.0.3.2.14 respectively. The staff determined determined that since components are in continuous service and not subject to cyclic loading, since these components loading, cracking due to cyclic loading is not an applicable applicable aging effect for these components.

The staff noted that GALLGALL Report item V.D1-31 in PWR emergency core cooling system recommends recommends Water Chemistry Chemistry Program by itself to manage manage the aging effect of cracking cracking due to stress corrosion cracking for stainless steel piping, piping components, components, and pipingpiping elements elements in an environment of treated borated water greater greater than 140 OF. The applicant is proposing proposing the use of the One-Time Inspection program to verify the effectiveness One-Time Inspection effectiveness of the the Water Chemistry program. Therefore, on the basis that the applicant is verifying the the effectiveness of the Water Chemistry Program, which beyond the recommendations effectiveness recommendations of the the GALL Report to use only the Water Chemistry program, program, the staff finds the combination of Water Chemistry program and the One-Time One-Time Inspection Inspection program program will adequately manage adequately manage 3-271

the aging effects of cracking cracking due to stress corrosion corrosion cracking in stainless.

stainless steel PWR non-regenerative heat exchanger regenerative exchanger components exposedexposed to treated borated borated water greater than OF in the chemical 140 of chemical and volume control control system. .

(2) LRA Section 3.3.2.2.4 refers to LRA Table 3.3.1, 3.3.1, line item 8, and addresses addresses cracking due due to stress corrosion cracking and cyclic loading in stainless steel PWR non-regenerative non-regenerative heat exchanger exchanger components components exposed to treatedtreated borated water greater than 60 °e borated water °C (greater than 140 140 °F).

OF). The applicant stated that the component, material, environment, and aging effect/mechanism does not apply effect/mechanism apply to auxiliary systems.

Section 3.3.2.2.4 states that cracking due to see SRP-LR Section SCC and cyclic loading loading may occur in in regenerative heat exchanger stainless steel PWR regenerative components exposed exchanger components exposed to treated treated borated water greater greater than 60 'C °e (140 °F).

(140 OF).

The staff reviewed LRA Section Section 3.3.2.2.4 3.3.2.2.4 against the criteria criteria in SRP-LR Section 3.3.2.2.4, which states that cracking due to SCC see and cyclic loading may occur in stainless steel ste~1 PWR regenerative regenerative heat exchanger exchanger components exposed to treated components exposed treated borated water greatergreater than 140 of.OF. The existing AMP monitors and controls primary primary water chemistry chemistry in PWRs PWRs to to manage cracking due to see.

manage the aging effects of cracking SCC. However, control control of water chemistry preclude cracking due to see does not preclude SCC and cyclic loading; therefore, therefore, the effectiveness effectiveness of water chemistry programs should be verified to ensure that cracking chemistry control programs cracking does not not occur. The GALL ReportReport recommends plant-specific AMP be evaluated recommends that a plant-specific evaluated to verify the the absence of cracking absence cracking due to SCCsee and cyclic loading loading to ensure ensure that these aging effect's effects are adequately managed.

SRP-LR Section 3.3.2.2.4 invokes AMR Item 8 in Table 3 of the GALL GALL Report, Volume 1, 1, and AMR Item VII.E1-5 in the GALL Report, Volume 2, as applicable applicable to stainless steel regenerative heat PWR regenerative exchanger components exposed to treated heat exchanger borated water greater treated borated greater than 140 OF.

of.

In RAI AMR-Generic-2, AMR-Generic-2, dateddated January January 5, 2009, the staff requested requested that the applicant provide additional information to justify why LRA Table 3.3.1, 3.3.1, line item 3.3.1-8 3.3.1-8 is not applicable. '

In its response response to the RAI dated January 12, 2009, the applicant stated stated there are no no stainless steel regenerative regenerative heat exchanger components exchanger components exposed to treated borated borated water greater than 60 °e °C (greater than 140140 OF) in auxiliary systems systems and that the TMI':'1 TMI-1 design design does not include include regenerative regenerative heat exchangers.

exchangers. Based on its review of the LRA, the, the staff staff confirmed that there are no stainless regenerative heat exchanger components stainless steel regenerative components exposed exposed to treated borated water greater than 60 °e treated borated °C (greater than 140 OF) OF) in auxiliary systems and that the TMI-1 design does not include regenerativeheatexchangers.

regenerative heat'exchangers. The The staff finds the applicant's applicant's determination determination acceptable.

(3)

(3) LRA Section Section 3.3.2.2.4 3.3.2.2.4 refers to LRA Table 3.3.1, 3.3.1, line item 9, and addresses cracking due due to stress corrosion cracking cracking and cyclic loading loading in stainless steel pump casingscasings for thethe PWR PWR high pressure pumps in the chemical chemical and volume control system. The applicant applicant stated that the component, material, stated material, environment, and aging effect/mechanism effect/mechanism does not apply to auxiliary systems.

3-272 3-272

SRP-LR Section SRP-LR Section 3.3.2.2.4 3.3.2.2.4 states states that that cracking cracking duedue to SCC SCC and cyclic loading may cyclic loading may occur occur in the stainless the stainless steel steel pump pump casing casing for thethe PWR PWR high-pressure chemical and pumps in the chemical high-pressure pumps and control system.

volume control system.

In RAI AMR-GENERIC-2, In AMR-GENERIC-2, dated January 5, 2009, the staff dated January staff requested requested thatthat the applicant applicant provide provide additional justify why LRA information to justify additional information 3.3.1, line item 3.3.1-9 is not LRA Table 3.3.1, applicable.

response to the RAI In its response RAI dated January 12, dated January applicant stated that 12, 2009, the applicant that this particular particular component, effect/mechanism combination material, environment, and aging effect/mechanism component, material, combination does does not not exist.

exist. The applicant also stated The applicant stated that item is from GALL Section VII.E1 for PWR that this line item PWR Chemical and Chemical Control System stainless steel high pressure and Volume Control pressure pumps pumps and and that thisthis GALL system system has been been included included in TMI-1 makeup in the TMI-1 purification (MUP) makeup and purification (MUP) license license renewal applicant also stated that the subject pumps system. The applicant renewal system. pumps are the the MU-P-1A/B/C MU-P-1NB/C make-up make-up and purification purification pumps and that the components components are not subject a treated subject to treated environment greater water environment 140 °F greater than 140 OF so cracking cracking due to SSC does does not apply. The The applicant also stated that cracking due to cyclic loading applicant also loading does not apply since since these these components components are are continuously service and not subject to cyclic loading.

continuously in service loading. Based Based on its its review confirmed that this GALL system has been review of the LRA, the staff confirmed included in the been included the TMI-1 makeup and purification license TMI-1 license renewal system. The staff also confirmed that the staff also the subject pumps are subject are the MU-P-1A/B/C MU-P-1NB/C make-up purification pumps and that the make-up and purification the components are components are not subject subject to a treated water water environment greater than 140 environment greater 140 OF.

OF. The staffstaff cracking due to cyclic loading confirmed that that cracking also confirmed loading does not apply these apply since these components are continuously components service and not subject to cyclic loading.

continuously in service loading. The staff staff finds finds the applicant's applicant's determination acceptable.

acceptable.

(4) LRA Section 3.3.2.2.4 3.3.2.2.4 refers to LRA Table 3.3.1, 3.3.1, line item 10, and addresses addresses cracking cracking due due to stress corrosion cracking and cyclic loading in high strength steel closure bolting bolting exposed steam or water leakage. The applicant stated that the component, exposed to air with steam material, material, environment, effect/mechanism does not apply environment, and aging effect/mechanism apply to auxiliary auxiliary systems.

manages the cracking of high strength bolting with the Bolting Integrity The applicant manages Program which is discussed discussed in SER Section 3.0.3.1.3. The applicant's applicant's Bolting Integrity Program follows the guidelines of EPRI NP-5769, "Degradation and Failure of Bolting in Program Nuclear Power Plants," in its selection of bolting material and the use of lubricants and Nuclear sealants. Additionally, the program follows the guidelines guidelines of NUREG-1339, "Resolution of Generic Safety Issue 29: Bolting Degradation or Failure in Nuclear Nuclear Power Plants," to prevent or mitigate degradation degradation and safety-related bolting, including the and failure of safety-related the verification of gasket compression, and application of an appropriate appropriate preload. The staff finds this acceptable acceptable because agreement with the GALL recommendations for the because it is in agreement the Bolting Integrity Program.

In RAI AMR-GENERIC-2, dated January requested that the applicant January 5, 2009, the staff requeste.d applicant additional information to justify why LRA Table 3.3.1, provide additional 3.3.1, Item#

Item# 3.3.1-10 is is not applicable.

response to the RAI In its response RAI dated January 12, 2009, the applicant stated that there is no exposed to air with steam or water leakage in auxiliary high-strength steel closure bolting exposed high-strength auxiliary systems. Based on its review of the LRA, the staff confirmed that that there is no no high-strength steel closure bolting exposed to air with steam or water leakage in auxiliary auxiliary systems, and therefore, the staff finds the applicant's determination acceptable. acceptable.

3-273

Based on a review of the programs programs identified above, the staff concludes that the applicant's applicant's programs meet SRP-LRSRP-LR Section Section 3.3.2.2.4 3.3.2.2.4 criteria.

criteria. For those line items that apply to LRA determines that the LRA is consistent with the GALL Report and that Section 3.3.2.2.4, the staff determines the applicant has demonstrated demonstrated that the effects of aging will be adequately adequately managed managed so that the the intended functions maintained consistent with the CLB during the period of extended functions will be maintained extended operation, operation, as required by by1100 CFR 54.21 54.21(a)(3).

(a)(3).

3.3.2.2.5 Hardening and Loss of Strength 3.3.2.2.5 Hardening Strength due to Elastomer Degradation Elastomer Degradation (1) LRA Section 3.3.2.2.5 states that TMI-1 will credit the External 3.3.2.2.5 states Surfaces Monitoring External Surfaces Monitoring*

Program to manage hardening and loss of strength due to elastomer manage hardening degradation of elastomer degradation elastomer hoses exposed elastomer exposed to indoorindoor air, air with borated water leakage, and dry air in the the auxiliary steam system, emergency diesel generators generators and auxiliary systems, instrument instrument and control air system, reactor coolant system, and station blackout and UPS diesel generator systems. The applicant further stated generator stated that the External Surfaces Surfaces Monitoring Monitoring Program Program consists of system inspections inspections and walkdowns, walkdowns, and includes periodicperiodic visual inspections of elastomer hoses inspections hoses within the scope of license renewal and subject to an AMR AMR in order to manage aging aging effects. The applicant also stated that the program manag~s program manages aging effects through visual inspection inspection of elastomer elastomer surfaces surfaces for evidence of elastomer elastomer degradation.

degradation.

LRA Section Section 3.3.2.2.5 3.3.2.2.5 also states that TMI-1 will implement implement Inspection Inspection of Internal Surfaces Internal Surfaces in Miscellaneous Miscellaneous Piping and Ducting Components Program Program to manage hardening and loss of strength due to elastomer degradation of elastomer expansion joints exposed to indoor elastomer degradation air and wetted air in the auxiliary auxiliary and fuel handling building building ventilation ventilation systems, control building ventilation system, diesel generatorgenerator building ventilation intake screen and ventilation system, intake pump house ventilation system, intermediate intermediate building ventilation ventilation system, and primary containment containment heating and ventilation ventilation system.

The applicant applicant further stated that these internal internal inspections inspections are performed during the the periodic system and component surveillancessurveillances or during the performance of maintenance performance maintenance activities activities when the surfaces surfaces are made accessible accessible for visual inspection.

The staff reviewed LRA Section 3.3.2.2.5 against staff reviewed against the criteria in SRP-LR Section 3.3.2.2.5, which states that hardening and loss of strength due to elastomer elastomer degradation degradation may occuroccur in elastomeric seals and components components associated associated with auxiliary heating and ventilation ventilation systems that are exposed either internally internally or externally externally to uncontrolled uncontrolled indoor air. The The SRP-LR recommends SRP-LR recommends further evaluation evaluation of a plant-specific a plant-specific AMP to ensure ensure that these aging effects are adequately managed.

SRP-LR Section 3.3.2.2.5 3.3.2.2.5 invokes invokes AMR Item 11 11 in Table 3 of the GALL Report, Volume 1, and AMR Items Items VII.F1-7, VII.F2-7, VII.F3-7 and VII.F4-6 VII.F4-6 in the GALL Report, Volume 2, as as applicable to elastomeric applicable elastomeric seals and components in control room, auxiliary and radwaste, primary containment, containment, and diesel generator generator building heatingheating and ventilation systems *that that are exposed exposed either internally or externally to uncontrolled either internally uncontrolled indoor air.

The staff reviewed the External External Surface Monitoring Program and finds that the program Surface Monitoring program provides provides for management management of aging effects through visual inspection of external surfaces surf9ces for evidence hardening hardening and loss of strength and loss of material.

material. The applicant stated that visual inspections inspections will be augmented by physical manipulation manipulation to detect hardening and loss of strength of elastomers. The staff determined that additional information staff determined information was was c 3-274 3-274

required in order to complete its review. In part 2 of RAI B.2.1.21-1, required September 29, B.2.1.21-1, dated September 2008, the staff requested requested that the applicant applicant provide provide additiona-I additional information information to justify thethe including elastomers in the scope basis for including Surfaces Monitoring scope of the External Surfaces Monitoring Program, to explain explain how the program program will adequately adequately manage hardening and manage the aging effects of hardening loss of strength as it applies applies to the additional non-metallic components non-metallic components added scope to the scope of the program, and to describe inspection techniques that will be used to describe the specific inspection detect the applicable applicable aging aging effects for elastomers elastomers and clarify the acceptance acceptance criteria that will be used for these inspection inspection techniques.

In its response response to the RAI dated dated October 20, 2008, the applicant stated that the visual inspection will look for cracking and flaking. The applicant further stated that a resiliency test will be performed performed by compressing compressing the material material and observing a return to the original shape. The staff reviewed Surfaces Monitoring reviewed the External Surfaces Monitoring Program and its evaluation is documented documented in SER Section Section 3.0.3.2.16. The staff finds the External External Surface Monitoring Monitoring Program acceptable acceptable because because visual inspections of external inspections external surfaces for cracking cracking and flaking will be performed periodically periodically and physical manipulation of the elastomeric physical manipulation elastomeric components components will be performed, including aa resiliency resiliency test, to detect the aging effects of hardening hardening and loss of strength.

Based on its review, the staff finds the applicant's Based applicant's response response to RAI B.2.1.21-1 acceptable acceptable because because a visual inspection inspection will be conducted conducted that will look for cracking and flaking and a resiliency resiliency test will also be conducted by compressing the material and observing observing aa return to the original shape. The staffs concern described described in part 2 of RAI B.2.1.21-1 is resolved.

resolved.

The staff reviewed the Inspection Inspection of Internal Internal Surfaces Surfaces in Miscellaneous Miscellaneous Piping and Ducting Ducting Components Program and finds that itit requires periodic Components Program periodic visual inspections inspections of internal surfaces during periodic surfaces periodic maintenance, maintenance, predictive maintenance, maintenance, surveillance surveillance testing, and corrective maintenance corrective maintenance to detect aging effects effects that could result in a loss of component component intended function. The applicant stated that in addition to visual inspection, physical intended manipulation manipulation will be used to detect hardening and loss of strength of elastomers detect hardening elastomers both internally and externally. The staffs review of the Inspection internally Inspection of Internal Surfaces Surfaces in in

.Miscellaneous Miscellaneous Piping Piping and Ducting Components Program Program and its evaluation evaluation is documented documented SER Section 3.0.3.2.17. The staff in SERSection staff finds the Inspection Inspection of Internal Surfaces in Miscellaneous Piping Miscellaneous Components program Piping and Ducting Components acceptable because visual program acceptable inspections of internal surfaces for cracking inspections cracking and flaking will be performed periodically and performed periodically manipulation of the elastomeric physical manipulation elastomeric components, including a resiliency test, will be be performed performed to detect detect the aging effects of hardening and loss of strength:

(2) LRA Section 3.3.2.2.5 3.3.2.2.5 states states that TMI-1 will credit the Inspection Inspection of Internal Surfaces Surfaces in Miscellaneous Miscellaneous Piping and Ducting Components Components ProgramProgram to manage manage hardening and loss of hardening strength strength due due to elastomer elastomer degradation degradation of elastomer exposed to treated elastomer hoses exposed treated water in thethe auxiliary auxiliary steam system. The applicant applicant stated stated that these internal internal inspections performed inspections are performed during the periodic systemsystem and component surveillances performance of surveillances or during the performance maintenance maintenance activities activities when the surfaces are made accessible accessible for visual inspection.

inspection.

The staff reviewed reviewed LRA Section Section 3.3.2.2.5 against the criteria in SRP-LR Section Section 3.3.2.2.5, which states that hardening and loss of strength due to elastomer degradation may occur elastomer degradation occur in elastomer linings linings of the filters, valves, and ion exchangers exchangers in spent fuel pool cooling and cleanup systems (BWR (BWR and PWR) exposed to treated treated water or to treated borated water.

The GALL Report recommends that a plant-specific plant-specific aging management management program be be 3-275

evaluated evaluated to determine determine and assess the qualified qualified life of the linings environment to linings in the environment to ensure that these aging effects are adequately adequately managed.

SRP-LR Section 3.3.2.2.5 invokes AMR Item 12 in Table Table 3 of the GALLGALL Report, Volume 1, and AMR AMR Item VII.A3-1 in the GALL Report, Volume Volume 2, as applicable applicable to elastomeric elastomeric linings linings in PWR spent fuel pool cooling and cleanup systems that are exposed exposed to treated treated borated water.

Inspection of Internal Surfaces in Miscellaneous The staff reviewed the Inspection Miscellaneous Piping and Ducting Components Components Program and finds that it performs periodic periodic visual inspections inspections of internal surfaces during periodic maintenance, predictive maintenance, surveillance testing, and predictive'maintenance, and corrective maintenance maintenance to detect detect aging effects effects that could result in a loss of component component addition to visual inspection, physical applicant stated that in addition intended function. The applicant manipulation manipulation may be used to detect hardening elastomers both hardening and loss of strength of elastomers determined that additional information internally and externally. The staff determined information was required in order to complete its review. In part 2 of RAI 8.2.1.22-1, B.2.1.22-1, dated September September 29, 2008, the 29,2008, the staff requested that the applicant applicant provide additional information information to justify the basis for neoprene and rubber in the scope of the Inspection of Internal including neoprene Internal Surfaces in Miscellaneous Miscellaneous Piping and Ducting Components Program, Components Program, explain how this program will adequately manage the aging effects of hardening and loss of strength as itit applies adequately manage applies to thethe additional non-metallic additional components added to the scope of the program, describe non-metallic components describe the the specific inspection specific inspection techniques that will be used to detect the applicable applicable aging effects for elastomers, and clarify the acceptance inspection acceptance criteria that will be used for these inspection techniques.

applicant stated that the visual October 20, 2008, the applicant In its response to the RAI dated October inspection will look for cracking inspection flaking. The applicant further stated that a resiliency cracking and flaking.

test will also be performed performed by compressing the material observing aa return to the material and observing the original shape. The staff reviewed the Inspection of Internal Internal Surfaces in Miscellaneous Miscellaneous Piping and Ducting Components Program and its evaluation is documented documented in SER .

Section 3.0.3.2.17. The staff finds the Inspection Inspection of Internal Surfaces Miscellaneous Surfaces in Miscellaneous Piping and Ducting Components Program Program acceptable acceptable because visual inspections because visual inspections of internal surfaces internal performed periodically and physical surfaces for cracking and flaking will be performed manipulation manipulation of the elastomeric elastomeric components, including including resiliency test, will be performed a resiliency performed to detect the aging effects of hardening and loss of strength. '

applicant's response to RAI B.2.1.22-1 8ased on its review, the staff finds the applicant's Based acceptable 8.2.1.22-1 acceptable conducted that will look for cracking and flaking and a because a visual inspection will be conducted conducted by compressing the material and observing aa return resiliency test will also be conducted to the original shape. The staff's staffs concern described B.2.1.22-1 is resolved.

described in part 2 of RAI 8.2.1.22-1 resolved.

concludes that the applicant's programs Based on a review of the programs identified, the staff concludes programs 3.3.2.2.5 criteria.

SRP-LR Section 3.3.2.2.5 meet SRP-LR items that apply to LRA Section criteria. For those line items Section 3.3.2.2.5, determines that the LRA is consistent with the GALL Report the staff determines Report and that the applicant, has applicant has effects of aging will be demonstrated that the effects demonstrated adequately managed managed so that the intended maintained consistent with the CL8 function(s) will be maintained CLB during extended operation, as during the period of extended required by 10 CFR 54.21(a)(3).

required 54.21(a)(3).

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3.3.2.2.6 Neutron-Absorbing Capacity 3.3.2.2.6 Reduction of Neutron-Absorbing Capacity and Loss of Material due to General Corrosion Corrosion The staff reviewed LRA Section 3.3.2.2.6 against the criteria in SRP-LR 3.3.2.2.6 against SRP-LR Section 3.3.2.2.6.

LRA Section 3.3.2.2.6 describes describes the program to manage the loss of material and the rationale rationale for not requiring a neutron-absorbing neutron-absorbing capacity capacity aging management management program program as follows:

Reduction of neutron-absorbing Reduction neutron-absorbing capacity capacity and loss of material due to general general corrosion neutron-absorbing sheets of BWR and PWR spent fuel storage racks could occur in the neutron-absorbing racks exposed to treated water exposed water or to treated borated water. The GALL GALL Report recommends recommends further evaluation evaluation of a plant-specific plant-specific aging management management program to ensure that these aging effects adequately managed.

effects are adequately managed. Acceptance Acceptance criteria are described described in Branch Technical Technical Position RLSB-1 (Appendix A.1 of this SRP-LR).

implement a Water Chemistry TMI-1 will implement Chemistry program, program, B.2.1.2, to manage manage loss of material material duedue to general general corrosion of the Boral, boron steel spent fuel storage racks neutron-absorbing neutron-absorbing sheets exposed exposed to treated treated water in the fuel handling and fuel storage system. The Water Chemistry Chemistry Program consists of measures that are used to manage manage aging of piping, piping piping components, piping elements exchangers and mitigate damage elements and heat exchangers damage caused by corrosion and stress corrosion corrosion cracking (SCC). The Water Chemistry Chemistry Program relies on monitoring monitoring and control of reactor water chemistry chemistry based on industry industry guidelines for primary primary water and secondary secondary water chemistry chemistry such as EPRI TR-1 05714, TR-105714, Rev. 3 3 and TR-1 02134, TR-102134, Rev. 3 or later revisions. The Water Chemistry Chemistry Program is described described in Appendix B.

Reduction of neutron-absorbing Reduction neutron-absorbing capacity of the Boral, boron steel spent fuel storage racks racks neutron-absorbing sheets exposed to treated water is insignificant neutron-absorbing insignificant and requires no agingaging management. The potential management. potential for aging effects effects due sustained irradiation due to sustained irradiation of Boral waswas previously evaluated previously evaluated by the staff (BNL-NUREG-25582, (BNL-NUREG-25582, dated January January 1979; NUREG-1 NUREG-1787, 787, VC Summer SER, paragraph 3.5.2.4.2, page 3-406) and determined determined to be insignificant.

experience with Boral coupons inspected Plant operating experience inspected in 1995, 1997, 1997, 1999, and 2001 is consistent consistent with the staff's conclusion conclusion and an aging management management program is not required.

In accordance accordance with 10 CFR 54.21(a)(3),

54.21(a)(3), the staff reviewed reviewed the information in LRA Section 3.3.2.2.6 3.3.2.2.6 on the applicant's management management of the loss of material to ensureensure that the effects effects of aging, as discussed discussed above, will be adequately adequately managed managed so that the intended intended function(s) function(s) will be be maintained consistent with the CLB for the period of extended operation. The staff also reviewed maintained reviewed the rationale for not requiring a neutron-absorbing neutron-absorbing capacity aging management management program.

program.

The staff reviewed reviewed LRA Section 3.3.2.2.6 against the staff's recommended regulatory staffs recommended regulatory criteria criteria in SRP-LR Section 3.3.2.2.6 Section 3.3.2.2.6 and in GALL AMR Item VII.A2-5 GALL AMRltem VII.A2-5 of the GALL Report, Volume 2.

The staff questioned that the rationale provided provided by the applicant applicant for not requiring an aging management program for the neutron-absorbing management program neutron-absorbing capacity was adequate. After teleconferences teleconferences with the applicant, the staff noted noted that TMI-1 TMI-1 does have a Boral Surveillance Program in place.

Boral Surveillance The staff also required more information about the details of the Water Chemistry Program's Chemistry Program's management management of the loss of material material due to the general Boral. In RAI 3.3.2.2.6-1, general corrosion of Bora!. 3.3.2.2.6-1, dated October October 20, 2008, the staff requested that the applicant provide additional informationinformation concerning the details concerning details of the Boral Surveillance Surveillance Program Program and the Water Chemistry Chemistry Program.

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In its response to the RAI dated November November 12, 2008, the applicant provided information on the provided information the Boral Surveillance Program, Surveillance Program, relevant operating operating experience, and the Water Chemistry Program. II Also, the applicant made commitment: "Boral test coupon surveillance will continue made the following commitment: continue period of extended through the period operation."

extended operation."

applicant responded The applicant details on the method of testing in the Boral responded with more details Surveillance Boral Surveillance Program by stating:

directs coupon testing in accordance surveillance program directs The TMI-1 Boral test coupon surveillance accordance recommendations. The coupon is removed manufacturer's recommendations.

with the spent fuel rack manufacturer's removed from the the located in the spent fuel pool and is shipped to aa contractor measurement test coupon tree located measurement laboratory. The measurement measurement laboratory characterizes the test coupon in conformance laboratory characterizes conformance with the rack manufacturer's procedure. Inspection of the test coupon includes manufacturer's procedure. includes visual observation measurements, weight and density/specific dimensional measurements, observation and photography, dimensional density/specific gravity, and neutron attenuation. examined to detect pitting, attenuation. The coupon is visually examined !,

swelling, or other degradation. The coupon may be photographedphotographed if, if, in the judgment judgment of the the significance that should technician, there is any information of significance technician, photographically should be photographically documented. Length and width of the coupon are measured at multiple locations (three documented. (three each per coupon) each comparison to the original (pre-irradiated) coupon) for comparison (pre-irradiated) dimensions. Thickness of the coupon is measured locations (five per coupon) for comparison measured at multiple locations comparison to the" the" density/specific gravity original dimensions. Coupon weight and density/specific original measured and gravity are measured measured using a collimated thermal neutron attenuation is measured calculated. Neutron attenuation neutron beam. The The intervals used are sufficient to assure the standard error counting intervals error due to counting counting statistics

<<0.15%) at the lowest counting rate.

essentially negligible (<0.15%)

is essentially reviewed the testing aspects of the program and has found them to be acceptable The staff has reviewed acceptable since there is extensive degradation of the coupons would be extensive testing that would ensure that degradation be detected. Also, the measurements neutron attenuation, physical distortion, and weight change measurements of neutron change functionality in the Boral panels, and by performing these measurements, precede a loss of functionality would precede measurements, the program provides assurance degradation would be detected before loss of functionality.

assurance that degradation The applicant responded with details on the Boral coupons applicant responded coupons usedused by stating:

Two coupon sample trees are located in the TMI-1 TMI-1 spent fuel pool. A total of fourteen sample coupons remain. coupon sampled every nominal rate of one coupon remain. At the nominal every five years, a more more than sufficient number of couponscoupons remains to maintain sampling frequency maintain the sampling through the period of extended operation.

operation.

Upon installation in 1992 storage racks containing the Boral 1992 of the high density fuel storage absorber material, one coupon tree, intended for long-term testing, was located absorber located in the spent fuel pool in a manner such that it was surroundedsurrounded by freshly discharged spent fuel assemblies. The secondsecond coupon accelerated coupon tree was intended for accelerated such that itit was surrounded by hot, freshly located such exposure. This tree was located freshly ý1 installation of the racks discharged fuel for each of the first five cycles following installation racks containing Boral. This coupon tree has remainedremained in the last location location following the the strategy fifth cycle discharge. This sample location strategy meets the recommendations recommendations from the rack manufacturer.

The Boral sample sample coupons are encased jackets of an alloy encased in stainless steel jackets alloy identical to that used in the storage racks, formed so as to encase the Boral,:and Boral and fix fix 3-278 3-278

it in position with tolerances tolerances similar to those for the storage racks. The Boral coupon specimens specimens are fully exposed to the pool water, as are the Boral absorber panels in the vented storage racks.

panels

- The coupon is visually examined examined to detect pitting, pitting, swelling, or other degradation degradation such as blistering.

blistering. The coupon photographed if, coupon may be photographed if, in the judgment of thethe technician, technician, there is any information information of significance that should be photographically photographically documented. determined from neutron attenuation, which is documented. Areal density is determined measured using a collimated collimated thermal neutron neutron beam. The counting intervals used are sufficient to assure the standard errorerror due to counting statistics is essentially essentially

(<0.15%) at the lowest counting rate. A collimated negligible <<0.15%) collimated beam of thermalized neutrons is passed through the sample in a perpendicular perpendicular direction. The number number of neutrons emerging is counted with a neutron neutron detector. By comparing the counting rate for the surveillance surveillance sample sample with a corresponding corresponding rate from a standard sample, the relative transmission transmission is determined.

TMI-1 has not reinserted To date, TMI-1 reinserted test coupons into the spent fuel pool following following their removal and inspection.

inspection.

The staff has has reviewed reviewed the details on the Boral Boral coupons and has found it to be acceptable acceptable since there are are a sufficient number of coupons to ensure that testing will be able to continue through the the extended operation, period of extended operation, and the staff considers considers the program program to collect collect data from representative representative coupon coupon samples to assessassess for stability and integrity integrity of Boral to be acceptable acceptable for detection detection of aging effects.

The applicant applicant provided details on how the Boral would be monitored and trended trended by stating:

Monitoring Monitoring of the Boral neutron absorber absorber is accomplished accomplished through periodic examination examination of the Boral test coupons, consisting consisting of visual observations observations (which may include include photography),

dimensional measurements dimensional measurements (length, width, and thickness), weight and density determinations, and neutron attenuation attenuation measurements measurements (for B-10 areal density). Results Results compared to archive values from pre-irradiated are compared pre-irradiated samples, and with results from previous previous coupon examinations, summarizedsummarized in reports of the surveillance surveillance compiled compiled by thethe measurement laboratory measurement laboratory and forwarded to TMI-1 TMI-1 Reactor Engineering for review. The Reactor Engineering The results are evaluated evaluated against against acceptance acceptance criteria for determination determination of any follow-up follow-up appropriate (e.g., removal activities as appropriate removal and examination examination of additional additional coupons, wet chemical analyses, radiography, etc.). The evaluation reports of the coupon examinations examinations are maintained to provide a continuing provide continuing source of data for trend analysis.

The staff has reviewed reviewed the program program details details regarding the monitoring monitoring and trending of Boral and has found itit to be acceptable acceptable since since the applicant monitors and trends the appropriate appropriate parameters parameters to identify appropriate appropriate follow-up activities.

The applicant provided acceptance criterion and corrective actions of the Boral provided details on the acceptance Surveillance Program by stating:

Surveillance Program Acceptance Acceptance criteria of the TMI-1 Boral surveillance surveillance program are as follows:

A decrease decrease of no more than 5% 5% in Boron-10 content as determined determined by neutron attenuation measurements.

attenuation measurements.

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increase in thickness at any point should not exceed An increase exceed 10%10% of the initial initial thickness thickness at that point.

The Boral test coupon surveillance program was established to monitor coupon surveillance monitor the integrity and performance continuing basis and to assure performance of Boral on aa continuing developing or assure that any slowly developing!or long-term effects, if if any, do not become significant. The surveillance surveillance program is intended degradation with ample time to take corrective action to detect the onset of any significant degradation as may be necessary.

Changes Changes in excess of either of the acceptance investigation and acceptance criteria require investigation engineering evaluation as directed engineering directed by TMI-1 Reactor Engineering. Based on the results of determined to be appropriate.

engineering evaluation, additional activities may be determined the engineering These additional activities may include:

- Early retrieval and measurement measurement of one or more of the remaining coupons to 1 provide corroborative evidence that the measurements corroborative evidence measurements are real.

- Wet chemical chemical analyses analyses (destructive) and radiography (non-destructive)

(non-destructive) for confirming measurements.

measurements.

surveillance program If corroborated results of the test coupon surveillance If program do not satisfy acceptance acceptance criteria, additional actions such as in situ radiography, or "blackness testing" of the spent additional actions fuel racks, may investigate the extent of degradation, may be employed to investigate degradation, if if any, in the racks. In In degradation of the Boral absorber the event that any degradation absorber in the spent fuel racks is detected, neutron radiographs of the suspected neutron obtained. Positive confirmation of suspected locations may be obtained.

evaluations to assure that required subcriticality any defects will result in evaluations subcriticality margin is Actions may include restrictions on rack cell use, repair maintained. Actions maintained. repair of the cell to restore restore effectiveness, or installation of new racks.

absorber effectiveness, The staff has reviewed the acceptance criterion and corrective acceptance criterion corrective actions and has found it to be be acceptable acceptance criterion acceptable since the acceptance assurance that corrective criterion will provide assurance corrective actions could be be taken before loss of functionality functionality would occur.

The staff has reviewed the information provided by the applicant on the details of the Boral information provided Program. The staff has found the specific Surveillance Program.

Surveillance specific method of testing of the Boral coupons, Boral coupqns, monitoring and trending of the Boral condition, acceptance monitoring acceptance criteria, corrective actions to criteria, and corrective be t6 be acceptable as stated stated previously.

In addition, the applicant information in the response applicant provided information regarding response to RAI 3.3.2.2.6-1 regarding*

relevant operating experience.

operating experience. The applicant stated the following:

Seabrook operating experience The Seabrook subsequent Part 21 notification concerning experience report and subsequent concerning surveillance coupon has had no impact on the TMI-:

bulging and blistering of a Boral surveillance TMI- 1 Boral test coupon coupon surveillance program in that the existing TMI-1 program surveillance program program continues!

continues i as planned, with removal of test coupons planned, coupons for examination examination by the measuring laboratory continuing as per the surveillance program. An Exelon evaluation evaluation of the Seabrook .

operating experience determined experience determined that Exelon fleet and industry Boral surveillance and industry surveillance ':

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programs programs will continue to will continue to provide provide datadata that that can can be interpreted by company be interpreted company and and support support organizations to organizations to determine determine if further further action action is required.

required.

Blisters are characterized by aa local are characterized local area area where where the the Boral Boral aluminum cladding separates aluminum cladding separates the aluminum from the aluminum and boron carbide core and the clad is plastically carbide core deformed outward plastically deformed away from the core. Water intrusion into away aluminum and boron carbide core into the aluminum core of the Boral material material maymay occur through through small voids voids present present in in the core due due to the manufacturing manufacturing process, and and can react react with thethe aluminum powder aluminum oxide and powder to form aluminum and hydrogen.

hydrogen.

The appearance blisters suggests appearance of blisters their mechanism suggests their mechanism of of formation related to a local formation is related pressure buildup in the the core causing clad/core core causing clad/core delamination subsequent local delamination and subsequent plastic local plastic deformation of the aluminum deformation aluminum cladding.

cladding. Neutron Neutron attenuation attenuation teststests have have confirmed confirmed that blisters blisters have have not altered neutron absorption altered the neutron properties of the Boral material.

absorption properties material. However, blister formation has the potential to displace blister formation displace water from the flux trap region of the TMI-1 trap region TMI-1 Region 1 fuelfuel racks, and blister formation occurring in the TMI-1 formation occurring TMI-1 Region Region 2 fuel fuel racks racks has has deform the sheathing the potential to deform sheathing material material which may cause cause a reduction reduction of clearance clearance in in the fuel storage cell.

In the TMI-1 Region Region 1 fuel storage water in the flux trap storage racks, water between the fuel rack trap region between storage cells thermalizes thermalizes neutrons, neutrons, enhancing neutron absorber enhancing the neutron absorber effect. In In the event event that a blister intrusion into the Boral core resulted in the does not fill with water (whose intrusion blister does the hydrogen generation that formed the blister),

hydrogen generation blister), blister formation Boral absorber formation in the Boral absorber panelspanels in the Region 1 fuel racks can displace water in the flux trap region, and a localized displace water localized increase in reactivity (at the blister increase location) could blister location) could result.

In the TMI-1 Region 2 fuel storage racks, Boral blister formation sufficient to deform deform thethe stainless steel sheathing material could cause a reduction of clearance clearance in the affected affected location. Should blisters occur in more than one Boral panel adjacent to aa single storage location. single cell, and at a coincident axial elevation, the condition could become become acute acute enough to make make fuel assembly insertion or removal in that cell difficult. The TMI-1 Region 2 fuel storage storage rack design, however, reduces this potential due to use of a sheathing material thickness thickness sheathing thickness greater than the typical sheathing thickness (and, for example, greater sheathing greater than the sheathing thickness in the TMI-1TMI-1 Region 1 storage racks, which due to the storage storage rack design are not subject clearance reduction due to sheathing subject to cell clearance sheathing deformation). Since resistance to Since resistance to displacement is increased, a subsequent decrease sheathing displacement decrease of clearance clearance the cell is in less likely than in a storage rack design that uses thinner sheathing material. material.

These effects are not safety concerns continuation of the TMI-1 Boral test concerns at TMI-1 since continuation surveillance program through the period of extended coupon surveillance extended operation, as well as monitoring and evaluation of Exelon fleet and industry industry operational and testing experience, degradation in the Boral material to be detected early so that will allow the onset of any degradation appropriate mitigation measures may be applied.

appropriate deformation of storage rack cells that had been observed Bulging deformation observed in some early unvented rack designs was due to swelling of the unvented Boral storage pockets when hydrogen gas was generated during development of the protective protective oxide film on the aluminum surface of the Boral material when first immersed in the pool water. Subsequent Subsequent rack designs, including TMI-1 TMI-1's's storage racks, are of the vented design where any hydrogen that may be generated during the passivation process is permitted to escape the rack cell's cell's Boral panel storage pocket.

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Swelling was observed in early foreign applications of Boral in storage racks manufacturedmanufactured in the 1980s. The cause of swelling in these early panels panels was corrected in laterlater production appropriate controls by instituting appropriate controls on the boron carbide chemical composition. Holtec composition. The Holtec TMI-1's procured Boral panels utilized in TMI-1 manufactured under quality

's storage racks were manufactured assurance/quality assurance/quality control programs that conform conform to the requirements requirements of 10 10 CFR 50 50 Appendix Appendix B. These Boral panelspanels have performed well in the industry in part as a result of the development development of a Holtec procurement specification Holtec procurement specification for Boral, which imposed stricter imposed striCter controls controls on the manufacturing manufacturing process process and amounts amounts of key materials.

Generalized localized pitting corrosion of the aluminum cladding material of Generalized corrosion and localized the Boral panels can occur in the spent fuel pool environment. However, in the boric acid solution typical of TMI-1 TMI-1 and other PWR spent fuel pools, generalized generalized corrosion does not occur. The EPRI Handbook of NeutronNeutron Absorber Absorber Materials Materials for Spent Nuclear Fuel I Nuclear Fuel' Transportation and Storage, 2006 Edition, has Transportation reported that localized has reported localized pitting has been observed in test specimens. Causes were determined to be the presence observed presence of corrosion occurring along along the boundaries boundaries of long thin grains along the edge edge of the Boral material caused by the rolling processing, processing, impurities impurities in the aluminum aluminum powder and boron carbide carbide used to manufacture the core matrix, and incomplete incomplete cleaning of metallurgical used in metallurgical oils uS,ed in the rolling process. These degradations have not resulted in any decrease These corrosion degradations decrease in in Boron-10 areal areal density, and consequently have not diminished material's diminished the Boral material's effectiveness effectiveness in neutron neutron absorption.

absorption.

These These effects effects are, not safety safety concerns concerns at TMI-1 since continuation continuation of the TMI-1 TMI-1 Boral test surveillance program coupon surveillance program through the period of extended operation, as well as as monitoring and evaluation of Exelon fleet and industry operational operational and testing experience, will allow the onset of any degradation degradation in the Boral material to be detected detected early so that appropriate appropriate mitigation mitigation measures maymay be applied.

applied.

The staff has reviewed reviewed and confirmed the operating experience experience and the staff finds this acceptable acceptable since the operating operating experience supports the conclusion that the implementation implementation of the Boral Surveillance Program will continue to be able to manage Surveillance manage the loss of neutron-absorbing neutron-absorbing capacity and degradation degradation of Boral effectively.

The applicant in response to the Water Chemistry part of RAI 3.3.2.2.6-1 has stated:

The Water Chemistry program manages loss of material program manages material due to general general corrosion ofthe of the aluminum cladding of the Boral material by controlling and monitoring aluminum monitoring the spent fuel pool water water chemistry. The boric acid solution concentration concentration in the spent fuel pool water water inventory is maintained at a goal level inventory level to assure that loss of material due to general '

corrosion of the aluminum cladding of the Boral materialmaterial is adequately adequately managed. The The spent fuel pool water inventory is sampled and analyzed for Boron on a frequency frequency o~ of at least once per seven days. The goal concentration concentration for Boron in the spent fuel pool water water inventory is greater greater than or equal to 2500 ppm, and less than 5000 ppm. If the Boron concentration concentration is found to be less than the minimum goal value, plant Operations, and Chemistry Supervision are to be immediately Chemistry Supervision immediately notified, notified, with actions initiated to return thethe parameter specified range. Per the EPRI Handbook of Neutron parameter to the specified Neutron Absorber Absorber Materials Materials Nuclear Fuel Transportation for Spent Nuclear Transportation and Storage, 2006 2006 Edition, Edition, in a 2500 ppm boricbo~ic aid solution, generalized generalized corrosion of aluminum does not occur.

In addition to Boron, the spent fuel pool water inventory inventory is sampled sampled and analyzed for parameters parameters including pH, Chloride, Fluoride, Sulfate, Silica, Aluminum, Calcium, 3-282 3-282

Magnesium, and others. More details Magnesium, details on the Water Chemistry program, B.2.1.2, are available in the TMI-1 TMI-1 LRA in Appendix Appendix B.

The staff has reviewed the Water Chemistry Program response from the applicant and finds that the response provides provides adequate adequate assurance ad~quately manage assurance that the program will be able to adequately manage the loss of material from the general general corrosion of Boral since the program has controls to ensure that the correct boron concentration concentration is in the pool.

The staff reviewed reviewed the applicant's applicant's response response and finds that it adequately explains that through the the Surveillance Program, the reduction use of the Boral Surveillance reduction of neutron absorption absorption capacity aging effect, will be adequately managed managed for the period of extended operation. Additionally, the staff finds that the applicant's applicant's Water Chemistry Program will adequatelyadequately manage manage the aging effect of loss of material because because the program has controls to ensure the correct correct boron concentration concentration in the pool.

The staff's staffs concern described described in RAI 3.3.2.2.6-1 3.3.2.2.6-1 is resolved.

In response to RAI 3.3.2.2.6-1, 3.3.2.2.6-1, the applicant made an addition to the Appendix Appendix A, A.5 License License Commitment List. There, the applicant Renewal Commitment applicant makes the commitment that the "Boral test coupon surveillance surveillance Willwill continue through the period of extended operation." operation." This is found to be be acceptable acceptable by the staff since it it gives assurance that the neutron-absorbing neutron-absorbing capacity will be be adequately managed in the period adequately managed extended operation.

period of extended On the basis of its technical technical review of the applicant's Surveillance Program applicant's Boral Surveillance Program and Water Chemistry Program, Program, the staff concludes concludes that the applicant applicant has demonstrated demonstrated that effects effects of aging aging will be adequately adequately managed so that the intended function(s) function(s} will be maintained maintained consistent the consistent with the CLB for the period period of extended extended operation, as required by 10 CFR 54.21 (a)(3). (a}(3). The staff also reviewed commitment and concludes that itit provides reviewed the commitment assurance that the program provides adequate assurance will be maintained maintained in the period period of license extension.

3.3.2.2.7 Loss of Material Material due to General, General, Pitting, and Crevice Crevice Corrosion The staff reviewed LRA Section 3.3.2.2.7 3.3.2.2.7 against the criteria in SRP-LR SectionSection 3.3.2.2.7.

(1) LRA Section 3.3.2.2.7 3.3.2.2.7 refers to LRA Table 3.3.1, 3.3.1, line items 14, 15, and 16, and addresses addresses loss of material material due to general, general, pitting, and crevice corrosion for steel piping, piping piping components, and piping elements exposed to lubricating lubricating oil; for steel reactor coolant pump pump oil collection collection system piping, tubing, and valve bodies exposed to lubricating lubricating oil; and for steel reactor coolant coolant pump oil collection system tank exposed to lubricating oil. The The applicant applicant stated stated that the component, material, environment, and aging effect/mechanism effect/mechanism does not apply to auxiliary auxiliary systems.

Section 3.3.2.2.7 SRP-LR SeCtion 3.3.2.2.7 states that loss of material material due to general, pitting, and crevice crevice corrosion may occur in steel piping, piping components, and piping elements, including the the tubing, valves, and tanks in the reactor coolant pump oil collection system, exposed to to lubricating oil (as part of the fire protection protection system).

In RAI AMR-Generic-2, AMR-Generic-2, dated January 5, 2009, the staff requested January requested that the applicant applicant provide additional information information to justify why LRA Table 3.3.1, 3.3.1, Items Items 3.3.1-14, 15, and 16 are not applicable.

In its response to the RAI dated January 12, dated January 12, 2009, the applicant stated the following:

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Item 3.3.1-14:\

3.3.1-14: TMI-1 predicts predicts the additional aging effect/mechanism effect/mechanism of loss of material/MIC for carbon steel in lubricating oil. This component, material, material/MIC environment, and aging effect/mechanism combination is addressed by item 3.4.1-effect/mechanism combination 3.4.1-12.

Item 3.3.1-15: Component/material combination does not exist in Auxiliary Component/material combination Systems. The TMI-1 reactor reactor coolant pump lubricating lubricating oil collection components components are stainless steel. Line item 3.3.1-33 addresses the stainless steel reactor coolant 3.3.1-33 addresses coolant lubricating oil collection components. See LRA Section 3.3.2.2.12.2.

pump lubricating 3.3.2.2.12.2.

Item 3.3,1-16:

3.3.1-16: Component/material Component/material combination does not exist in Auxiliary Systems. The TMI-1 reactor coolant pump lubricating lubricating oil collection components are collection components stainless steel. Line item 3.3.1-33 addresses the stainless steel reactor coolant coolant pump lubricating oil collection components. See LRA Section 3.3.2.2.12.2. 3.3.2.2.12.2.

Based on its review of the LRA, the staff confirmed the following:

That TMI-1 predicts the additional effect/mechanism of loss of material/MIC additional aging effect/mechanism material/MIC for carbon steel in lubricating lubricating oil and that this component, material, environment, and aging effect/mechanism effect/mechanism combination combination is addressed by item 3.4.1-12.

That the TMI-1 reactor reactor coolant pump lubricating oil collection components components are are stainless steel and line item 3.3.1-33 addresses addresses the stainless steel reactor coolant pump lubricating lubricating oil collection components.

components.

The staff finds the applicant's applicant's determination determination acceptable.

acceptable.

(2)

(2) LRA Section 3.3.2.2.7 3.3.2.2.7 addresses loss of material material due to general, pitting, and crevice crevice corrosion, stating that this aging effect effect is not applicable applicable to TMI-1, TMI-1, which is a PWR.

SRP-LR Section 3.3.2.2.7 states that loss of materialmaterial due to general, pitting, crevice pitting, and crevice corrosion may occur occur in steel piping, piping components, and piping elements in the BWR BWR reactor water cleanup and shutdown shutdown cooling systems exposed to treated exposed treated water.

TMI-1 is a PWR and does not have reactor water cleanup cleanup and shutdown cooling systems.

On this basis, the staff finds that this item is not applicable applicable to TMI-1.

TMI-1.

(3) LRA Section Section 3.3.2.2.7 3.3.2.2.7 addresses general (steel only), pitting and addresses loss of material due to general crevice corrosion in steel and stainless stainless steel diesel engine exhaust exhaust piping, piping piping components and piping elements exposed exposed to diesel diesel exhaust. The applicant applicant stated stated that the the Inspection Inspection of Internal Surfaces Surfaces in Miscellaneous Miscellaneous Piping Components Program Piping and Ducting Components P~ogram will manage manage this aging effect in steel and stainless stainless steel internal internal surfaces surfaces exposed to t6 diesel exhaust. The staff reviewed LRA Section Section 3.3.2.2.7 against the criteria in SRP:-LR SRP;LR Section 3.3.2.2.7, which states that loss of material material due to general general (steel only), pitting and crevice corrosion corrosion may occur in steel and stainless steel diesel diesel engine engine exhaust exhaust piping, piping, components and piping elements piping components elements exposed exposed to diesel diesel exhaust.

The GALL recommends that a plant-specific GALL Report, under Item VII.H2-2 recommends plant-specific program program be be credited to manage manage aging aging effect for steel and stainless steel piping, piping components components and piping elements elements in the auxiliary systems.

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The staff The staff confirmed confirmed that that only only piping, piping, fittings fittings and expansion joints and expansion joints that GALL AMRs that align to GALL AMRs VII.H2-2 for the VII.H2-2 the emergency emergency diesel diesel generators generators and auxiliary auxiliary system and the station and the station blackout and blackout and UPS UPS diesel diesel generator generator system system that fabricated from steel that are fabricated steel and and stainless stainless steel materials steel materials that that credit credit the the Inspection Inspection of of Internal Internal Surfaces Miscellaneous Piping and Surfaces in Miscellaneous Ducting Components Ducting Components Program applicable to TMI-1.

Program are applicable TMI-1.

reviewed the Inspection The staff reviewed Inspection of Internal Internal Surfaces Miscellaneous Piping and Surfaces of Miscellaneous and Ducting Ducting Components Program Components Program and and its its evaluation evaluation is documented documented in SER Section 3.0.3.2.17.

3.0.3.2.17. The The Inspection of Internal staff finds that the Inspection Internal Surfaces Miscellaneous Piping Surfaces in Miscellaneous and Ducting Ducting Components program Components requires visual program requires visual inspections inspections of internal surfaces of components internal surfaces components during periodic during periodic system and component component surveillance activities or during maintenance surveillance activities maintenance activities when the activities the internal surface surface becomes accessible for visual becomes accessible inspections to detect visual inspections detect aging effects aging effects that could could result result in aa loss loss of the component's intended function. The component's intended The staff staff program includes finds that this program activities that are includes activities consistent with are consistent with the recommendations in the recommendations the GALL adequate to manage loss of material GALL Report, and that itit is adequate general (steel material due to general only), pitting and and crevice crevice" corrosion in steel and stainless stainless steel diesel exhaust piping, piping, piping piping components and piping elements components elements exposed exposed to diesel exhaust on the internal diesel exhaust internal surface.

Based on a review of the program Based program identified identified above, the staff concludes applicant's concludes that the applicant's program meets SRP-LR program meets SRP-LR Section 3.3.2.2.7 criteria. For those line items 3.3.2.2.7 criteria. items that apply to LRA LRA determines that the LRA is consistent with the GALL Section 3.3.2.2.7, the staff determines Report and that GALL Report that the applicant applicant has has demonstrated demonstrated that the effectseffects of aging will be be adequately managed so that the adequately managed the intended consistent with the CLB during maintained consistent intended function(s) will be maintained period of extended during the period extended operation, as required by 10 10 CFR 54.21(a)(3).

Material due to General, Pitting, Crevice, and MIC 3.3.2.2.8 Loss of Material MIC The staff reviewed 3.3.2.2.8 against the criteria in SRP-LR Section 3.3.2.2.8.

reviewed LRA Section 3.3.2.2.8 LRA Section LRA Section 3.3.2.2.8 3.3.2.2.8 states that the Buried Piping and Tanks Inspection Inspection Program, will be be implemented implemented to manage material due to general, pitting, crevice, and microbiologically-manage the loss of material influenced corrosion of the steel (with or without coating or wrapping) influenced wrapping) piping, piping components, piping elements, and structural members exposed to soil in the circulating water system, generators and auxiliaries system, fire protection emergency diesel generators instrument and protection system, instrument control air system, open cycle cooling water system, primary containment heating and ventilation system, station blackout blackout and UPS diesel generatorgenerator systems, and dike/flood control system.

The staff reviewed LRA SectionSection 3.3.2.2.8 against the criteria in SRP-LR Section 3.3.2.2.8, which states that states that loss of material due to general, pitting, crevice corrosion, and MIC could could occur for steel (with or without coating or wrapping) wrapping) piping, piping components, and piping elements buried in soil. The buried piping and tanks inspection program relies on industry elements practice, frequency of pipe excavation, and operating experience experience to manage the effects of loss of material from general, pitting, and crevice corrosion and MIC. The effectiveness effectiveness of the buried piping and tanks inspection inspection program should be verified to evaluate an applicant's inspection experience with buried components, ensuring that loss of material is frequency and operating experience is not not occurring.

The staff reviewed the Buried Piping and Tanks Inspection Program Program and its evaluation is documented documented in SER Section 3.0.3.2.15. The staff finds that this program provides focused and opportunistic excavations excavations and inspections for general, pitting, microbiologically-pitting, crevice, and microbiologically-influenced influenced corrosion of buried steel piping and tanks within ten years before the period of 3-285

extended operation and within ten years after the initiation of the period of operation operation except for the buried diesel diesel generator 30,000 gallon tank. The walls of this tank will be generator fuel storage 30,000 be ultrasonic testing from the inside of tank to verify subjected to ultrasonic subjected acceptable wall thickness. The verify acceptable The operating experience regarding buried buried piping and tanks at TMI-1 did not indicate indicate adverse adverse trends trends degradation. The results of focused and opportunistic of piping degradation. inspection of buried piping and opportunistic inspection evaluated and any degradation will be evaluated through the applicant's tanks will be evaluated applicant's corrective corrective replacement options and inspection frequency will be action program where repair and replacement be addressed. Therefore, the staff finds that, based on a review of the program addressed. program identified above, the the applicant has met the criteria of SRP-LR Section 3.3.2.2.8.

Based on a review programs identified, review of the programs concludes that the applicant's programs identified, the staff concludes programs SRP-LR Section 3.2.2.2.8 criteria. For those line items that apply to LRA Section 3.2.2.2.8, meet SRP-LR determines that the LRA is consistent with the GALL the staff determines GALL Report and that the applicant has has demonstrated that the effects adequately managed effects of aging will be adequately managed so that the intended maintained consistent with the CLB during the period of extended operation, function(s) will be maintained function(s) operation, as as 54.21(a)(3).

required by 10 CFR 54.21(a)(3).

Material due to General, Pitting, Crevice, MIC and Fouling 3.3.2.2.9 Loss of Material 3.3.2.2.9 Fouling reviewed LRA Section 3.3.2.2.9 The staff reviewed against the criteria in SRP-LR 3.3.2.2.9 against SRP-LR Section 3.3.2.2.9.

(1) LRA Section 3.3.2.2.9 states that the One-Time Inspection Inspection Program, Program, will be implemented implemented effectiveness of the Fuel Oil Chemistry Program to manage the loss of .

to verify the effectiveness microbiologically-influenced corrosion, and general, pitting, crevice, and microbiologically-influenced material due to general, fouling of the steel piping, piping components, piping elements, and tanks exposed to fuel steam system, emergency oil in the auxiliary steam emergency diesel generators and auxiliary auxiliary systems, systems, fuel oil system, and station blackout blackout and UPS diesel systems.

The staff reviewed LRA Section 3.3.2.2.9 against the criteria in SRP-LR SRP-LR Section 3.3.2.2.9 3.3.2.2.9 which states that loss of material due to general, pitting, crevice, MIC, MIC, and fouling couldcould occur occur for steel piping, piping components, piping elements, and tanks exposed to fuel oil.

existing aging management program The existing program relies on the fuel oil chemistry chemistry program for for contamination to manage loss of material monitoring and control of fuel oil contamination material due to to i~

corrosion or fouling. Corrosion or fouling may occur corrosion locations where contaminants occur at locations contaminants effectiveness of the fuel oil chemistry control should be verified to l3nsure accumulate. The effectiveness ensure that corrosion is not occurring. .

The GALL GALL Report recommends further evaluation Report recommends programs to manage loss of material evaluation of programs due to general, pitting, crevice, general, pitting, crevice, MIC, and fouling to verify effectiveness of the Fuel Oil the effectiveness Chemistry Program. A one-time inspectioninspection of selected susceptible I components at susceptible selected components acceptable method to ensure that corrosion is not occurring locations is an acceptable locations occurring and that the the component's intended function will be maintained component's intended maintained during the period of extended operation.

The staff reviewed the Fuel Oil Chemistry Program Program and the One-Time Inspection Program documented in SER Sections 3.0.3.2.12 and 3.0.3.2.14 evaluations are documented and its evaluations 3.0.3.2.14 programs 1) provide for periodic sampling respectively. The staff finds that that these programs sampling of inspection of fuel tanks to maintain fuel oil and periodic, draining, cleaning and visual inspection maintaip contaminants at acceptable limits contaminants to preclude preclude loss of material due to pitting and corrosion corrosion and 2) will require require one-time inspection of select one-time inspection select susceptible steel piping, piping piping, piping components, piping elements, and tanks exposed to fuel oil for loss of material due.to due~to general, pitting, crevice general, corrosion and fouling microbiologically-influenced corrosion crevice and microbiologically-influenced fouling to verify the the 3-286 3-286

effectiveness of the Fuel Oil Chemistry Program effectiveness Program in applicable auxiliary auxiliary systems.

Therefore, Therefore, the staff finds that, based on a review of the programs identified above, the programs identified the applicant has met the criteria of SRP-LR SRP-LR Section 3.3.2.2.9.1.

3.3.2.2.9.1.

(2) LRA Section 3.3.2.2.9 addresses Section 3.3.2.2.9 addresses loss of material material due to general, pitting, crevice, microbiologically-influenced corrosion microbiologically-influenced corrosion and fouling in steel piping, piping components components and elements elements and tanks exposed to fuel oil. The applicant applicant stated that the Inspection Inspection of Internal Surfaces Miscellaneous Piping and Ducting Components Surfaces in Miscellaneous Components Program will manage manage this this aging effect effect in steel internal surfaces exposed exposed to internal internal fuel oil environment. The staff staff reviewed 3.3.2.2.9 against reviewed LRA Section 3.3.2.2.9 against the criteria in SRP-LR SRP-LR Section 3.3.2.2.9, which states that loss of material material due to general, pitting, crevice, microbiologically-influenced microbiologically-influenced corrosion corrosion and fouling may occur in steel piping, piping components components and elements and tanks exposed to fuel oil. The GALL Report, under under Item Item VII.H1-10 VII.H1-10 and VII.H2-24 VII.H2-24 recommends recommends that the Fuel Oil ChemistryChemistry Program be credited to manage manage this aging effect and that a plant-specific plant-specific AMP be evaluated evaluated and credited to toverify

,verify that the Fuel Oil Chemistry Program is effective. These These GALL AMRs identifyidentify a One-Time Inspection One-Time Inspection Program is an acceptable Program acceptable AMP to credit for the verification effectiveness of the Fuel verification of the effectiveness Oil Chemistry Program.

Program.

The staff confirmed that only tanks, piping and fittings that align to GALL GALL AMRs VII.H1-1 VII.H1-1 for the Emergency Diesel Generators Generators and Auxiliary System and the Station Blackout Blackout and UPS Diesel Generator Generator System System that are fabricated from steel materials materials that credit the the Inspection Inspection of Internal Surfaces in Miscellaneous Miscellaneous Piping and Ducting Components Components Program, are applicable to TMI-1. TMI-1. '

Inspection of Internal The staff reviewed the Inspection Internal Surfaces of Miscellaneous Miscellaneous Piping and Ducting Ducting Components Program and its evaluation is documented Components documented in SER Section Section 3.0.3.2.17. The The staff finds that the Inspection Inspection of Internal Surfaces in Miscellaneous Internal Surfaces Miscellaneous Piping and Ducting Ducting Components Program requires visual inspections Components inspections of internal internal surfaces surfaces of components components during periodic system and component surveillancesurveillance activities or during maintenance maintenance activities when the internal surface surface becomes accessible for visual inspections to detect becomes accessible aging effects that could result in aa loss of the component's component's intended function. The staff staff finds that this program includes includes activities are adequate adequate to manage loss of material due to general, general, pitting, microbiologically-influenced corrosion and fouling in steel piping, pitting, crevice, microbiologically-influenced piping components, piping elements and tanks exposed exposed to fuel oil on the internal internal surface.

(3) LRA Section 3.3.2.2.9 states that the One-TimeOne-Time Inspection Inspection Program, Program, will be implemented implemented to verify the effectiveness effectiveness of the Lubricating Lubricating Oil Analysis Program, Program, to manage loss of material material due to general, pitting, crevice, and microbiologically-influenced microbiologically-influenced corrosion of steel piping, piping components, and piping eleme~ts elements exposed exposed to lubricating lubricating oil in the reactor reactor coolant system. Fouling is not predicted predicted for this component, material and environment environment combination.

The staff reviewed LRA Section 3.3.2.2.93.3.2.2.9 against against the criteria criteria in SRP-LR SRP-LR Section 3.3.2.2.9 3.3.2.2.9 which states that loss of material due to general, pitting, crevice, MIC, and fouling could could occur occur for steel heat exchanger exchanger components exposed exposed to lubricating oil. The existing aging management program relies on the periodic management periodic sampling and analysis of lubricating lubricating oil to acceptable limits, thereby preserving maintain contaminants within acceptable preserving an environment environment that is not conducive to corrosion. The effectiveness effectiveness of lubricating lubricating oil control should be verified to ensure that corrosion corrosion is not occurring. The GALL Report recommends further evaluation of programs programs to manage corrosion corrosion to verify the effectiveness of the lube oil program.program. A one-3-287 3-287

inspection of selected components time inspection locations is an acceptable susceptible locations components at susceptible acceptable method occurring and that the component's intended function will be to ensure that corrosion is not occurring be maintained maintained during the period of extended extended operation.

fouling of steel piping, piping components, and piping elements applicant stated that fouling The applicant elements exposed environment is not predicted.

lubricating oil environment exposed to a lubricating predicted. In RAI 3.3.1.21-1, 3.3.1.21-1, dated October requested that the applicant 16, 2008, the staff requested applicant provide provide additional information that demonstrates steel piping, piping components demonstrates elements are not subject to components and piping elements fouling when exposed lubricating oil.

exposed to lubricating In its response to the RAI dated November applicant stated that the EPRI November 12, 2008, the applicant Report Mechanical Tools," Revision 4, Appendix C, Table 4-1 1010639, "Non-Class 1 Mechanical Report 1010639, 4-1 does not predict the fouling of steel piping when exposed to lubricating oil.

oil. The staff noted alone did not provide sufficient 1010639 alone that citing the EPRI Report 1010639 sufficient information for the the staff to complete complete its evaluation.

evaluation.

AMR-GENERIC-3, dated January In RAI AMR-GENERIC-3, staff requested that the applicant January 05, 2009, the staff applicant provide provide additional information predicted for steel information stating the reason why fouling is not predicted components in lubricating lubricating oil. .

In response to the RAI dated January 12, 2009, the applicant stated that fouling is not dated January predicted predicted because microorganisms are not expected microorganisms lubricating oil because water expected in lubricating contamination that is necessary necessary to support microorganisms lubricating oil.

microorganisms is not present in lubricating The applicant further stated even ifif a fouling deposit caused the aging effect of loss of mechanisms would manage inspection for other aging mechanisms one-time inspection material, aa one-time manage fouling as well.

applicant's response to the RAI acceptable Based on its review, the staff finds the applicant's acceptable because loss of material due to fouling of steel piping and piping is not likely to occur because occur because the water contamination necessary because microorganisms to cause necessary for microorganisms cause fouling is not lubricating oil, a one-time lubricating oil and ififfouling is active in lubricating generally found in lubricating one-time inspection of select components inspection components will identify it.

The staff reviewed the Lubricating Oil Analysis Program and the One-Time Inspection Inspection documents its review in SER Program and documents SER Sections Sections 3.0.3.2.18 3.0.3.2.14 respectively 3.0.3.2.18 and 3.0.3.2.14 respectively and found that these programs 1) provide sampling of lubricating oil to provide for periodic sampling maintain contaminants acceptable limits to preclude loss of material due to general, contaminants at acceptable general, pitting, crevice and microbiologically-influenced corrosion and fouling and 2) will require microbiologically-influenced corrosion one-time inspection of select susceptible one-time components for loss of susceptible steel pump and valve components microbiologically-influenced corrosion material due to general, pitting, crevice and microbiologically-influenced corrosion to verify effectiveness of the Lubricating the effectiveness Lubricating Oil Analysis Program in applicable auxiliary Analysis Program auxiliary systems.

programs identified, the staff concludes Based on a review of the programs Based concludes that the applicant's programs applicant's programs meet SRP-LR Section 3.3.2.2.9 criteria. For those line items that apply to LRA Section meet Section 3.3.2.2.9, determines that the LRA is consistent with the GALL Report and that the applicant the staff determines applicant has has demonstrated that the effects of aging will be adequately managed demonstrated managed so that the intended maintained consistent with the CLB during the period of extended operation, as function(s) will be maintained as required by 10 CFR 54.21(a)(3).

3.3.2.2.10 Loss of Material due to Pitting and Crevice Corrosion The staff reviewed LRA Section 3.3.2.2.10 against the criteria in SRP-LR Section 3.3.2.2.10.

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(1) LRA Section 3.3.2.2.10 addresses Section 3.3.2.2.10 addresses loss of material material due to pitting and crevice corrosion corrosion in steel piping with elastomer elastomer lining exposed to treated treated borated borated water, stating that this aging effect is not applicable to TMI-1 which is a PWR.

effect SRP-LR SRP-LR Section 3.3.2.2.10 3.3.2.2.10 states that loss of material material due to pitting and crevice crevice corrosion corrosion may occur in BWR and PWR steel piping with elastomer elastomer lining or stainless steel cladding that are exposed to treated waterwater and treated borated water if the cladding cladding or lining lining is degraded.

AMR-Generic-2, dated January 5, 2009, In RAI AMR-Generic-2, 2009; the staff requested that the applicant applicant provide additional information to justify why LRA Table 3.3.1, additional information 3.3.1, line item 3.3.1-22 3.3.1-22 is not applicable.

In its response to the RAI dated dated January 12, 2009, the applicant applicant stated the item is not not applicable because there are no steel with elastomer elastomer lining or stainless stainless steel cladding piping, piping components, and piping elementselements exposed to treated water and treated borated water in auxiliary auxiliary systems.

The staff confirmed that there are no elastomer-lined elastomer-lined steel components within the scope of license renewal renewal for auxiliary systems. Based on this, the staff finds that the item does not apply to TMI-I.

TMI-1.

(2) LRA Section Section 3.3.2.2.10 3.3.2.2.10 addresses addresses the applicant's applicant's aging management management basis for managing managing loss of material due to pitting and crevice corrosion in stainless steel and steel with with stainless steel cladding heat exchanger components, heat exchanger penetration bellows, support components, tanks, penetration members, and the fuel transfer transfer canal liner, and in aluminum support members exposed to members exposed to treated treated water in the closed-cycle closed-cycle cooling water system, the component supports component supports commodities group, the fuel handling building, the miscellaneous miscellaneous floor and equipment equipment drains drains system, and the reactor building. The applicant applicant stated that the aging aging effect of loss loss of material material due to pitting and crevice corrosion corrosion in these components managed by aa components will be managed combination combination of the Water Chemistry Program and the One-Time Inspection Inspection Program.

The staff reviewed 3.3.2.2.10 against reviewed LRA Section 3.3.2.2.10 against the criteria criteria in SRP-LR Section 3.3.2.2.10, which states that loss of material material due to pitting and crevice crevice corrosion may occur in stainless steel and aluminum piping, piping components, piping elements, and in stainless steel and steel with stainless steel cladding heat exchanger components components exposed to treated treated water. The SRP-LR states thatthe that the existing AMP monitors monitors and controls controls reactor water chemistry chemistry to manage manage the aging effects of loss of material from pitting and crevice corrosion, but that high concentrations concentrations of impurities in crevices and with stagnant flow conditions may cause pitting or crevice corrosion; corrosion; therefore, the effectiveness effectiveness of water water chemistry control programs programs should be verified to ensure that corrosion does does not occur. The GALL ReportReport recommends recommends further further evaluation evaluation of programs to managemanage loss of material from pitting and crevice corrosion to verify the effectiveness effectiveness of water chemistry control programs. The SRP-LRSRP-LR states that a one-time inspection inspection of selected selected components components at susceptible locations locations is an acceptable acceptable method to ensure that corrosion does not occur and that component intended functions will be maintained component intended maintained during the period of extended extended operation.

The staff reviewed reviewed the applicant's applicant's Water Chemistry Program and its evaluation evaluation is documented documented in SER Section 3.0.3.2.2. The staff finds the applicant's applicant's Water Chemistry 3-289

Program, with an enhancement, enhancement, is consistent with GALL GALL AMP XI.M2, XI,M2, "Water Chemistry."

The staff reviewed reviewed the applicant's One-Time Inspection Program and its evaluation One-Time Inspection evaluation is documented in SER Section documented Section 3.0.3.2.14. The staff finds that that the applicant's applicant's One-Time One-Time Inspection Inspection Program Program is consistent with GALL AMP XI.M32, XI,M32, "One-Time Inspection," and is adequate to detect adequate presence or note the absence of loss of material in susceptible detect the presence susceptible locations due to pitting or crevice corrosion for components components within the scope of the the program. Based Based on the staff's determination determination that the applicant's applicant's Water Water Chemistry Program provides Program provides mitigation and the applicant's One-TimeOne-Time Inspection Inspection Program Program provides provides detection detection for the aging effect of loss of material material due to pitting or crevice crevice corrosion, corrosion, thethle staff staff finds the applicant's applicant's proposed AMPs for managingmanaging the aging effect of loss of material due due to pitting and crevice corrosion of the stainless steel and steel with stainless steel cladding exchanger components, heat exchanger components, tanks, penetration penetration bellows, support members, fuel transfer canal canal liner, and aluminum aluminum support support members members exposed to treated water in the closed-cycle closed-cycle cooling water system, the component component supports commodities commodities group, the fuel handlinghandling building, building, the miscellaneous miscellaneous floor and equipment equipment drains system, and the reactor building to be acceptable.

(3) LRA Section 3.3.2.2.10 addresses material due to pitting and crevice corrosion in addresses loss of material copper alloy HVAC piping, piping components and piping elements exposed to condensation.

condensation. The applicant stated that the Inspection Inspection of Internal Internal Surfaces in Miscellaneous Piping and Ducting Components Miscellaneous Components program or the External Surfaces Surfaces Monitoring program Monitoring program will manage this aging effect in copper alloy internal surfaces or internal surfaces external surfaces, respectively, exposed exposed to condensation condensation (i.e. outdoor air, wetted air/gas air/gas and air with borated borated water leakage). The staff reviewed LRA Section 3.3.2.2.10 against against the criteria in SRP-LR SRP-LR Section 3.3.2.2.10, which states that loss of material due to pitting pitting and crevice corrosion may occur in copper alloy alloy HVAC HVAC piping, piping components and and piping elements exposed to condensation.

The GALL Report, under under Items VII.F1-16, VII.F2-14, VII,F2-14, VII.F3-16 and VII.F4-12 VII.F4-12 and SRP-LR SRP-LR Section 3.3.2.2.10.3 3.3.2.2.10.3 recommends that a plant-specific plant-specific program program be credited credited to manage manage this this aging effect for copper all9Y alloy HVAC HVAC piping, piping components components and piping elementselements in the the auxiliary Systems.

The staff confirmed confirmed that only heat exchanger exchanger components, piping, fittings and valve valve bodies bodies that align to GALL AMRs VII.F1 -16 for the reactor VII.F1-16 reactor building spray system, fuel oil system and the control building ventilation system that are fabricated fabricated from copper copper alloy materials materials that credit the Inspection Inspection of Internal Internal Surfaces Miscellaneous Piping and Ducting Surfaces in Miscellaneous Ducting Components Components Program or the External Monitoring Program are applicable External Surface Monitoring applicable to TMI-TMI-

1. The staff noted that the reactor building spray system in which the applicant referenced Item VII.F1-16, is not an auxiliary auxiliary system, but was grouped grouped together with this GALLIAMR GALL AMR because the material, environment, and aging effect combination corresponded.

item because corresponded.

The staff reviewed the Inspection Inspection of Internal Surfaces Miscellaneous Piping and Ducting Surfaces of Miscellaneous Ducting Components Program Program and its evaluation is documented documented in SER Section 3.0.3.2.17. The The staff finds that the Inspection of Internal Surfaces in Miscellaneous Miscellaneous Piping and Ducting Components Program requires visual inspections inspections of internal surfaces of components components during periodic periodic system system and component component surveillance surveillance activities activities or during maintenance maintenance activities activities when the internal surface becomes accessible surface becomes accessible for visual inspections to detect visual inspections detect aging effects that could result in a loss of the component's component's intended function.

intended function. The staff staff finds that this program program includes activities activities that are consistent with the recommendations recommendations in in the GALL GALL Report, and that it is adequate adequate to manage manage loss of material due to pitting and 3-290 3-290

crevice corrosion in copper alloy HVAC piping, piping components and elements exposed HVAC piping, to wetted air/gas environment on the the internal internal surface.

surface.

The The staff noted that that for those AMR line items items in LRA Section 3.2, 3.2, in which the applicant applicant references Item 3.3.1-25, the applicant listed the environment as references as air with borated water leakage, which is aa more aggressive environment than a condensation environment. The The staff confirmed in LRA Section 3.2, that for the same system, material and environment combination, the applicant manages loss of material due to boric acid corrosion with the the Program, which is consistent with the GALL Report. The staff noted Boric Acid Corrosion Program, noted that the applicant is managing aging of these components for loss of material due to pitting and crevice corrosion with the External Surfaces Monitoring Program. The staff reviewed Monitoring Program and its the applicant's External Surfaces Monitoring its evaluation is documented in in determined that the External SER Section 3.0.3.2.16. The staff determined Monitoring External Surfaces Monitoring Program, which includes includes periodic periodic visual inspections performed during system walkdowns, manage loss of material due to pitting and crevice corrosion for copper is adequate to manage alloy HVAC piping, piping components, and piping elements exposed to an external condensation condensation environment addressed by this AMR. The staff finds that the External Surfaces Surfaces Monitoring Program requires periodic periodic visual inspections inspections of external surfaces surfaces maintenance to detect aging effects that could result in a loss of during periodic system maintenance the component's intended function. The staff finds that this program includes activities that recommendations in the GALL Report, and that it is adequate to are consistent with the recommendations manage loss of material due to pitting and crevice manage crevice corrosion for copper copper alloy HVAC piping, piping components and piping elementselements exposed condensation on the external surface.

(4) 3.3.2.2.10 states that the One-Time LRA Section 3.3.2.2.10 Inspection Program will be implemented One-Time Inspection effectiveness of the Lubricating Oil Analysis Program, to verify the effectiveness manage the loss of Program, to manage material due to pitting and crevice corrosion material of the copper copper alloy heat exchanger exchanger lubricating oil in the closed cycle cooling water system.

components exposed to lubricating components The staff reviewed LRA Section 3.3.2.2.10 against the criteria in SRP-LR Section 3.3.2.2.10 SRP-LR 3.3.2.2.10 which states that loss of material due to pitting and crevice Section 3.3.2.2.10 crevice corrosion corrosion occur for copper alloy piping, piping components, and piping elements could occur exposed to elements exposed lubricating oil. The effectiveness lubricating lubricating oil control should be verified to ensure that effectiveness of lubricating corrosion is not occurring. The GALL Report recommends recommends further evaluation evaluation of programs programs to to manage effectiveness of the lubricating corrosion to verify the effectiveness manage corrosion lubricating oil program. one-time program. A one-time inspection inspection of selected components components at susceptible susceptible locations is an acceptable method to acceptable method ensure corrosion is not occurring ensure that corrosion component's intended occurring and that the component's function will be intended function be maintained during the period maintained extended operation.

period of extended operation.

staff reviewed the Lubricating Oil Analysis Program The staff Program and the One-Time Inspection One-Time Inspection documented its findings in SER Sections 3.0.3.2.18 Program and documented Program 3.0.3.2.14 3.0.3.2.18 and 3.0.3.2.14 respectively and respectively periodic sampling of lubricating programs 1) provide for periodic and found that these programs lubricating oil to maintain acceptable limits to preclude contaminants at acceptable maintain contaminants material due to pitting preclude loss of material pitting and crevice crevice corrosion and 2) will require one-time require one-time inspection of select susceptible select susceptible copper components, and piping elements alloy piping, piping components, exposed to elements exposed to lubricating oil for loss of lubricating oil of material due to pitting and crevice material due corrosion to verify the crevice corrosion effectiveness of the the effectiveness the Lubricating Lubricating Oil Analysis Program in the closed cycle cooling Analysis Program cooling water system. Therefore, Therefore, the staff finds finds that, based based on review of the programs on aa review programs identified applicant has met the criteria identified above, the applicant criteria SRP-LR Section of SRP-LR Section 3.3.2.2.10.

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LRA Section 3.3.2.2.10 3.3.2.2.10 states that Inspection Inspection of Internal Surfaces Miscellaneous ~iping Surfaces in Miscellaneous Piping and Ducting Components Program, will be implemented implemented to manage manage the loss of material due to pitting and crevice crevice corrosion corrosion of the copper alloy piping, piping components, components, and exposed to waste lubricating piping elements exposed lubricating oil in the Radwaste Radwaste System. The InspectionInspection of Internal Surfaces Surfaces in Miscellaneous Miscellaneous Piping and Ducting Components Components Program consists Program consists of inspections inspections of the copper alloy piping, piping components, and piping elements exposed to lubricating lubricating oil that are not covered covered by other aging management management programs. These These " 'I inspections are performed during the periodic system and component surveillances or component surveillances or during the performance performance of maintenance maintenance activities when the surfaces surfaces are made accessible made accessible for visual inspection. includes visual inspections to assure that existing!'

inspection. The program includes existing!!

environmental environmental conditions conditions are not causing material degradation that could result in a loss of material degradation component intended functions.

component functions.

LRA Section 3.3.2.2.10 3.3.2.2.10 addresses loss of material due to pitting and crevice corrosion in copper copper alloy piping and components components exposed to lubricating lubricating oil. The applicant applicant stated that that the Inspection Inspection of Internal Internal Surfaces in Miscellaneous Miscellaneous Piping and Ducting ComponentsComponents Program will manage manage this aging effect in copper alloy piping and components components exposed exposed to lubricating lubricating oil. The staff reviewed 3.3.2.2.10 against reviewed LRA Section 3.3.2.2.10 against the criteria in SRP!LR SRP-LR Section 3.3.2.2.10, which states that loss of material due to pitting and crevice crevice corrosion may occur in copper alloy piping and components exposed to lubricating oil.

components exposed The GALL Report, under under Items VII.C1-8, VII.Cl-8, VII.C2-5, VII.E1-12, VII.El-12, VII.E4-6, VII.E4-6, VII.G-11 and VII.H2-10 and SRP-LR SRP-LR Section 3.3.2.2.10 recommends that Lubricating 3.3.2.2.10 recommends Analysis Lubricating Oil Analysis Program be credited to manage Program manage this aging effecteffect and that a plant-specific AMP be be evaluated evaluated and credited credited to verify that the Lubricating Lubricating Oil Analysis Program is achieving its achieving mitigative function to manage this aging effect mitigative effect for copper copper alloy piping and pipingpiping components and elements. These GALL AMRs states that a one-time inspection program program acceptable AMP to credit for the verification of the effectiveness of the Lubricating is an acceptable Lubricating Oil Analysis Analysis Program. '

The staff confirmed that only pump casings, sight glasses and valve bodies bodies that align to VII.El-12 for the radwaste GALL AMRs VII.E1-12 radwaste system that are fabricated from copper alloy allo~

materials that credit the Inspection Inspection of Internal Surfaces in Miscellaneous Internal Surfaces Miscellaneous Piping and' and' Components Program Ducting Components Program are applicable applicable to TMI-1.

TMI-1.

The staff reviewed the Inspection Inspection of Internal Surfaces of Miscellaneous Miscellaneous Piping and IpuctingDucting Components Program Program and its evaluation documented in SER Section 3.0.3.2.17. The evaluation is documented The staff finds that the Inspection Inspection of Internal Surfaces in Miscellaneous Miscellaneous Piping and Ducting Components Program requires inspections of internal requires visual inspections internal surfaces components surfaces of components during during periodic system and component surveillance activities or during maintenance component surveillance maintenance activities when the internal internal surface becomes becomes accessible accessible for visual inspections to detect aging effects that could result in a loss ofthe of the component's intended intended function. The staff staff finds that this program includes activities that are adequate includes activities adequate to manage manage loss of material material due due to pitting and crevice corrosion corrosion in copper alloy piping, piping components components and elements elements exposed to lubricating lubricating oil.

(5)

(5) addresses loss of material due to pitting and crevice corrosion LRA Section 3.3.2.2.10 addresses corrosipn in in HVAC aluminum HVAC aluminum piping, piping, piping components, components, and piping elements elements and stainless steel ducting ducting and components condensation. The applicant stated that the components exposed to condensation. the Inspection of Internal Internal Surfaces in Miscellaneous Miscellaneous Piping and Ducting ComponentsComponents Program will manage manage this aging effect effect in stainless steel internal surfaces surfaces exposed to condensation condensation 3-292 3-292

(wetted air/gas). The staff reviewed reviewed LRA Section 3.3.2.2.10 3.3.2.2.10 against the criteria in SRP-LR SRP-LR Section 3.3.2.2.10, which states loss of material states that 1055 material due to pitting and crevice crevice corrosion corrosion may occur in HVAC aluminum components and piping elements and aluminum piping, piping components and stainless steel ducting components exposed ducting components exposed to condensation. The staff s~aff noted noted that only stainless steel components is applicableapplicable to TMI-1 and therefore therefore the portion relating to aluminum components components will not be discusseddiscussed in this section of the SER.

The GALL Report, under Item VII.F1-1, VII.F2-1, Item VILF1-1, VILF2-1, VII.F3-1, VII.F1-14, VILF2-12, VILF3-1, VILF1-14, VII.F2-12, VII.F3-14 VILF3-14 and VILF4-10 VII.F4-10 and SRP-LR 3.3.2.2.10.5 recommends that a plant-specific SRP-LR Section 3.3.2.2.10.5 plant-specific program be credited to address this aging effect for stainless steel ducting and components components and piping elements in the auxiliary systems.

The staff confirmed confirmed that only filter housing, housing, piping, fittings, sight glasses, steam steam traps, tanks, thermowells and valve bodies bodies that align to GALL AMRs VILF1-1, VII.F1-1, VILF2-1 VII.F2-1 and VII.F3-1 for the auxiliary VILF3-1 auxiliary and fuel handling ventilation system, extraction steam system, main steam system, primary containment heating and ventilation system and the steam steam.

turbine and auxiliary auxiliary system that are fabricated fabricated from stainless steel materials materials are applicable applicable to TMI-1 that credit the InspectionInspection of Internal Surfaces in Miscellaneous Miscellaneous Piping and Ducting Components Components Program.Program. The staff noted noted that the steam turbine and auxiliary system, the extraction extraction steam system, and the main steam system in which the applicant applicant referenced Item has referenced Item VII.F1-1, VILF1-1, are not auxiliary auxiliary systems, but were grouped together with this GALL GALL AMR item because because the material, environment, and aging effect combination corresponded.

corresponded.

The staff reviewed reviewed the Inspection Inspection of Internal Surfaces Surfaces of Miscellaneous Miscellaneous Piping and Ducting Ducting Components Components Program and its evaluation is documented documented in SER Section Section 3.0.3.2.17. The The staff finds that the Inspection of Internal Miscellaneous Piping and Ducting Internal Surfaces in Miscellaneous Ducting Components Components Program requires visual inspections inspections of internal surfaces surfaces of components components during periodic system and component surveillance surveillance activities or during maintenance maintenance activities when the internal surfacesurface becomes becomes accessible for visual inspections inspections to detect aging effects that could result in a 1055 loss of the component's intended intended function. The staff staff finds that this program program includes includes activities activities that are consistent consistent with the recommendations recommendations in the GALL GALL Report, and that itit is adequate adequate to manage manage 1055 loss of material due to pitting and crevice corrosion in stainless steel componentscomponents exposed exposed to condensation. (6) LRA Section 3.3.2.2.10 addresses addresses 1055 loss of material material due to pitting and crevice crevice corrosion corrosion in copper copper alloy fire protection system piping, piping components and piping elements elements exposed exposed to internal condensation. The staff reviewed reviewed the Inspection Inspection of Internal Internal Surfaces Surfaces of Miscellaneous Miscellaneous Piping and Ducting Components Components Program and its evaluation is documented documented in SER Section 3.0.3.2.17. The staff finds that the Inspection Inspection of Internal Surfaces in Miscellaneous Surfaces Miscellaneous Piping and Ducting Components Ducting Components program performs visual performs inspections inspections of internal surfaces internal surfaces of components during periodic system and component component surveillance surveillance activities or during maintenance activities maintenance activities when the internal surface becomes surface becomes accessible for visual inspections accessible inspections to detect aging effects effects that could result in a loss of the the component's intended function. The staff finds that this program includes activities component's activities that are consistent with the recommendations recommendations in the GALL Report, and that it is adequate to manage 1055 manage loss of material material due to pitting and crevice crevice corrosion in copper alloy piping, piping components and piping elements exposed to internal internal condensation.

condensation. LRA Section 3.3.2.2.10 states states that the Inspection of Internal Surfaces Internal Surfaces in Miscellaneous Miscellaneous Piping Piping and Ducting Components Components Program will be used to manage 1055 loss of material due to pitting pitting and crevice corrosion of the cooper cooper alloy piping, piping components components and piping elementselements exposed exposed to wetted air in the emergency emergency diesel generators and auxiliary system, radwaste diesel generators radwaste 3-293 3-293

system, and reactor building sprayspray system. reviewed the Inspection of Internal system. The staff reviewed Surfaces Surfaces of Miscellaneous Components Program and its evaluation Miscellaneous Piping and Ducting Components evaluation is 3.0.3.2.17. The staff finds that the Inspection documented in SER Section 3.0.3.2.17.

documented Inspection of Internal Surfaces in Miscellaneous Components Program requires Miscellaneous Piping and Ducting Components requires visual components during periodic system and component inspections of internal surfaces of components inspections component maintenance activities when the internal surface becomes surveillance activities or during maintenance becomes accessible for visual inspections to detect effects that could result in a loss of the detect aging effects the intended function. The staff finds that this program includes activities that are component's intended recommendations in the GALL Report, and that it is adequate to consistent with the recommendations to manage loss of material due to pitting and crevice corrosion in copper alloy piping, and crevice piping piping, piping components and piping elements internal condensation.

elements exposed to internal Compressed Air Monitoring Program 3.3.2.2.10 states that the Compressed LRA Section 3.3.2.2.10 Program will be used to to manage loss of material corrosion of the copper alloy piping, material due to pitting and crevice corrosion piping, piping components, piping elements, and heat exchanger components exposed exchanger components exposed to wetted air in the control building ventilation system, and instrument and control air system. The control The Monitoring Program applicant stated that the Compressed Air Monitoring inspections of Program consists of inspections the internal surfaces of copper alloy components.

3.3.2.2.10 invokes AMR Item 28 in Table 3 of the GALL SRP-LR Section 3.3.2.2.10 SRP-LR Volume GALL Report, Volume 1, and GALL AMR Item VII.G-9, applicable to copper copper alloy piping components exposed to protection system, and recommends condensation in the fire protection condensation recommends a plant-specific plant-specific aging management program.

management The staff reviewed the Compressed Monitoring Program, which Compressed Air Monitoring which includes periodic visual includes periodic inspection of internal surfaces of piping and heat exchanger inspection components for loss of exchanger components monitoring of system air quality in accordance material and fouling, monitoring material accordance with industry standards and guidelines, and is consistent with the GALL AMP XI.M24, "Compressed Air Air Monitoring." Monitoring Program Compressed Air Monitoring Monitoring." The staff reviewed the Compressed Program and its documented in SER evaluation is documented Section 3.0.3.2.8.

SER Section Oli the basis that periodiC 3.0.3.2.8. On periodic visual Monitoring program performed, the staff finds that the Compressed Air Monitoring inspection will be performed, will adequately manage loss of material due to pitting and crevice adequately manage crevice corrosion corrosion of copper alloy copper alloy piping, piping components, piping elements, exchanger components elements, and heat exchanger components exposed to ventilation system, and instrument wetted air in the control building ventilation wetted instrument and control air system extended operation.

through the period of extended operation.

Based on a review of the programs identified, concludes that the applicant's identified, the staff concludes applicant's programs meet 3.3.2.2.10 criteria. For those line items that apply to LRA meet SRP-LR Section 3.3.2.2.10 determines that the LRA is consistent with the GALL Report Section 3.3.2.2.10, the staff determines Section demonstrated that the effects of aging will be adequately and that the applicant has demonstrated adequately function(s) will be maintained consistent with the CLB managed so that the intended function(s) managed CLB during the period of extended operation, operation, as required by 10 10 CFR 54.21 (a)(3).

3.3.2.2.10 states that the Fire Protection Program will be used to manage Section 3.3.2.2.10 LRA Section manage loss of material due to pitting and crevice corrosion of the copper alloy spray nozzles nozzles applicant further stated that the wetted air in the fire protection System. The applicant exposed to wetted the Fire Protection Program includes monitoring, Protection Program inspection activities monitoring, testing, and inspection including activities including suppression system flow testing to verify flow from each low-pressure carbon dioxide fire suppression low-pressure nozzle. The applicant also stated that any adverse conditions such as broken or missing missing excessive dirt or debris, or other parts, loose fasteners, excessive degrading condition are required other degrading required corrective action evaluation.

to be reported for corrective 3-294 3-294

SRP-LR Section 3.3.2.2.10 3.3.2.2.10 invokes invokes AMRAMR Item 28 in Table 3 of the GALL Report, Volume Volume 1, and GALL AMR Item VII.G-9, applicable to copper alloy piping components exposed VII.G-9, applicable exposed to condensation in the fire protection system, and recommends recommends a plant-specific plant-specific aging management program.

management program.

The staff reviewed reviewed the Fire Protection Program, which includes inspection and performance testing of low-pressure performance low-pressure carbon dioxide dioxide system components components at periodic periodic intervals, and is consistent with GALL AMP XI.M26, "Fire Protection."Protection." The staff reviewed the Fire Protection Protection Program and its evaluation documented in SER Section 3.0.3.2.9.

evaluation is documented On the basis that inspection inspection and testing will be performed, performed, the staff finds that the Fire Fire Protection Program will adequately Protection Program adequately manage manage loss of material due to pitting and crevicecrevice corrosion of copper alloy spray nozzles corrosion exposed to wetted air in the fire protection nozzles exposed protection system through the period of extended operation.

LRA LRA Section 3.3.2.2.10 states that the Fire Water System Program Program will be used to manage manage loss of material material due to pitting and crevice corrosion corrosion of the copper copper alloy sprinkler heads heads exposed to wetted air in the fire protection system. The Fire Water System Program Program manages the aging effects of fire water system sprinkler manages sprinkler heads heads through system monitoring, periodic tests and inspection activities.

monitoring, The staff reviewed reviewed LRA Section 3.3.2.2.10 against the criteria in SRP-LR SRP-LR Section 3.3.2.2.10, which states that loss of materialmaterial due due to pitting and crevice crevice corrosion corrosion could occur for copper alloy fire protection protection system components exposed to internal condensation. The GALL Report Report recommends recommends further further evaluation evaluation of a plant-specific plant-specific aging management program management program to ensure these aging effects are adequatelyadequately managed.

SRP-LR Section 3.3.2.2.10 invokes Section 3.3.2.2.10 invokes AMR AMR Item 28 in Table 3 of the GALL Report, Volume Volume 1, and GALL AMR Item VII.G-9, applicable to copper alloy piping components VII.G-9, applicable components exposed to to condensation in the fire protection protection system, recommends a plant-specific

~ystem, and recommends plant-specific aging management program.

management The staff reviewed, reviewed-thethe Fire Water System Program, Program, which manages identified identified aging effects water-based fire protection effects for the water-based protection system and associated associated components, through the the use of periodic inspections, inspections, monitoring, and performance performance testing, and finds that itit is consistent consistent with the GALL AMP XI.M27, "Fire Water System." As recommended recommended by the the GALL GALL AMP XI.M27, XI. M27, the applicant has committed committed to testing or replacement replacement of sprinkler heads that have been in service for 50 years. The staff's staffs review of the Fire Water System Program and its evaluation Program evaluation is documented documented in SER Section 3.0.3.2.10. On the basis that the sprinkler heads heads will be tested or replaced, replaced, the staff finds that the Fire Water System Program Program will adequately manage loss of material adequately manage material due to pitting and crevice crevice corrosion of copper alloy sprinkler sprinkler heads heads exposed exposed to wetted air in the fire protection system throughthrough the period of extended extended operation.

(7)

(7) LRA Section 3.3.2.2.10 3.3.2.2.10 states that the Buried Piping and Tanks InspectionInspection Program, Program, will be implemented implemented to manage loss of materialmaterial due to pitting and crevice corrosion of the the stainless stainless steel piping, piping components, and piping elements elements exposed exposed to soil in the firefire protection system. The Buried Piping and Tanks Inspection Program consists of Tanks Inspection preventive preventive measures measures to mitigate corrosion and periodic inspection to manage manage the effects effects of corrosion pressure-retaining capacity of buried stainless steel piping, piping corrosion on the pressure-retaining piping components, and piping elements.

3-295 3-295

The staff reviewed LRA Section 3.3.2.2.10 against the criteria in SRP-LR SRP-LR Section 3.3.2.2.10 which which states that loss of material due to pitting and crevicecrevice corrosion corrosion could occur for stainless steel piping, piping components, components, and piping elements exposed to soil. The GALL GALL Report recommends evaluation of a plant specific aging recommends further evaluation program to ensure that these aging effects are adequately management program management adequately managed.

Technical Position described in Branch Technical Acceptance criteria are described Acceptance RLSB-1 (Appendix A.1 of Position RLSB-1 this SRP-LR). .

piping material of stainless steel piping In LRA Table 3.3.2-10, the applicant stated that loss of material exposed to the buried (ext) environment managed with the Buried Piping and Tank environment is managed Inspection Program. During the audit, the staff noted that for the AMR results line that Inspection that references LRA Table Table 3.3.2, the applicant included a reference to Generic Note Note E. The The staff reviewed the AMR results line referenced to Generic determined that the Generic Note E and determined component type, material, environment, and aging effect effect are consistent with the the corresponding line of the GALL Report; however, where the GALL corresponding GALL Report recommends aa Report recommends plant specific specific program, the applicant proposed using the Buried Piping and Tank applicant has proposed Inspection Inspection Program.

The staff reviewed the Buried Piping and Tanks Inspection Program, and its evaluation Inspection Program, evaluation is documented documented in SER Section 3.0.3.2.15. The staff finds that this program will provide provide, planned inspections planned inspections within ten years from entering entering the period of extended operation extended operation opportunistic inspection unless an opportunistic ten-year period for stainless occurred within this ten-year inspection has occurred stainless material due to pitting and steel components exposed to soil for loss of material corrosion and crevice corrosion Appendix B, Buried Piping and Tanks Protection System. The LRA Appendix in Fire Protection Inspection Tanks Inspection Program is in accordance Program recommendations of GALL accordance with the recommendations GALL AMP XI.M34 "Buried Piping Piping noted that although GALL AMP XI.M34 cites applicability Inspection." The staff noted and Tanks Inspection."

components that are su~ject cOrTIPonents; stainless steel components to only steel and gray cast iron components, subject to the provisions of GALL AMP XI.M34 will also be adequately managed adequately managed for loss of .

material. The staff noted that the inspection methods used for buried cast iron, carbon steel and concrete-coated applicable to buried stainless steel as well. The staff concrete-coated steel are applicable staff buried stainless steel piping is more resistant to pitting and crevice corrosion noted that buried noted materials addressed in GALL AMP XI.M34, "Buried Piping carbon steels and other materials than carbon and Tanks Inspection," when exposed inspection of stainless steel exposed to soil and that visual inspection will detect unacceptable unacceptable loss of material.

(8)

(8) LRA Section 3.3.2.2.10 3.3.2.2.10 addresses addresses loss of material corrosion, material due to pitting and crevice corroskm, TMI-1, which is a PWR.

stating that this aging effect is not applicable to TMI-1, SRP-LR Section 3.3.2.2.10 3.3.2.2.10 states that loss of material due to pitting and crevice corrosioncorrosion may occur in stainless steel piping, piping components, and piping elements elements of the BWR BWR standby liquid control system exposed to sodium pentaborate solution.

sodium pentaborate solution.

does not have a standby PWR and does TMI-1 is a PWR liquid control system. The staff agrees standby liquid agrees that applicable to TMI-1.

this item is not applicable TMI-1.

concludes that the applicant's programs identified above, the staff concludes review of the programs Based on a review applicant's programs meet SRP-LR Section 3.3.2.2.10 criteria. For those line items that apply to LRA .

Section 3.3.2.2.10 Section 3.3.2.2.10, determines that the LRA is consistent with the GALL Report 3.3.2.2.10, the staff determines Report and that I.

effects of aging demonstrated that the effects the applicant has demonstrated aging will be adequately managed so that the the maintained consistent with the CLB during the period intended functions will be maintained intended period of extended required by 10 CFR 54.21(a)(3).

operation, as required 54.21 (a}(3).

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3.3.2.2.11 Loss of Material due to Pitting, Crevice, and Galvanic Galvanic Corrosion Corrosion 3.3.2.2.11 against The staff reviewed LRA Section 3.3.2.2.11 against the criteria criteria in SRP-LR SRP-LR Section 3.3.2.2.11.

3.3.2.2.11.

LRA Section 3.3.2.2.11 addresses loss of material material due due to pitting ,crevice, and galvanic corrosion, stating that this aging effect is not applicable TMI-1, which is a PWR.

applicable to TMI-1, SRP-LR Section 3.3.2.2.11 states that loss of material SRP-LR material due to pitting, crevice, and galvanic galvanic occur in copper corrosion may occur corrosion copper alloy piping, piping, piping components, components, and piping elements exposed to elements exposed treated water.

This item pertains pertains to loss of material in copper alloy auxiliary system components exposed to a alloy auxiliary BWR treated water environment. TMI-1 BWR TMI-1 is a PWR. The staff agreesagrees that this item is not applicable applicable TMI-1.

to TMI-1.

Based on the above, the staff concludes that SRP-LR SRP-LR Section 3.3.2.2.11 criteria do not apply.

Section 3.3.2.2.11 3.3.2.2.12 Loss of Material 3.3.2.2.12 Material due to Pitting, Crevice, and MIC MIC reviewed LRA Section The staff reviewed 3.3.2.2.12 against the criteria in SRP-LR Section 3.3.2.2.12.

Section 3.3.2.2.12 (1) LRA Section 3.3.2.2.12 states that the One-Time Section 3.3.2.2.12 One-Time Inspection Program, will be implemented Inspection Program, to verify the effectiveness Program, to manage effectiveness of the Fuel Oil Chemistry Program, manage the loss of material microbiologically-influenced corrosion of the stainless material due to pitting, crevice, and microbiologically-influenced stainless steel and copper alloy (Zn greater than 15%), 15%), piping components, and piping elements elements exposed to fuel oil in the auxiliary emergency diesel auxiliary steam system, emergency generators and diesel generators auxiliary systems, fuel oil system, and station blackout and afld ups, diesels and auxiliary systems.

The staff reviewed LRA Section 3.3.2.2.12 against the criteria in SRP-LR SRP-LR Section 3.3.2.2.12 which which states that loss of material due to pitting, pitting, crevice, and MIC could occur in stainless steel, aluminum, and copper copper alloy piping, piping components, and piping piping elements exposed Corrosion may occur at locations exposed to fuel oil. Corrosion locations where contaminants contaminants accumulate and the effectiveness accumulate chemistry control should be verified to ensure effectiveness of fuel oil chemistry ensure one-time inspection that corrosion is not occurring. A one-time inspection of selected selected components at susceptible acceptable method to ensure susceptible locations is an acceptable ensure that corrosion corrosion is not occurring occurring and that the component's intended maintained during the period intended function will be maintained period of extended extended operation.

The staff reviewed the Fuel Oil Chemistry Program and the One-Time Chemistry Program Inspection Program One-Time Inspection Program and its evaluations are documented documented in SER Sections 3.0.3.2.12 and 3.0.3.2.14 3.0.3.2.14 respectively. The staff finds that that these programs 1) provide provide for periodic sampling of of draining, cleaning and visual inspection of fuel tanks to maintain fuel oil and periodic, draining, maintain acceptable limits to preclude loss of material due to pitting and corrosion contaminants at acceptable corrosion and 2)2) will require one-time inspection inspection of select susceptible stainless steel and copper select susceptible alloy piping, piping components, piping elements to fuel oil for loss of material due to piping, piping pitting, crevice and microbiologically-influenced microbiologically-influenced corrosion effectiveness of the corrosion to verify the effectiveness the applicable auxiliary systems.

Fuel Oil Chemistry Program in applicable predicted for copper alloys applicant stated that pitting and crevice corrosion is not predicted The applicant content less than 15%

with zinc content 15% in a fuel oil environment. The staff determined determined that 3-297 3-297

additional additional information information was was required required toto complete complete its its review.

review. In In RAI RAI 3.3.2.2-1, 3.3.2.2-1, dated dated October October 16, 16, 2008, the the staff staff requested requested that that the the applicant applicant provide provide additional additional information information thatthat demonstrates demonstrates coppercopper alloys with zinc content less less than 15% 15% areare not subject subject to pitting pitting and and crevice crevice corrosion corrosion whenwhen exposed exposed to fuel oil. oil.

In its response to the In the RAI RAI dated dated November November 12, 12, 2008, the applicant applicant stated that the EPRI Report 1010639, "Non-Class Report 1010639, "Non-Class Mechanical 1 Mechanical Tools," Revision Revision 4, Appendix Appendix C, does not not predict predict pitting pitting and and crevice crevice corrosion corrosion of copper copper alloys with zinc content content less less than 15% 15% whenwhen exposed exposed to fuel oil. oil. The The staff staff noted noted that just just citing citing EPRI EPRI Report 1010639 1010639 alone does does not provide the staff provide staff with sufficient information information to complete complete its evaluation.

evaluation.

In In RAI RAI AMR-Generic-3, AMR-Generic-3, dated January 05, 2009, the staff dated January staff requested requested that the applicant applicant provide provide additional additional information information stating the the reason reason why pittingpitting and and crevice crevice corrosion corrosion are not active in copper copper alloys with zinc content less less than 15% 15% when when exposed exposed to fuel oil.

oil.

In response to the RAI dated January In its response January 12,12, 2009, the applicant stated that in order to be be consistent with corrosion corrosion of copper alloys with zinc content less than 15% 15% exposed exposed to to lubricating oil, where pitting and crevice lubricating crevice corrosion is predicted, predicted, pitting andand crevice crevice corrosion will be included mechanisms for copper alloy with zinc content included as aging mechanisms less content less than 15%15% in aa fuel oil environment.

environment.

Based on its review, the staff finds that applicant's response to RAI applicant's response RAI 3.3.2.2-1 acceptable acceptable because the changes because changes made by the applicant applicant to manage manage pitting and crevice crevice corrosion corrosion of copper alloy with zinc zinc content less than 15% 15% in aa fuel oil environment, result result in nono exception exception to the SRP-LR. The staffs concern described described in RAI 3.3.2.2-1 is resolved.

(2) 3.3.2.2.12 states that the One-Time LRA Section 3.3.2.2.12 One-Time Inspection Program, Program, will be implemented implemented effectiveness of the Lubricating Oil Analysis to verify the effectiveness Program, to manage the loss of Analysis Program,*

material due to pitting, crevice, and microbiologically-influenced microbiologically-influenced corrosion of the stainless steel piping, piping components, piping elements, heat exchanger exchanger components, components, and tanks exposed exposed to lubricating oiUn oil in the decay decay heat heat removal system, emergency emergency diesel generators generators and auxiliaries system, makeup makeup and purification purification system, reactor coolant system, and and station blackout blackout and UPS diesel generator generator system.

reviewed LRA Section 3.3.2.2.12 against the criteria in SRP-LR The staff reviewed 3.3.2.2.12 Section 3.3.2.2: 12 which states that loss of material material due to pitting, crevice, and MIC could occur in stainless steel piping, piping components, and piping elements exposed exposed to lubricating oil. The existing program relies on the periodic periodic sampling and analysis of lubricating oil to maintain contaminants lubricating contaminants within acceptable acceptable limits, thereby preserving preserving an environment that is not conducive to corrosion. The effectiveness effectiveness of the lubricating oil bil program is verified through one-time inspection inspection of selected components susceptible at susceptible locations to ensure that corrosion is not occurring and that the component's component's intended maintained during the period of extended function will be maintained extended operation.

The staff reviewed the Lubricating Oil Analysis Program and the One-Time Inspection Program and its its evaluations evaluations are documented documented in SER SER Sections 3.0.3.2.18 and 3.0.3.2.14 3.0.3.2.14 respectively. The staff finds that these programs 1) provide for periodic periodic sampling of lubricating oil to maintain contaminants at acceptable limits to preclude loss loss of material material due to pitting, crevice, and microbiologically-influenced microbiologically-influenced corrosion and 2) will require one-time inspection of select susceptible susceptible stainless steel piping, piping, piping components, and piping piping elements exposed to lubricating lubricating oil for loss of material due to pitting, crevice and 3-298

effectiveness of the Lubricating Oil microbiologically-influenced corrosion to verify the effectiveness microbiologically-influenced

. Analysis Program Program in applicable auxiliary systems. Therefore, Therefore, the staff finds that, that, based based on a review review of the programs programs identified identified above, the applicant has met the criteria criteria of SRP-LR Section 3.3.2.2.12.

(3) LRA Section 3.3.2.2.12 states that the External Surfaces Monitoring Program will be implemented to manage loss of material due to pitting, crevice, and microbiologically-influenced corrosion of the stainless steel drip pans exposed to waste lubricating lubricating oil in the the External Surfaces Monitoring Program consists of system fire protection system. The External inspections and walkdowns. This program includes periodic visual inspections of of components within the scope of license renewal and subject to AMR in order to manage manage aging effects. The program manages aging effects through visual inspection of external surfaces surfaces for evidence of aging effects. The External Surfaces Monitoring program is described described in Appendix B. B.

The staff noted that in Auxiliary System Tables 3.3.2.-2, 3.3.2-9, 3.3.2-12, and 3.3.2-24 3.3.2-24 that for copper alloy (Zn content less 15%) 15%) piping, fittings, and valves exposed exposed to a fuel oil environment, loss of material influence corrosion is managed with material due to microbiologically influence Chemistry Program and the One-Time Inspection Program. The applicant the Fuel Oil Chemistry applicant assigned a note "I" "I"for these cases although the assignment of the Fuel Oil Chemistry Program Program and the One-Time Inspection Inspection Program to manage loss of material due to MIC is accordance with GALL Report. In addition, the staff noted that loss of material due to in accordance MIC for copper alloys with zinc content less than 15% 15% is addressed 3.3.2.2.12 addressed in Section 3.3.2.2.12 of the LRA. The staff determined determined that additional information was needed to complete its its review. In RAI 3.3.2.2-1, October 16, 3.3.2.2-1, dated October 16,2008, 2008, the staff requested that the applicant applicant provide additional information justifying the use of Note "I" additional information "1"(Aging effect effect in NUREG-1 NUREG-1801 801 for this component, material material and environment environment combination is not applicable) for copper alloy (Zn content less 15%) exposed to a fuel oil environment, 15%) piping, fittings, and valves exposed environment, when loss of material due to MIC is managed with the Fuel Oil Chemistry Program and the the One-Time One-Time Inspection addressed in the GALL Inspection Program as addressed GALL Report.

In its response to the RAI dated NovemberNovember 12, 2008, the applicant statedstated that Generic Generic "I" is used for this material, component, and environment Note "I" environment because crevice because pitting and crevice component, and environment combination.

corrosion does not apply for this material, component, combination.

applicant's response to RAI 3.3.2.2-1 Based on its review, the staff finds the applicant's 3.3.2.2-1 unacceptable unacceptable because the applicant did not provide the reason why Generic because Note "I" Generic Note "I" was used for this this material, component, and material, and environment. The applicant also did not explain why pitting and The applicant corrosion does not apply crevice corrosion crevice material, component, and environment apply for this material, environment combination.

combination.

ARM-Generic-3, dated In RAI ARM-Generic-3, dated January January 5,5,2009, requested in part, that the 2009, the staff requested the applicant statestate the reasons predicted for copper corrosion is not predicted reasons why pitting and crevice corrosion copper alloys with less than 15% 15% zinc in a fuel oil environment.

response to In its response to the RAI dated January RAI dated applicant committed to manage January 12, 2009, the applicant manage pitting and crevice corrosion of copper pitting copper alloy (Zn content content less 15%) components exposed 15%) components exposed to fuel oil using using the Fuel Fuel Oil Chemistry Program and the Oil Chemistry the One-Time Inspection Program.

One-Time Inspection Program.

Based Based in its the staff finds its review, the finds the applicant's response the applicant's response to the applicable part of the applicable RAI-AMR-Generic-3 acceptable RAI-AMR-Generic-3 acceptable because because the changes made the changes applicant to manage made by the applicant manage 3-299 3-299

corrosion of copper alloy with zinc content pitting and crevice corrosion content less than 15% 15% in a fuel oil exception to the GALL environment, result in no exception concern in RAI 3.3.2.2-1 GALL report. The staff concern and the applicable part of RAI-AMR-Generic-3 RAI-AMR-Generic-3 is resolved.

addresses the loss of material due to pitting, crevice LRA Section 3.3.2.2.12 addresses crevice and microbiologically-influenced corrosion for stainless steel piping, piping components microbiologically-influenced components and and lubricating oil internally exposed to lubricating piping elements exposed reviewed LRA internally or externally. The staff reviewed SRP-LR Section 3.3.2.2.12, which states that loss 3.3.2.2.12 against the criteria in SRP-LR Section 3.3.2.2.12 loss of material due to pitting, pitting, crevice microbiologically-influenced corrosion may occur in crevice and microbiologically-influenced stainless steel piping, piping components and piping elements exposed lubricating oil exposed to lubricating internally or externally.

internally GALL Report, under The GALL under Items VII.C1-14, VII.C2-12, VII.El-15, VII.E1-15, VII.E4-12, VII.G-18 and VII.H2-17 and SRP-LR Section 3.3.2.2.12 recommends Section 3.3.2.2.12 Lubricating Oil Analysis recommends that Lubricating Analysis Program be credited to manage this aging effect plant-specific AMP be effect and that a plant-specific be evaluated and credited to verify that the Lubricating evaluated Oil Analysis Program is achieving its material due to pitting, crevice and microbiologically-manage loss of material mitigative function to manage microbiologically-corrosion for stainless steel piping, piping components. These GALL AMRs influenced corrosion AMRs acceptable AMP to credit for the verification one-time inspection program is an acceptable state that a one-time effectiveness of the Lubricating of the effectiveness applicant stated that the Lubricating Oil Analysis Program. The applicant the Inspection of Internal Internal Surfaces Miscellaneous Piping and Ducting Surfaces in Miscellaneous Components Program Ducting Components External Surfaces Monitoring Program will manage this aging effect in stainless or the External stainless internal surfaces or external surfaces, respectively, exposed steel internal exposed to lubricating lubricating oil.

The staff confirmed that only piping, fittings, drip pan, tanks and valve bodies that align to GALL AMR VII.G-18 GALL fabricated from stainless VII.G-18 for the fire protection system that are fabricated stainless steel materials that credit the Inspection of Internal materials Surfaces in Miscellaneous Internal Surfaces Miscellaneous Piping and .

Ducting Components Program or the External Ducting Components Monitoring Program are applicable Surfaces Monitoring External Surfaces applicable to TMI-1.

TMI-1.

The staff reviewed reviewed the Inspection Miscellaneous Piping and Ducting Inspection of Internal Surfaces of Miscellaneous Components Program and its evaluation Components documented in SER Section 3.0.3.2.17. The evaluation is documented The staff finds that the Inspection Internal Surfaces Inspection of Internal Miscellaneous Piping and Ducting Surfaces in Miscellaneous Components Program Components requires visual inspections Program requires internal surfaces of components inspections of internal components activities or during maintenanc~

component surveillance activities periodiC system and component during periodic maintenance activities when the internal surface becomes becomes accessible inspections to detect accessible for visual inspections effects that could result in a loss of the component's aging effects intended function. The staff component's intended staff finds that this program includes includes activities that are adequate to manage loss of material due materiial due to pitting, crevice and microbiologically-influenced corrosion microbiologically-influenced corrosion stainless steel piping, piping p'iping components and piping elements exposed components lubricating oil on the internal surface.

exposed to lubricating The staff reviewed the applicant's External Surfaces Monitoring External Surfaces Program and its Monitoring Program 3.0.3.2.16. The staff finds that the External documented in SER Section 3.0.3.2.16.

evaluation is documented Program which includes Monitoring Program Surfaces Monitoring includes periodic performed during periodic visual inspections performed auring system walkdowns, is adequate to manage loss of material crevice and material due to pitting, crevice corrosion and detect aging effects that could result in a :iloss microbiologically-influenced corrosion microbiologically-influenced loss of the component's intended function for stainless component's intended steel components exposed components exposed to external addressed by this AMR. The staff finds that this program.

lubricating oil environment addressed program adequate to manage loss of material includes activities that are adequate includes material due to pitting, crevice and MIC in stainless steel piping, components and piping elements piping, piping components elements exposed to to lubricating oil on the external lubricating external surface.

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Based on a review of the programs identified above, the staff concludes that the applicant's programs identified applicant's programs meet SRP-LR programs SRP-LR Section 3.3.2.2.12 3.3.2.2.12 criteria. For those line items that apply to LRA Section 3.3.2.2.12, the staff determines determines that the LRA is consistent with the GALL Report and that GALL Report the applicant applicant has demonstrated demonstrated that the effects effects of aging will be adequately managed so that the adequately managed the intended functions will be maintained intended maintained consistent with the CLB during the period of extended extended operation, operation, as required by 10 54.21(a)(3).

10 CFR 54.21(a}(3}.

3.3.2.2.13 Loss of Material due to Wear Wear The staff reviewed LRA Section 3.3.2.2.13 3.3.2.2.13 against the criteria in SRP-LR SRP-LR Section 3.3.2.2.13.

LRA Section 3.3.2.2.13 3.3.2.2.13 refers to LRA Table 3.3.1, 3.3.1, line item 34, and addresses loss of material due to wear for elastomer elastomer seals and components components exposed exposed to air - indoor uncontrolled uncontrolled (internal or external). The applicant applicant stated that the component, material, material, environment, and aging effect/mechanism effecUmechanism does not apply to auxiliary systems.

SRP-LR 3.3.2.2.13 states that loss of material SRP-LR Section 3.3.2.2.13 material due to wear may occur in the elastomer elastomer seals and components exposed exposed to air - indoor uncontrolled uncontrolled (internal or external). The GALL Report recommends further evaluation to ensure that the aging effect is adequately Report recommends adequately managed.

managed.

AMR-Generic-2, dated In RAI AMR-Generic-2, January 5, 2009, the staff requested dated January requested that the applicant provide applicant provide additional information to justify why LRA Table 3.3.1, Item 3.3.1-34 is not applicable.

Table 3.3.1, In its response to the RAI dated January 12, 2009, the applicant stated the item is not applicable applicable because because this component, material, environment, and aging effecUmechanism effect/mechanism combination does does not exist in auxiliary auxiliary systems. The applicant also stated that the ventilation ventilation system elastomer elastomer components components are not subject to relative motion between between surfaces and therefore therefore do not include thethe loss of material material due to wear.

Based Based on its review of the LRA, the staff confirmed confirmed that this component, material, environment, effect/mechanism combination does and aging effecUmechanism does not exist in auxiliary systems and that the the ventilation system elastomer components are not subject elastomer components subject to relative relative motion between surfaces, and, therefore, therefore, the staff finds the applicant's applicant's determination acceptable.

determination acceptable.

Based on the above, the staff concludes concludes that SRP-LR SectionSection 3.3.2.2.13 criteria do not apply.

3.3.2.2.14 Loss of Material due to Cladding Cladding Breach The staff reviewed LRA Section 3.3.2.2.14 against the criteria in SRP-LR Section 3.3.2.2.14.

LRA Section 3.3.2.2.14 refers to LRA Table 3.3.1, line item 35, and addresses loss of material Table 3.3.1, due to cladding breach breach for steel with stainless steel cladding pump casing exposed to treated borated water. The applicant stated that the component, material, environment, and aging borated effect/mechanism effecUmechanism does not apply to auxiliary auxiliary systems.

SRP-LR SRP-LR Section 3.3.2.2.14 states that loss of materialmaterial due to cladding breach (also referred to as as underclad underclad cracking may occur in PWR steel charging pump casings with stainless steel cladding steel cladding exposed to treated borated borated water. The GALL Report referencesreferences IN 94-63, 94~63, "Boric Acid Corrosion Of Charging Pump Casing Caused Caused By Cladding Cladding Cracks," and recommends further evaluation of a plant-specific AMP to ensure that the aging plant-specific aging effect is adequately adequately managed.

managed.

In RAI AMR-Generic-2, In AMR-Generic-2, dated January 5, 2009, the staff requested that the applicant dated January provide applicant provide additional information to justify why LRA Table 3.3.1, 3.3.1, Item 3.3.1-35 3.3.1-35 is not applicable.

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response to the RAI dated In its response dated January January 12, 2009, the applicant applicant stated applicable stated the item is not applicable because there are no steel with stainless steel cladding cladding pump casings exposed exposed to treated borated water in auxiliary auxiliary systems.

Based on its review of the LRA, the staff confirmed that there are no steel with stainless steel cladding pump casings exposed exposed to treated treated borated water in auxiliary auxiliary systems and, therefore, the the staff finds the applicant's determination determination acceptable.

acceptable.

Based on the above, the staff concludes that SRP-LR SRP-LR Section 3.3.2.2.14 criteria do not apply.

"

3.3.2.2.15 3.3.2.2.15 Quality Assurance Assurance for Aging Management Management of Nonsafety-Related Components Nonsafety-Related Components SER Section Section 3.0.4 provides provides the staff's staffs evaluation evaluation of the applicant's applicant's QA program.

3.3.2.3 AMR Results That 3.3.2.3 That Are Not Consistent Consistentwith or or Not Addressed Addressed in the GALL GALL Report In LRA Tables 3.3.2-1 through 3.3.2-25, the staff reviewed reviewed additional details of AMR results*for results for material, environment, AERM, AERM, and AMP combinations combinations not consistent with or not addressed; addressedl:in in the the GALL Report.

In LRA Tables 3.3.2-1 through 3.3.2-25, the applicant indicated, indicated, via Notes F through J, thatithe that!lthe combination of component component type, material, environment, and AERM does not correspond a correspond to a line line item in the GALL Report. The applicant applicant provided information concerning provided further information concerning how the aging effects effects will be managed. Note F indicates that the material managed. Specifically, Note material for the AMR line itemitem component is not evaluated evaluated in the GALL Report. Note G indicates indicates that the environment environment for the the AMR line item component component and material material is not evaluated evaluated in the GALL Report. Note H indicates that that the aging effect for the AMR line item component, material, and environment combination combination is not evaluated evaluated in the GALL GALL Report. Note I indicates indicates that the aging effect identified Report identified in the GALL Report for the line item component, material, material, and environment combination is not applicable. Note ,JJ environment combination indicates that neither neither the component component nor the material and environment environment combination combination for the line line item is evaluated evaluated in the GALL Report.

For component component type, material, and environment environment combinations not evaluated in the GALL Report, combinations r:-tot the staff reviewed the applicant's applicant's evaluation to determine whether the applicant had demonstrated demonstrated that the aging effects will be adequately adequately managed managed so that the intended intended function(s) function(s) will be be maintained consistent with the CLB during the period of extended operation.

maintained operation. The staffs staffs evaluation evaluation is discussed discussed in the following sections.

3.3.2.3.1 Auxiliary Systems - Auxiliary and Fuel Handling 3.3.2.3.1 Handling Building Ventilations Ventilations Systems -

Summary Summary of Aging Management Management Evaluation Evaluation - LRA Table 3.3.2-1 The staff staff reviewed LRA Table 3.3.2-1, which summarizes the results of AMR Table 3.3.2-1, AMR evaluations evaluations for the the auxiliary and fuel handling building ventilations systems component component groups.

In LRA Table 3.3.2-1, 3.3.2-1, the applicant applicant proposed to manage loss of preload/thermal preload/thermal effects, gasket creep, and self loosening for carbon carbon and low alloy steel mechanical mechanical closure bolting in an outdoor outdoor air (external) environment using the Bolting Integrity (external) environment Integrity Program.

Program. The AMR line items cite Generic Generic Note H, which indicates that the aging effect is not addressed addressed in the GALL ReportReport for this component, material and environment combination.

3-302 3-302

The staff reviewed the applicant's Integrity Program and its evaluation applicant's Bolting Integrity evaluation is documented documented in SER Section 3.0.3.1.3. The LRA states that this program manages the loss of material material due to general, pitting and crevice corrosion, corrosion, microbiologically-influenced microbiologically-influenced corrosion (MIC) (MIC) and loss of preload due to thermal effects, gasket creep, and self-loosening.

self-loosening. The staff found that the aging effects are managed managed through the implementation implementation of procedures procedures which follow NRC approved approved guidance.

guidance. Additionally, the LRA line item is similar to GALL GALL item VII.I-5, which VILI-5, which accounts for an air-indoor uncontrolled uncontrolled (external)

(external) environment, but not an air-outdoor air-outdoor (external) environment. This This environment environment consists of moist air, exposure to weather, precipitation, and wind. TMI-1 inspects for loss of preload using methods including inspecting for leakage indicating indicating loss of preload, preload, and for loose loose bolts. Therefore, the staff concludes concludes that the management management of loss of preload/thermal preload/thermal effects, gasket gasket creep, and self loosening for carbon and low alloy steel mechanical closure bolting in an (external) environment is acceptable.

outdoor air (external)

On the basis of its review, the staff finds that the applicant applicant has appropriately appropriately evaluated the AMR AMR results of material, environment, AERM, and AMP cqmbinations combinations not evaluated evaluated in the GALL Report. The staff finds that the applicant demonstrated that the effects of aging applicant has demonstrated aging will be be managed so that the intended function(s) adequately managed function(s) will be maintained maintained consistent consistent with the CLB for the period of extended extended operation, operation, as required by 10 CFR 54.21 (a)(3).

3.3.2.3.2 Auxiliary Systems - Auxiliary Auxiliary Steam System - Summary Summary of Aging Management Management Evaluation - LRA Table 3.3.2-2 The staff reviewed LRA Table 3.3.2-2, which summarizes the results of AMR which summarizes evaluations for the AMR evaluations the auxiliary steam system component component groups.

In LRA Table 3.3.2-2, the applicant applicant proposed proposed to manage manage loss of material material due to pitting and crevice crevice corrosion for steel material material for valve bodies exposed to an air/gas wetted internal environment environment using the Inspection Inspection of Internal Internal Surfaces in Miscellaneous Miscellaneous Piping and Ducting ComponentsComponents program. The AMR line items cite Generic Generic Note G, which indicates that the environmentenvironment is notnot addressed in the GALL Report GALL Report for this component and material combination.

material combination.

The staff reviewed the Inspection of Internal Surfaces of Miscellaneous Internal Surfaces Miscellaneous Piping and Ducting Ducting Components Program and its evaluation is documented in SER Section 3.0.3.2.17. The staff finds finds that the Inspection of Internal Internal Surfaces Surfaces in Miscellaneous Miscellaneous Piping and Ducting ComponentsComponents Program requires periodic visual inspections .of .of internal surfaces during periodic periodic system and component'surveillance component' surveillance activities, or during maintenance activities when the internal during maintenance internal surface surface is accessible accessible for visual inspections, inspections, to detect detect aging effects effects that could result in a loss of thethe component's component's intended function.

function. On the basis of its review, the staff finds that because these these components components will be inspected periodically periodically by visual inspections inspections they will be adequately managed managed by the Inspection Inspection of Miscellaneous Miscellaneous Piping and Ducting Components Components Program.

On the basis of its review, the staff finds that the applicantapplicant has appropriately appropriately evaluated evaluated the AMRAMR results of material, environment, AERM, and AMP combinations not evaluated evaluated in the GALL Report. The staff finds that the applicant has demonstrated demonstrated that the effects effects of aging will bebe .

adequately managed adequately managed so that the intended function(s) intended function(s) will be maintained consistent maintained consistent with the CLB for the period period of extended extended operation, as required required by 10 CFR 54.21(a)(3).

54.21 (a)(3).

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3.3.2.3.3 Auxiliary Systems - Circulating Water System - Summary 3.3.2.3.3 Summary of Aging Management Management Evaluation - LRA Table 3.3.2-3 summarizes the results of AMR evaluations The staff reviewed LRA Table 3.3.2-3, which summarizes evaluations for the the component groups.

circulating water system component applicant designated Note H for copper alloy heat exchanger In LRA Table 3.3.2-3, the applicant exchanger components lubricating oil environment in the circulating components exposed to a lubricating circulating water system (Table 3.3.2-

3) because the aging effect for the AMR line item component, material, and environment environment '

combination is not evaluated evaluated in the GALL Report for heat exchanger exchanger components components and the staffst~ff reviewed the GALL reviewed concluded that the AMR iine GALL Report and concluded line item, exchanger item, copper alloy heat exchanger evaluated for a lubricating components is not evaluated lubricating oil for loss of material due to pitting, crevice, microbiologically influence corrosion. The applicant microbiologically influence applicant credits the Lubricating Oil Analysis Program and the One-time One-time Inspection Program for managing loss of material due to pitting, crevice, "

Inspection Program microbiologically influence microbiologically influence corrosion. evaluated the Lubricating corrosion. The staff evaluated Analysis Progr~m Lubricating Oil Analysis Program evaluations are documented One-Time Inspection Program and its evaluations and the One-Time documented in SER Sections Sections 3.0.3.2.18 and 3.0.3.2.14, respectively.

3.0.3.2.18 programs 1) provide for periodic The staff noted that these programs periodic sampling of lubricating oil to maintain contaminants contaminants at acceptable acceptable limits to preclude loss of material pitting, crevice and material due to pitting, and microbiologically-influenced corrosion and 2) will perform microbiologically-influenced perform one-time inspection inspection of select susceptible components exposed susceptible exposed to lubricating crevice and lubricating oil for loss of material due to pitting, crevice and microbiologically-influenced corrosion to verify the effectiveness microbiologically-influenced effectiveness of the Lubricating Analysis Lubricating Oil Analysis Program. The staff noted that the one-time one-time inspection inspection is an acceptable acceptable method to determine determine whether or not loss of material occurring slowly such that the intended material is occurring intended function will bebe during the period of extended maintained during maintained operation. On this basis, the staff finds that the extended operation. the Analysis and the One-Time Lubricating Oil Analysis

. Lubricating One-Time Inspection Inspection programs are adequate adequate to manage loss of manage material microbiologically-influenced corrosion for these copper alloy material due to pitting, crevice, and microbiologically-influenced alloy components through the period of extended components extended operation.

On the basis of its review, the staff finds that the applicant evaluated the AMR applicant has appropriately evaluated AMR AERM, and AMP combinations not evaluated results of material, environment, AERM, evaluated in the GALL" GALL' demonstrated that the effects Report. The staff finds that the applicant has demonstrated effects of aging will be be adequately managed managed so that the intended function(s) function(s) will be maintained consistent with the the,CLBCLB for the period extended operation, as required by 10 CFR 54.21 (a)(3).

period of extended '

3.3.2.3.4 Auxiliary Systems - Closed Cycle Cooling Water System - Summary Summary of Aging Aging Management Evaluation Management Evaluation - LRA Table 3.3.2-43.3.2-4 .

The staff reviewed LRA Table 3.3.2-4, which summarizes the results of AMR evaluations evaluations for the the closed cycle cooling water closed water system component groups.

In LRA Table 3.3.2-4, the applicant proposed to manage manage reduction of heat transfer due to fouling for copper alloy with 15% material for heat exchanger 15% zinc or more material components exposed exchanger components exposed to an external air environment using the Inspection of external of Internal Internal Surfaces Miscellaneous Piping ~nd Surfaces in Miscellaneous and Program. The AMR line items cite Generic Ducting Components Program.

Ducting Note G, which indicates that the Generic Note addressed in the GALL Report environment is not addressed Report for this component and material combin~tion.

material combination.

Miscellaneous Piping and Ducting' Surfaces of Miscellaneous Inspection of Internal Surfaces The staff reviewed the Inspection Ducting' Components Program documented in SER Section 3.0.3.2.17. The staff finds Program and its evaluation is documented finds that the Inspection Surfaces in Miscellaneous Inspection of Internal Surfaces Miscellaneous Piping and Ducting Components Components I performs periodic Program performs periodic visual inspections inspections of internal surfaces during periodic system and internal surfaces 3-304

component component surveillance activities maintenance activities when the internal surface is activities or during maintenance accessible accessible for visual inspections inspections to detect aging effects that could result in a loss of the aging effects the component's noted that these periodic visual inspections intended function. The staff further noted component's intended inspections are adequate adequate to manage manage reduction of heat transfer due due to fouling for these components, because because aa visual inspection inspection will be capable of detecting whatever source) on the detecting any fouling (build up from whatever the internal surface components. On the surface of these components. basis of its review, the staff finds that because because components will be inspected these components inspected periodically inspections when exposed to an internal periodically by visual inspections environment of external indoor air they will be adequately managed by the Inspection of adequately managed Miscellaneous Miscellaneous Piping and Ducting Components Components Program.

Program.

In LRA Table 3.3.2-4, the applicant applicant proposed manage reduction of heat transfer due to fouling proposed to manage for copper alloy with 15%15% zinc or more material for heat exchanger components exposed to an exchanger components external external air with borated water water leakage leakage environment environment using the Inspection of Internal Surfaces in Internal Surfaces Miscellaneous Miscellaneous Piping and Ducting Components Components Program. The AMR line items cite Generic Note Note G, which indicates that the environment addressed in the GALL environment is not addressed GALL Report for this componentcomponent material combination. The staff confirmed in LRA Section 3.3, that for the same system, and material component, material environment combination, the applicant manages material and environment manages loss of materialmaterial due due to Corrosion Program," as recommend boric acid corrosion with the AMP B.2.1.4, "Boric Acid Corrosion recommend by GALL.

GALL.

Surfaces of Miscellaneous reviewed the Inspection of Internal Surfaces The staff reviewed Miscellaneous Piping and Ducting Components Program and its evaluation Components documented in SER Section 3.0.3.2.17. The staff finds evaluation is documented finds that the Inspection of Internal Surfaces Miscellaneous Piping and Ducting Components Surfaces in Miscellaneous Components program requires program requires periodic visual inspections surfaces during periodic inspections of internal surfaces periodic system and component component surveillance activities and during maintenance activities activities when the internal internal surface surface is inspections to detect aging accessible for visual inspections accessible effects that could result in a loss of the aging effects the component's intended function. The staff further noted that these periodic component's periodic visual inspections are adequate to manage reduction of heat transfer due to fouling for these components adequate components exposed exposed to to external addressed by this AMR because external air with borated water leakage addressed because a visual inspection will detecting any fouling (build up from whatever source) on the surface be capable of detecting surface of these components. On the basis of its review, the staff finds that because components will be because these components be inspected periodically inspected managed by the Inspection adequately managed periodically by visual inspections, they will be adequately Inspection of Miscellaneous Components Program.

Miscellaneous Piping and Ducting Components Program.

appropriately evaluated applicant has appropriately On the basis of its review, the staff finds that the applicant evaluated the AMR AMR results of material, environment, AERM,AERM, and AMP combinations not evaluated evaluated in the GALL demonstrated that the effects Report. The staff finds that the applicant has demonstrated aging will be effects of aging be adequately managed so that the intendedintended function(s) will be maintained consistent with the CLB CLB period of extended operation, as required by 10 CFR 54.21 (a)(3).

for the period Containment Isolation System - Summary Auxiliary Systems - Containment 3.3.2.3.5 Auxiliary Summary of Aging ManagementManagement Evaluation - LRA Table 3.3.2-5 Evaluation The staff reviewed LRA Table 3.3.2-5, which summarizes the results of AMR which summarizes AMR evaluations for the the containment isolation containment isolation system component component groups.

The staff's review did not find any line items indicating plant-specific Notes F through J whereby indicating plant-specific whereby component type, material, environment, and AERM does not correspond the combination of component correspond to a line item in the GALL Report.

3-305

evaluation of the line items with Notes A through E is documented The staff's evaluation in SER documented inSER Section 3.3.2.1.

3.3.2.1.

3.3.2.3:6 Auxiliary Ventilation System - Summary of Aging Auxiliary Systems - Control Building Ventilation Aging Evaluation - LRA Table 3.3.2-6 Management Evaluation Management reviewed LRA Table 3.3.2-6, which summarizes the results of AMR evaluations The staff reviewed evaluations for the the control building ventilation system componentcomponent groups.

In LRA Table 3.3.2-6, the applicant stated that for glass sight glasses in closed cycle cooling cooling environment there are no aging effects requiring management. The applicant referenced water environment indicating that environment is not listed in the GALL Generic Note G for this line item, indicating Generic GALL Report for for environment combination.

this component and environment indicated in the "Corrosion Handbook" by H.H.Uhlig, As indicated H.H.Uhlig, the staff noted that glass, as a material, is impervious to normal plant environments. This conclusion is based on industry impervious industry experience where where the staff noted that no failure due to an aging effect of glass components environments free of components in environments hydrofluoric acid, caustics, or hot water have been recorded hydrofluoric temperatures or during recorded in industry at temperatures concern for extended operation. The staff acknowledges time periods of concern acknowledges that the use of glass gla5's inin power plant environments is a design-driven design-driven criterion selected for the environment criterion and once selected environment will not have any significant degradation, since the closed-cycle significant age related degradation, closed-cycle cooling water environment does environment hydroflouric acid or caustics. The staff reviewed the GALL Report does not contain hydroflouric VILJ-13 indicates and noted that item VII.J-13 environment has no aging indicates that glass in a treated water environment effects that require agingaging management. On the basis that the closed cycle cooling water water environment is similar to a treated environment treated water environment, the staff finds that glass in a closed cycle cycle environment will not have any aging effects requiring aging management.

cooling water environment In LRA Table 3.3.2-6, the applicant proposed to manage reduction of heat transfer due to fouling manage reduction for copper copper alloy with less than 15% zinc material for heat exchanger components exposed to an exchanger environment using the Inspection of Internal external indoor air environment external Surfaces in Miscellaneous Internal Surfaces Miscellaneous Piping Program. The AMR line items cite Generic Components Program.

Ducting Components and Ducting Generic Note H, which indicates that the aging effect is not addressed addressed in the GALL Report Report for this component, material material andand environment combination.

environment combination.

The staff reviewed the Inspection staff reviewed Inspection of Internal Internal Surfaces Miscellaneous Piping and Ducting S!Jrfaces of Miscellaneous Ducting Components Program and its evaluation is documented Components documented in SER Section Section 3.0.3.2.17. The staff findsfinds Inspection of Internal Surfaces that the Inspection Miscellaneous Piping and Ducting Components Surfaces in Miscellaneous Components Program requires periodic visual inspections of internal surfaces during periodic system and Program surveillance activities or during component surveillance component during maintenance internal surface is maintenance activities when the internal accessible for visual inspections detect aging effects that could result in a loss of the inspections to detect the '

intended function. The staff further noted that these periodic visual inspections component's intended component's inspections areare to manage adequate manage reduction reduction of heat transfer transfer due to fouling for these components exposed to to indoor air environment environment addressed addressed by this AMR because a visual inspection will be capable capable of detecting any fouling (build up from whatever detecting whatever source) on the surface of these components. On On thethe basis of its review, the staff finds that because these components periodically by components will be inspected periodically adequately managed visual inspections, they will be adequately managed by the Inspection Miscellaneous Piping Inspection of Miscellaneous Piping and Ducting Components Components Program.

On the basis of its review, the staff finds that the applicant appropriately evaluated the AMR applicant has appropriately AMR results of material, material, environment, AERM, and AMP combinations combinations not evaluated in the GALL Report. The staff finds that the applicant demonstrated that the effects of aging applicant has demonstrated aging will bebe 3-306

adequately managed so that the intended function(s) will wi" be maintained consistent consistent with the CLB CLB for the period of extended operation, operation, as required by 10 CFR 54.21(a)(3).

3.3.2.3.7 Auxiliary Systems - Cranes and Hoists Hoists - Summary of Aging Management Management Evaluation Evaluation -

LRA Table 3.3.2-7 .

The staff reviewed reviewed LRA Table 3.3.2-7, which summarizes summarizes the results of AMR evaluations evaluations for the the component groups.

cranes and hoists component In LRA Table 3.3.2-7, the applicant proposed proposed to manage loss of material/wear material/wear for carbon steel crane/hoist (rail system) system) externally externally exposed Inspection of Overhead exposed to outdoor air using the Inspection Overhead Heavy Load and Light Load (Related (Related to Refueling) Handling Handling Systems Program. The AMR line line item cites Generic Generic Note E, which indicates indicates that the material, aging effect, and environment environment are are consistent consistent with the NUREG-1 NUREG-1801 801 however however a different different aging management program is credited.

The staff reviewed the applicant's Overhead Heavy Heavy Load and Light Load (Related(Related to Refueling)

Refueling)

Handling Program and its evaluation is document Handling Systems Program document in SER Section Section 3.0.3.2.7. The LRA program manages states that this program manages the effects of general general corrosion corrosion on the crane and trolley trolley structural components and the effects effects of wear on the rails in the rail system. Inspection frequency is annually annually for cranes and hoists that are accessibly during plant operation and every every 2 years for cranes and hoists that are only accessible during refueling outages. The staff found that the aging aging managed through the implementation effects are managed implementation of procedures procedures that follow NRC approved approved guidance, and inspected using visual techniques. Therefore, Therefore, the staff concludes concludes that the the management of loss of material/wear management material/wear for carbon crane/hoist (rail carbon steel crane/hoist (rail system) externally externally exposed to outdoor outdoor air is acceptable.

acceptable.

In LRA Table 3.3.2-7, the applicant proposed to manage loss of material/general, material/general, pitting and crevice corrosion for carbon steel crane/hoist crane/hoist (bridge/trolley/girders), crane (bridge/tro"ey/girders), crane/hoist (jib crane columns/beams/plates/anchorage), crane/hoist columns/beams/plates/anchorage), crane/hoist (monorail beams/lifting devices/plates), and (monorail beamsllifting crane/hoist (rail system) externally crane/hoist externally exposed exposed to an outdoor air environment environment using the Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems Program for 4 Refueling) Handling AMR line items. The AMR line items cite Generic Generic Note E, which indicates indicates that the material, aging effect, and environment environment are consistent NUREG-1801 however consistent with the NUREG-1801 however a different aging management program is credited.

management program The staff reviewed reviewed the applicant's applicant's Overhead Heavy Load and Light Load (Related (Related to Refueling)

Refueling)

Handling Systems Program and its evaluationevaluation is documented documented in SER Section 3.0.3.2.7. The LRA LRA states that this program manages manages the effects of general corrosion on the crane and trolley trolley structural components and the effects of wear on the rails in the rail system. Inspection structural Inspection frequency is annually cranes and hoists that are accessibly during plant operation and every annually for cranes every 2 years for cranes and hoists that are only accessible accessible during refueling refueling outages. The staff found that the aging aging effects are managed through the implementation implementation of procedures that follow NRC approved approved guidance, and inspected Additionally, these particular inspected using visual techniques. Additiona"y, particular line items items reference GALL reference VII.H1-8, which accounts GALL item V".H1-8, accounts for the same material, material, environment, environment, and aging aging effect. The aging management management program identified to manage this line item is not the "External Surfaces Monitoring Program" as specified by GALL.

Surfaces Monitoring GALL. However, the applicant has* has identified this this discrepancy discrepancy with a plant plant specific note, and the staff has evaluated evaluated the proposed Overhead Heavy Load and Light Load (Related Refueling) Handling (Related to Refueling) Handling Systems Program for aging management management adequacy as stated above. Therefore, the staff concludes adequacy concludes that the management management of loss of material/wear material/wear for carbon steel crane/hoist (rail system) externally exposed exposed to outdoor outdoor air is acceptable.

3-307

In LRA Table 3.3.2-7, the applicant applicant proposed to manage manage loss of material/general, material/general, pitting and crevice corrosion for carbon carbon and low alloy steel bolting externally exposed to an outdoor air externally air environment using the Inspection of Overhead environment Refueling)

Heavy Load and Light Load (Related to Refueling)

Overhead Heavy Handling Systems Program. The AMR line item cites Generic which indicates that th'e Note E, which Generic Note the material, aging environment are consistent with the GALL Report, however a different aging effect, and environment different aging management program is credited.

management program The staff reviewed applicant's Overhead Heavy reviewed the applicant's Heavy Load and Light Load (Related Refueling)

(Related to Refueling)

Handling Systems Program Program and its evaluation documented in SER Section evaluation is documented The LRA Section 3.0.3.2.7. The,LRA manages the effects of general corrosion on the crane and trolley I states that this program manages components and the effects of wear on the rails in the rail system. Inspection frequency structural components is annually for cranes and hoists that are accessibly during during plant operation and every 2 years for accessible during refueling cranes and hoists that are only accessible refueling outages. The staff found that the ,'agingýaging effects are managed implementation of procedures that follow NRC approved managed through the implementation approved guidance, and inspected inspected using visual techniques. Therefore, the staff concludes that the techniques. Therefore, the management management of loss of material/general, crevice corrosion for carbon and low alloy material/general, pitting and crevice alloy steel bolting externally exposed to an outdoor outdoor air environment environment is acceptable.

applicant proposed to manage In LRA Table 3.3.2-7, the applicant material/general, pitting and manage loss of material/general, exposed to indoor air and air externally exposed corrosion for carbon and low alloy steel bolting externally crevice corrosion air borated water leakage environments with borated Overhead Heavy Load and Light using the Inspection of Overhead environments using Light (Related to Refueling)

Load (Related Systems Program Handling Systems Refueling) Handling Program for 2 AMR line items. The AMR line items items cite Generic Note E, which indicates that the material, environment are material, aging effect, and environment are consistent with the GALL GALL Report, however, a different different aging management program is credited.

management program reviewed the applicant's Overhead The staff reviewed (Related to Refueling)

Heavy Load and Light Load (Related Overhead Heavy Refueling)

Handling Systems Program evaluation is document in SER Section 3.0.3.2.7.

Program and its evaluation 3.0.3.2.7. The LRA states that this program manages states manages the effects general corrosion on the crane and trolley effects of general components and the effects of wear on the rails in the rail system. Inspection frequency structural components freq~ency is annually for cranes and hoists that are accessibly during plant operation and every 2 years for for cranes accessible during refueling outages. The staff found that theý cranes and hoists that are only accessible thei aging managed through the implementation effects are managed procedures that follow NRC approved implementation of procedures approved Ii techniques. Therefore, the staff concludes inspected using visual techniques.

guidance, and inspected guidance, concludes that thethe management of loss of material/general, management material/general, pitting and and crevice crevice corrosion corrosion for carbon carbon and low alloy steel bolting externally exposed to indoor air and air with borated water leakage leakage environments is acceptable.

manage loss of material/general, applicant proposed to manage In LRA Table 3.3.2-7, the applicant material/general, pitting and crevice corrosion corrosion for carbon steel crane/hoist crane/hoist (bridge/trolley/girders), crane/hoist (jib crane (bridge/trolley/girders), crane/hoist crane columns/beams/plates/anchorage),

columns/beams/plates/anchorage), crane/hoist (monorail beams/liftingbeams/lifting devices/plates), and devices/plates), and, externally exposed to an air with borated water leakage (rail system) externally crane/hoist (rail environment leakage environmeht Inspection of Overhead using the Inspection Overhead Heavy Load and Light Load (Related Refueling) Handling (Related to Refueling) Handling Systems Program for 4 AMR line items. The AMR line items cite Generic indicates Generic Note E, which indicates that the material, aging effect, and environment environment are consistent consistent with the GALL GALL Report, however, a different different aging management management program is credited.

Overhead Heavy Load and Light Load (Related applicant's Overhead The staff reviewed the applicant's (Related to Refueling)

Refueling)

Handling Systems Program and its evaluation is documented Handling Section 3.0.3.2.7. The LRA documented in SER Section LRA effects of general program manages the effects states that that this program corrosion on the crane and trolley general corrosion structural components and the effects of wear Inspection frequency wear on the rails in the rail system. Inspection frequency 3-308

is annually annually for cranes cranes and hoists hoists that are accessibly during plant operation operation and every 2 years for cranes and and hoists hoists that are are only only accessible during during refueling outages. The staff staff found that the aging implementation of effects are managed through the implementation of procedures that that follow NRC approved guidance, and inspected using visual visual techniques. Additionally, these particularparticular line line items items reference GALL item item VII.I-4, which accounts for the same material, environment, environment, and aging effect.

management program identified The aging management identified to manage this line line item is not the External SurfacesSurfaces Monitoring Monitoring Program as specified by GALL. However, the applicant has identified identified this discrepancy with a plant specific note, and the staff has evaluated the proposed Overhead Overhead Heavy Heavy Load and (Related to Refueling) Handling Systems Program for aging management Light Load (Related management adequacy as stated above. Therefore, the staff concludes that the management of loss of material/wear material/wear for carbon steel crane/hoist (rail system) externally exposed to outdoor air is is acceptable.

In LRA Table 3.3.2-7, the applicant proposed to manage loss of material/pitting, material/pitting, crevice and microbiologically-influenced corrosion on stainless steel crane and hoist bolting microbiologically-influenced bolting externally exposed to lubricating oil using the Inspection Inspection of Overhead Heavy Heavy Load and Light Load (Related (Related to Refueling)

Refueling) Handling Handling Systems Program. The AMR line items cite Generic Generic Note G, which indicates that the environment is not addressed in the GALL Report for this component and indicates material.

The staff reviewed the applicant's Overhead Heavy Load and Light Load (Related to Refueling) Refueling)

Handling Systems Program Handling Program and its evaluation is documented in SER Section 3.0.3.2.7. The LRA states that this program manages the effects of general corrosion on the crane and trolley structural components components and the effects of wear on the rails in the rail system. Inspection Inspection frequency is annually for cranes and hoists that are accessibly during plant operation and every 2 years for cranes and hoists that are only accessible accessible during refueling outages. The staff found that the aging effects are managed through implementation of procedures through the implementation procedures which follow NRC approved guidance, and inspected inspected using visual techniques. Therefore,Therefore, the staff concludes concludes that the the management of loss of material/pitting, management material/pitting, crevice and microbiologically-influenced microbiologically-influenced corrosion on stainless steel crane and hoist bolting externally exposed to lubricating oil is acceptable.

In LRA Table 3.3.2-7, the applicant proposed to manage manage loss of preload/thermal preload/thermal effects, gasket creep, and self-loosening self-loosening of stainless steel crane and hoist bolting externally externally exposed exposed to to lubricating lubricating oil using the Inspection Inspection of Overhead Overhead Heavy Load and Light Load (Related (Related to Refueling)

Refueling)

Handling Systems Program.

Program. The AMR line items cite Generic Generic Note Note G, which indicates indicates that the the environment is not addressed environment addressed in the GALL Report Report for this component and material.

The staff reviewed applicant's Overhead reviewed the applicant's Overhead Heavy Heavy Load and and Light (Related to Refueling)

Light Load (Related Refueling)

Handling Systems Program Handling Systems Program and and its evaluation is documented evaluation documented in SER Section 3.0.3.2.7.

Section 3.0.3.2.7. The staff staff verified that the Inspection Inspection of Overhead Heavy Overhead Heavy Load Load And Light Load (Related To Refueling)

Refueling)

Handling Systems Handling Program states Systems Program states the following: Structural monitored for loss of preload Structural bolting is mOr:litored preload by inspecting inspecting for loose loose or missing bolts, or nuts. The staff determined determined that the method method for inspecting for loss loss of preload preload specified specified by the Inspection Inspection Of Overhead Overhead HeavyHeavy Load And Light Light (Related To Refueling)

Load (Related Refueling) Handling Handling Systems Systems Program is not affected affected by a lubricating lubricating oil environment.

environment. Therefore, Therefore, the staff concludes concludes thatthat the management management of of loss of preload/thermal preload/thermal effects, gasket gasket creep, and self-loosening and self-loosening of stainless steel stainless steel crane and hoist bolting bolting externally externally exposed exposed to to lubricating lubricating oil oil is acceptable.

In In LRA Table Table 3.3.2-7, 3.3.2-7, the applicant applicant proposed manage loss proposed to manage loss of preload/self-loosening preload/self-loosening for carbon and and low low alloy steel steel crane and hoist boltingbolting externally exposed to outdoor externally exposed outdoor air using the Inspection Inspection of of Overhead Heavy Load and Overhead Heavy and Light Light Load (Related (Related to Refueling)

Refueling) Handling Handling Systems Program.Program. The The 3-309 3-309

AMR AMR line line items items cite cite Generic Generic Note Note H, which which indicates indicates that that the the aging aging effect effect is is not not addressed addressed in in the the GALL ReportReport for this component, component, material material and environment environment combination.

combination.

The The staff staff reviewed reviewed thethe applicant's applicant's Overhead Overhead HeavyHeavy Load and Light Load Load (Related (Related to to Refueling)

Refueling)

Handling Handling Systems Program as documented Systems Program documented in SER Section Section 3.0.3.2.7. The staff verified that that AMPAMP B.2.1.11 specifically 8.2.1.11 specifically states states that: "Structural bolting is monitored monitored for loss of preload preload by inspecting inspecting for loose loose or missing bolts, or or nuts." The staff staff determined determined that that the method method for inspecting inspecting for loss of of preload preload specified specified by AMP B.2.1.11 8.2.1.11 is adequate adequate for this component, component, material and environment environment combination. Therefore, the staff concludes that the management combination. management of loss of preload/self-loosening preload/self-loosening for carbon carbon and low alloy steel crane crane and and hoist bolting bolting externally externally exposed exposed to outdoor outdoor air is I acceptable.

acceptable. '

In LRA LRA TableTable 3.3.2-7, the applicant applicant proposed proposed to manage manage loss of preload/self preload/self loosening loosening for carbon carbon and and low low alloy steel cranecrane and hoist hoist bolting externally exposed bolting externally exposed to indoor air air using using the Inspection Inspection of Overhead Overhead Heavy Load and Light Load Refueling) Handling Load (Related to Refueling) Handling Systems Program.Program. The The AMR line line items cite Generic Generic Note Note I,I, which indicates indicates that the aging effect identified in the GALL effect identified Report for this component, material material and environment combination and environment combination is not applicable.

applicable.

The staff staff reviewed the applicant's Overhead Heavy Load and Light Load (Related applicant's Overhead (Related to Refueling)

Refueling)

Handling Systems Handling Systems Program Program and its evaluation is documented evaluation documented in SER Section Section 3.0.3.2.7. The 3.0.3.2.7. Th~ staff staff verified that the Inspection Of Overhead Overhead Heavy Heavy Load And Light Load (Related (Related To Refueling)

'Refueling)

Handling Systems Program states the following:

Handling following: Structural monitored for loss of preload Structural bolting is monitored preload by inspecting inspecting for loose or missing missing bolts, or nuts. The staff staff determined determined that the method method for inspecting inspecting for loss loss of preload specified by the Inspection preload specified Inspection Of Overhead Overhead Heavy Load And Light Light (Related To Refueling)

Load (Related Refueling) Handling Handling Systems Program Program is adequate adequate for this component, material and environment environment combination. Therefore, the staff concludes that the management management of loss of preload/self loosening for carbon and low alloy steel crane and hoist bolting externally preload/self exposed to externally exposed indoor air is acceptable.

acceptable.

In LRA Table 3.3.2-7, the applicant proposed proposed to managemanage loss of preload/self preload/self loosening for carbon and low alloy steel crane crane and hoist bolting externally externally exposed to air with borated water leakage water leakage using the Inspection Inspection of Overhead Overhead Heavy Heavy Load and Light Load (Related to Refueling) Refueling) Handling Handlihg ,

Systems Program. The AMR line items cite Generic Generic Note I,I, which indicates indicates that the aging effect effect identified in the GALL Report identified Report for this component, material material and combination is not environment combination and environment applicable. I The staff reviewed the applicant's applicant's Overhead Heavy Load and Light Load (Related to Refueling) Refueling)

Handling Systems Program and its' its evaluation is documented documented in SER Section 3.0.3.2.7. The staff staff verified that the Inspection Of Overhead Heavy Load And Light Load (Related To Refueling) Refueling)

Handling Systems Program specifically states the following: Structural bolting is monitored for for loss of preload by inspecting for loose or missing bolts, or nuts. The staff determined determined that the the method for inspecting for loss of preload preload specified by the InspectionInspection Of Overhead Overhead Heavy Load Load And Light Load (Related To Refueling) Refueling) Handling Handling Systems Program is adequate for this this component, material material and environment combination. Therefore, the staff concludes that the management of loss of preload/self management preload/self loosening for carbon and and low alloy steel crane and hoist bolting externally exposed to air with borated water leakage is acceptable.

On the basisbasis of its review, review, the staff finds that the applicant has appropriately evaluated the AMR AMR results of material, environment, AERM, AERM, and AMP combinations not evaluated in the GALL.

GALL Report. The staff finds that the applicant has demonstrated that the effects of aging will be 3-310 3-310

adequately managed so that the intended function(s) will adequately will be be maintained maintained consistent consistent with the CLB for the period of of extended operation, as required by 10 10 CFR CFR 54.21 (a)(3).

54.21(a)(3).

3.3.2.3.8 Auxiliary 3.3.2.3.8 Auxiliary Systems -- Diesel Generator Generator Building Ventilation System - Summary Summary of AgingAging Management Evaluation - LRA Table 3.3.2-8 Management The staff reviewed LRA Table 3.3.2-8, which summarizes the results of AMR evaluations evaluations for the diesel generator building ventilation system component groups.

The staffs review did not find any line items indicating plant-specific plant-specific Notes F through J whereby combination of component the combination component type, material, environment, and AERM does not not correspond to a GALL Report.

line item in the GALL The staffs evaluation of the line items with Notes Notes A through E is is documented documented in SER Section 3.3.2.1.

3.3.2.1.

3.3.2.3.9 Auxiliary Systems - Emergency Diesel Generators Generators and Auxiliary Systems - Summary of Aging Management Management Evaluation - LRA Table 3.3.2-9 The staff reviewed LRA Table 3.3.2-9, which summarizes the results of AMR evaluations evaluations for thethe emergency diesel generators and auxiliary auxiliary systems component component groups.

In LRA Table 3.3.2-9, the applicant proposed proposed to manage reduction of heat transfer due to fouling for copper alloy with 15% 15% zinc or more material for heat exchanger exchanger components exposed exposed to an external external indoor indoor air environment using using the Inspection of Internal Surfaces in MiscellaneousMiscellaneous Piping and Ducting Components program. The AMR line items cite Generic Note H, which indicates indicates that the aging effect aging effect is not addressed addressed in the GALL Report for this component, material and environment combination.

environment combination.

The staff reviewed reviewed the Inspection Inspection of Internal Surfaces Miscellaneous Piping and Ducting Surfaces of Miscellaneous Components Program Components Program and its evaluation documented in SER Section 3.0.3.2.17. The staff finds evaluation is documented finds that the Inspection Inspection of Internal Internal Surfaces Miscellaneous Piping and Ducting Components Surfaces in Miscellaneous Components Program requires periodic visual inspections inspections of internal surfaces surfaces during periodic periodic system and component component surveillance activities and during surveillance activities maintenance activities when the internal surface is during maintenance accessible accessible for visual inspections to detect visual inspections detect aging aging effects effects that could result in a loss of the the component's component's intended intended function.

function. The staffstaff further noted that these these periodic visual inspections are visual inspections are adequate adequate to manage manage reduction reduction of heat transfer due to fouling fouling for these components components exposed to external indoor air environment external indoor environment addressed by this AMR because because a visual inspection inspection will be be capable of detecting detecting any fouling (build up from whatever whatever source) source) on the surface these surface of these components. On the basis of its review, the staff finds that because because these components components will be be inspected periodically inspected periodically by visual inspections, they will be adequately managed adequately managed by the Inspection Inspection of Miscellaneous Miscellaneous PipingPiping and Ducting Components Program.

Components Program.

The staff reviewed reviewed LRA LRA Table 3.3.2-9, 3.3.2-9, which which summarizes summarizes the results of AMRs AMRs for the emergency emergency diesel diesel generator generator and auxiliary auxiliary system system component component groups. In LRA Table Table 3.3.2-9, the applicant applicant stated stated that that for glass glass sight glasses glasses in in aa closed cycle cycle cooling cooling water water environment environment there are no no aging aging effects effects requiring requiring management.

management. The The applicant referenced footnote applicant referenced footnote "G" lOG" for this line line item item indicating indicating that environment environment is not listed in the GALL Report Report for this component component and environment environment combination.

combination.

3-311 3-311

As indicated indicated in "Corrosion Handbook" by H.H.Uhlig, the staff noted noted that glass as a material material is normal plant environments.

impervious to normal environments. This conclusion experience where industry experience conclusion is based on industry where noted that no failure due to an aging effect of glass components in environments the staff noted environments free of hydrofluoric acid, caustics, or hot water have been recorded hydrofluoric temperatures or dlJring recorded in industry at temperatures during concern for extended operation.

time periods of concern acknowledges that the use of glass in operation. The staff acknowledges power power plant environments design-driven criterion and once selected environments is a design-driven selected for the environment environment will not have significant age related degradation, have any significant degradation, since closed-cycle environment closed-cycle cooling water environment hydroflouric acid or caustics. The staff reviewed the GALL does not contain hydroflouric GALL Report and noted that that item VII.J-13 indicates that glass in a treated VII,J-13 indicates treated water environment requires environment has no aging effects that requires aging management. On the basis that a closed cycle cooling water environment environment is similar to a water environment, the staff finds that glass in closed cycle cooling treated water environment will COOling water environment requiring aging not have any aging effects requiring management.

aging management.

proposed to manage In LRA Table 3.3.2-9, the applicant proposed manage loss of preload/thermal preload/thermal effects, gasket creep, and self loosening for carbon and low alloy steel mechanical closure closure bolting in an outdoor outdoor air (external)

(external) environment environment using the Bolting Integrity Program. The AMR line items cite Generic Integrity Program. Generic Note H,H, which indicates addressed in the GALL Report for this effect is not addressed indicates that the aging effect this material and environment combination.

component, material combination.

Program and its evaluation is documented Integrity Program applicant's Bolting Integrity The staff reviewed the applicant's documented in SER Section 3.0.3.1.3. The LRA states manages the loss of material states that this program manages material due to general, pitting and crevice corrosion, MIC and loss of preload due to thermal effects, gasket

general, creep, and self-loosening. The staff found that the aging effects effects are managed managed through through the the procedures that follow NRC approved implementation of procedures implementation approved guidance. Additionally, the LRA line item item similar to GALL item VII.1-5, is similar VII.I-5, which accounts for an air-indoor uncontrolled uncontrolled (external) .

(external) environment.

environment, but not an air- outdoor (external) environment consists environment. This environment consists of moist moist precipitation, and wind. TMI-1 inspects for loss of preload using air, exposure to weather, precipitation, using methods indicating loss of preload, and for loose bolts. The staff including inspecting for leakage indicating methods including staff concludes that the management concludes management of loss of preload/thermal preload/thermal effects, gasket creep, and self mechanical closure bolting in an outdoor air (external) loosening for carbon and low alloy steel mechanical (external) environment environment is acceptable.

Generic Note H for copper alloy heat exchanger deSignated Generic 3.3.2-9 the applicant designated In LRA Table 3.3.2-9 exchanger lubricating oil environment components exposed to a lubricating components environment in the emergency diesel generators and emergency diesel auxiliary systems because the aging auxiliary effect for th~

aging effect the AMR line item component, material, and environment combination environment evaluated in the GALL Report combination is not evaluated Report for heat exchanger components.

reviewed the GALL Report The staff reviewed Report and finds that the AMR AMR line item for copper alloy heat exchanger components that are exposed to a lubricating exchanger environment are not evaluated for lubricating oil environment f9r loss of material due material due to pitting, crevice, microbiologically microbiologically influence corrosion Generic Note corrosion and that Generi~ Note H is appropriate. credits the Lubricating applicant credits appropriate. The applicant Program and the One-time Lubricating Oil Analysis Program One-time Inspection Program Program for managing material due to pitting, crevice, and MIC.

managing loss of material Lubricating Oil Analysis Program and the One-time The staff reviewed the Lubricating Inspection Program One-time Inspection and its evaluations documented in SER Sections 3.0.3.2.18 and 3.0.3.2.14, respectivelyl evaluations are documented respectively. The The staff noted that these programs 1) provide lubricating oil to maintain' provide for periodic sampling of lubricating maintain contaminants acceptable limits to preclude loss of material contaminants at acceptable material due due to pitting, crevice andand microbiologically-influenced corrosion microbiologically-influenced corrosion and 2) will require one-time inspection inspection of select susceptible select susceptible components lubricating oil for loss of material due to pitting, crevice components exposed to lubricating crevice and microbiologically-influenced corrosion microbiologically-influenced effectiveness of the Lubricating corrosion to verify the effectiveness Lubricating Oil Analysis Analysis .

Program. The staff noted that the one-time Program. one-time inspection is an acceptable determine acceptable method to determine whether or not loss of material occurring slowly such that the intended function will be material is occurring be 3-312 3-312

maintained maintained during the period of extended extended operation. On this basis, the staff finds that the the Lubricating Lubricating Oil Analysis and the One-Time InspectionInspection programs programs are adequate to manage manage loss of material material due to pitting, crevice, and microbiologically-influenced microbiologically-influenced corrosion corrosion for these copper copper alloy components components through the period of extended operation. operation.

On the basis of its review, the staff finds that the applicant has appropriately appropriately evaluated the AMR AMR results of material, material, environment, AERM, and AMP combinations combinations not evaluated in the GALL Report. The staff finds that the applicant applicant has demonstrated demonstrated that the effectseffects of aging aging will be be adequately managed so that the intended adequately intended function(s) function(s) will be maintained maintained consistent consistent with the CLB for the period of extended extended operation, operation, as required by 10 10 CFR 54.21(a)(3).

54.21(a)(3),

3.3.2.3.10 Auxiliary Systems - Fire Protection System - Summary Summary of Aging Management Management Evaluation - LRA Table 3.3.2-10 Table 3.3.2-10 The staff reviewed reviewed LRA Table 3.3.2-10, which summarizessummarizes the results of AMRs for the fire fire protection system component groups.

In LRA Table Table 3.3.2-10, the applicant proposed to manage applicant proposed material due to manage loss of material microbiologically-influenced corrosion and fouling of aluminum alloy water motor alarm in an microbiologically-influenced environment environment of raw water by using the Fire Water Water System Program. The applicant referenced referenced "H" for this line item indicating that aging effect is not in the GALL footnote "H" GALL Report for this this component, material and environment combination.

environment combination.

The staff reviewed the Fire WaterWater System Program, Program, which manages identifiedidentified aging effects for water-based fire protection the water-based protection system and associated associated components, through the use of periodic periodic inspections, monitoring, and performance inspections, monitoring, performance testing, and finds that itit is consistent with the GALL AMP XI.M27, XI,M27, "Fire Water System." The staff reviewed the Fire Water System Program Program and its evaluation is documented documented in SER Section Section 3.0.3.2.10. On the basis that periodic inspection and periodic inspection monitoring monitoring and testing will be performed, performed, the staff finds that the Fire Water System program program will adequately adequately manage loss of material due to microbiologically-influenced microbiologically-influenced corrosion and fouling of aluminum aluminum piping components components exposed to raw water in the fire protection protection system through the the period of extended operation.

In LRA Table Table 3.3.2-10, the applicant proposed to manage manage change in material properties, loss of material material and cracking cracking of mecatiss and thermo-lag material material fire barriers in air-indoor air-indoor and air with borated borated water leakage leakage external environments environments by using the Fire Protection program.

program. The applicant referenced footnote "F" indicating referenced indicating the material is not in the GALL Report.

The staff reviewed the Fire Protection Protection Program, which provides for periodic visual inspection of fire barrier penetration seals, fire barrier barrier walls, ceilings and floors, and manages the aging effects effects of change change in material material properties, cracking, hardening hardening and loss of material.

material. The staff staff noted that thethe Fire Protection Program is consistent with the GALL Protection Program GALL AMP XI,M26, XI.M26, "Fire Protection," which recommends visual inspection of fire barriers at least least once every refueling outage by qualifiedqualified inspectors. The staff reviewed the Fire Protection Program Protection Program and its evaluation is documented evaluation documented in in SER Section Section 3.0.3.2.9. Based on this review, the staff finds that the Fire Protection program will adequately manage change in material properties, loss of material and cracking adequately barriers in cracking in fire barriers the fire protection system through the period of extended extended operation inspection is operation because periodic inspection performed degradation before loss of intended performed to detect any signs of degradation intended function.

function.

In LRA Table 3.3.2-10, the applicant applicant proposed manage concrete proposed to manage concrete cracking and spalling and loss loss concrete fire walls and slabs in an air with borated of material of concrete borated water water leakage environment by 3-313 3-313

using the Fire Protection Program.

Program. The applicant referenced footnote "G" and plant-specific applicant referenced plant-specific" footnote 18, indicating indicating that this environment environment is not listed in the GALL Report Report for this material material and applicant also stated that concrete component. The applicant barriers (walls and slabs) with concrete fire barriers environment of air with borated water leakage have the same aging effects environment effects and mechanisms, and managed with the same are managed same programs as air-indoor.

reviewed the Fire Protection The staff reviewed Protection Program, provides for periodic visual inspection of Program, which provides penetration seals; fire barrier walls, ceilings and floors. The staff noted that the Fire fire barrier penetration Fire Protection Program Protection consistent with the GALL AMP XI.M26, Program is consistent XI.M26, "Fire Protection," which recommends inspection of fire barriers recommends visual inspection once every refueling barriers at least onGe refueling outage qualified outage by qualified degradation such as inspectors for any sign of degradation as concrete concrete cracking, spalling, and loss of material cracking, spalling, caused by freeze-thaw, chemical attack, and reaction with aggregates. The staff reviewed the Fire Fire Protection program Protection program and its evaluation evaluation is documented documented in SER Section 3.0.3.2.9. Based on this this review, the staff finds that the Fire Protection adequately manage Protection program will adequately change in material manage change properties, loss of material barriers in the fire protection system through the material and cracking in fire barriers the period of extended inspection is performed to detect any signs of operation because periodic inspection extended operation degradation before loss of intended function.

degradation before function.

In LRA Table 3.3.2-10, the applicant polymer piping and fittings in air-indoor applicant stated that for polymer air-indoor external and air/gas - wetted internal environments, there are no aging effects requiring external management. The applicant referenced footnote "F" stating that this material applicant referenced material is not listed in the the GALL Report.

3.3.2.3-1, dated October 16, 2008, the staff requested that the applicant provide In RAI 3.3.2.3-1, provide additional information identifying polymer material is used and to justify why there are no aging identifying what polymer effects aging effects management for this material.

requiring management '

response to the RAI dated In its response November 12, dated November 12, 2008, the applicant stated the following:

The polymer piping and fitting component used in the fire protection protection system is Nylon 11 11 polyamide material with inside the Control Building. Nylon 11 is aa polyamide tubing and it is located inside resistance to acids, including boric acid. ItIt is heat and light stabilized with a excellent resistance maximum operating temperature of 70°C operating temperature 70 0C (158 OF). Nylon 11 is resistant to moisture, (158 °F).

cracking, and has good flexibility. The design temperature in the corrosion and stress cracking, the Control Building Building is 80 °F OF and the radiation level is negligible. Therefore, there are no aging effects that would result from the Nylon effects Nylon 11 tubing contacting the air-indoor and air/gas air/gas Control Building.

environments inside the Control.Building.

environments applicant's response and noted that Nylon 11 reviewed the applicant's The staff reviewed material is highly resistant to 11 material withstand temperatures from -40 OF to 200 OF. The staff acknowledges corrosion and can withstand acknowledges that the the use of Nylon 11 material for flexible tubing in power plant environments environments is a design-driven design-driven '

once selected for the environment will not have any significant age related criterion and once degradation. On the basis that the Nylon 11 tubing is located in the Control Building in an :'

environment that does not exceed 80 OF and a non-radioactive atmosphere, the staff finds that non-radioactive atmosphere, Nylon 11 tubing will not have any aging effects requiring management in air-indoor requiring management air/gas air-indoor and air/gas protection system.

environments in the fire protection environments applicant's response to RAI 3.3.2.3-1 Based on its review, the staff finds the applicant's 3.3.2.3-1 acceptable because acceptable because material for flexible tubing in power plant environments Nylon 11 material the use of Nylon design-driven environments is a design-driven environment will not have any criterion and once selected for the environment criterion significant age related any significant degradation degradation and because because the Nylon 11 tubing is located located in the Control Building in an environment Control environment 3-314 3-314

that does not exceed exceed 80 of °F and aa non-radioactive non-radioactive atmosphere, and therefore, there will be no no aging effects requiring management management in air-indoor air-indoor and air/gas air/gas environments environments in the fire protection protection system. The staff's staffs concern concern described described in RAI 3.3.2.3-1 is resolved.

On the basis of its review, the staff finds that the applicant applicant has appropriately appropriately evaluated evaluated the AMR AMR results of material, environment, environment, AERM, AERM, and AMP combinations not evaluated evaluated in the GALL Report. The staff finds that the applicant has demonstrated demonstrated that the effects of aging will be be adequately adequately managed managed so that the intended intended function(s) maintained consistent with the CLB function(s) will be maintained CLB extended operation, as required by 10 CFR 54.21(a)(3).

for the period of extended 54.21(a}(3).

In LRA Table 3.3.2-10, the applicant proposed to manage loss of material due to pitting and applicant proposed crevice corrosion for aluminum alloy material material for water motor alarms exposed exposed to an air with borated water leakage leakage (external) environment using the External Surfaces (external) environment Surfaces Monitoring Monitoring Program.

The AMR line items cite Generic Generic Note H, which indicates indicates that the aging aging effect is not addressed addressed in in the GALL GALL Report for this component, material and environment combination. combination.

The staff confirmed for these AMR line items in LRA Table Table 3.2.2-10, in which the applicant applicant listed the environment environment as air with borated water leakage, that for the same system, component, material and environment environment combination, the applicant applicant manages loss of material material due to boric acid corrosion with the "Boric Acid Corrosion Corrosion Program," as recommend recommend by GALL. The staff reviewed the the applicant's applicant's External Surfaces Monitoring Program and its evaluation is documented Surfaces Monitoring documented in SER Sections determined that the External Surfaces Sections 3.0.3.2.16. The staff determined Monitoring Program which Surfaces Monitoring includes includes periodic visual inspections inspections of external external surfaces performed performed during system walkdowns, are adequate adequate to manage loss of material due to general, pitting and crevice corrosion for aluminum aluminum alloy components components exposed to air with borated water leakage environment environment addressed by this AMR.

On the basis of periodic periodic visual inspections inspections being performed performed during system system walkdowns walkdowns of these components components by the External Surfaces Monitoring Monitoring Program, and the applicant applicant monitoring these monitoring these components components with the Boric Acid Corrosion Program, for loss of material due to boric acid acid corrosion, corrosion, the staff finds the applicant's use of the External Surfaces Monitoring Program Surfaces Monitoring acceptable.

acceptable.

In LRA Table 3.3.2-10, the applicant applicant proposed proposed to manage loss of material/general, material/general, pitting and crevice corrosion, 1055 loss of material/microbiologically-influenced material/microbiologically-influenced corrosion, corrosion, and 1055loss of preload/thermal effects, preload/thermal effects, gasketgasket creep, and self loosening for carbon and low alloy steel and ductile cast iron mechanical mechanical closure closure bolting in a soil (external) environment using the Bolting Bolting Integrity Integrity Program Program for six line items. The AMR line items cite Generic Generic Note G, which indicates indicates that the environment environment is not addressed addressed in the GALL GALL Report for this component component and material.

The staff reviewed the applicant's applicant's Bolting Integrity Integrity Program Program and its evaluation documented in evaluation is documented SER SER Section 3.0.3.1.3. The LRA states that this program manages the loss of material material due to

general, general, pitting and crevice crevice corrosion, MIC, MIC, and loss of preload preload due to thermal effects, gasket creep, and self-loosening.

self-loosening. The staff found that the aging effects are managed managed through the the implementation implementation of procedures procedures which follow NRC approved guidance. Additionally, this this environment consists of a mixture environment inorganic materials mixture of inorganic materials produced produced by the weathering weathering of rocks and clays, and organic material material produced produced by the decomposition decomposition of vegetation.

vegetation. Water content, pH, ion ion exchange capacity, density, and permeability exchange permeability of the soil can affect degradation kinetics. TMI affect degradation inspects for loss of preload preload using methods including inspecting inspecting for leakage leakage indicating indicating loss of of preload, and for loose bolts, MIC and loss of material material are also managed by the Bolting Integrity Integrity Program at a frequency defined by ASME B&PV Code,Section XI, Table IWB Program 2500-1, IWC 2500-IWB 2500-1, 1, and IWD 2500-1.

2500-1. Therefore, the staff concludes concludes that the management management of loss of material due to 3-315 3-315

general, pitting and crevice corrosion, microbiologically-influenced microbiologically-influenced corrosion and loss of preload preload due to thermal effects, gasket gasket creep, and self-loosening of carbon and low alloy steel bolting and mechanical closure bolting externally ductile cast iron mechanical externally exposed environment is acceptable.

exposed to soil environment acceptable.

In LRA Table 3.3.2-10, the applicant proposed to manage loss of preload/thermal applicant proposed preload/thermal effects, gasket creep, and self loosening loosening for carbon and low alloy steel and ductileductile cast iron mechanical closure mechanical closure bolting in an outdoor outdoor air (external) environment (external) environment using the Bolting Integrity Program Integrity Program for two line line items. The AMR line items cite GenericGeneric Note H, H, which indicates indicates that the aging effect effect is not addressed addressed in the GALL Report for this component, material material and environment environment combination.

The staff reviewed the applicant's applicant's Bolting Integrity Program and its evaluation Integrity Program evaluation is documented in in SER Section Section 3.0.3.1.3. The LRA states that this program manages manages the loss of material due to general, pitting and crevice crevice corrosion, MIC and loss of preload preload due to thermal thermal effects, gasket creep, and self-loosening. The staff found that the aging effects are managed through the the implementation of procedures that follow NRC approved guidance. Additionally, implementation Additionally, the LRA lineline items are similar Similar to GALL Items VIII.H-4, VIII.H-4, and VIII.H-5, VIII.H-5, which accounts accounts for an air-indoor air-indoor uncontrolled (external) uncontrolled (external) environment, but not an air-outdoor air-outdoor (external) environment. This This environment consists of moist air, exposureexposure to weather, precipitation, and wind. TMI-1 inspects for loss of preload using methods including inspecting for leakage indicating loss of preload, and for for loose bolts. The staff concludes that the management management of loss of preload/thermal preload/thermal effects, gasket gasket creep, and self loosening for carbon and low alloy steel and ductile cast iron mechanicalmechanical clo.sure closure bolting in an outdoor air (external)

(external) environment environment is acceptable.

acceptable.

In LRA Table 3.3.2-10 3.3.2-10 the applicant applicant designated Note Note H for stainless steel piping and fittings fittings exposed exposed to a soil (external) environment in the fire protection (external) environment protection system because the aging effect for the AMR line item component, material, and environment combination is not evaluated in the the GALL GALL Report. The staff reviewed the GALL Report Report and concluded concluded that the AMR AMR line item, piping piping and fittings is not evaluated evaluated for a soil (external) environment (external) environment for loss of material material due to MIC. The The applicant Inspection Program applicant credits the Buried Piping and Tanks Inspection Program for managing loss of material due MIC.

The staff reviewed the BuriedBuried Piping and Tanks Tanks Inspection Program and its evaluation evaluation is documented documented in SER Section 3.0.3.2.15. It was noted noted by the staff that this program program provides for opportunistic opportunistic and focused excavations excavations of stainless steel piping and fittings during the last ten years of the current license period and within ten years of the commencement commencement of the period period of Inspection of the exposed extended operation. Inspection exposed piping will determine ifif microbiologically-influenced microbiologically-influenced material. Unacceptable corrosion is causing loss of material. Unacceptable degradation degradation will be corrected corrected through the the applicant's Corrective Action Program. The staff concluded that loss of material due to applicant's microbiologically-influenced corrosion will be adequately microbiologically-influenced adequately managed managed through the period of extended operation because piping will be subject to inspection operation inspection that will detect loss of material material such that unacceptable degradation any unacceptable degradation will be corrected.

On the baSis basis of its review, the staff finds that the applicant has appropriately appropriately evaluated evaluated the AMR AMR results of material, environment, AERM, and AMP combinationscombinations not evaluated evaluated in the GALL Report. The staff finds that the applicant has demonstrated demonstrated that the effects effects of aging aging will bebe adequately adequately managed so that the intended intended function(s) will be maintained maintained consistent with the CLB CLB .

for the period of extended operation, operation, as required by 10 CFR 54.21(a)(3). .

3-316 3-316

3.3.2.3.11 Auxiliary Systems Systems - Fuel Handling Handling and Fuel Storage Storage System - SummarySummary of Aging Aging Management Management EvaluationEvaluation - LRA Table 3.3.2-11 3.3.2-11 The staff The reviewed LRA staff reviewed LRA Table Table 3.3.2-11, which summarizes 3.3.2-11, which summarizes the the results of AMR evaluations evaluations for the the fuel handling handling and fuel storage system component component groups.

In LRA Table 3.3.2-11, applicant stated that for Tygon 3.3.2-11, the applicant Tygon hoses in air with borated water external external and treated water internal treated water internal environments, there are no aging effects requiring requiring management. The applicant referenced footnote "F" stating that this material is not listed listed in the the GALL GALL Report for this environment.

In RAI 3.3.2.3-1, 3.3.2.3-1, dated October 16, 2008, the staff requested requested that the applicant applicant provide additional information to justify why there are no aging effects requiring management information management for Tygon material.

In its response to the RAI dated November 12, 2008, dated November applicant stated the following:

2008 , the applicant The Tygon tubing is used inside the Auxiliary Building as a sight hose for the fuel transfer tube drain line. Tygon Tygon tubing is made from PVC and itit has excellent excellent chemical resistance resistance to water water and to acids, including boric acid. Tygon tubing has a maximum recommended recommended operating temperature operating temperature of 165 OF of and has a radiation radiation damage threshold of 5 x 105 rads. The damage threshold The design temperature design temperature for the Auxiliary Auxiliary Building is 104 104 OF of and the maximum maximum radiation level at the service service location location is 1.31.3 x 1044 rads in 60 years. Therefore, Therefore, there are no aging effects that would wOl,lld result from using Tygon tubing inside the Auxiliary Auxiliary Building where it contacts the the treated treated water (internal) environment (internal) environment and the air with borated water leakage leakage (external)

(external) environment.

environment.

The staff reviewed the applicant applicant response and industry documentsdocuments related to Tygon material. The The staff noted that Tygon Tygo,n material is made made from PVC and is highly resistant to corrosion and can temperatures up to _165 withstand temperatures F., The staff acknowledges 165 OF, acknowledges that the use of Tygon material for flexible tubing in power plant environments environments is a design-driven design-driven criterion and once selected selected for thethe environment will not have environment have any significant age age related degradation.

degradation. On the basis that the Tygon tubing is located in the Auxiliary Auxiliary Building in an environment environment that does not exceed 104 104 OF and radioactive atmosphere that does not exceed 1.3 x 1044 radioactive atmosphere exceed 10 rads, the staff staff finds that Tygon tubing will not have have any aging effects requiring management management in air with boric acid leakage and treated water treated water environments environments in the fuel handling handling and fuel storage storage system.

Based Based on its review, the staff finds the applicant's applicant's response to RAI 3.3.2.3-1 acceptable because 3.3.2.3-1 acceptable because the use of Tygon tubing in power plant environments is a design-driven design-driven criterion and once selected for the environment will not have any significant selected significant age age related degradation degradation and because because the Tygon tubing is located in the auxiliary auxiliary building in an environment environment that does not exceed exceed 104104 4

radioactive atmosphere OF and radioactive atmosphere that does does not exceed 1.3 x 10 104 rads, the Tygon tubing will not have any aging aging effects requiring management management in air with boric acid leakage and treated water environments environments in the fuel handling handling and fuel storage storage system. The staff's concern described described in RAI 3.3.2.3-1 3.3.2.3-1 is resolved.

resolved.

In LRA Table 3.3.2-11, 3.3.2-11, the applicant applicant proposed to manage loss of preload/thermal preload/thermal effects, gasket creep, and self loosening loosening of stainless steel bolting externally exposed exposed to air with borated water leakage and treated water environments leakage environments using the Bolting Integrity Program Program for two line items.

The AMR line items cite Generic Generic Note G, which indicates which indicates that the environment environment is not addressed in the GALL GALL Report for this componentcomponent and material.

3-317 3-317

The staff reviewed the applicant's Integrity Program and its evaluation applicant's Bolting Integrity documented in evaluation is documented in SER Section 3.0.3.1.3. The LRA states that this program manages manages the loss of material material due to to general, pitting and crevice corrosion, corrosion, MIC and and loss of preload due to thermal effects, gasket creep, and self-loosening. The staff found that the aging effects managed through the effects are managed the implementation of procedures implementation procedures that follow NRC approved guidance. Additionally, the two LRA line line items are similar similar to GALL Item VIII.H-5, air-indoor uncontrolled VIII.H-5, which accounts for an air-indoor uncontrolled (external) environment, but not an air with borated water leakage (external) or treated water (external) (external) environment. Both of these environments environments are potentially potentially contaminated and could make the the detection of loss of preload more difficult, as detection of leakage, one of the methods for preload more for detecting loss of preload, will be difficult to identify in these wet environments.

environments. However, TMI inspects for loss of preload preload using other methods including inspecting for loose bolts.

methods as well, including Therefore, Therefore, the staff management of loss of preload/thermal staff concludes that the management preload/thermal effects, gasket creep, and self loosening of stainless steel bolting externally borated water externally exposed to air with borated water environments is acceptable.

leakage and treated water environments acceptable.

On the basis of its review, the staff finds that the applicant appropriately evaluated applicant has appropriately evaluated the AMR AMR results of material, environment, AERM, and AMP combinations combinations not evaluated evaluated in the GALL effects of aging will be demonstrated that the effects Report. The staff finds that the applicant has demonstrated be managed so that the intended function(s) will be maintained adequately managed adequately maintained consistent with the CLB for the period of extended operation, as required by 10 10 CFR 54.21(a)(3).

3.3.2-11, the applicant proposed to manage In LRA Table 3.3.2-11, material/general, pitting and manage loss of material/general, crevice corrosion crane/hoist (aux fuel handling bridge), crane/hoist corrosion for carbon steel crane/hoist (main fuel crane/hoist (main crane/hoist (rails), and the crane/hoist (spent fuel handling bridge) externally handling bridge), crane/hoist exposed to an air with borated borated water leakage leakage environment environment using the Inspection of OverheadOverhead Handling Systems Program for four AMI1line (Related to Refueling) Handling Heavy Load and Light Load (Related AMR line items. The AMR line items cite Generic Generic NoteNote E, which indicates indicates that the material, aging effect, environment are consistent with the GALL Report, however, a different and environment management different aging management program is credited.

The staff reviewed reviewed the applicant's Overhead Heavy applicant's Overhead Heavy Load and Light Load (Related (Related to Refueling)

Refueling)

Handling Systems Program and its evaluation evaluation is documented documented in SER Section 3.0.3.2.7. The LRA LRA program manages states that this program manages the effects effects of general corrosion corrosion on the crane and trolley structural components structural effects of wear on the rails in the rail system. Inspection frequency components and the effects freq'uency annually for cranes and hoists that are accessible is annually accessible during plant operation operation and every every two years years for cranes cranes and hoists that are only accessible accessible during refueling refueling outages. The staff found that that the the aging effects are managed implementation of managed through the implementation procedures that follow NRC approved of procedures approved inspected using visual techniques. Therefore, the staff concludes guidance, and inspected guidance, concludes that the the management material/general, pitting and crevice corrosion for carbon steel crane/hoist management of loss of material/general, crane/hoist (aux fuel handling bridge), crane/hoist crane/hoist (main fuel handling crane/hoist (rails), and the handling bridge), crane/hoist the externally exposed to an air with borated water leakage crane/hoist (spent fuel handling bridge) externally crane/hoist leakage acceptable.

environment is acceptable.

3.3.2-11, the applicant In LRA Table 3.3.2-11, applicant proposed proposed to manage manage loss of material/wear stainless steel material/wear for stainless externally exposed to an air with borated water leakage crane/hoist (rails) externally environment using the leakage environment the Heavy Load and Light Load (Related Inspection of Overhead Heavy Inspection (Related to Refueling) Handling SystemsSystems Program. The AMR line items cite GenericGeneric Note G, which indicates environment is not indicates that the environment addressed in the GALL Report for this component addressed component and material.

The staff reviewed reviewed the applicant's Overhead Overhead Heavy Load and Light Load (Related (Related to Refueling)

Handling Handling Systems Program Program and its evaluation is documented documented in SER Section 3.0.3.2.7. The LRA 3-318 3-318

states that this program manages the effects of general corrosion on the crane and trolley program manages Inspection frequency effects of wear on the rails in the rail system. Inspection structural components and the effects is annually for cranes accessibly during plant operation and every two years cranes and hoists that are accessibly years accessible during refueling outages. The staff found that the for cranes and hoists that are only accessible the aging effects are managed through the implementation aging procedures that follow NRC implementation of procedures approved NRC approved guidance, guidance, and inspected Therefore, the staff concludes using visual techniques. Therefore, inspected using concludes that the the material/wear for stainless steel crane/hoist management of loss of material/wear (rails) externally exposed to crane/hoist (rails) an air with borated water environment is acceptable.

leakage environment water leakage acceptable.

On the basis of its review, the staff finds that the applicant appropriately evaluated the AMR applicant has appropriately AMR results of material, environment, AERM, combinations not evaluated AERM, and AMP combinations evaluated in the GALL demonstrated that the effects of aging will be Report. The staff finds that the applicant has demonstrated be adequately managed so that the intended adequately managed function(s) will be maintained intended function(s) maintained consistent with the CLB CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3).

3.3.2.3.12 Auxiliary Systems - Fuel Oil System - Summary 3.3.2.3.12 Management Evaluation Summary of Aging Management Evaluation -

LRA Table 3.3.2-12 3.3.2-12 summarizes the results of AMR evaluations for the reviewed LRA Table 3.3.2-12, which summarizes The staff reviewed component groups.

fuel oil system component applicant proposed to manage In LRA Table 3.3.2-12, the applicant preload/thermal effects, gasket manage loss of preload/thermal creep, and self loosening loosening for carbon mechanical closure bolting carbon and low alloy steel mechanical bolting in an outdoor air (external) environment environment using the Bolting Integrity Program. The AMR line items cite Generic Generic Note H,H, which indicates that the aging effect is not addressed in the GALL Report Report for this this component, material and environment combination.

environment combination.

staff reviewed the applicant's The staff documented in applicant's Bolting Integrity Program and its evaluation is documented SER Section applicant states Section 3.0.3.1.3. The applicant states in the LRA that this program manages the loss of program manages general, pitting and crevice corrosion, MIC and material due to general, and loss of preload preload due to thermal effects, gasket gasket creep, and self-loosening.

self-loosening. The staff found that the aging effects are managed procedures that follow NRC approved implementation of procedures through the implementation approved guidance. Additionally, the the LRA line item is similar to GALL Item VII.I-5, which accounts accounts for an air-indoor air-indoor uncontrolled uncontrolled (external) environment, environment, but not an air-outdoor environment. This environment air-outdoor (external) environment. environment consists consists precipitation, and wind. TMI-1 of moist air, exposure to weather, precipitation, TMI-1 inspects inspects for loss of preload using including inspecting for leakage methods including indicating loss of preload, and for loose bolts. The staff leakage indicating staff concludes that the management preload/thermal effects, gasket management of loss of preload/thermal gasket creep, and self mechanical closure bolting in an outdoor air (external) loosening for carbon and low alloy steel mechanical loosening (external) environment is acceptable.

acceptable.

appropriately evaluated On the basis of its review, the staff finds that the applicant has appropriately evaluated the AMR AMR results of material, AERM, and AMP combinations not evaluated material, environment, AERM, evaluated in the GALL Report. The staff finds that the applicant demonstrated that the effects applicant has demonstrated effects of aging aging will bebe adequately adequately managed maintained consistent with the CLB managed so that the intended function(s) will be maintained CLB for the period of extended required by 10 CFR 54.21(a)(3).

extended operation, as required 54.21 (a)(3).

3.3.2.3.13 Auxiliary Systems - Hydrogen 3.3.2.3.13 Monitoring - Summary Hydrogen Monitoring Summary of Aging Management Management Evaluation - LRA Table Evaluation 3.3.2-13 Table 3.3.2-13 reviewed LRA Table 3.3.2-13, which summarizes the results of AMR evaluations The staff reviewed evaluations for the the hydrogen monitoring hydrogen stainless steel piping and component groups. For stainless monitoring component and fittings, and stainless stainless 3-319 3-319

steel valve bodies, with an intended intended function of pressure pressure boundary in an air/gas wetted (internal) (internal) environment, the applicant indicated no aging effect requiring management requiring management and no aging aging management program. These line items reference management reference Note G and plant-specific plant-specific Note Note 1, which statesstates the following: "The internal environment environment for this component component is air/gas (wetted), however pooling of condensation would not be present condensation present because the lines are sloped to prevent prevent pooling per Drawing Drawing LR-302-674. Stainless steel in an air/gas internal environmentenvironment without the potential for pooling pooling condensation is equivalent condensation equivalent to stainless steel in an air - indoor uncontrolled uncontrolled environment, and no no aging effects are predicted for this combination combination per NUREG-1801, NUREG-1 801, Item VII.J-15."

The staff reviewed the GALL Report and confirmed confirmed that no aging effects are predicted for stainless steel piping, piping components, and piping elements exposed exposed to air in an indoor uncontrolled (external) environment. The staff reviewed the LRA and confirmed uncontrolled confirmed that line item 3.3.1-94 for stainless steelsteel piping, piping, piping components, and piping elements exposed to air in an indoor uncontrolled environment is consistent with the GALL Report, Item VII.J-15.

uncontrolled (external) environment VII.J-1 5. The The staff agrees agrees with the applicant's determination applicant's determination that that the two line items items in LRA Table 3.3.2-13 3.3.2-13 referencing Note G, and plant-specific plant-specific Note 1 are equiyalent equivalent to GALL Report, Item VII.J-15,VII.J-15,, .

because because pooling of condensation condensation would not occur because the lines are sloped and that no aging effect is predicted management program is required.

predicted and no aging management The staffs staff's evaluation evaluation of the line items with Notes A through E documented in SER E is documented Section 3.3.2.1.

3.3.2.1.

3.3.2.3.14 3.3.2.3.14 Auxiliary Auxiliary Systems - Instrument and Control Air System - Summary of Aging Aging Management Evaluation - LRA Table Management Table 3.3.2-14 3.3.2-14 The staff reviewed LRA Table 3.3.2-14, which summarizes summarizes the results of AMRs for the instrument instrument and control air system system component groups.

In LRA Table 3.3.2-14, the applicant proposed to manage reduction applicant proposed reduction of heat transfer due to fouling fouling of copper alloy with less than 15% Zinc heat exchanger exchanger components components in an air/gas wetted internal environment by using the Compressed environment Compressed Air Monitoring Monitoring Program. The applicant referenced footnote applicant referenced f06tnote "G"

"Gil for this line item indicating environment is not listed indicating that the environment listed in the GALL Report for this this material and component component combination.

combination.

The staff reviewed the Compressed Air Monitoring Monitoring Program and its evaluation evaluation is documented documented in in SER Section 3.0.3.2.8. The staff finds that during disassembly, the the internals internals of the aftercoolers aftercoolers are accessible accessible and can be visually inspected inspected and any fouling would be observed observed and identified identified for further corrective corrective actions. Based on this review, the staff finds that the Compressed Compressed Air Monitoring Monitoring Program will adequately manage reduction of heat transfer due to fouling of copper alloy with less less than 15% Zinc heat exchanger exchanger components

'components in an air/gas wetted internal environment environment through the the period of extended operation period operation because periodic inspection is performed to detect any signs of because periodic degradation before degradation before loss of intended intended function.

function.

In LRA Table Table 3.3.2-14, the applicant applicant proposed proposed to manage loss of material due to pitting and crevice corrosion for aluminum aluminum material for filter housing exposed to an air with borated water water leakage leakage (external) environment using the External Surfaces Surfaces Monitoring Monitoring Program. The AMR line line items cite Generic Note H, H, which indicates indicates that the aging effect is not addressed in the GALL Report for this component, material and environment environment combination.

The staff confirmed confirmed for these AMR line items in LRA Table 3.2.2-14, in which the applicant applicant listed the environment environment as air with borated water leakage, that for the same system, component, material 3-320 3-320

and environment environment combination, the applicant manages loss of material due to boric acid corrosion applica'nt manages with the Boric Acid Corrosion Program, as recommend recommend by the GALL Report. The staff reviewed reviewed the applicant's External External Surfaces Monitoring Program and its evaluation is documented Surfaces Monitoring documented in SER Sections Sections 3.0.3.2.16. The staff determined determined that the External Surfaces Monitoring Monitoring Program Program which includes periodic visual inspections inspections of external performed during system walkdowns, external surfaces performed walkdowns, are adequate to manage loss of material due adequate due to general, pitting and crevice corrosion for aluminum components exposed components exposed to air with borated water leakage environment addressed leakage environment addressed by this AMR. On the basis of periodic visual inspections inspections being performed performed during system walkdowns of these these components by the External Surfaces components Monitoring Program, and the applicant Surfaces Monitoring applicant monitoring monitoring these these components components with the Boric Boric Acid Corrosion Program, Program, for loss of material due to boric acidacid corrosion, the staff finds the applicant's use of the External External Surfaces Surfaces Monitoring program program acceptable.

In LRA Table 3.3.2-14, the applicant applicant proposed to manage loss of preload/thermal preload/thermal effects, gasket creep, and self loosening loosening for stainless steel mechanical closure bolting in an indoor steel mechanical indoor air (external) and air with borated borated water leakage leakage (external)

(external) environment environment using the Bolting Integrity Program for two AMR line items. The AMR line items cite Generic Generic Note H, H, which indicates that the aging effect is not is not addressed in the addressed in the GALL GALL Report Report for for this this component, material material and and environment combination.

environment combination.

The staff reviewed the applicant's applicant's Bolting Integrity Program and its evaluation evaluation is documented in SER Section Section 3.0.3.1.3. The LRA states that this program manages the loss of material due to program manages general, pitting and crevice crevice corrosion, MIC and loss of preloadpreload due to thermal effects, gasket creep, and self-loosening. The staff found that the aging effects are managed managed through the the implementation implementation of procedures procedures that follow NRC approved approved guidance. Additionally the LRA line items items are similar to GALL GALL item VIII.H-5, which which accounts accounts for an air-indoor uncontrolled uncontrolled (external) environment, but not an air-indoor air-indoor (external) or air with borated borated water leakage leakage (external) environment. Air-indoor is considered considered by the GALL to be synonymous synonymous with air-indoor air-indoor uncontrolled. The air with borated water uncontrolled. water leakage leakage (external) environment environment consists of water from leakage which is considered considered to be untreated, untreated, due to the potential for water contamination. TMI-1 contamination. TMI-1 inspects for loss of preload using methods including inspecting inspecting for leakage indicating loss of

preload, preload, and for loose bolts. The staff concludes that the management management of loss of preload/thermal effects, gasket creep, and self loosening for stainless stainless steel mechanical mechanical closure closure bolting in an indoor air (external) and air with borated water leakage (external)

(external) environment environment is acceptable.

acceptable.

On the basis of its review, the staff finds that the applicant has appropriately appropriately evaluated the AMR AMR results of material, environment, AERM, AERM, and AMP combinations combinations not evaluated evaluated in the GALL Report. The staff finds that the applicant applicant has demonstrated demonstrated that the effects of aging will be be adequately managed adequately managed so that the intended intended function(s) will be maintained maintained consistent consistent with the CLB required by 10 CFR 54.21 (a)(3).

for the period of extended operation, as required 3.3.2.3.15 Auxiliary Systems - Intake Screen Intake Screen and Pump House Ventilation Ventilation System System - Summary Summary of Aging Management Management Evaluation - LRA Table 3.3.2-153.3.2-15 The staff reviewed reviewed LRA Table 3.3.2-15, which summarizesummarize the results of AMR evaluations for the the intake intake screen and pump house house ventilation component groups.

ventilation system component The staff's staffs review did not find any line items indicating indicating plant-specific plant-specific Notes F through J whereby the combination of component type, material, environment, and AERM does not correspond correspond to a line item in the GALL Report.

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staffs evaluation of the line items with Notes A through E is documented The staff's documented in SER Section 3.3.2.1.

Section 3.3.2.1.

3.3.2.3.16 3.3.2.3.16 Auxiliary - Intermediate Building Auxiliary Systems -Intermediate Building Ventilation System - Summary Summary of Aging Management Evaluation Management Evaluation - LRA Table 3.3.2-16 3.3.2-16 The staff reviewed LRA Table 3.3.2-16, which summarize summarize the results of AMR evaluations evaluations for the the intermediate building ventilation intermediate ventilation system component groups.

The staffs staff's review did not find any line items indicating plant-specific plant-specific Notes F through J whereby whereby the combination of component type, material, environment, and AERM does not correspond to a line item in the GALL Report.

The staff's staffs evaluation evaluation of the line items with Notes A through E is documented documented in SER Section 3.3.2.1.

3.3.2.1.

3.3.2.3.17 3.3.2.3.17 Auxiliary Auxiliary Systems - Liquid and Gas Sampling Sampling System - Summary Summary of Aging Aging Management Evaluation Management Evaluation - LRA Table 3.3.2-17 3;3.2-17 The staff reviewed LRA Table 3.3.2-17, which summarize summarize the results of AMR evaluations the evaluations for the liquid liquid and gas sampling sampling system system component component groups.

The staff's staffs review did not find any line items indicating plant-specific plant-specific Notes F through J whereby combination of component type, material, environment, and AERM does not correspond the combination correspond to aa line item in the GALL Report.

The staff's evaluation evaluation of the line items with Notes Notes A through documented in SER through E is documented 3.3.2.1.

Section 3.3.2.1.

3.3.2.3.18 Auxiliary Systems - Miscellaneous Miscellaneous Floor and Equipment Equipment Drain System - Summary Summary of Aging Management Management Evaluation Evaluation - LRA Table 3.3.2-18 3.3.2-18 .

The staff reviewed 3.3.2-18, which summarizes reviewed LRA Table 3.3.2-18; summarizes the results of AMRsfor AMRs for the the miscellaneous floor and equipment miscellaneous equipment drain system component component groups.

In LRA Table Table 3.3.2-18, the applicant applicant stated that for organic polymer polymer floor flbor sumps in air/gas air/gas- -

wetted internal, concrete concrete embedded, embedded, air with borated water leakageleakage external and raw water water internal environments environments there are no aging effects requiring requiring management. The applicant applicant referenced referenced footnote "F" stating that this material material is not listed listed in the GALL GALL Report for these environments.

3.3.2.3-1, dated October 16, In RAI 3.3.2.3-1, 2008, the staff requested 16,2008, requested that the applicant applicant provide additional adQitional information information identifying identifying what polymer material is used and to justify why there are no aging effects effects requiring management management for this material.

In its response to the RAI dated November November 12, 2008, the applicant statedstated the following:

These line items refer to a fiberglass liner used insideinside the Tendon Access Gallery Sump.

Fiberglass is a composite Fiberglass composite material comprised comprised of glass fibers and a polyester polyester or epoxy resin. Fiberglass composites have excellent Fiberglass composites excellent moisture moisture resistance resistance and chemical chemical resistance resistance to many corrosive materials, including including acids (specifically including including boric acid), chlorides, nitrates, and sulfates. The maximum recommended recommended operating temperature temperature for fiberglass is 3-322 3-322

200 of.*F. The average average normal normal operating temperature temperature of the tendon access gallery gallery is 85 of°F and the radiation level is negligible. Therefore, there are no aging effectseffects resulting from using the fiberglass sump liner inside the tendon access gallery where it contacts contacts concrete, borated water leakage, air-gas wetted and raw water environments.

air with borated environments.

The staff reviewed reviewed the applicant's response response and noted that fiberglass piping and liners provide liners provide excellent corrosion resistance, combined with high temperature temperature and pressure pressure capabilities, capabilities, and it is impervious to normal impervious normal plant environments. The staff acknowledges acknowledges that the use of fiberglass lininglining inside the gallery sump in power plant environments is a design-driven design-driven criterion criterion and once once selected selected for the environment environment will not have any significant age related degradation.

degradation. On the basisbasis that the fiberglass fiberglass liner is located located in the tendon access access gallery sump in an environment environment that doesdoes not exceed 85°F 85 0 F and the radioactivity level is negligible, the staff finds that the fiberglass piping piping and liner will not have any aging effects requiring management management in concrete, air with borated water

leakage, leakage, air-gas environments in the fuel handling and fuel storage system.

air-gas wetted and raw water environments Based Based on its review, the staff finds the applicants response to RAI 3.3.2.3-1 acceptable acceptable because because the use of fiberglass piping and lining inside inside the gallery gallery sump in power power plant environments environments is a design-driven design-driven criterion and once selected for the environment environment will not have any significant age age related related degradation degradation and because because the fiberglass piping and liner is located in the tendon access tendon access gallery sump in an environment environment that does not exceed 85°F and the radioactivity radioactivity level is negligible, the fiberglass piping and liner will not have any aging effects requiring management management in concrete, air with borated water leakage, air-gas wetted wetted and raw water environments environments in the fuel handling handling and fuel storage system. The staff's concern described in RAI 3.3.2.3-1 is resolved.

concern described On the basis of its review, the staff finds that the applicant applicant has appropriately evaluated the AMR AMR results of material, material, environment, AERM, AERM, and AMP combinations not evaluated in the GALL Report. The staff finds that the applicant has demonstrated demonstrated that the effects of aging will be be adequately adequately managed so that the intended function(s) maintained consistent intended function(s) will be maintained consistent with the CLB CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3).

3.3.2.3.19 3.3.2.3.19 Auxiliary Systems - Open Cycle Cooling Water System - Summary Summary of AgingAging Management Evaluation Management Evaluation - LRA Table 3.3.2-19 3.3.2-19 The staff reviewed reviewed LRA Table 3.3.2-19, which summarize summarize the results of AMR evaluations evaluations for the the open cycle cooling water system component component groups.

The staff's review review did not find any line items indicating indicating plant-specific plant-specific Notes F through J whereby the combination component type, material, environment, and AERM does not correspond combination of component correspond to a line item in the GALL Report.

The staff's staffs evaluation of the line items with Notes A through E is documented documented in SER 3.3.2.1.

Section 3.3.2.1.

3.3.2.3.20 3.3.2.3.20 Auxiliary Systems - Radiation Monitoring System - Summary of Aging Management Radiation Monitoring Management Evaluation Evaluation - LRA Table Table 3.3.2-20 The staff reviewed LRA Table 3.3.2-20, which summarize the results of AMR evaluations evaluations for the the radiation monitoring system component component groups.

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The staffs The staffs review review did not find find any any line line items indicating plant-specific items indicating Notes F through plant-specific Notes through J whereby whereby the combination the component type, material, combination of component environment, and material, environment, AERM does and AERM does not correspond to aa not correspond line item line item inin the the GALL GALL Report. '

The staff's The staffs evaluation evaluation of thethe line line items with Notes A through items with through E E is documented in SER is documented Section 3.3.2.1.

3.3.2.1.

3.3.2.3.21 Auxiliary Systems 3.3.2.3.21 Systems - Radwaste Radwaste System Summary of Aging Management System - Summary Evaluation -

Management Evaluation LRA Table Table 3.3.2-21 The staff reviewed The reviewed LRA Table 3.3.2-21, LRA Table 3.3.2:'21, which summarize the which summarize evaluations for the results of AMR evaluations the results the component groups.

radwaste system component radwaste In LRA Table Table 3.3.2-21, 3.3.2-21, the the applicant applicant proposed manage cracking proposed to manage stress corrosion cracking due to stress corrosion cracking for stainless steel material for piping, fittings, eductors, heat steel material exchanger components, heat exchanger pump casing, rupture thermowell and valve body components rupture disks, strainer body, tanks, thermowell components exposed to an exposed an internal environment of raw water greater internal environment greater than 140OF 140°F using the Internal Insp~ction Internal Inspection Miscellaneous Piping and Ducting of Miscellaneous Ducting Components. The AMR Generic Note AMR line items cite Generic Note G, enviro~ment is not addressed in the GALL Report indicates that the environment which indicates Report for this component component and combination.

material combination.

Inspection of Internal The staff reviewed the Inspection Internal Surfaces Miscellaneous Piping Surfaces of Miscellaneous Piping and Ducting Ducting Components Program and its evaluation Components Program documented in SER evaluation is documented Section 3.0.3.2.17. The staff SER Section staff noted that the applicant's proposed program program will supplement visual inspections with supplement its period visual with volumetric testing to specifically volumetric manage cracking due to stress corrosion cracking specifically manage cracking in stainless stainless degradation. The staff components for indication of degradation.

steel components staff finds that the Inspection of Internal Surfaces in Miscellaneous Surfaces Miscellaneous Piping and Ducting Components Components program requires periodic visual inspections of internal surfaces during periodic periodic system and component component surveillance activiti~s and surveillance activities during maintenance maintenance activities when the internal surface is accessible accessible for visual inspections to detect aging detect aging effects intended function. On the basis component's intended effects that could result in a loss of the component's basis of its review, the staff finds that because these components will be inspected periodically by visual be inspected supplemented by volumetric test for stainless steel components inspections and then supplemented components to detect the the aging effect of cracking due to stress corrosion cracking cracking when exposed internal environment exposed to an internal environment of raw water greater than 140°F they will be adequately adequately managed Inspection of managed by the Inspection Miscellaneous Miscellaneous Piping and Ducting Components Program.

3.3.2-21, the applicant proposed to manage loss of material due to In LRA Table 3.3.2-21, to microbiologically-influenced corrosion for copper alloy (with 15%

microbiologically-influenced 15% zinc or more and with less than material for pump casing, sight glasses and valve body components 15% zinc) material 15% components exposed to an environment using the Inspection of Internal Surfaces in MiscelianeOl!Js lubricating oil environment internal lubricating Miscellaneous Components Program. The AMR line items cite Generic Note H, which Piping and Ducting Components indicates that the aging effect is not addressedaddressed in the GALLGALL Report for this component, material environment combination.

and environment The staff reviewed the Inspection of Internal Surfaces of Miscellaneous Miscellaneous Piping and Ducting Components Program and its evaluation evaluation is is documented documented in SER Section 3.0.3.2.17. The staff finds finds Surfaces in Miscellaneous that the Inspection of Internal Surfaces Piping and Ducting Components '

Miscellaneous Piping inspections of internal surfaces during periodic system and Program requires periodic visual inspections Program activities and during maintenance activities when the internal surface is component surveillance activities component is inspections to detect aging effects that could result in a loss of the accessible for visual inspections accessible component's intended function. On the basis of its review, the staff finds that because these component's 3-324 3-324

components components will be inspected periodically periodically by visual inspection, inspection, they will be adequately adequately managed by the Inspection Inspection of Miscellaneous Miscellaneous Piping and Ducting Components Components Program.

In LRA Table 3.3.2-21, 3.3.2-21, the applicant applicant proposed to manage manage loss of material due to microbiologically-influenced corrosion and fouling for nickel alloy material microbiologically-influenced material for piping and fitting components exposed to an internal raw water environment using the Inspection rawwater Inspection of Internal Surfaces in Miscellaneous Surfaces Miscellaneous Piping and Ducting Components Program. The AMR line items items cite cite Generic Note H, ~hich indicates H, which indicates that the aging effect is not addressed in the GALL Report Report for this this component, material and environment component, environment combination.

combination.,

The staff reviewed reviewed the Inspection of Internal Surfaces of Miscellaneous Internal Surfaces Miscellaneous Piping and Ducting Ducting Components Program Components Program and its evaluation evaluation is documented documented in SER Section 3.0.3.2.17. The staff staff finds finds that the Inspection of Internal Miscellaneous Piping and Ducting Components Internal Surfaces in Miscellaneous Components Program requires periodic Program periodic visual inspections inspections of internal surfaces during periodic system and component surveillance component surveillance activities and during maintenance maintenance activities when the internal surface surface is accessible for visual inspections inspections to detect aging effects that could result in a loss of the the component's intended intended function. On the basis of its review, the staff finds that because these because these components will be inspected periodically periodically by visual inspections when exposed exposed to an internal environment of raw water they will be adequately managed environment managed by the Inspection Inspection of Miscellaneous Miscellaneous Piping and Ducting Components Program.

In LRA Table Table 3.3.2-21, 3.3.2-21, the applicant applicant proposed to manage loss of material due to pitting and crevice corrosion for nickel alloy material for piping and fitting components exposed exposed to an internal treated treated water environment environment using Inspection of Internal Surfaces in Miscellaneous using the Inspection Miscellaneous Piping and Components Program.

Ducting Components Program. The AMR line items cite Generic Generic Note G, which indicates that the the environment environment is not addressed in the GALL Report for this component component and material combination.

combination.

The staff reviewed the Inspection Inspection of Internal Surfaces of MiscellaneousMiscellaneous Piping and Ducting Components Program and its evaluation Components evaluation is documented documented in SER Section 3.0.3.2.17. The staff finds finds that the Inspection Surfaces in Miscellaneous Inspection of Internal Surfaces Miscellaneous Piping and Ducting Components Components Program requires Program periodic visual requires periodic visual inspections inspections ,ofof internal internal surfaces during during periodic system and and component surveillance surveillance activities and during maintenance maintenance activities when the internal surface is accessible for visual inspections to detect detect aging effects that could result in a loss of the the component's intended intended function. On the basis of its review, re'{iew, the staff finds that because these because these, components components will be inspected periodically by visual inspections, inspected periodically inspections, they will be adequately adequately managed Inspection of Miscellaneous Piping and Ducting by the Inspection Ducting Components Program.

Components Program.

In LRA Table 3.3.2-21, 3.3.2-21, the applicant proposed to manage manage loss of material due to crevice crevice corrosion and fouling for titanium alloy material for tanks exposed exposed to an internal raw water greater 140OF environment using the Inspection than 140°F Inspection of Internal Internal Surfaces Miscellaneous Piping and Surfaces in Miscellaneous Ducting Components Ducting Components Program. The AMR line items cite Generic Generic Note F, which indicates Note indicates that the the material material is not addressed in the GALL Report for this environment.

The staff reviewed Inspection of Internal reviewed the Inspection Internal Surfaces of Miscellaneous Miscellaneous Piping and DuctingDucting Components Program and its evaluation Components evaluation is documented documented in SER SER Section Section 3.0.3.2.17. The staff finds finds that the Inspection Surfaces in Miscellaneous Inspection of Internal Surfaces Miscellaneous Piping and Ducting Components Ducting Components program requires periodic visual inspectionsinspections of internal internal surfaces during periodic system and component component surveillance surveillance activities activities and during maintenance activities when the internal surface is during maintenance accessible inspections to detect aging effects that could result in a loss of the accessible for visual inspections the component's component's intended function. On the basis of its review, the staff finds that because these these components components will be inspected inspected periodically by visual inspections, inspections, they will be adequately adequately managed by the Inspection Inspection of Miscellaneous Miscellaneous Piping and Ducting Components Components Program.

3-325 3-325

In LRA LRA Table 3.3.2-21, the applicant Table 3.3.2-21, applicant proposed to manage loss of material material due to pitting and crevice corrosion crevice corrosion for titanium alloy material for tanks exposed exposed to an internal treated water greater

~nd 0

1400 F environment than 140 environment using the Inspection of Internal Miscellaneous Piping and Internal Surfaces in Miscellaneous Ducting Ducting Components Components program. The AMR line items items cite Generic Note F, which indicatesindicates that the the material material is not addressed addressed in the GALL Report for this environment. environment.

The staff reviewed the Inspection Inspection of Internal Surfaces Surfaces of Miscellaneous Miscellaneous Piping Piping and Ducting Components Components Program and its evaluationevaluation is documented in SER Section 3.0.3.2.17. The staff finds finds that the Inspection Inspection of Internal Surfaces in Miscellaneous Miscellaneous Piping and and Ducting Components Components :

Program Program requires periodic visual inspections inspections of internal surfaces during periodic system and component surveillance activities maintenance activities when the internal surveillance activities or during maintenance internal surface is accessible for visual inspections accessible inspections to detect aging effects effects that could result in a loss of the the component's intended function. On the basis of its review, the staff finds that because component's because these; these components will be inspected components inspected periodically by visual inspections, they will be adequatelyadequately mahaged managed by the Inspection of Miscellaneous Miscellaneous Piping and Ducting Components Components Program.

Program.

/

In LRA Table 3.3.2-21, the applicant Table 3.3.2-21, applicant stated that for glass flow device and sight glasses glasses in air with leakage external environment borated water leakage environment there are no aging effects requiring management. II The applicant referenced referenced footnote "G" for this line item indicating that the environmentenvironment is not listed in the GALL Report for this material material and component combination.

As indicated in "Corrosion Handbook" by H.H.Uhlig, the staff noted that glass as a material is impervious to normal plant environments.

environments. This conclusion is based on industry experience where industry experience the staff noted noted that no failure due to an aging effect effect of glass components components in environments environments ftee free of hydrofluoric hydrofluoric acid, caustics, or hot water have been recorded in industry at temperatures temperatures or during extended operation. The staff acknowledges time periods of concern for extended acknowledges that the use of glass in power power plant environments is aa design-driven design-driven criterion and and once selected for the environment environment will not have any significant age related degradation, degradation, since air with borated water leakage leakage exte~nal exterinal environment does not contain hydroflouric environment hydroflouric acid or caustics. The staff reviewed the'GALL the GALL Report and noted that item VII.J-12 indicates that glass in a treated borated water environment VII.J-12 indicates environment has no no aging effects that require require aging management. On the basis that air with borated borated water leakage leakage is a less aggressive aggressive environment environment than treated boratedborated water, the staff finds that glass in an air with with borated water borated leakage will not have water leakage have any aging effects requiring aging management.

In LRA Table 3.3.2-21, the applicant applicant stated that for titanium alloy tanks in air with borated borated water water leakage external environment leakage environment there are no aging effects effects requiring management. The applicant applicant referenced footnote "F" for this line item indicating referenced indicating that material material is not listed in the GALL GALL Report for this component component and environment combination.

environment combination.

In RAI 3.3.2.3-1, In 3.3.2.3-1, dated dated October 16, 2008, the staff requested requested that the applicant applicant provide additional information to justify why there are no aging effects requiring management management for titanium alloy alloy material.

In its response response to the RAI dateddated November November 12, 2008, the applicant stated stated the following:

Titanium resistance to a wide variety of environments, including Titanium offers outstanding resistance including oxidizing, oxidizing, neutral, and inhibited reducing reducing conditions. It It also remains remains passive under under m'ildlY mildly reducing reducing conditions. Titanium is not susceptible susceptible to boric acid acorrosion, based upon based upori corrosion corrosion testing performed manufacturer. Based performed by the titanium manufacturer. Based on these material 3-326

properties, titanium is not susceptible to aging effects effects in the air with borated water leakage leakage environment.

The staff noted that as shown in the "Metals Handbook," Ninth Edition, Volume 13, the corrosion corrosion resistance of titanium is aa result of the formation of a continuous, stable, highly-adherent highly-adherent protective oxide layer on the metalmetal surface. The staff noted that the metal itself, very reactive with a high affinity for oxygen, reforms damagedamage to this layer layer instantaneously. The staff also noted that no failure due to an agingaging effect of titanium components in normal plant environments environments has been recorded recorded in industry. Based on this review, the staff finds the applicant's applicant's response response acceptable, acceptable, and finds that titanium alloy tanks in air with borated borated water leakage external environment environment will not have have any aging effects requiring management.

The staff noted noted that for nickel alloy piping and fittings exposed to an air with boratedborated water water leakage leakage (external) environment, the applicant assigned no aging effect effect and therefore no aging aging management management program was assigned for these component/material/environment componenVmaterial/environment combinations.

The staff noted that austenitic materials materials such as nickel alloys alloys are not subject to loss of material or cracking when subjected to this environment environment and these materials are used as corrosion resistant replacement materials where other materials have degraded. According replacement According to EPRI NP-5769, "Degradation and Failure Failure of Bolting in Nuclear Nuclear Power Plants, Volumes 1 and 2," April 1988, corrosion resistant materials such as austenitic and martensitic martensitic stainless steels and high strength nickel base alloys offer good protection againstagainst boric acid corrosion.

corrosion. Therefore, the staff staff finds that no aging management management program is necessarynecessary for nickel alloys in the air with borated water leakage leakage (external)

(external) environment.

On the basis of of. its review, the staff finds that the applicant applicant has appropriately appropriately evaluated evaluated the AMR AMR results of material, environment, AERM, AERM, and AMP combinations combinations not evaluated evaluated in the GALL Report. The staff finds that the applicant has demonstrated demonstrated that the effects effects of aging aging will be be adequately adequately managed so that the intended intended function(s) function(s) will be maintained maintained consistent with the CLB for the period of extended extended operation, as required required by 10 CFR 54.21(a)(3).

3.3.2.3.22 3.3.2.3.22 Auxiliary Auxiliary Systems - Service Service Building Chilled Water System - SummarySummary of Aging Aging Management Evaluation Management Evaluation - LRA Table 3.3.2-22 3.3.2-22 The staff reviewed LRA Table 3.3.2-22, 3.3.2-22, which summarize summarize the results of AMR evaluations for the the service building building chilled water system component groups.

The staff's staffs evaluation of the line items with Notes A through E is documented documented in SER 3.3.2.1. The staff's evaluation Section 3.3.2.1. evaluation of the line item with Note I is documented documented in SER Section Section 3.3.2.1.15.

3.3.2.3.23 3.3.2.3.23 Auxiliary Systems - Spent Fuel Cooling System - Summary Summary of Aging Management Management Evaluation - LRA Table 3.3.2-23 3.3.2-23 The staff reviewed LRA Table 3.3.2-23, which summarize the results of AMR evaluations evaluations for the the spent fuel cooling component groups.

cooling system component The staff's staffs review review did not find any line items indicating plant-specific items indicating plant-specific Notes F through J whereby the combination combination of component type, material,material, environment, and AERM does not correspond correspond to a line item in the GALL GALL Report.

3-327 3-327

evaluation of the line items with Notes A through E The staffs evaluation E is documented in SER Section 3.3.2.1.

3.3.2.1.

3.3.2.3.24 Auxiliary Systems - Station Blackout 3.3.2.3.24 Auxiliary Blackout and UPS Diesel GeneratorGenerator Systems - Summary Management Evaluation - LRA Table of Aging Management 3.3.2-24 Table 3.3.2-24 reviewed LRA Table 3.3.2-24, which summarize The staff reviewed summarize the results of AMR evaluations evaluations for the the station blackout and UPS dieseldiesel generator systems component component groups.

In LRA Table 3.3.2-24, the applicant proposed proposed to manage reduction of heat transfer due to fouling heat transfer fouling for carbon steel material components exposed to an internal dry air/gas exchanger components material for heat exchanger air/gas environment using the Inspection of Internal environment Miscellaneous Piping and Ducting Internal Surfaces in Miscellaneous Ducting :,

Components Program. The AMR Components AMR line items cite Generic Generic Note H, H, which indicates that the aging addressed in the GALL Report for this component, material effect is not addressed material and environment environment combination.

Inspection of Internal Surfaces The staff reviewed the Inspection Surfaces of Miscellaneous Miscellaneous Piping and DuctingDucting Components Program documented in SER Section Program and its evaluation is documented 3~0.3.2.17. The staff finds Section 3.0.3.2.17. finds that the Inspection Miscellaneous Piping and Ducting Components Inspection of Internal Surfaces in Miscellaneous Components '

periodic visual inspections Program requires periodic inspections of internal surfaces surfaces during periodic system and component component surveillance maintenance activities when the internal surface is surveillance activities and during maintenance accessible for visual inspections to detect accessible effects that could result in a loss of detect aging effects of the the .

component's intended function. The staff further noted component's noted that these periodic visual inspections inspections are reduction of heat transfer due to fouling for these components adequate to manage reduction adequate components exposed exposed to internal dry air/gas environment addressed by this AMR because environment addressed because a visual inspection will be be capable capable of detecting whatever source) on the surface of these detecting any fouling (build up from whatever components. On the basis of its review, the staff finds that because these components components will be be inspected periodically by visual inspections inspected. exposed to an internal inspections when exposed internal dry air/gas they will be be adequately managed by the Inspection adequately managed Miscellaneous Piping and Ducting Components Inspection of Miscellaneous Components' Program.

In LRA Table 3.3.2-24 the applicant designated designated Generic Generic Note H H for copper alloy piping and ilfittings ifittings exposed environment in the station blackout and UPS diesel generator exposed to a lubricating oil environment generator systems systems (Table 3.3.2-24) because the aging effect effect for the AMR line item component, material, and and evaluated in the GALL Report for heat exchanger environment combination is not evaluated exchanger components components and the staff reviewed the GALLGALL Report Report and concluded concluded that the AMR line item, copper alloy piping and fittings is not evaluated lubricating oil for loss of evaluated for lubricating of material due to pitting, crevice, microbiologically-influenced corrosion. The applicant credits the Lubricating microbiologically-influenced Lubricating Oil Analysis Program and the One-time Inspection Program for managing Inspection Program material due to pitting, crevice, and managing loss of material microbiologically-influenced corrosion. The staffs evaluation of the Lubricating Oil Analysis' microbiologically-influenced Analysis" documented in SER Sections 3.0.3.2.18 Inspection Program is documented Program and the One-time Inspection 3.0.3.2.18 and 3.0.3.2,14, respectively. The staff noted 3.0.3.2.14, noted that these programs programs 1) 1) provide sampling of provide for periodic sampling lubricating oil to maintain maintain contaminants at acceptable acceptable limits to preclude preclude loss of material due to due; to pitting, crevice and microbiologically-influenced microbiologically-influenced corrosion and 2)

2) will require one-time one-time inspection susceptible components of select susceptible lubricating oil for loss of material components exposed to lubricating material due to pitting, microbiologically-influenced corrosion to verify the effectiveness crevice and microbiologically-influenced effectiveness of the Lubricating Oil Analysis Program. one-time inspection is an acceptable Program. The staff noted that the one-time acceptable method to whether or not loss of material is occurring slowly such that the intended determine whether intended function function will be maintained maintained during the period extended operation. On this basis, the staff finds that the period of extended the Lubricating Lubricating Oil Analysis Program Program and the One-Time Inspection Program Inspection Program are adequate manage adequate to m'6nage 3-328 3-328

loss of material loss material due to pitting, crevice, crevice, and microbiologically-influenced corrosion and microbiologically-influenced these copper corrosion for these copper alloy components components through through the period period of of extended extended operation.

operation.

basis of On the basis of its review, the staff staff finds finds that that the the applicant applicant has appropriately evaluated the AMR appropriately evaluated AMR of material, results of material, environment, environment, AERM,AERM, and AMP combinations combinations not evaluated in the GALL not evaluated Report. The staff finds that the demonstrated that applicant has demonstrated the applicant aging will be that the effects of aging be adequately managed adequately managed so that intended function(s) will be maintained that the intended consistent with the CLB maintained consistent CLB for the period extended operation, period of extended required by 10 operation, as required 10 CFR 54.21(a)(3).

3.3.2.3.25 Auxiliary 3.3.2.3.25 Auxiliary Systems Treatment and Distribution System - Summary Systems - Water Treatment Summary of AgingAging Management Evaluation Management Evaluation - LRA Table 3.3.2-25 LRA Table 3.3.2-25 The staff reviewed The reviewed LRALRA Table 3.3.2-25, which summarize 3.3.2-25, which summarize thethe results evaluations for the results of AMR evaluations the water treatment and distribution water treatment system component distribution system component groups.

In LRA Table 3.3.2-25, the applicant proposed LRA Table proposed to manage cracking due to stress cracking due stress corrosion corrosion cracking for stainless steel material for pump cracking pump casings exposed environment of raw internal environment exposed to an internal raw water greater than 140°F140°F using Internal Inspection using the Internal Miscellaneous Piping and Inspection of Miscellaneous and Ducting Ducting Components Program.

Components Program. The AMR Generic Note AMR line items cite Generic indicates that the Note G, which indicates the environment is not addressed environment addressed in the GALL Report for this component GALL Report combination.

component and material combination.

The staff reviewed Inspection of Internal reviewed the Inspection Miscellaneous Piping and Internal Surfaces of Miscellaneous and Ducting Ducting Components Program Components Program and its evaluation documented in SER Section 3.0.3.2.17.

evaluation is documented staff 3.0.3.2.17. The staff noted, that the applicant's proposed program applicant's proposed supplement its periodic program will supplement inspections with periodic visual inspections with volumetric testing to specifically volumetric manage cracking due to stress corrosion cracking in stainless specifically manage stainless degradation. The staff finds that the Inspection of Internal components for indications of degradation.

steel components Miscellaneous Piping and Ducting Components Surfaces in Miscellaneous Surfaces Program performs periodic visual Components Program inspections of internal surfaces during periodic system and component surveillance activities or or maintenance activities when the internal surface is accessible for visual inspections during maintenance during inspections to component's intended function. On the basis detect aging effects that could result in a loss of the component's basis of its review, the staff finds that because these components will be inspected periodically by visual supplemented by volumetric inspections and then supplemented inspections components to detect the volumetric test for stainless steel components the aging effect of cracking cracking due to stress corrosion cracking cracking when exposed to an internal environment internal environment of raw water greater than 140°F 140OF they will be adequately adequately managed by by the Inspection of Miscellaneous Miscellaneous Piping and Ducting Components Components Program.

In LRA Table 3.3.2-25, the applicant stated that for PVC piping and fittings in raw water, treated environments there are no aging effects requiring management. The water and air-indoor environments The indicating that material is not listed in the GALL referenced footnote "F" for this line item indicating applicant referenced Report for this component and environment combination. combination.

Engineering Plastics," the staff noted that PVC Materials Handbook - Engineering As identified in "Engineering Materials concentrated alkalis, non-oxidizing acids, oils, ozone, sunlight, or humidity is unaffected by water, concentrated changes. The staff also noted noted that unlike metals, thermoplastics do not display corrosion rates, and rather-than rather-than depend on an oxide layer for protection, they depend on chemical resistance to environments to which they are exposed. The use of thermoplastics in power plant the environments plant environments is environments is a design-driven design-driven criterion. The staff acknowledges that plastic is an impervious impervious once selected for the environment will not have any significant material and once significant age related degradation. The staff has has not observed any age related industry experienceexperience for plastic plastic material in in raw water, treated water and air-indoor environments. Based Based on this review, the staff finds that 3-329 3-329

raw water, treated water and air-indoor environments environments on PVC materials will not result in aging effects effects that will be of concern concern during during the period of extended operation.

On the basis basis of its review, the staff finds that the applicant has appropriately appropriately evaluated evaluated the AMR AMR results of material, environment, AERM, and AMP combinations combinations not evaluated in the GALL Report. The staff finds that the applicant applicant has demonstrated demonstrated that the effects of aging will be be adequately managed so that the intended function(s) will be maintained adequately managed maintained consistent with the CLB for the period of extended extended operation, operation, as required required by 10 CFR 54.21 (a)(3).

3.3.3 3.3.3 Conclusion Conclusion The staff concludes concludes that the applicant has provided provided sufficient information to demonstrate sufficient information demonstrate that the the effects effects of aging for the Auxiliary Auxiliary System components within the scope of license renewal and System components a~d subject subject to an AMR will be adequately managed so that the intended functions will be maintained adequately managed consistent consistent with the CLB for the period of extended operation, operation, as required by 10 CFR 54.21 (a)(3).

3-330 3-330

3.4 Aging Management Aging Management of Steam Steam and Power ConversionConversion System This section of the SER documents documents the staffs review of the applicant's applicant's AMR results for the steam power conversion system components and power components and component component groups of the following:

- Condensate System Condensate

- Condensers and Air Removal System

" Emergency Feed water System Emergency

- Extraction Steam Extraction Steam System

- Feed water System

- Generator and Auxiliary Systems Main Generator Systems

- Main Steam System

- 'Steam Turbine and Auxiliary Systems Systems 3.4.1 Summary of Technical Information Information in the Application Application LRA Section Section 3.4 provides provides AMR AMR results for the steam and power conversion conversion system system components components and component groups. In LRA Table 3.4.1, Table 3.4.1, "Summary of Aging Management.Evaluations ManagementEvaluations for for Steam and Power Conversion," the applicant applicant provided a summary comparison of its AMRs to summary comparison evaluated in those evaluated in the GALL Report Report for steam and power conversion conversion system components and component component groups.

The applicant's evaluated and incorporated applicant's AMRs evaluated incorporated plant-specific plant-specific and industry industry operating experience in the determination experience determination of AERMs from plant-specific condition reports and discussions discussions with site personnel and from the GALL Report and issues identified identified since its publication.

publication.

3.4.2 Evaluation Staff Evaluation The staff reviewed reviewed LRA Section Section 3.4 to determine determine whether the applicant provided provided sufficient sufficient information to demonstrate demonstrate that the effects effects of aging for steam steam and powerpower conversion system components within the scope of license renewal renewal and subject subject to an AMR, will be adequately adequately managed so that the intended managed intended functions functions will be maintained maintained consistent consistent with the CLB for the period period of extended extended operation, as required required by 10 CFR 54.21 (a)(3).

The staff conducted conducted an onsite onsite audit of AMPs to ensure the applicant's applicant's claim that certain certain AMPs AMPs were consistent consistent with the GALL Report. The purpose of this audit was to examine the applicant's applicant's AMPs and related documentation documentation and to verify the applicant's applicant's claim of consistency consistency with the the corresponding corresponding GALL Report Report AMPs. The staff did not repeat repeat its review of the matters described in in the GALL Report. The staff's evaluations evaluations of the AMPs are documented documented in SER Section 3.0;3. 3.0.3.

The staff reviewed the AMRs to confirm confirm the applicant's applicant's claim that certain identified AMRs were consistent with the GALL Report. The staff did not repeat its review of the matters described in in the GALL Report; however, the staff staff did verify that the material presented presented in the LRA was was applicable applicable and that the applicant identified the appropriate applicant had identified appropriate GALL ReportReport AMRs. Details of the the staff's evaluation are discussed discussed in SER Section 3.4.2.1 and 3.4.2.2.

The staff also reviewed the AMRs not consistentconsistent with or or not addressed in the GALL Report. The The review evaluated whether all plausible aging effects were identified identified and whether the aging effects 3-331

listed were appropriate appropriate for the combination of materials and environmentsenvironments specified. Details of the the staffs staff's evaluation are discussed discussed in SER Section 3.4.2.3.

For components components which which the applicant claimedclaimed were not applicable applicable or required required no aging management, management, the staff reviewed reviewed the AMR line items and the plant's operating operating experience experience to.

to verify applicant's claims.

the applicant's Table 3.4-1 summarizes summarizes the staff's evaluation evaluation of components, aging effects or mechanisms; mechanisms, and AMPs listed in LRA SectionSection 3.4 and addressed in the GALL Report.

Table 3.4-1 Evaluation for Steam and Power Conversion 3.4*1 Staff Evaluation Conversion Systems Components in the GALL Report Report Component Group Aging AMP in GALL* Furthe'r - AMP iii LRA, Stf (GdALL Report Ef~tMcaimReport Evaluation S" vliaih Reor 'Amendments ______

Steel piping, piping

"

Cumulative fatigue TLAA, evaluated TLM, evaluated Yes TLAA TLM Fatigue is a components, components, and piping piping damage damage in accordance in accordance TLAA TLM(See (See elements elements exposed to with SER Section steam or treated water 10 CFR 54.21(c)

S4.21(c) 3.4.2.2.1))

3~4.2.2.1 (3.4.1-1)

(3.4.1-1)

Steel piping; piping, piping material due Loss of material Water Chemistry Yes Water Consistent components, and piping to general, pitting and and One-Time One-Time Chemistry Chemistry and with GALL elements elements exposed to crevice corrosion Inspection One-Time One-Time Report steam Inspection Inspection (See SER (3.4.1-2) Section 134.2.2.2) 3A.2.2.2)

Steel heat heat exchanger exchanger Loss of material due Chemistry Water Chemistry Yes Water Consistent components exposed to components to general, pitting and and One-Time Chemistry and with GALL treated water crevice crevice corrosion Inspection One-Time One-Time Report (See

~eport(See (3.4.1-3) Inspection Inspection SER Section 3.4.2.2.2)

Steel piping, piping Loss of material material due Water Chemistry Yes Water Consistent components, and piping to general, pitting and and One-Time Chemistry and vwith With GALL elements exposed to crevice corrosion Inspection Inspection One-Time One-Time Report (See treated treated water Inspection, Inspection, or SER Section Section (3.4.1-4) Closed-Cycle Closed-Cycle 3.4.2.2.2) 3.4.2.2.2)

Cooling Water Cooling Water System Steel heat exchanger exchanger Loss of material due Water Chemistry Chemistry Yes Water Consistent components components exposed to to general, pitting, and One-Time Chemistry and and with GALL GALL treated water water crevice, and galvanic galvanic Inspection One-Time One-Time Report (See Report (3.4.1-5) corrosion Inspection SER Section 3.4.2.2.2.)

3.4.2.2.2.)

Steel and stainless steel Loss of material material due Water Chemistry Yes Water Consistent tanks exposed to treated treated general (steel only) to general and One-Time One-Time Chemistry with GALL water pitting and crevice crevice Inspection Inspection One-Time One-Time Report (3.4.1-6)

(3.4.1-6) corrosion Inspection Inspection (See SER Closed-Cycle Section

-Cooling Cooling Water Water 3.4.2.2.2) 3.4.2.2.2) 3-332

Component GrpAgngAJMP'in ýGALL. Fur6e H* *M i A Staf (ALL Reprt Effect/Mechanism pr-.' Ev('I Evaluation.S 6pents Repor"No. in GALL ppornet Eauto Report Amendments, Steel piping, piping Loss of material material due Lubricating Oil Yes Lubricating Lubricating Oil Not Not components, and piping to general, pitting and and Analysis and Analysis applicable to applicable elements exposed to elements crevice corrosion crevice corrosion One-Time One-Time TMI-1.

TMI-1. (See lubricating lubricating oil Inspection Inspection Inspection of SER Section Section (3.4.1-7) steel heat 3.4.2.2.5) 3.4.2.2.5) exchanger exchanger components components See GALL Item Report Item 3.4.1-12 No. 3.4.1-12 below.

Steel Steel piping, piping Loss of material due due Plant specific Yes Inspection of Inspection Consistent components, and and piping to general, pitting, Internal Internal with GALL elements elements exposed exposed to crevice, crevice, and Surfaces in Report raw water microbiologically- Miscellaneous Miscellaneous (See SER (3.4.1-8) influenced influenced corrosion, Piping and Section Section and and fouling Ducting 3.4.2.2.3) 3.4.2.2.3)

Components Components Stainless steel steel and Reduction Reduction of heat Water Chemistry Chemistry Yes Water Consistent copper alloy heat heat transfer due to fouling and One-Time One-Time Chemistry and with GALL exchanger exchanger tubes Inspection Inspection One-Time Report exposed exposed to treated water Inspection Inspection (See SER (3.4.1-9) Section 3.4.2.2.4) 3.4.2.2.4)

Lubricating Oil Consistent Steel, stainless steel, Reduction Reduction of heat Lubricating Oil Lubricating Yes Analysis Analysis with GALL and copper copper alloy heat transfer due to fouling Analysis and One-Time One-Time Report (See exchanger tubes exchanger tubes One-Time Inspection SER Section exposed to lubricating lubricating oil Inspection Inspection 3.4.2.2.4)

(3.4.1-10)

Buried steel piping, Loss of material due Buried Piping Piping No No Buried Piping Consistent piping components, components, to general, pitting, and Tanks and Tanks with GALL piping elements, elements, and crevice, and micro Surveillance Surveillance Inspection Report (See tanks (with or without without biologically-influenced biologically-influenced program SER Section coating or wrapping) wrapping) corrosion or 3.4.2.2.5) exposed to soil Yes Yes (3.4.1-11))

(3.4.1-11 Buried Piping Piping and Tanks Tanks Inspection Steel heat exchanger exchanger Loss of material due due Lubricating Lubricating Oil Yes Inspection of Inspection Consistent components components exposed to to general, pitting, pitting, Analysis and Internal with GALL lubricating oil crevice, crevice, and One-Time One-Time Surfaces Surfaces in Report (3.4.1-12)

(3.4.1-12) microbiologically- Inspection Miscellaneous Miscellaneous (See SER influenced corrosion corrosion , Piping and Section Ducting 3.4.2.2.5)

Components Components Lubricating Oil Lubricating Analysis and One-Time One-Time Inspection Inspection 3-333

Component Group Aging AMP-in GALL!: Furthr AMP, in LRA,~ Staff (GALL Report, EffectMec-anism Report Evaluation Supplements Evaluation.

Item No.) .~i ALor

- R~e~poft . Amendments 'P Stainless steel piping, Cracking due to stress Chemistry Water Chemistry Yes Not applicable applicable Not Not piping components, corrosion cracking corrosion and One-Time applicable applicable to piping elements Inspection Inspection TMI-1* (See TMI-1.

exposed to steam SER Section II \

(3.4.1-13) 3.4.2.2.6.,

3!4.2.2.6.)

,

Stainless steel piping, Cracking due to stress Cracking Water Chemistry Yes Water Water Consistent Consistent piping components, corrosion corrosion cracking and One-Time Chemistry Chemistry and with GALL piping elements, tanks, Inspection Inspection One-Time One-Time Report and heat exchanger Inspection Inspection (See SER components exposed to components exposed Section water > 60°C treated water> 3':4.2.2.6) 3.4.2.2.6)

(> 140°F) 140'F)

(3.4.1-14)

Aluminum Aluminum and copper Loss of material due Water Chemistry Yes Water Consistent C.onsistent alloy piping, piping to pitting and crevice crevice and One-Time One-Time Chemistry Chemistry and with GALL components, components, and piping piping corrosion Inspection One-Time One-Time Report elements elements exposed to Inspection Inspection (See SER treated water Section (3.4.1-15) 3.4.2.2.7)

Stainless Stainless steel piping, Loss of material due Water Chemistry Yes Water Consistent piping components, and to pitting and crevice and One-Time Chemistry with GALL GALL piping elements; tanks, corrosion corrosion Inspection One-Time One-Time Report exchanger and heat exchanger. Inspection Inspection (See SER SER components components exposed to Inspection Inspection of Section treated water Internal Intemal 3,~4.2.2.

3.4.2.2.7)7)

(3.4.1-16) Surfaces in Surfaces in Miscellaneous Miscellaneous Piping and Ducting Ducting Components Components Stainless steel piping, Loss of material material due Plant specific Yes Buried Piping Consistent piping components, and to pitting and crevice and Tanks with GALL piping elements corrosion Inspection Inspection Report (See exposed to soil program SER Section (3.4.1-17) 3.4.2.2.7)

Copper alloy piping, Loss of material due Lubricating Oil Yes Lubricating Oil Lubricating Consistent piping components, and to pitting and crevice crevice Analysis Analysis and Analysis with GALL piping elements elements corrosion One-Time and One-Time Report (See exposed to lubricating oil Inspection Inspection Inspection Inspection SER Section Section (3.4.1-18) 3.4.2.2.7)

Stainless steel piping, Loss of material material due Lubricating Lubricating Oil Yes Lubricating Oil Consistent Consistent piping components, to pitting, crevice, and Analysis and Analysis with GALL piping elements, and microbiologically-microbiologically- One-Time One-Time One-Time (See SER heat exchanger influenced corrosion influenced corrosion Inspection Inspection Inspection Section components exposed to components exposed Inspection of 3.4.2.2.8) lubricating oil Internal (3.4.1-19) Surfaces in Surfaces Miscellaneous Miscellaneous Piping and Piping and Ducting Ducting Components Components 3-334 3-334

""'Component Group ,ging "'AMP in GALL Further AMP in, LRA, Staff (GALL Report ,' EffectlMechanism Report Evaluation S upplements, Evaluation Item No.) innGALL or

_____________________________Report Amnen~dments Steel tanks exposed to Loss of material, material, Aboveground Aboveground No Above ground ground Consistent air - outdoor outdoor (external) general, pitting, and general, Steel Tanks Steel Tanks Steel GALL with GALL (3.4.1-20) crevice crevice corrosion Report High-strength steel High-strength Cracking Cracking due to cyclic Bolting Integrity Integrity No applicable Not applicable Not Not closure bolting bolting exposed exposed loading, loading, stress ' Applicable Applicable to to air with steam or corrosion cracking corrosion cracking TMI-1 (See water leakage leakage SER Section (3.4.1-21))

(3.4.1-21 3.4.2.1.1) 3.4.2.1.1)

Steel bolting and closure closure Loss of material due Bolting Integrity Integrity No External Consistent bolting exposed to air to general, pitting and Surfaces Surfaces with GALL with steam or water crevice corrosion; crevice corrosion; loss Monitoring Monitoring Report (See leakage, air - outdoor of preload preload due to Program Program SER Section (extemal), or air - indoor (external), thermal effects, Bolting Integrity 3.4.2.1.2) uncontrolled (external);

uncontrolled gasket creep, and Program Program (3.4.1-22) self-loosening self-looseninQ Stainless steel piping, Cracking due to stress Closed-Cycle Closed-Cycle No Not applicable Not Not

. piping components, and corrosion cracking Cooling Water applicable to piping elements System TMI-1.

TMI-1. (See exposed to closed-cycle SER Section cooling water water> > 60°C 3.4.2.1.1) 3.4.2.1.1)

(> 140°F) 140°F)

(3.4.1-23)

Steel heat heat exchanger exchanger Loss of material due due Closed-Cycle Closed-Cycle No No Not applicable Not components exposed exposed to to general, pitting, pitting, Cooling Water applicable to closed cycle cooling cooling crevice, galvanic crevice, and galvanic System TMI-1 (See (See water water corrosion corrosion SER Section (3.4.1-24) 3.4.2.1.1) 3.4.2.1.1)

Stainless steel piping, Loss of material material duedue Closed-Cycle No Not applicable applicable Not piping components, to pitting and crevice Cooling Water applicable applicable to piping elements, and corrosion corrosion System TMI-1 (See exchanger heat exchanger SER Section components components exposed exposed to 3.4.2.1:1))

3.4.2.1:1 closed closed cycle cooling cooling water .

(3.4.1-25)

Copper Copper alloy piping, Loss of material material due Closed-Cycle No Not applicable Not piping components, components, and to pitting, pitting, crevice, andand Cooling Water applicable to piping elements elements galvanic corrosion System TMI-1 (See exposed to closed cycle exposed SER Section cooling water water 3.4.2.1.1))

3.4.2.1.1 (3.4.1-26)

Steel, stainless steel, Reduction of heat Reduction Closed-Cycle Closed-Cycle No Not applicable applicable Not and copper alloy heat transfer due to fouling Cooling Cooling Water Water applicable to applicable exchanger tubes tubes System TMI-1 (See exposed to closed closed cycle cycle SER Section cooling water 3.4.2.1.1))

3.4.2.1.1 (3.4.1-27) 3-335 3-335

Component Group Aging AMP -.in GALL . urther AMP i-LA..Staf (GALL Report Effect/Mechanism Report Evaluation. Supplements, LEvailuatiohi Item No.) in GALL> or

_______________Repoh-,

_________________ Amendments______

Steel external surfaces Steel external surfaces Loss of Loss material due ofmaterial due External External No No External External Consistent Consistent exposed to exposed air--indoor toair indoor to general corrosion to general corrosion Surfaces Surfaces Surfaces Surfaces with GALL with GALL uncontrolled (external),

uncontrolled (external), Monitoring Monitoring Monitoring Monitoring Report Report condensation (external),

condensation (external),

or airoutdoor or air outdoor (external)

(external)

(3.4.1-28)

Steel piping, piping Steel piping, piping thinning due Wall thinning Wall due to to Flow-Flow- No No Flow-Flow- Consistent C.onsistent components, and components, and piping piping flow-accelerated flow-accelerated Accelerated Accelerated Accelerated Accelerated with GALL with GALL elements exposed to elements exposed to corrosion corrosion Corrosion Corrosion Corrosion Corrosion Report Report steam steam or treated water ortreated water (3.4.1-29)

(3.4.1-29) piping, piping Steel piping, Steel piping Loss of Loss material due of material due Inspection of Inspection of No No Inspection of Inspection of Consistent Consistent components, and components, and piping piping to to general, pitting, and general, pitting, and Internal Internal Internal Internal with with GALL GALL elements exposed to elements exposed to air air crevice corrosion crevice corrosion Surfaces in Surfaces in . Surfaces in Surfaces in Report Report outdoor (internal) or outdoor (internal) or Miscellaneous Miscellaneous Miscellaneous Miscellaneous condensation (internal) condensation (internal) Piping and Piping and Piping and Piping and (3.4.1-30)

(3.4.1-30) Ducting Ducting Ducting Ducting Components Components Components Components Steel heat exchanger Steel heat exchanger Loss of Loss material due of material due Open-Cycle Open-Cycle No No Open-Cycle Open-Cycle Consistent Consistent components exposed components exposed to to to general, pitting, to general, pitting, Cooling Water Cooling Water Cooling Water Cooling Water with GALL with GALL raw water raw water galvanic, and crevice, galvanic, crevice, and System System System System Report.

Report.

(3.4.1-31)

(3.4.1-31 ) microbiologically-microbiologically-influenced corrosion, influ~nced corrosion, and fouling_

and fouling Stainless steel and Stainless steel and Loss of Loss material due of material due Open-Cycle Open-Cycle No No Not applicable Not applicable Not Not alloy piping, copper alloy copper piping, to to pitting, crevice, and pitting, crevice, and Cooling Water Cooling Water applicable to applicable to components, and piping components, piping and microbiologically-microbiologically- System System TMI-1 (See TMI-1 (See piping elements piping elements influenced corrosion influenced corrosion SER Section SER Section exposed to exposed raw water to raw water 3.4.2.1.1) 3.4.2;1.1)

(3.4.1-32)

Stainless steel heat Stainless steel heat Loss of Loss material due of material due Open-Cycle Open-Cycle No No Open-Cycle Open-Cycle Consistent Consistent exchanger components exchanger components to to pitting, crevice, and pitting, crevice, and Cooling Water Cooling Water Cooling Water Cooling Water with GALL with GALL exposed to exposed raw water to raw water microbiologically-microbiologically- System System System System Report.

Report.

(3.4.1-33)

(3.4.1-33) influenced corrosion, influenced corrosion, and fouling_

and fouling stainless steel, Steel, stainless Steel, steel, Reduction of Reduction of heat heat Open-Cycle Open-Cycle No No Open-Cycle Open-Cycle Consistent Consistent copper alloy and copper and alloy heat heat transfer due transfer due to to fouling fouling Cooling Water Cooling Water Cooling Water Cooling Water with GALL with GALL exchanger tubes exchanger tubes System System System System Report Report exposed to exposed raw water to raw water (3.4.1-34)

(3.4.1-34)

Copper alloy Copper alloy> 15% Zn

> 15% Zn Loss of Loss material due of material due Selective Selective No Selective Selective Consistent Consistent No piping, piping piping, piping to selective leaching to selective leaching Leaching of Leaching of Leaching Leaching with GALL with GALL components, and components, and piping piping Materials Materials Report Report elements exposed to elements exposed to closed cycle cooling closed cycle cooling raw water, water, raw water, oror treated water treated water (3.4.1-35)

(3.4.1-351 3-336 3-336

- . ;. Comrponent c~J;~~~~ht:~~~~~<:5*t (GALL Reiprt' Group C\::.**~~;.:ir;.*~~i~*~*:?:;.:,.:f.:~J.rr~~~'i;~~~~t~:;';:i7;'.iff~4~~{J**

Aging Effect/Mechanism AMP in GALL.

Report Further.

Evaluation 0*;};~g~k;i~:L~**.*

AMP in LRA, 1****;***~**St~~':.~*

E Stf

.' ',: (GALl,*Repo.rt:;*** :EffectilYlechants~ ... .. R~P,9rt*;: '.':" ~y~l!Jatlol1§.;(,.~S~p'plE!rnE!nts;* ,:Evah.I~~lon GALL or' Amendments' ':'",.:,:,,::; <::-,-

.;~. ~,!tE!~T~~} ..'.~;.,~. *: ;**.::*X: ***.:~...:.*,***,.~.:i:.*i:':: ,\. , **'~.i.:;".,.*. . ':."6h~~Ipt~;:':S::'~rri'~n~~~~~:

l tem .No.)n

-~Re'port. .

Gray Gray cast cast iron iron piping, piping, Loss Loss of material due of material due Selective Selective No No Selective Selective Consistent Consistent piping components, piping components, and and to selective leaching to selective leaching Leaching of Leaching of Leaching Leaching with with GALL GALL piping elements piping elements Materials Materials Report Report exposed to exposed to soil, soil, treated treated water, or water, raw water or raw water (3.4.1-36)

(3.4.1-36)

Steel, stainless steel, Steel, stainless steel, Loss Loss ofof material material due due Water Chemistry Water Chemistry No No Water Water Consistent Consistent and nickel-based alloy and nickel-based alloy to pitting and to pitting and crevice crevice Chemistry Chemistry with with GALL GALL piping, piping, piping piping corrosion corrosion Report Report components, and components, and piping piping elements exposed elements exposed to to steam steam (3.4.1-37)

(3.4.1-37)

Steel bolting Steel bolting andand Loss Loss of of material material due due Boric Boric Acid Acid No No Boric Boric Acid Acid Consistent Consistent external external surfaces surfaces to boric acid corrosion to boric acid corrosion Corrosion Corrosion Corrosion Corrosion with GALL with GALL exposed to exposed to air air with with Report Report borated water borated water leakage leakage (3.4.1-38)

(3.4.1-38)

Stainless steel Stainless steel piping, piping, Cracking Cracking due due to to stress stress Water Chemistry Water Chemistry No No Water Water Consistent Consistent piping components, and piping components, and corrosion cracking corrosion cracking Chemistry Chemistry with with GALL GALL piping elements piping elements Report Report exposed exposed to to steam steam (3.4.1-39)

(3.4.1-39)

Glass Glass pipingpiping elements elements None None None None No No None None Consistent Consistent exposed exposed to to air, air, with GALL with GALL lubricating lubricating oil, raw water, oil, raw water, Report Report and treated and treated water water (3.4.1-40)

(3.4.1-40)

Stainless steel, Stainless steel, copper copper None None None None No No None None Consistent Consistent alloy, alloy, and nickel alloy and nickel alloy with with GALL GALL piping, piping, piping piping Report Report components, and components, and piping piping elements exposed elements exposed to to air air indoor uncontrolled

-- indoor uncontrolled (external)

(external)

(3.4.1-41)

Steel Steel piping, piping, piping piping None None None None No No None None Not Not components, and components, and piping piping applicable applicable to to elements elements exposedexposed to to air air TMI-1 (See TMI-1 (See indoor controlled

-- indoor controlled SER SER Section Section (external)

(external) 3.4.2.1.1) 3.4.2.1.1)

(3.4.1-42)

Steel Steel and stainless steel and stainless steel None None None None No No None None Consistent Consistent piping, piping, pipingpiping with GALL with GALL components, and components, and piping piping Report Report elements in elements in concrete concrete (3.4.1-43)

(3.4.1-43) 3-337 3-337

GopAngMP Component~ inGL ute M in IRA, Staff (GALL Report Effect/Mechanism Report Evaluation Supplements, Evaluation Item ~ IinGALL eort~

O o r-Amendmni6hts k

Steel, Steel, stainless stainless steel, steel, None None None None No None Consistent aluminum, and aluminum, and copper copper with GALL alloy alloy piping, piping, piping piping Report components, components, and and piping piping elements exposed to elements exposed to gas gas (3.4.1-44) 3.4.1-44 staff's review The staff's The review of of the steam and the steam and power conversion system power conversion system component followed several groups followed component groups several approaches.

approaches. One One approach, approach, documented documented in in SER SER Section Section 3.4.2.1, 3.4.2.1, discusses discusses thethe staff's staff's review review of of AMR AMR results results for for components components the the applicant applicant indicated indicated are are consistent consistent with with the the GALL GALL Report Report and and require require no no further further evaluation.

evaluation. AnotherAnother approach, approach, documented documented in in SER SER Section Section 3.4.2.2, 3.4.2.2, discusses discusses the staff's review of AMR results for components the applicant indicated the staff's review of AMR results for components the applicant indicated are consistent withlthe are consistent withl!the GALL GALL ReportReport and and for for which which further further evaluation evaluation is is recommended.

recommended. A A third third approach, approach, documented documented in in SER SER Section Section 3.4.2.3, 3.4.2.3, discusses discusses the the staffs staffs review review of of AMR AMR results results for for components components the the applicant applicant indicated indicated are are not not consistent consistent with with oror not not addressed addressed in in the the GALL GALL Report.

Report. The The staff's staff's review review of of AMPs AMPs credited credited to to manage manage or or monitor monitor agingaging effects effects of of the the steam steam and and power power conversion conversion system system .

components components is is documented documented in in SER SER Section Section 3.0.3.

3.0.3.

3.4.2.1 3.4.2.1 AMR AMR Results Results That That Are Are Consistent Consistent with with thethe GALL GALL Report Report LRA LRA Section Section 3.4.2.1 3.4.2.1 identifies identifies the the materials, materials, environments, environments, AERMs, AERMs, and and the the following following programs programs that manage aging that manage aging effects effects for for the steam and the steam and power power conversion system components:

conversion system components:

- Aboveground Aboveground Steel Steel Tanks Tanks

Bolting Bolting Integrity Integrity

- Boric Boric Acid Acid Corrosion Corrosion

"* Buried Buried Piping Piping and and Tanks Tanks Inspection Inspection

- External Surfaces External Surfaces Monitoring Monitoring.

- Flow Flow Accelerated Accelerated Corrosion Corrosion

"* Inspection Inspection of of Internal Internal Surfaces Surfaces in in Miscellaneous Miscellaneous Piping Piping and and Ducting Ducting Components Components

- Lubricating Oil Lubricating Oil AnalysisAnalysis

- One-time One-time Inspection Inspection

"* Open Open CycleCycle Cooling Cooling WaterWater System System

- Selective Selective Leaching Leaching of of Materials Materials

- TLAA TLAA

- Water Water Chemistry Chemistry

,.

LRA LRA Tables Tables 3.4.2-1 3.4.2-1 through through 3.4.2-8 3.4.2-8 summarize summarize the the AMRs AMRs for for the the steam steam andand power power conversion conversion system components and indicate AMRs claimed to be consistent system components and indicate AMRs claimed to be consistent with the GALL Report. with the GALL Report.

For For component component groups groups evaluated evaluated in in the the GALL GALL Report Report for for which which thethe applicant applicant had had claimed claimed :~

consistency and for which the GALL Report does not recommend consistency and for which the GALL Report does riot recommend further evaluation, the further evaluation, the staff staff 3-338 3-338

performed performed an audit and review to determinedetermine whether whether the plant specific components in these GALL Report Report component component groups groups were bounded by the GALL Report evaluation.

The applicant applicant provided a note for each AMR line item. The notes describe describe how the information information in the tables aligns with the information information in the GALL Report. The staff auditedaudited those AMRs AMRs with Notes A through E, whichwhich indicate how the AMR AMR was consistent consistent with the GALL Report.

Note A indicates Note indicates that the AMR line item is consistent with the GALL GALL Report for component, material, environment, material, environment, and aging effect. In addition, the AMP is consistent with the GALL Report AMP. The staff audited these line items to verify consistency consistency with the GALL Report the Report and the validity of the AMR AMR for the site-specific site-specific conditions.

Note B indicates indicates that the AMR line item is consistent consistent with the GALL Report for component, material, environment, and aging effect. In addition, the AMP takes some exceptions to the AMP material, AMP identified in the GALL Report. The staff audited audited these line items to verify consistency with the the GALL Report and confirmed confirmed that it had reviewed accepted the identified reviewed and accepted identified exceptions exceptions to thethe GALL Report Report AMPs. The staff also determined determined whether the AMP identified identified by the applicant was was consistent with the AMP identified identified in the GALL GALL Report and whether the AMR was valid for the the site-specific site-specific conditions.

Note C indicates indicates that the component component for the AMR line item, although different from, is consistent consistent with the GALL Report Report for material, environment, and aging effect. In addition, the AMP is consistent identified by the GALL consistent with the AMP identified GALL Report. This note indicates indicates that the applicant was was unable to find a listing of some system componentscomponents in the GALL Report; however, the applicant applicant identified a different component in the GALL Report that had different component had the same material, environment, aging effect, and AMP as the component component under review. The staff audited audited these line items to verify consistency consistency with the GALL GALL Report and determined whether determined whether the AMR line item of the different different component applied component applied to the component under review and whether the AMR was valid for the site-specific specific conditions.

Note 0 Note D indicates indicates that the component component for the AMR different from, is consistent AMR line item, although different with the GALL Report for material, environment, and aging effect. In addition, the AMP takes with some exceptions exceptions to the AMP identified identified in the GALL Report. The staff audited audited these line items to verify consistency with the GALL Report and confirmed whether whether the AMR line item of the different different component component was applicable to the component under under review. The staff confirmed whether it had reviewed reviewed and accepted accepted the exceptions exceptions to the GALL GALL Report AMPs. It It also determined determined whether the the AMP identified identified by the applicant was consistent with the AMP identified identified in the GALL Report and and whether the AMR was valid for the site-specific site-specific conditions.

Note Note E indicates indicates that the AMRAMR line item is consistent consistent with the GALL Report Report for material, environment, and aging effect, but a different AMP is credited. The staff audited audited these line itemsitems to verify consistency with the GALL Report, and determined determined whether the identified identified AMP would would manage the aging effect consistent manage consistent with the AMP identified in the GALL Report and whether the the AMR was valid for the site-specific conditions.

The staff audited The staff and reviewed audited and reviewed the information in the LRA. The staff did not repeat its review of of the the matters described in the GALL Report; however, the staff did verify that the material matters described presented in the LRA was applicable presented applicable and that the applicant identified identified the appropriate appropriate GALL Report AMRs. The staffs staff's evaluation follows.

3-339

3.4.2.1.1 ARM Results Identified Identified as Not Applicable Applicable Based on its initial review, the staff could not determinedetermine the specific reason why the applicant considered LRA Table 3.4.1, line items Table 3.4.1, 21, 23 to 27,32, items 21,23 27, 32, and 42 to be not applicable. RAI-AMR-applicable. In RAI-AMR-Generic-I, dated October Generic-1, October 16, 2008, the staff requested applicant provide additional requested that the applicant information regarding information regarding these not applicable applicable line items so the staff could complete its evaluation. evaluation.

In its response to the RAI dated NovemberNovember 12, 12, 2008, the applicant stated stated that "Not Applicable" has been been used when the component, material and environment environment combination does not exist in the the identified GALL system grouping identified grouping and also when the component, material and environment environment combination does exist but the LRA Table 3.x.1 item was not used because because a different different Table 3.x.1 item was selected to manage the identifiedidentified aging effect/mechanism.

effect/mechanism.

Based on its review, the staff finds the applicant's applicant's response to RAI-AMR-Generic-1 RAI-AMR-Generic-1 unacceptable unacceptable because the applicant because provide the specific reasons it used to consider the subject line applicant did not provide lide items in LRA Table Table 3.1.1 not applicable and the staff could not complete complete its review.

RAI-AMR-Generic-2, dated In RAI-AMR-Generic-2, dated January January 5, 2009, the staff requested requested that the applicant indicate for each each of the LRA Table 3.x.1 3.x. 1 items were "not applicable" is listed in the "discussion" column,' the the specific specific reason why the item is considered applicable to TMI-1.

considered not applicable TMI-1. The staff also requested requested that if the component, material material and environment environment does exist but the LRA Table 3.x.1 item was not used, that the applicant applicant indicate indicate what other 3.x.1 item was selected selected to manage identified aging manage the identified effect/mechanism.

effect/mechanism.

In its response to the RAI dated January 12, 2009, the applicant applicant provided a table identifying identifying thethe specific reason(s) why a Table 3.x.1 item is not considered considered applicable applicable to TMI-1.

TMI-1. I Based Based on its review, the staff finds the applicant's applicant's response to RAI AMR-Generic-2 AMR-Generic-2 acceptable acceptable because because the applicant provided provided the basis for LRA Table 3.x.1 line items identified identified as "not applicable." The staffs concern described in RAI staffs concern described RAI AMR-Generic-2AMR-Generic-2 is resolved.

LRA Table 3.4.1, 3.4.1, Item 21 addresses addresses high strength steel closure bolting exposed exposed to air with steam or water leakage. The GALL Report recommends recommends the BoltingBolting Integrity AMP to manage manage cracking cracking due to cyclic loading, loading, stress corrosion cracking in this component group. In the applicant's applicant's response response to RAI-AMR-Generic-2, RAI-AMR-Generic-2, the applicantapplicant stated that this line item is not applicable applicable because because there is no high-strength high-strength steel closure bolting exposed exposed to air with steam or water leakage leakage in:in steam and power conversion systems. The staff reviewed reviewed LRA Sections 2.3.4 2.3.4 and 3.4 and confirmed that TMI-1 TMI-1 does not have support systems that are part of the steam and power conversion systems with-in the scope of license renewal that contain the high strength bolting strength closure bolting fabricated fabricated from steel exposed exposed to air with steam or water leakage. Based on its review of the LRA, the staff confirmed that there is no high-strength high-strength steel steel closure bolting exposed to air with steam or water leakage in steam and power water leakage power conversion conversion systems, and therefore, finds the applicant's'] applicant's' determination determination acceptable.

3.4.1, Item LRA Table 3.4.1, Item 23 addresses addresses stainless stainless steel piping, piping components, and piping elements elements exposed exposed to closed cycle cooling water greater than 60° 600 C (greater than 140°F). 1400 F). The The GALL GALL Report recommends recommends the Closed Cycle Cooling Water System AMP to manage cracking due to stress corrosion cracking cracking in this component component group. In the applicant's response response to RAI- RAI-AMR-Generic-2, AMR-Generic-2, the applicant applicant stated stated that this line item is not applicable because because there are no no stainless steel piping, piping components, and piping elements exposed exposed to closed-cycle cooling closed-cycle cooling water greater than 60° 600 C (greater than 140°F)140 0 F) in steam and power conversion conversion systems. The staff staff reviewed LRA Sections 2.3.4 and 3.4 and confirmed confirmed that TMI-1 does does not have support systems systems that are part part of the steam and power conversion conversion systems with-in the scope of license license renewal that 3-340

contain the piping, piping components and piping elements fabricated fabricated from stainless stainless steel exposed to closed cycle cooling water greater than 60 140'F). Based 60° C (greater than 140°F). Based on its review of the LRA, the staff confirmed confirmed that there are no stainless steel piping, piping components, and piping elements exposed exposed to closed-cycle closed-cycle cooling water greater than 600 60° C (greater than 0

140 F) in steam and power conversion conversion systems, and therefore, finds the applicant's applicant's determination determination 140°F) acceptable.

acceptable.

LRA Table 3.4.1, 3.4.1, Item 24 addresses addresses steel heat exchanger exchanger components components exposed to closed cycle cycle cooling water. The GALL Report cooling Report recommends Closed Cycle Cooling Water System AMP to recommends the Closed manage loss of material due to general, pitting, crevice, and galvanicgalvanic corrosion. In the applicant's applicant's response response to RAI-AMR-Generic-2, RAI-AMR-Generic-2, the applicant applicant stated stated that this line item is not applicable applicable because because steel steam and power conversion systems heat exchanger components exposed components exposed to closed cycle cycle cooling water have been included auxiliary systems closed cycle cooling water included in the auxiliary water system and references references LRA Section 2.1.6.1. The applicant also stated that this component, material, Section 2.1.6.1.

environment, and agingaging effect combination combination is addressed addressed by item 3.3.1-47 3.3.1-47 from the auxiliary systems grouping grouping since galvanic galvanic corrosion as identified identified in item 3.4.1-24 does not apply to these exchanger components.

heat exchanger components. Based Based on its review of the LRA, the staff confirmed that steel steam and power conversion systems heat exchanger components exposed to closed cycle cooling heat exchanger cooling water have been included in the auxiliary systems systems closed cycle cooling water system. The staff staff also confirmed that this component, material, environment, and aging effect combination is addressed auxiliary systems grouping addressed by item 3.3.1-47 from the auxiliary grouping since galvanic corrosion as as identified identified in item 3.4.1-24 does not apply to these heat exchanger components. The staff finds the exchanger components. the applicant's determination applicant's determination acceptable.

LRA Table 3.4.1, Item 25 addresses stainless steel Table 3.4.1, steel piping, piping components, piping elements, exchanger components and heat exchanger components exposed exposed to closed cycle cooling water. The GALL Report recommends the Closed recommends Closed Cycle Cooling Water Water System AMP to manage manage loss of material due to pitting and crevice corrosion in this component group. In the applicant's response response to RAI-AMR-Generic-2, RAI-AMR-Generic-2, the applicant applicant stated that this line item is not applicable applicable because because there is no no stainless steel piping, piping components, piping elements, and heat exchanger components heat exchanger components exposed to closed cycle cooling water in steam and power conversion conversion systems. The staff staff reviewed LRASections reviewed LRA Sections 2.3.4 and 3.4 and confirmed that TMI-1 TMI-1 does does not have support systems systems that are part of the steam and power power conversion conversion systems with-in the scope of licenselicense renewal that contain the piping, piping components, piping elements elements and heat exchanger exchanger components components fabricated fabricated from stainless stainless steel exposed exposed to closed cycle cooling water. Based Based on its review of the the LRA, the staff confirmed that there are no stainless steel piping, piping components, piping piping elements, and heatheat exchanger exchanger components exposed exposed to closed cycle cooling cooling water in steam and power conversion systems, and therefore, therefore, the staff finds the applicant's applicant's determination acceptable.

determination acceptable.

3.4.1, Item 26 addresses LRA Table 3.4.1, addresses copper alloy piping, piping components, and piping elements elements exposed exposed to closed cycle cooling water. The GALL Report recommends Report recommends the Closed Cycle Cooling Cooling Water System AMP to manage loss of material due to pitting, crevice, and galvanic corrosion in this component group. In the applicant's applicant's response response to RAI-AMR-Generic-2, RAI-AMR-Generic-2, the applicant applicant stated that this line item is not applicable applicable because there is no copper alloy piping, piping components, and piping elements exposed to closed cycle cooling water in steam and power conversion conversion system. The staff reviewed reviewed LRA Sections Sections 2.3.4 and 3.4 and confirmed confirmed that TMI-1 does not have have support systems that are part of the steam and power power conversion systems systems with-in the scope of license renewal that contain the piping, license piping, piping components and piping elements elements fabricated from copper alloy exposed to closed cycle cooling water. Based on its review of the LRA, the staff staff confirmed that there is no copper copper alloy piping, piping components, and piping elementselements exposed 3-341

to closed cycle cooling conversion systems, and therefore, the st~ff cooling water in steam and power conversion staff determination acceptable.

finds the applicant's determination acceptable.

LRA LRA Table 3.4.1, 3.4.1, Item Item 27 addresses steel, stainless steel, and copper alloy alloy heat exchanger exchanger tubes tubes exposed to closed cycle cooling exposed cooling water. The GALL GALL Report Report recommends recommends the Closed Cycle Cooling Water System System AMP to manage reduction of heat transfer due to fouling in this component group. g'roup.

In the applicant's applicant's response to RAI-AMR-Generic-2, RAI-AMR-Generic-2, the applicant stated that this line item is not applicable because there is no steel, stainless steel, or copper alloy heat exchanger applicable exchanger tubes tubes I exposed to closed cycle cooling water with an intended function of heat transfer transfer in steam and power conversion systems. The staff reviewed LRA Sections 2.3.4 and 3.4 and confirmed confirmed that TMI-1 does does not have support systems that are part of the steam and power conversion systems syst~ms with-in the scope of license renewal that contain the heat exchanger exchanger tubes fabricated from steel, stainless steel and copper copper alloy exposed to closed cycle cooling water. Based Based on its review of the the LRA, the staff confirmed confirmed that there is no steel, stainless steel, or copper alloy heat exchanger exchanger tubes exposed exposed to closed cycle cooling water with an intended intended function of heat transfer in stJam steam and power conversion conversion systems, and therefore, the staff finds the applicant's determination determination acceptable.

acceptable.

LRA Table Table 3.4.1, 3.4.1, Item Item 32 addresses stainless steel and copper alloy piping, piping components, and piping elements elements exposed to raw water. The GALL Report recommends the Open Open Cycle Cycle Cooling Water System AMP to manage manage loss of material due to pitting, crevice, and '

microbiologically-influenced corrosion microbiologically-influenced corrosion in this component applicant's response to component group. In the applicant's RAI-AMR-Generic-2, the applicant RAI-AMR-Generic-2, applicant stated that this line item is not applicable because it predicts applicable because predicts the additional additional aging effect/mechanism effect/mechanism of loss of material/fouling material/fouling for stainless stainless steel in raw water.

The applicant also statedstated that this component, material, environment, and aging ,

effect/mechanism combination effect/mechanism addressed by item 3.4.1-33. Based on its review of the LRA, the combination is addressed the staff confirmed that the applicant predicts the additional additional aging effect/mechanism aging effect/mechanism of loss of material/fouling for stainless material/fouling stainless steel in raw water and also confirmed confirmed that this component, material, environment, and aging effect/mechanism effect/mechanism combination is addressed addressed by item item 3.4.1-33.

3.4.1-33. The staff staff finds the applicant's applicant's determination determination acceptable.

LRA 3.4.1, Item 42 addresses LRA Table 3.4.1, addresses steel piping, piping piping components, and piping element exposed to air - indoor exposed indoor controlled (external). The GALL Report Report does not recommend an AMP A~P as as there is no aging effect/mechanism effect/mechanism in this component component group. In the LRA, the applicant stated that indoor air (controlled)

(controlled) environment environment is not used for steam and power conversion systems. The staff staff reviewed LRA Sections reviewed Sections 2.3.4 and 3.4 and confirmed confirmed that TMI-1 does does not have support support systems systems that are part of the steam power conversion systems with-in the scope of license steam and power license renewal that contain the piping, piping, piping components components and piping elements elements fabricated from steel exposed to air --

controlled (external). Based on its review of the LRA, the staff confirmed that indoor air indoor controlled air (controlled) environment environment is not used for steam and power power conversion conversion systems, and, therefqre, therefore, the the staff finds the applicant's determination determination acceptable.

acceptable. .

3.4.2.1.2 Material due to General, Pitting and Crevice 3.4.2.1.2 Loss Of Material Crevice Corrosion; Loss Of Preload Due to Thermal Effects, Gasket Creep, and Self-Loosening Self-Loosening LRA Table 3.4.1, 3.4.1, Item 3.4.1-22 addresses addresses loss of material due to general, pitting and crevice crevice corrosion for steel components components with its external external surfaces exposed to outdoor air in the surfaces exposed the Condensate Condensate System.

The LRA credits the External SurfacesSurfaces Monitoring Program to manage manage this aging effect effect for steel piping, fittings and and valve body components in an outdoor air (external) environment environment only. The The 3-342

GALLReport recommends GALL AMP XI.M1B, GALL Report recommends XI.M18, "Bolting Integrity,"

Integrity," to manage manage this aging effect.

The AMR line items that referencereference this line item in GALL Report Report Table 1 cite Generic Note E, indicating that the AMR line items are consistent with the GALL Report material, environment, and Report material; and aging effect, but a different management program is credited.

different aging management The staff reviewed reviewed the applicant's External External Surfaces Surfaces Monitoring Monitoring Program and its evaluation evaluation is documented documented in SER Section 3.0.3.2.16. 3.0.3.2.16. The staff staff noted from its review that the AMR items AMR line items that the referenced referenced Item 3.4.1-22 3.4.1-22 and credited the External Surfaces Monitoring Monitoring Program are not components with an intended function for mechanical bolting components mechanical closure. The staff further noted that the applicant referenced Item 3.4.1-22 of LRA Table 3.4.1 because there was not another applicant referenced another applicable Table applicable Table 1 line item in LRA LRA Table 3.4.1 that corresponded corresponded to the same material, environment environment and aging effect combination.combination.

The staff determined determined that the External Surfaces Monitoring Monitoring Program, Program, which includes periodic includes periodic visual inspections inspections of external performed during system walk downs, is adequate to external surfaces performed to manage loss of material material due to general, general, pitting and crevice corrosion for steel components components exposed (external) addressed by this AMR. On the basis of periodic visual exposed to outdoor air (external) inspections being inspections being performed during system walk downs of these components, performed components, the staff finds the the applicant's applicant's use of the External Surfaces Surfaces Monitoring program program acceptable.

LRA Table 3.4.1, 3.4.1, Item 3.4.1-22 addresses addresses loss of material due to general, general, pitting and crevice crevice corrosion corrosion for steel components with their external surfaces surfaces exposed to outdoor air or uncontrolled indoor indoor air in the feed water system, the emergency emergency feed water system and the main steam system, The staff noted that for those AMR system. AMR line items in LRA Section 3.4 in which the applicant applicant references Item references Item 3.4.1-22, the applicant listed the environment as air with borated borated water leakage, which is a more aggressive aggressive environment, compared compared to outdoor air or uncontrolled uncontrolled indoor air. The The staff confirmed confirmed in LRA Section 3.4 that for the same system, component, material and environment combination, environment combination, the applicant manages loss of material material due to boric acid corrosion with the Boric Acid Corrosion Program, recommend by the GALL Program, as recommend GALL Report.

The LRA credits the External Surfaces Surfaces Monitoring Monitoring Program to manage manage this aging effect for steel piping, fittings and valve body components piping, components in an air with borated water leakage environment water leakage environment only.

The GALL Report recommends recommends GALL AMP XI.M18, XI.M1B, "Bolting Integrity," to manage manage this aging thisaging effect. The AMR AMR line items that reference reference this line item in GALL GALL Report Table 1 cite Generic Note Note E, indicating indicating that the AMR AMR line items are consistent with the GALL Report Report material, environment, and aging effect, but a different different aging management management program is credited. credited.

The staff reviewed reviewed the applicant's External Surfaces Monitoring applicant's ExternalSLirfaces Monitoring program and its evaluation evaluation is documented in SER Section 3.0.3.2.16. The staff noted from its review that all AMR items AMR line items that the referenced referenced Item 3.4.1-21 and credited the External External Surfaces Monitoring Program are not bolting components components with an intended intended function for mechanical mechanical closure. The staff determined determined that the External Surfaces Surfaces Monitoring Monitoring Program, which includes includes periodic visual inspections inspections of external surfaces performed during system walk downs, is adequate to manage surfaces performed manage loss of material due to

general, general, pitting and crevice corrosion corrosion for steel components components exposed to air with borated water water leakage leakage environment environment addressed by this AMR. On the basis of periodic inspections being periodic visual inspections performed during performed during system walk downs of these components components by the External Surfaces Monitoring Monitoring Program, and the applicant applicant monitoring these components components with the Boric Acid Corrosion Program, Program, for loss of material material due to boric acid corrosion, the staff finds the applicant's applicant's use of the External Surfaces Monitoring Program acceptable.

Monitoring Program 3-343 3-343

Based on a review of the programs identified, identified, the staff determines determines that the applicant's proposed programs are acceptable managing acceptable for managing the aging effect in the applicable components. The staff staff demonstrated that the effects of aging for these components applicant has demonstrated concludes that the applicant components will be adequately adequately managed maintained consistent managed so that their intended function(s) will be maintained consistent with thethe period of extended CLB during the period operation, as required by 10 extended operation, 10 CFR 54.21(a)(3).

54.21(a)(3).

Material due to Pitting and Crevice 3.4.2.1.3 Loss of Material Crevice Corrosion Corrosion 3.5.1, Item 3.5.1-50 addresses loss of material LRA Table 3.5.1, material due to pitting and crevice corrosion for stainless steel components with their external surfaces exposed stainless exposed to outdoor air in the condensate noted that the applicant referenced system. The staff noted Item 3.5.1-50 of LRA Table referenced Item because Table 3.5.1 because there was not an applicable Table 1 line item in LRA Table 3.4.1 that corresponded corresponded to the sames~me material, environment and aging effect material, environment effect combination.

The LRA credits the External Surfaces Monitoring Monitoring Program manage this aging effect for !:lý Program to manage stainless steel piping, fittings and valve body components in an outdoor air (external) environment envirohment only. The GALLGALL Report recommends GALLAMP XI.S6, "Structures Monitoring recommends GALLAMP Monitoring Program," to manage this aging effect. The AMR line items that reference manage reference this line item in GALL Report Table liable 1 cite Generic Note E, indicating that the AMR AMR line items are consistent with the GALL Reporti Report material, environment, and aging effect, but a different management program is credited.

different aging management confirmed that only components that align to GALL The staff confirmed I11.B2-7 and are fabricated GALL Item III.B2-7 fabricated from stainless steel applicable to TMI-I.

steel materials, are applicable TMI-1.

Surfaces Monitoring Program and its evaluation reviewed the External Surfaces The staff reviewed documented in evaluation is documented Section 3.0.3.2.16. The staff finds that the External Surfaces SER Section Monitoring Program, Surfaces Monitoring Program, which periodic visual inspections of external surfaces include periodic performed during system walkdowns, is surfaces performed material due to pitting and crevice corrosion for stainless steel*

adequate to manage loss of material adequate steel components exposed components (external) addressed by this AMR. On the basis of periodic exposed to outdoor air (external) periodic performed during system walkdowns of these components, the staff finds visual inspections being performed finds the applicant's applicant's use of the External Surfaces Monitoring program acceptable.

Monitoring program acceptable.

Based on a review of the programs programs identified, the staff determines proposed determines that the applicant's proposed programs acceptable for managing the aging effect in the applicable programs are acceptable applicable components. The $taff staff demonstrated that the effects of aging for these components concludes that the applicant has demonstrated components will managed so that their intended be adequately managed intended function(s) function(s) will be maintained consistent with the maintained consistent the extended operation, as required CLB during the period of extended required by 10 CFR 54.21 54.21(a)(3).

(a)(3). .

3.4.2.2 AMR AMR Results That Are Consistent Consistentwith the GALL GALL Report, Further Report, for Which Further Evaluation Evaluation is is Recommended recommended by the evaluation of aging management, as recommended LRA Section 3.4.2.2 provides further evaluation the GALL Report for the steam and power conversion system components. The applicant proviped GALL provided manage the following information concerning how itit will manage following aging effects: '

oo Fatigue Damage Cumulative Fatigue Damage

- Loss of Material Material due due to General, Pitting, and Crevice Corrosion oo Loss of Material due to General, Pitting, Crevice, MIC, and Fouling Material due oo Reduction of Heat Transfer due. due to Fouling

- Material due to General, Pitting, Crevice, and MIC Loss of Material MIC 3-344

- Cracking Cracking due to SCC

- Loss loss of Material Material due to Pitting and Crevice Corrosion

- Loss of Material due loss due to Pitting, Pitting, Crevice, and MIC MIC

- Loss loss of Material due to General, General, Pitting, Crevice, and Galvanic Corrosion Corrosion component groups For component groups evaluated evaluated in the GALL Report Report for which the applicant applicant claimed consistency consistency GALL Report and for which the GALL Report recommends with the GALL recommends further evaluation, evaluation, the staff audited and reviewed the applicant's applicant's evaluations determine whether evaluations to determine whether they adequately address adequately address those issues and reviewed the applicant's applicant's further evaluations against against the criteria in SRP-LR SRP-LR Section 3.4.2.2. The staffs review of the applicant's applicant's further evaluations evaluations follows.

3.4.2.2.1 Cumulative Fatigue Damage Cumulative Fatigue Damage LRA Section 3.4.2.2.1 states that fatigue is a TLAA, as defined defined in 10 CFR 54.3. An applicant applicant must evaluate accordance with 10 CFR 54.21(c)(1). SER Section 4.3 documents the staffs evaluate TLAAs in accordance staffs review of the applicant's applicant's evaluation evaluation of this TLAA.

3.4.2.2.2 3.4.2.2.2 Loss of Material Material due to General, General, Pitting, Pitting, and Crevice Corrosion The staff reviewed reviewed LRA Section Section 3.4.2.2.2 against the criteria in SRP-LR SRP-LR Section Section 3.4.2.2.2.

(1) LRA Section 3.4.2.2.2.1 3.4.2.2.2.1 addresses loss of materialmaterial due to general, pitting, and crevice crevice corrosion corrosion in steel piping, piping, piping components, piping elements, tanks, and heat exchanger exchanger components components exposed to treated treated water or steam in the auxiliary auxiliary steam system, condensate condensate system, condensers condensers and air removal system, emergency feedwater system, extraction emergency feedwater extraction steam steam system, feedwater feedwater system, liquid and gas sampling system, main steam system, makeup and purification purification system (high pressure injection), miscellaneous miscellaneous floor and equipment equipment drains system, steam turbine and auxiliary system, system, and water treatment and distribution distribution system. The applicant applicant stated that the aging aging effect of loss of material due to general, components will be managed general, pitting and crevice corrosion in these components managed by a combination combination of the Water Chemistry Program and the One-Time One-Time Inspection Program. The The applicant applicant also stated that loss of material material due to general, pitting, and crevice corrosion in steel piping, piping components, components, piping elements, and and tanks exposed to treated treated water in in the closed-cycle cooling closed-cycle cooling water system will be managed by the Closed-Cycle Closed-Cycle Cooling Water System Program.

Water System Program.

The staff reviewed reviewed LRA Section Section 3.4.2.2.2 against the criteria in SRP-LR Section 3.4.2.2.2, which states that loss of material due to general, pitting, and crevice crevice corrosion may occuroccur in steel piping, piping components, piping elements, tanks, and heat exchanger exchanger exposed to treated water and for steel piping, piping components, and piping components exposed piping elements exposed elements exposed to steam. The SRP-LR SRP-LR states that the existing existing AMP relies on on monitoring and control of water chemistry to manage manage the effects of loss of material due to general, general, pitting, and crevice corrosion, corrosion, but that control of water chemistry does not material due to general, pitting, and crevice preclude loss of material crevice corrosion at locations with stagnant stagnant flow conditions; therefore, the effectiveness effectiveness of water chemistry chemistry control programs programs should be confirmed confirmed to ensure that corrosion corrosion does does not occur. The GALL Report recommends further evaluation evaluation of programs programs to verify the effectiveness effectiveness of water chemistry control control programs. The SRP-LR states that a one-time inspection inspection of selected components components and susceptible susceptible locations is an acceptable method method to ensure that corrosion does not occur 3-345

and that component intended intended functions maintained during functions will be maintained during the period of extended extended operation.

operation.

The staff reviewed the applicant's applicant's Water Water Chemistry Program and its evaluation is documented in SER Section 3.0.3.2.2. The staff finds that the program, with an documented enhancement, consistent with GALL enhancement, is consistent GALL AMP XI.M2, "Water Chemistry." The staff reviewed applicant's One-Time the applicant's One-Time Inspection program. The staff's staffs evaluation of this program, program, which is documented documented in SER SectionSection 3.0.3.2.14, determined determined that the One-Time One-Time Inspection.!

Inspection Program is consistent consistent with GALL AMP XI.M32, Inspection," and is adequate XI.M32, "One-Time Inspection," adequate to to detect the presence presence or note the absence of loss of material material in susceptible locations due to susceptible locations to general, pitting, and crevice corrosion corrosion for components components within the scope of the program.

Based Based on the staff's staffs determination determination that the applicant's applicant's Water Chemistry program provides provides mitigation and the applicant's mitigation applicant's One-Time Inspection Program provides detection for the the potential aging effect of loss of material material due to general, pitting, and crevice corrosion, the the staff finds the applicant's managing the aging effect of loss of material applicant's proposed AMPs for managing due to general, pitting, and crevice corrosion in steel piping, piping components, piping piping elements, tanks, and heat exchanger exchanger components components exposed exposed to treated treated water or steam in the auxiliary steam system, condensate condensate system, condensers and air removal system, emergency feedwater system, extraction extraction steam steam system, feedwater feedwater system, liquid arid and gas sampling system, main steam system, makeup and purification purification system (high pressure pressure miscellaneous floor and equipment drains system, steam turbine and auxiliary injection), miscellaneous system, and water treatment and distribution system to be acceptable. '

The staff noted that in LRA Table 3.3.2-43.3.2-4 ( LRA pages 3.3-154 and -159) -159) the applicant applicant included two (2) AMR result lines referring referring to LRA Table 3.4.1, 3.4.1, item 3.4.1-4, for carbon carbon steel piping and fittings and for valve bodies exposed to treated water in the closed cycle cycle cooling water system. For these components, the applicant applicant stated that the aging effect of loss of material material due to general, pitting, and crevice corrosion will be managed managed by the the Closed-Cycle Closed-Cycle Cooling Water System Program and cited generic generic note note E, indicating indicating that the the AMR result is consistent with the GALL material, environment, and aging~effect, GALL Report for material, aging effect, but a different AMP is credited.

credited. The staff reviewed the applicant's Closed-Cycle Cooling applicant's Closed-Cycle Cooling Water System Program Program and its evaluation is documented documented in SER Section 3.0.3.2.6. The The staff finds that the Closed-Cycle Cooling Closed-Cycle Cooling Water System Program, when enhanced, iIs is consistent with GALLGALL AMP XI.M21, XI.M21 , "Closed-Cycle Cooling Water." The staff found that the the applicant's Closed-Cycle applicant's Closed-Cycle Cooling Water System System Program includes preventive actions to to minimize corrosion and periodic inspection activities to detect corrosion.corrosion. Because Because the AMP AMP includes both preventive includes preventive actions and inspection inspection activities, the staff finds that the the applicant's use of the Closed-Cycle Closed-Cycle Cooling Water System Program for managing the the aging effect of loss of material due to general, general, pitting, and crevice corrosion in steel piping, piping components, piping elements and valves exposed to treated treated water in the closed cooling water system to be acceptable.

(2) LRA Section 3.4.2.2.2 addresses the loss of material material due to general, pitting, and crevice cr~vice corrosion in steel piping, piping components, components, and piping elements exposed exposed to lubricating lubricating oil stating that line item number 3.4.1-7 3.4.1-7 is not applicable to TMI-1.

TMI-1. The LRA also states that the lubricating lubricating oil environment environment in the steam and power conversion system includesincludes the additional aging mechanism of MIC and that Table 1 item number 3.4.1-12 3.4.1-12 applies.

The existing aging management management program program relies on the periodic periodic sampling and analysis of lubricating oil to maintain lubricating maintain contaminants contaminants within acceptable acceptable limits, thereby preserving preserving an environment that is not conducive environment conducive to corrosion. The GALL Report recommendsrecommends further evaluation of programs evaluation programs to manage manage corrosion corrosion to verify the effectiveness effectiveness of the lube oil 3-346

program. A one-time inspection chemistry control program.

chemistry components at susceptible inspection of selected components susceptible locations acceptable method to ensure locations is an acceptable ensure that corrosion is not occurring.

compared SRP-LR The staff compared SRP-LR Sections 3.4.2.2.2 and 3.4.2.2.5 and noted that both sections sections management of loss of material provide for management general, pitting and crevice corrosion in material due to general, in steel components by controlling effectiveness, in which controlling contaminants and a verification of effectiveness, applicant will utilize its Lubricating the applicant Analysis Program Lubricating Oil Analysis Program and verify the effectiveness effectiveness of the Lubricating Oil Analysis Program Program with the One-Time Inspection Program.

One-Time Inspection Program. The staff staff noted piping, piping components, and piping elements exposed to lubricating noted that steel piping, lubricating oil are part of the scope of LRA Section 3.4.2.2.5 and therefore general, crevice general, pitting and crevice corrosion will be managed in accordance corrosion accordance with GALL recommendations through the GALL Report recommendations the period period of extended operation.

operation.

reviewed the Lubricating Oil Analysis The staff reviewed Program and the One-Time Inspection Analysis Program Inspection Program Program and its evaluations documented in SER Sections 3.0.3.2.18 evaluations are documented 3.0.3.2.18 and 3.0.3.2.14, respectively. The staff finds that these programs provide for periodic programs 1) provide periodic sampling of lubricating oil to maintain contaminants lubricating acceptable limits to preclude contaminants at acceptable preclude loss of material and 2) will provide provide for one-time inspections of select steel components exposed to material due to general; lubricating oil for loss of material lubricating general, pitting and crevice corrosion corrosion at locations to verify the effectiveness of the applicant's Lubricating Oil Analysis susceptible locations Analysis Program in applicable Steam and Power systems. Therefore, Program Therefore, the staff finds that, based on identified above, the criteria of SRP-LR Section programs identified a review of the programs Section 3.4.2.2.2 3.4.2.2.2 is satisfied.

applicant's programs, the staff concludes that staff's review and evaluation of the applicant's Based on the staffs SRP-LR Section 3.4.2.2.2 applicant's programs satisfy SRP-LR the applicant's criteria. For those line items that apply 3.4.2.2.2 criteria.

determines that the LRA is consistent with the GALL Report to LRA Section 3.4.2.2.2, the staff determines demonstrated that the effects of aging will be adequately and that the applicant has demonstrated adequately managed so intended function(s) will be maintained that the intended maintained consistent with the CLB during the period of theCLB extended operation, as required extended required by 10 CFR 54.21(a)(3).

54.21(a)(3). .

3.4.2.2.3 Loss of Material

.3.4.2.2.3 Material due to General, Pitting, Crevice, and MIC, and Fouling The staff reviewed LRA SectionSection 3.4.2.2.3 against the criteria in SRP-LR Section 3.4.2.2.3.

3.4.2.2.3 addresses loss of material due to general, LRA Section 3.4.2.2.3 general, pitting, crevice, microbiologically-influenced corrosion and fouling in steel piping, piping components microbiologically-influenced piping components and piping exposed to raw water.

elements exposed elements SRP-LR Section 3.4.2.2.3 states that loss of material due to general, pitting, crevice, microbiologically-influenced corrosion and fouling may occur in steel piping, piping components microbiologically-influenced components exposed to raw water. The applicant stated that the Inspection elements exposed and piping elements Inspection of Internal Miscellaneous Piping and Ducting Surfaces in Miscellaneous Components Program will manage Ducting Components manage this aging effect effect in steel surfaces exposed to internal raw water.

internal surfaces steel internal The GALL Report, under Item VIII.G-36 recommends plant-specific program be credited to recommends that a plant-specific manage this aging effect effect for steel piping, piping components components and piping elementselements in the Steam and Power Conversion Systems.

The staff confirmed that only piping, fittings and tanks that align to GALL AMR VIII.G-36 for for the the Reactor Building Sump and Drain System and the Radwaste Reactor Building Radwaste System that are fabricated from 3-347

steel materials are applicable applicable to TMI that credit the Inspection Inspection of Internal Surfaces in in Miscellaneous Piping and Ducting Components Miscellaneous Components Program.

Program. The staff noted that these systems,system,s, in which the applicant applicant has referenced referenced Item VII.G-36, are not part of the Steam and Power Power Conversion Conversion Systems. The systems were grouped grouped together with this GALL AMR item because because the the material, environment, and aging aging effect combination combination corresponded.

corresponded. The staff confirmed, as stated in the LRA, that there are no steel piping, piping components and piping elements exposed exposed to raw water in the steam and power conversion systems. '

The staff reviewed reviewed the Inspection Inspection of Internal Internal Surfaces of Miscellaneous Miscellaneous Piping and Ducting Components Components Program Program and its evaluation evaluation is documented documented in SER Section 3.0.3.2.17. The staff finds finds that the Inspection Inspection of Internal Internal Surfaces Surfaces in Miscellaneous*Piping Miscellaneous Piping and Ducting Ducting Components Components Program Program requires requires visual inspections inspections of internal internal surfaces surfaces of components components during periodic system and component surveillance component surveillance activities or during maintenance maintenance activities when the internal su~ace internal surface becomes becomes accessible for visual inspections inspections to detect aging effectseffects that could result in a loss of the the component's intended intended function.

function. The staff finds that this program includes activities activities that are adequate to manage loss of material due to general, general, pitting, crevice, microbiologically-influenced microbiologically-influenced corrosion and fouling in steel piping, piping components components and piping elementselements exposed exposed to raw raw water on the internal surface.

Based on the staffs review and evaluation evaluation of the applicant's program, the staff concludes concludes that the the applicant's program meets SRP-LR Section SRP-LR Section 3.4.2.2.3 criteria criteria and, therefore, applicant's AMRs the applicant's AMRs are consistent with those under under GALL Report Items Items VII.G-36. For those line items that apply to to LRA Section 3.4.2.2.3, the staff determines determines that the LRA is consistent consistent with the GALL Report and that the applicant applicant has demonstrated demonstrated that the effects of aging will be adequatelyadequately managed so that the intended function{s) function(s) will be maintained maintained consistent with the CLB during the period period of ext~nded extended operation, as required required by 10 10 CFR 54.21(a)(3).

54.21{a)(3)~

3.4.2.2.4 Reduction of Heat 3.4.2.2.4 Heat Transfer due to Fouling Fouling The staff reviewed LRA Section 3.4.2.2.4 3.4.2.2.4 against against the criteria criteria in SRP-LR SRP-LR Section 3.4.2.2.4.

(1) LRA Section 3.4.2.2.4 addresses the applicant's aging managementbasis management basis for managingmanaging reduction of heat transfer reduction transfer due to fouling in stainless stainless steel heat exchanger components components exposed to treated water in the condenser condenser and air removal system. The applicant stated that the aging effect of reduction reduction of heat transfer due to fouling in these components components will be managed managed by a combination combination of the Water Chemistry Program and the One-Time One-Time Inspection Inspection Program.

Program.

The staff reviewed LRA Section Section 3.4.2.2.4 against the criteria in SRP-LR SRP-LR Section 3.4.2.2.4, which states that reduction of heat transfer due to fouling may occur occur for stainless steel and copper copper alloy heat exchanger exchanger tubes exposed to treated water. The SRP-LR SRP-LR states states that the the existing existing aging management program management program relies on control of water water chemistry to manage manage reduction reduction of heat transfer transfer due to fouling, but control of water chemistry always chemistry may not always have have been adequate to preclude preclude fouling. The GALL Report recommends recommends that the the ,

effectiveness of the water chemistry control effectiveness control program program should be confirmed to ensure that reduction of heat transfer due to fouling is not occurring.

reduction occurring. The SRP-LR SRP-LR states that a one-inspection is an acceptable time inspection acceptable method to ensure that reduction of heat transfer transfer is not occurring and that the component's intendedintended function will be maintained maintained during during the period of extended extended operation.

operation.

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staff reviewed the Water Chemistry Program The staff Program and its evaluation is documented documented in SER Section 3.0.3.2.2. The staffstaff finds that the Water Chemistry Program, with an an enhancement, is consistent with GALL enhancement, GALL AMP XI.M2, "Water Chemistry." The staff reviewed reviewed the applicant's applicant's One-Time One-Time Inspection ProgramProgram and evaluation is documented and its evaluation documented in SER Section 3.0.3.2.14. The staff finds that the One-Time Inspection Program One-Time Inspection Program is consistent consistent with GALL AMP XI.M32, "One-Time Inspection,"Inspection," and is adequate adequate to detect detect the presence presence or note the absence absence of heat exchanger exchanger tube fouling that might result in reduction of heat heat transfer for components within the scope of the program. Based on the staffs staffs determination applicant's Water determination that the applicant's Water Chemistry Program Program provides mitigation mitigation and thethe applicant's applicant's One-Time One-Time Inspection Inspection Program provides provides detection for the potential potential aging effect of reduction reduction in heat transfer transfer due to heat exchanger exchanger tube tube fouling, the staff finds the-applicant's proposed AMPs for managing applicant's managing the aging effect of reduction reduction of heat transfer due due to fouling in stainless steel heat exchanger exchanger components exposed to treated water in the the condenser condenser and air removal system to be acceptable. acceptable.

(2) LRA Section 3.4.2.2.4 3.4.2.2.4 states that the One-Time Inspection Program One-Time Inspection Program will be implemented implemented to verify the effectiveness effectiveness of the Lubricating Lubricating Oil Analysis Analysis Program, B.2.1.23, to manage manage the reduction reduction of heat transfer due to fouling in steel, stainless stainless steel, and copper alloy heat exchanger tubes exposed to lubricating exchanger lubricating oil in the closed cycle cooling water system, emergency diesel generators emergency generators and auxiliary auxiliary systems, and station blackout and uninterruptable power supply (UPS) diesel generator uninterruptable generator systems.

The staff reviewed LRA Section 3.4.2.2.4 against against the criteria in SRP-LR SRP-LR Section 3.4.2.2.4, which which states that reduction reduction of heat transfer due to fouling could occur occur for steel, stainless stainless steel, and copper alloy alloy heat exchanger exchanger tubes exposed to lubricating lubricating oil. Furthermore, Furthermore, thethe existing management program existing aging management* program relies on monitoring and control of lube oil chemistry to mitigate reduction of heat transfer due to fouling. The GALL Report recommends recommends further evaluation of programs to verify the effectiveness effectiveness of lube oil chemistry control program.

SRP-LR states a one-time inspection inspection of select components at susceptible susceptible locations is an acceptable method to determine acceptable determine whether whether an aging effect is not occurring or an aging effect is progressing very slowly.

The staff staff reviewed the Lubricating Lubricating Oil Analysis Program and the One-Time Inspection One-Time Inspection Program and its evaluations evaluations are documented documented in SER Sections 3.0.3.2.183.0.3.2.18 and 3.0.3.2.14, respectively. The staff finds that these programs 1) provide provide for periodic sampling of lubricating lubricating oil to maintain maintain contaminants contaminants at acceptable limits to precludepreclude loss of heat heat transfer due due to fouling and 2) will provide inspections of select provide for one-time inspections stainless select steel, stainless steel and copper alloy heat exchanger exchanger tubing exposed to lubricating lubricating oil for loss of heat transfer due due to fouling at susceptible susceptible locations to verify the effectiveness effectiveness of the Lubricating Lubricating Oil Analysis Program in applicable steam and power power conversion conversion systems.

Based on the staffs review and evaluation Based evaluation of the applicant's applicant's programs, the staff concludes that the applicant's applicant's programs programs meet 3.4.2.2.4 criteria.

meet SRP-LR Section 3.4.2.2.4 criteria. For those line items that apply apply to LRA Section Section 3.4.2.2.4, the staff determines that the LRA is consistent with the GALL Report and that the applicant has demonstrated demonstrated that the effectseffects of aging aging will be adequately adequately managed so that the intended function(s) function(s) will be maintained maintained consistent consistent with the CLB during the period of extended operation, operation, as required by 10 CFR 54.21(a)(3).

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3.4.2.2.5 Loss of Material Material due to General, Pitting, Crevice, and MIC MIC The staff reviewed LRA Section 3.4.2.2.5 3.4.2.2.5 against the criteria in SRP-LR Section 3.4.2.2.5.

(1) LRA Section 3.4.2.2.5 3.4.2.2.5 states the Buried Piping and Tanks InspectionInspection Program Program will be be implemented implemented to manage manage the loss of material due to general, pitting, crevice, and microbiologically-influenced corrosion in steel piping, piping components, microbiologically-influenced components, piping ele nents, elelj)1ents, and tanks exposed exposed to soil in the condensate condensate system and the emergency generators emergency diesel generators and auxiliary system.

The staff reviewed LRA SectionSection 3.4.2.2.5 3.4.2.2.5 against the criteria in SRP-LR 3.4.2.2.5, SRP-LR Section 3.4:2.2.5, which states states that loss of material due to general, general, pitting and crevice corrosion, and MIC MIC could occur in steel (with or without coating coating or wrapping) piping, piping components, piping piping elements and tanks exposed to soil. Furthermore, the effectiveness effectiveness of the buried piping piping and tanks inspection inspection program should be confirmed evaluate an applicant's confirmed to evaluate applicant's inspection inspedtion frequency frequency and operating experience experience with buried components, components, ensuring ensuring that loss of material is not occurring.

occurring.

The staff reviewed the Buried Piping and Tanks Inspection Program and its evaluation is documented documented in SER Section 3.0.3.2.15. The staff finds that this program program provides provides focused or opportunistic excavations and inspections for general, opportunistic excavations general, pitting, crevice, and ,

microbiologically-influenced corrosion of buried microbiologically-influenced buried steel piping and tanks within ten years before the period of extended extended operation and within ten years after the initiation of the operation arid the period of operation operation except for the buried diesel generator generator fuel storage 30,000 gallon tank 30,000 gallon where ultrasonic ultrasonic testing of the tank walls will be performed performed from the inside of the tank to verify acceptable wall thickness. Therefore, the staff finds that, based on a review of the the program identified above, the applicant has met the criteria of SRP-LR Section 3.4.2.2.5.

program (2) LRA Section 3.4.2.2.5 states the One-Time InspectionInspection Program Program will be implemented implemented for susceptible locations to verify the effectiveness susceptible effectiveness of the Lubricating Lubricating Oil Analysis Program, to to manage the loss of material due to general, pitting, crevice, and MIC in steel, piping, manage piping components, piping elements, tanks, and heat exchanger exchanger components exposed exposIed to to lubricating oil in the closed cycle cooling water lubricating water system, condensate system, conden:sers condensers & &

emergency diesel generators air removal system, emergency generators and auxiliary auxiliary systems, emergency feedwater system, feedwater feedwater system, main generator generator and auxiliary auxiliary systems, makeup makeup and purification system (high purification (high pressure pressure injection), reactor reactor coolant system, station blackout and UPS diesel diesel generator generator systems, and steam turbine and auxiliary auxiliary systems.

The staff reviewed reviewed LRA Section Section 3.4.2.2.5 against the criteria criteria in SRP-LR SRP-LR Section 3.4.2.2.5, which states that loss of material material due to general, pitting and crevice corrosion, and MIC MIC could occur in steel heat exchanger components exposed exchanger components Furthermore exposed to lubricating oil. Furthermore the existing aging management program relies on the periodic sampling aging management sampling and analysis analysis of lubricating oil to maintain maintain contaminants contaminants within acceptable acceptable limits, thereby preserving preserving 'an an environment that is not conducive to corrosion. SRP-LR Section environment Section 3.4.2.2.5 3.4.2.2.5 states thethe effectiveness of lubricating effectiveness lubricating oil contaminant control can be achieved achieved through a one-time one-time inspection inspection of selected components components at susceptible locations.

The staff reviewed Lubricating Oil Analysis Program reviewed the Lubricating Program and the One-Time Inspection One-Time Inspection Program and its evaluations Program evaluations are documented documented in SER Sections 3.0.3.2.18 and 3.0.3 Sections 3.0.3.2.18 3.0.3.2.14,

..2.14, respectively. The staff finds that these programs 1) provide provide for periodic sampling sampling of'of!

lubricating oil to maintain contaminants contaminants at acceptable acceptable limits to preclude loss of material 3-350

due to general, general, pitting, crevice, and microbiologically-influenced microbiologically-influenced corrosion corrosion and 2) will one-time inspections provide for one-time inspections of select steel heat exchanger tubing heat exchanger exposed to tubing exposed lubricating oil for loss of heat heat transfer due susceptible locations due to fouling at susceptible locations to verify verify the the effectiveness effectiveness of the Lubricating Lubricating Oil Analysis Program in Analysis Program applicable applicable Steam and Power Power Conversion systems.

LRA Section Sectiqn 3.4.2.2.5 addresses loss of material due to general, pitting, crevice and 3.4.2.2.5 addresses microbiologically-influenced corrosion microbiologically-influenced corrosion in steel heat exchanger exchanger components exposed to components exposed to lubricating oil. The staff reviewed reviewed LRA Section 3.4.2.2.53.4.2.2.5 against against the criteria in SRP-LR Section Section 3.4.2.2.5, which states that loss of material material due to general, pitting, crevice crevice and microbiologically-influenced corrosion microbiologically-influenced corrosion may occuroccur in steel heat exchanger exchanger components components exposed exposed to lubricating oil. The applicant stated that the Inspection Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Miscellaneous Components Program will manage this aging effect Ducting Components effect in steel internal internal surfaces surfaces exposed to lubricating oil.

The GALL Report, under under Item VIII.G-6 recommends recommends that the Lubricating Analysis Lubricating Oil Analysis credited to manage Program be credited manage this aging effect effect and that a plant-specific plant-specific AMP be be evaluated evaluated and credited to verify that the Lubricating Lubricating Oil Analysis Analysis Program is achieving its its manage loss of material mitigative function to manage material due to general, pitting, crevice and microbiologically-influenced corrosion for steel heat exchanger microbiologically-influenced exchanger components. These GALL Report Report AMRs identify a One-TimeOne-Time Inspection Program as an acceptable acceptable AMP to credit for effectiveness of the Lubricating the verification of the effectiveness Lubricating Oil Analysis Program.

Program.

The staff confirmed confirmed that only piping, fittings, tanks and valve valve bodies that align to GALL AMRs VIII.G-6 for the Radwaste Radwaste System that are fabricatedfabricated from steel materials are applicable to TMI-1 that credit applicable credit the Inspection Inspection of Internal Surfaces in Miscellaneous Miscellaneous Piping and Ducting Components Components Program. The staff noted that the radwaste radwaste system which the the referenced in Item VIII.G-6 applicant has referenced VIII.G-6 is not a part of the steam and power power conversion grouped together systems, but was grouped together with this AMR GALL item because material, because the material, environment, and aging effect combination corresponded.

effect combination corresponded.

The staff reviewed reviewed the Inspection Inspection of Internal Internal Surfaces of Miscellaneous Miscellaneous Piping and DuctingDucting Components Program Components Program and its evaluation is documented in SER Section 3.0.3.2.17. 3.0.3.2.17. TheThe staff finds that the Inspection Inspection of Internal Surfaces in Miscellaneous Miscellaneous Piping and Ducting Ducting Components Program requires visual inspections of internal surfaces of components Components components during during periodic system system and component component surveillance activities or during maintenance maintenance activities activities when the internal becomes accessible internal surface becomes accessible for visual inspections inspections to detect aging aging effects that could result in a loss of the component's component's intended function. The staff staff finds that this program program includes activities that are adequate to adequate manage manage loss of material material duedue to general, general, pitting, crevice and microbiologically-influenced microbiologically-influenced corrosion in steel heat heat exchanger components exposed exchanger components exposed to lubricating oil.

Based Based on the staffs review review and evaluation of the applicant's applicant's program, the staff concludes that the the applicant's program program meets SRP-LR SRP-LR Section 3.4.2.2.5 criteria. For those line items items that apply to to LRA Section 3.4.2.2.5, the staff determines determines that the LRA is consistent with the GALL Report Report and that the applicant has demonstrated demonstrated that the effects of aging will be adequately adequately managed so that managed the intended function(s) will be maintained maintained consistent with the CLB during during the period of extended operation, as required by 10 CFR 54.21 54.21(a)(3).

(a)(3).

3.4.2.2.6 Cracking Cracking due to SCC SCC The staff reviewed LRA Section 3.4.2.2.6 against the criteria in SRP-LR SRP-LR Section 3.4.2.2.6.

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LRA Section 3.4.2.2.6 3.4.2.2.6 addresses cracking due to stress corrosion cracking, stating that line item item 3.4.1-13 3.4.1-13 is applicable applicable to BWRs BWRs only and is not used for TMI-1, which TMI-1, which is a PWR. This item item pertains pertains to SCC in stainless stainless steel piping, piping components,and components, and piping elementselements exposed exposed to steam. TMI-1 is a PWR. The staff agrees that this line item is not applicable applicable to TMI-1.

TMI-1.

states that TMI-1 LRA Section 3.4.2.2.6 states implement a One-Time Inspection Program, for TMI-1 will implement for" susceptible locations to verify the effectiveness susceptible effectiveness of the Water Chemistry Chemistry Program manage Program to manage cracking due to stress corrosion cracking in stainless steel piping, piping components, piping piping elements, and heat exchanger exchanger components exposed to treated water greater greater than 60 6000 C (g~eater (greater 14000 F) in the auxiliary than 140 auxiliary steam system, closed cycle cooling cooling water system, condensate '

extraction steam system, feedwater system, liquid and gas sampling system, main system, extraction main generator generator and auxiliary systems, main steam system, and steam turbine turbine and auxiliary systems.

The staff reviewed LRA Section 3.4.2.2.6 LRA Section 3.4.2.2.6 against against the criteria in SRP-LR Section 3.4.2.2.6 which which states that SCC may occur occur in stainless steel piping, piping components, piping elements, tanks, and heat exchanger exchanger components exposed exposed to treated water greatergreater than 60°C 60 °C (140 The (140 OF). The SRP-LR SRP-LR also states that the existing existing aging management management program program relies on monitoring monitoring and control of water chemistry to manage manage the effects of cracking due to SCC, however, however, high concentrations concentrations of impurities impurities at crevices and locations of stagnant stagnant flow conditions could cause SCC. The GALL Report Report recommends recommends that the effectiveness effectiveness of the water chemistry chemistry control program should be be verified to ensure that SCC is not occurring occurring and that a one-time inspection inspection of selected components at susceptible components susceptible locations locations is an acceptable acceptable method method to ensure that SCC is not occurring and that the component's maintained during the period of extended component's intended function will be maintained extended operation.

The staff reviewed the AMR referencing LRA Table 3.4.1, AMR result line referencing 3.4.1, item 3.4.1-14. The staff noted that the applicant applicant proposed proposed to manage manage the aging effect of crackingcracking due to stress corrosion '

cracking using a combination combination of the Water Chemistry Chemistry Program Program and the One-Time InspectionInspection Program for this line item.

The staff reviewed the applicant's Water Chemistry Chemistry Program and its evaluation evaluation is documented in in SER Section Section 3.0.3.2.2. The staff finds that the Water Chemistry Program, Program, with an enhancement, is consistent consistent with GALL GALL AMR XI.M2, "Water Chemistry." The staff reviewed the applicant's applicant's One-Time Inspection Inspection Program and its evaluation evaluation is documented documented in SER SectionSection 3.0.3.2.14.

3.0.3.2.14. The staff finds that the One-Time One-Time Inspection Program is consistent with GALL GALL AMP XI.M32, "One-Time XI.M32, "One-Time Inspection," and is adequate to detect the presencepresence of cracking due to stress corrosion cracking for components components within its scope. Based on the staffs staff's determination determination that the applicant's applicant's Water Water Chemistry Chemistry Program provides provides mitigation and the applicant's applicant's One-Time Inspection Inspection Program provides provides detection detection for the potential aging effect effect of cracking due to stress corrosion cracking,cracking, thethe staff finds the applicant's applicant's proposed proposed AMPs for managing managing the aging aging effect effect of cracking due to stress corrosion cracking in stainless steel piping, piping components, piping elements, tanks, and heat exchanger components exchanger components exposed exposed to treated water greater than 60°C 60 °C (140 OF)OF) acceptable. '

Based on the staff's staffs review and evaluation evaluation of the applicant's programs, the staff concludes that that the applicant's programs meet SRP-LR Section Section 3.4.2.2.6 criteria. For those line items that apply to LRA Section 3.4.2.2.6, the staff determines determines that the LRA is consistent with the GALL Report and that the applicant applicant has demonstrated demonstrated that the effects of aging will be adequatelyadequately managed managed so that the intended intended function(s) will be maintained maintained consistent consistent with the CLB during the period of extended operation, as required by 10 CFR 54.21(a)(3).

extended 54.21 (a)(3).

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3.4.2.2.7 Loss of Material Material due to Pitting and Crevice Corrosion The staff reviewed Section 3.4.2.2.7 against the criteria reviewed LRA Section SRP-LR Section 3.4.2.2.7.

criteria in SRP-LR (1) LRA Section 3.4.2.2.7 3.4.2.2.7 addresses addresses the applicant's management basis for managing applicant's aging management material due to pitting and crevice loss of material corrosion in aluminum and copper alloy piping, crevice corrosion piping components and piping elements exposed to treated treated water, and in stainless steel piping, piping components, and piping elements, tanks, and heat exchanger piping, exchanger components components exposed to treated exposed conversion system. The applicant treated water in the steam and power conversion applicant stated material due that the aging effect of loss of material crevice corrosion due to pitting and crevice corrosion will bebe managed by a combination of the Water Chemistry program and the One-Time managed One-Time Inspection Inspection Program.

Program. The applicant applicant also stated that the Inspection of Internal Internal Surfaces in in Miscellaneous Piping and Ducting Miscellaneous Components Program will be used to manage Ducting Components manage the agingaging effect of loss of material crevice corrosion in stainless steel piping, material due to pitting and crevice piping, components and piping elements exposed to treated piping components water in the circulating treated water circulating water system.

Section 3.4.2.2.7 against the criteria in SRP-LR Section The staff reviewed LRA Section Section 3.4.2.2.7, which states that loss of material due to pitting and crevice which crevice corrosion corrosion may occur for stainless steel, aluminum, and copper alloy piping, components and piping piping, piping components piping elements and for stainless steel tanks and heat exchanger exchanger components exposed exposed to treated water. SRP-LR Section 3.4.2.2.7 states that the existing aging management management program relies on monitoring and control of water chemistry manage the effects of loss chemistry to manage loss crevice corrosion; however, control of water chemistry does material due to pitting, and crevice of material does preclude corrosion at locations not preclude stagnant flow conditions.

locations of stagnant conditions. The GALL Report effectiveness of the recommends that the effectiveness recommends t~e water chemistry program program should be confirmed to ensure that corrosion is not occurring. SRP-LR Section 3.4.2.2.7 states that a one-time one-time selected components at susceptible inspection of selected inspection susceptible locations acceptable method locations is an acceptable method to occurring and the component's ensure that corrosion is not occurring intended function will be component's intended be maintained during the period of extended operation.

maintained during operation.

The staff staff reviewed the AMR results lines referencing to LRA Table 3.4.1, 3.4.1, items 3.4.1-15 3.4.1-15 and 3.4.1-16. The staff noted that the applicant proposed to manage the aging effect applicant proposed effect of combination of the Water loss of material due to pitting and crevice corrosion using a combination Water Inspection Program for all components Program and the One-Time Inspection Chemistry Program referencing components referencing items 3.4.1-15 and 3.4.1-16 except circulating water except for stainless steel valve bodies in the circulating system. For stainless steel valve bodies in the circulating water system the staff noted circulating water noted that the applicant proposed to manage the aging effect of loss of material due to pitting and crevice corrosion crevice Inspection of Internal corrosion using the Inspection Miscellaneous Piping and Surfaces in Miscellaneous Internal Surfaces Components Program.

Ducting Components reviewed the applicant's Water Chemistry Program and its evaluation The staff reviewed evaluation is documented in SER documented Section 3.0.3.2.2. The staff finds that the Water Chemistry SER Section Chemistry Program, Program, consistent with GALL AMR XI.M2, "Water Chemistry." The staff with an enhancement, is consistent staff reviewed the applicant's One-Time Inspection Program and its evaluation applicant's One-Time documented evaluation is documented Section 3.0.3.2.14. The staff finds that the One-Time in SER Section Inspection Program is One-Time Inspection consistent with GALLGALL AMP XI.M32, XI.M32, "One-Time Inspection," adequate to detect the Inspection," and is adequate the presence presence or note the absence absence of loss of material due to pitting and crevice crevice corrosion in susceptible locations for components within its scope. Based on the staffs staff's determination determination applicant's Water that the applicant's Chemistry Program provides mitigation and Water Chemistry and the applicant's One- One-Time Inspection Program providesprovides detection for the potential aging effect of loss of applicant's proposed crevice corrosion, the staff finds the applicant's material due to pitting and crevice proposed AMPs AMPs 3-353

managing the aging effect of loss of material due to pitting and crevice corrosion in for managing in aluminum alloy, copper alloy, and stainless steel piping, piping components, piping piping elements, tanks, and heat exchangers components exposed to treated water in exchangers components in the steam and power conversion system acceptable.acceptable.

The staff reviewed reviewed the applicant's Inspection of Internal applicant's Inspection Internal Surfaces in in Miscellaneous Piping Miscellaneous Piping Components Program and its evaluation and Ducting Components evaluation is documented documented in in SER Section Section 3.0.3.2.17. The staff finds thatthe applicant's AMP is consistent with GALL AMP XI.M38, that'the applicant's XLM38, "Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components," with in Miscellaneous acceptable exception.

an acceptable evaluation determined that the applicant's exception. The staff's evaluation AMP applicant's AMP provides for internal internal inspection components during periodic inspection of components component periodic system and component inspections are adequate maintenance activities, that the inspections surveillances or during routine maintenance adequate to detect the presence absence of loss of material due to pitting and crevice presence or note the absence crevice components within its scope, and that ifif degraded corrosion for components degraded conditions are found the the program requires evaluation evaluation and corrective actions in in accordance accordance with the applicant's applicant's assurance program. On the basis that the applicant's quality assurance applicant's Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components in Miscellaneous Components Program is capable of detecting the aging effect of loss of material due to pitting and crevice corrosion and detecting and requires corrective corrective actions if degraded conditions are found, the staff finds the applicant's if degraded applicant's proposed AMP for managing material due to pitting and crevice corrosion managing loss of material corrosion in in stainless valve bodies exposedexposed to treated water in in the circulating, circulating water system acceptable.

LRA Section 3.4.2.2.7 addresses material due to pitting and crevice corrosion in addresses loss of material in components, piping elements, tanks and heat exchanger stainless steel piping, piping components, exchanger components exposed to treated water. The staff 'reviewed components reviewed LRA Section 3.4.2.2.7 against 3.4.2.2.7 ag!3inst the criteria in Section 3.4.2.2.7, which states that loss of material in SRP-LR Section material due to pitting and crevice corrosion may occur in in stainless steel piping, piping components, piping piping elements, tanks and heat exchanger exchanger components exposed to treated water. The applicant applicant Inspection of Internal Surfaces in stated that the Inspection Miscellaneous Piping and Ducting in Miscellaneous Ducting .

Components Program will manage manage this aging effect in components exposed in stainless steel components to treated water.

The GALL report, under under Items VIII.E-4, VIILE-36, VIII.F-27, VIILE-4, VIII.E-36, VIILF-27, VIILB1-4, VIII.C-1, VIILD1-4, VIII.B1-4, VIILC-1, VIII.D1-4, VIII.D2-4, VIILD2-4, VIII.E-29, VIII.F-23 and VIII.G-32 VIILE-29, VIILF-23 VIILG-32 and SRP-LR Section 3.4.2.2.7 Item No.1 No. 1 recommends that Water Chemistry Program be credited recommends manage this aging effect credited to manage effect and that a plant-specific AMP be evaluatedevaluated and credited to verify that the Water Chemistry achieving its mitigative function to manage Program is achieving manage loss of material due to pitting and corrosion for stainless steel piping and piping components crevice corrosion components and elements. T~ese These GALL AMRs identify a one-time inspection acceptable AMP to credit for the program is an acceptable inspection program the verification verification of the effectiveness effectiveness of the Water Chemistry Chemistry Program.

The staff confirmed that only valve bodies that align to GALL GALL AMRs VIII.B1-4 for the the Circulating Water System that are fabricated from stainless steel materials are applicable Circulating applicable to TMI that credit the Inspection Inspection of Internal Internal Surfaces Miscellaneous Piping and Ducting Surfaces in Miscellaneous Ducting Program.

Components Program.

Components The staff reviewed reviewed the Inspection Surfaces of Miscellaneous Piping and Ducting Inspection of Internal Surfaces Ducting Components Program and its evaluation Components evaluation is documented documented in in SER Section 3.0.3.2.17. ,;ýTheThe Internal Surfaces in Inspection of Internal staff finds that the Inspection Miscellaneous Piping and Ducting in Miscellaneous Ducting Components Program performs visual inspections internal surfaces inspections of internal surfaces of components components during periodic periodic system and component surveillancesurveillance activities or during maintenance maintenance 3-354

activities when activities when the the internal internal surface surface becomes becomes accessible accessible for visual inspections to detect visual inspections detect aging effects aging effects that could result in aa loss of that could of the component's intended the component's function. The staff intended function. staff program includes finds that this program includes activities activities that that are are adequate adequate to manage loss of to manage material due of material due to pitting and and crevice corrosion in stainless crevice corrosion steel piping, stainless steel components, piping piping, piping components, piping elements, tanks and elements, heat exchanger and heat components exposed exchanger components exposed to treated water.

(2)

(2) LRA Section LRA Section 3.4.2.2.7 3.4.2.2.7 states states that aa Buried Buried Piping and program, *will be Inspection program,will and Tanks Inspection be manage the loss of implemented to manage implemented material due of material and crevice corrosion in due to pitting and stainless steel stainless steel piping, piping, piping components, components, and piping elements and piping exposed to soil in the elements exposed the condensate condensate system. The applicant's applicant's Buried Piping and and Tanks Tanks Inspection Inspection Program Program includes includes preventive measures preventive measures to mitigate corrosion corrosion such as as the use external use of external coatings and and wrappings, and includes periodic and it includes inspection of periodic inspection external surfaces of external material to surfaces for loss of material to manage the effects manage effects of corrosion pressure-retaining capacity corrosion on the pressure-retaining piping and capacity of piping and components in aa soil (external) components (external) environment, environment, which which are accordance with standard are in accordance standard industry practices.

industry The staff staff reviewed reviewed LRA Section Section 3.4.2.2.7 3.4.2.2.7 against against the criteria SRP-LR Section criteria in SRP-LR Section 3.4.2.2.7, which states states that states that loss of material material due corrosion could due to pitting and crevice corrosion could stainless steel piping, occur for stainless piping, piping components, components, and and piping elements exposed to soil.

elements exposed The GALL GALL Report recommends further evaluation Report recommends plant specific aging management evaluation of a plant management program to ensure that program that this aging adequately managed aging effect is adequately acceptance criteria managed and acceptance criteria described in Branch Technical are described RLSB-1 (Appendix A.1 of this SRP-LR.)

Position RLSB-1 Technical Position SRP-LR.)

In the discussion column of LRA Table 3.4.2-1, the applicant stated that loss of material Table 3.4.2-1, material of stainless steel piping exposed exposed to the buried (external) environment is managed buried (external) managed withwith Program. The staff noted that for the AMR results line Inspection Program.

Buried Piping and Tank Inspection line that references references LRA Table 3.4.2-1,3.4.2-1, the applicant applicant included reference to Note included a reference Note E. The staffstaff reviewed the AMR results line referenced reviewed determined that the component referenced to Note E and determined component material, environment, and aging type, material, effect are consistent with the corresponding aging effect corresponding line of

. the GALL Report; Report; however, where the GALL Report recommends recommends a plant specific specific program, the applicant has proposed using the Buried Piping and Tank Inspection program, Inspection

. Program.

reviewed the Buried Piping and Tanks Inspection The staff reviewed Program and its evaluation is Inspection Program documented in SER Section Section 3.0.3.2.15. The staff finds that this program provide program will provide .

inspections within ten years from entering the period of extended planned inspections extended operation unless an opportunistic inspection has occurred within this ten-year opportunistic inspection stainless ten-year period for stainless steel components components exposed to soil for loss of material due to pitting and crevice corrosion in condensate condensate system (the gland steam condenser condenser is evaluated condensate evaluated with the condensate system). The Buried Piping and Tanks Tanks Inspection Program is in accordanceaccordance with the the recommendati0ns recommendations of GALL AMP*XI.M34 AMP-XI.M34 "Buried Piping and Tanks Inspection." Inspection." The staffstaff noted that although GALL AMP XI.M34 cites applicability to only steel and gray cast iron iron components in the scope of this program will also be components, stainless steel components be adequately managed for loss of material because excavation adequately excavation of stainless steel subsequent visual inspection will detect any loss of material components and subsequent pitting material due to pitting crevice corrosion.

and crevice (3) LRA Section 3.4.2.2.7 states that a One-Time Inspection implemented for Inspection Program, will be implemented susceptible locations to verify the effectiveness of the Lubricating Program, to Lubricating Oil Analysis Program; manage the loss of material due to pitting and crevice corrosion in copper alloy piping, piping components, and piping elements exposed to lubricating oil in in the condensers & & air 3-355 3-355

removal system, emergency emergency feedwater feedwater system, and main generator feedwater system, feedwater generator and auxiliary systems.

The staff reviewed LRA Section 3.4.2.2.7 against the criteria criteria in SRP-LR Section 3.4.2.2.7, which states that loss of material due to pitting and crevice corrosion corrosion could occur for copper alloy piping, piping components, and piping elements exposed to lubricating lubricating oil.

Furthermore, the existing aging management Furthermore, program relies on the periodic management program sampling and periodic sampling analysis of lubricating lubricating oil to maintain contaminants maintain contaminants within acceptable acceptable limits, thereby**

thereby preserving preserving an environment that is not conducive to corrosion. corrosion. SRP-LR SRP-LR Section 3.4.2;2.7 3.4.2.2.7 contaminant control can be confirmed through a effectiveness of lubricating oil contaminant states the effectiveness one-time inspection inspection of selected components components at susceptible acceptable susceptible locations is an acceptable corrosion is not occurring.

method to ensure that corrosion occurring.

The staff reviewed reviewed the Lubricating Oil Analysis Program and the One-Time One-Time Inspection Inspection Program and its evaluations documented in SER Section evaluations are documented Section 3.0.3.2.18 and 3.0.3.2.14, 3.0.3.2:14, respectively. The staff finds that these programsprograms 1) provide for periodic periodic sampling of

lubricating oil to maintain maintain contaminants contaminants at acceptable preclude loss of material acceptable limits to preclude due to pitting and corrosion and 2) will provide one-time inspections of select provide for one-time copper select cORper alloy piping, piping components, and piping piping elements exposed exposed to lubricating oil for loss of susceptible locations to verify the material due to pitting and crevice corrosion at susceptible material the effectiveness of the Lubricating effectiveness Lubricating Oil Analysis Program in applicable applicable Steam Steam and Power Power Conversion systems.

Conversion Based on the staff's review and evaluation of the applicant's programs, the staff concludes concludes that the applicant's programs meet SRP-LR applicant's programs Section 3.4.2.2.7 criteria. For those line items that apply SRP-LR Section determines that the LRA is consistent with the GALL to LRA Section 3.4.2.2.7, the staff determines GALL Report demonstrated that the effects of aging applicant has demonstrated and that the applicant aging will be adequately managedmanaged so intended function(s) that the intended maintained consistent with the CLB during the period of function(s) will be maintained operation, as required by 10 extended operation, 10 CFR 54.21(a)(3).

Material due to Pitting, Crevice, 3.4.2.2.8 Loss of Material Crevice, and MIC MIC reviewed LRA Section 3.4.2.2.8 against the criteria The staff reviewed The criteria in SRP-LR Section 3.4.2.2.8.

SRP-LR Section Section 3.4.2.2.8 LRA Section 3.4.2.2.8 addresses microbiologically-material due to pitting, crevice and microbiologically-addresses loss of material influenced corrosion influenced corrosion in stainless steel piping, piping components, piping elements and heat heat components exposed to lubricating exchanger components exchanger lubricating oil.

SRP-LR Section 3.4.2.2.8 which states Section 3.4.2.2.8 due to pitting, crevice and material due states that loss of material and microbiologically-influenced corrosion, may occur in stainless microbiologically-influenced stainless steel piping, piping, piping components, exchanger components piping elements and heat exchanger exposed to lubricating oil.

components exposed The GALL GALL report, under VIII.D1-3, VIII.D2-3, VIII.A-9, VIILD1-3, under Items VIII.G-3, VIILA-9, VIII.E-26 and VIII.G-29 VIII.D2-3, VIILE-26 VIILG-29 recommends recommends that Lubricating Lubricating Oil Analysis Program be credited to manage manage this aging effect effect and that a plant-specific evaluated and credited to verify plant-specific AMP be evaluated verify that the Lubricating Oil Analysis Analysis Program is achieving its mitigative function to manage Program manage loss of material due to pitting, crevice crevice and I.

corrosion for stainless microbiologically-influenced corrosion microbiologically-influenced components and stainless steel piping and piping components and!

exchanger components. These GALL AMRs identify a One-Time Inspection elements and heat exchanger Inspection acceptable AMP to credit for the verification Program as an acceptable verification of the effectiveness Lubricating effectiveness of the Lubricating Oil Analysis Program.

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The staff confirmed that only piping and fittings that align to GALL AMRs VIII.E-26 for the the Instrument and Control Air System Instrument System that are fabricated from stainless steel materialsmaterials are applicable applicable Inspection of Internal to TMI that credit the Inspection Miscellaneous Piping and Ducting Internal Surfaces in Miscellaneous Ducting Components Program Components Program...

The staff reviewed Inspection of Internal Surfaces reviewed the Inspection Miscellaneous Piping and Ducting Surfaces of Miscellaneous Ducting Components Program and its evaluationevaluation is documented documented in SER Section 3.0.3.2.17. The staff staff Miscellaneous Piping finds that the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Components Program requires requires visual inspections internal surfaces inspections of internal surfaces of components during periodic system and component maintenance activities when the internal surface surveillance activities or during maintenance component surveillance surface becomes inspections to detect aging effects that could result in a loss of the becomes accessible for visual inspections the component's intended intended function.

function. The staff finds that this program includes activities that is program includes adequate to manage microbiologically-influenced manage loss of material due to pitting, crevice and microbiologically-influenced corrosion in stainless steel piping, piping components, piping elements and heat exchanger exchanger lubricating oil.

components exposed to lubricating LRA Section 3.4.2.2.8 states that a One-Time One-Time Inspection program, B.2.1.18, will be implementedimplemented for susceptible locations locations to verify the effectiveness Lubricating Oil Analysis Program, to effectiveness of the Lubricating manage the loss of material due to pitting, crevice, microbiologically-influenced corrosion crevice, and microbiologically-influenced corrosion inin stainless steel piping, piping components, piping elements, and tanks exposed lubricating oil in exposed to lubritating condensers &

the condensers & air removal system, emergency feedwater system, and feedwater system, feedwater emergency feedwater and steam auxiliary systems.

steam turbine and auxiliary The staff staff reviewed LRA Section 3.4.2.2.8 against the criteria in SRP-LR Section 3.4.2.2.8, which Section 3.4.2.2.8 states pitting, crevice, and MIC could occur in stainless states that loss of material due to pitting, stainless steel piping, piping components, piping elements, and heat exchanger components components exposed lubricating oil.

to lubricating Furthermore, the existing aging management program relies on the periodic aging management periodic sampling and analysis analysis of lubricating lubricating oil to maintain contaminants acceptable limits, thereby preserving contaminants within acceptable preserving an environment corrosion. SRP-LR Section 3.4.2.2.8 states the effectiveness environment that is not conducive to corrosion.SRP-LR effectiveness lubricating oil contaminant control can be confirmed through a one-time inspection of lubricating inspection of selected components acceptable method susceptible locations is an acceptable components at susceptible method to ensure ensure that corrosion is not occurring.

occurring.

The staff reviewed Lubricating Oil Analysis Program and the One-Time Inspection reviewed the Lubricating Inspection Program and .its 3.0.3.2.18 and 3.0.3.2.14, respectively. The documented in SER Sections 3.0.3.2.18 its evaluations are documented The staff finds that these programs 1) provide for periodic lubricating oil to maintain periodic sampling of lubricating maintain preclude loss of material acceptable limits to preclude contaminants at acceptable material due to* to pitting, crevice and and corrosion and 2) will provide microbiologically-influenced corrosion microbiologically-influenced inspections of select provide for one-time inspections stainless steel piping, piping components, piping elements elements exposed to lubricating oil for loss of material due to pitting, pitting, crevice and microbiologically-influenced corrosion at susceptible locations microbiologically-influenced locations effectiveness of the Lubricating Oil Analysis to verify the effectiveness Analysis Program in applicable applicable Steam and Power Power Conversion systems.

Based on the staffs review and evaluation of the applicant's applicant's programs, the staff concludes concludes that the applicant's applicant's programs meet SRP-LR criteria. For those line items that apply SRP-LR Section 3.4.2.2.8 criteria.

determines that the LRA is consistent with the GALL Report Section 3.4.2.2.8, the staff determines to LRA Section demonstrated that the effects of aging and that the applicant has demonstrated aging will be adequately adequately managed managed so consistent with the CLB during the period of maintained consistent that the intended function(s) will be maintained extended operation, as required by 10 CFR 54.21(a)(3).

extended 54.21 (a)(3).

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3.4.2.2.9 Loss 3.4.2.2.9 Loss of Material Material due due toto General, General, Pitting, Crevice, and Pitting, Crevice, Galvanic Corrosion and Galvanic Corrosion The staff The reviewed LRA staff reviewed LRA Section 3.4.2.2.9 against Section 3.4.2.2.9 criteria in SRP-LR against the criteria Section 3.4.2.2.9.

SRP-LR Section 3.4.2.2.9.

LRA Section 3.4.2.2.9 LRA addresses the applicant's 3.4.2.2.9 addresses management basis for managing applicant's aging management managing loss of material due material due to general, pitting, crevice, and and galvanic galvanic corrosion in steel heatheat exchanger exchanger components exposed components exposed to treated water condensers and air removal system. The applicant water in the condensers appli~ant stated that the aging aging effect effect of loss of material material due general, pitting, crevice due to general, crevice and galvanic galvanic components will be corrosion in these components corrosion be managed combination of the Water managed by a combination Water Chemistry Program and Program and the One-Time One-Time Inspection also stated that the aging effect of applicant also Inspection Program. The applicant loss of material corrosion in general, pitting and crevice corrosion material due to general, in steel heat exchanger components exchanger compopents in the the feedwater system will be feedwater system be managed managed by Chemistry Program Water Chemistry combination of the Water by a combination Program and the One-Time One-Time Inspection applicant stated that Program; however, the applicant Inspection Program; mechanism of that the aging mechanism galvanic corrosion does not corrosion does not apply to the feedwater system high pressure the feedwater heaters since pressure pressure heaters boundary and leakage boundary components are not boundary components leakage boundary not in contact materials higher in galvanic contact with materials galvanic series. ".

SRP-LR Section SRP-LR pitting, crevice, and galvanic material due to general, pitting, Section 3.4.2.2.9 states that loss of material galvanic corrosion maymay occur in steel heatheat exchanger components exposed exchanger components treated water. SRP-LR exposed to treated SRP-LR Section 3.4.2.2.9 states that the existing monitoring and control existing AMP relies on monitoring control of water chemistry manage the effects of loss of material due to general, pitting, to manage pitting, and crevice corrosion, but control crevice corrosion, of water chemistry does not preclude chemistry does material preclude loss of material due to general, pitting, crevice corrosion pitting, and crevice corrosion at locations locations with stagnant flow conditions; therefore, therefore, the effectiveness chemistry control water chemistry effectiveness of water programs should be ensure that corrosion be confirmed to ensure does not occur. The GALL Report I corrosion does recommends that the effectiveness recommends confirmed to confirm effectiveness of water chemistry should be confirmed confirm that that corrosion does not occur. SRP-LR Section 3.4.2.2.9 states that a one-time inspection of selected one-time inspection selected components and susceptible locations is an acceptable acceptable method to ensure that corrosion does not occur occur and that component maintained during the period of extended functions will be maintained component intended functions extended operation.

operation.

applicant's proposed AMPs, the staff In evaluating the applicant's staff noted that in LRA Table 3.4.1, 3.4.1, Item 3.4.1-5, the applicant consistent with the GALL applicant stated that the result is not consistent GALL Report. The staff also nqted noted that for AMR results in LRA Table 3.4.2-5 that refers to Item 3.4.1-5, the applicant applicant cited Generic Generic Note I,I, indicating that the aging effect in the GALL indicating-that Report is not applicable for the component, GALL Report material and environment material applicant's AMR result. The staff noted that the environment combination in the applicant's applicant had determined mechanism of galvanic corrosion not to be applicable for the determined the aging mechanism the in-scope (pressure and leakage boundary) components in-scope components in the feedwater feedwater system high pressure heaters.

reviewed the applicant's Water Chemistry Program and its evaluation The staff reviewed documented in evaluation is documented in SER Section 3.0.3.2.2. The staff finds that the Water Chemistry Chemistry Program, with an enhancement, is consistent with GALL AMP XI,M2, XI.M2, "Water "Water Chemistry." The staff reviewed the applicant's One-Inspection Program and its evaluation is documented in SER Section 3.0.3.2.14. The staff Time Inspection staff finds that the applicant's One-Time applicant's One-Time Inspection Program Program is consistent with GALL AMP XI.M32, XI,M32, "One-Time Inspection," and is adequate to detect the presence absence of loss of presence or note the absence material due to general, pitting, crevice, and galvanic corrosion in susceptible locations for components within the scope of the program. Based on the staff's staffs determination determination that the the applicant's Water Chemistry Program provides applicant's provides mitigation and the applicant's One-Time applicant's One-Time provides detection for the potential aging effect of Inspection Program provides of loss of material due to pitting, crevice, and galvanic corrosion, the staff finds the applicant's proposed AMPs for general, pitting, managing the aging effect of loss of material due to general, pitting, crevice, and galvanic galvanic 3-358

corrosion corrosion in steel heat exchanger exchanger components components exposed exposed to treated water in the condensers and air air removal system system to be acceptable.

acceptable. The staff finds the applicant's proposed AMPs for managing the the aging effect of loss of material due to general, general, pitting, and crevice corrosion in steel heat exchanger exchanger components in the feedwater feedwater system to be acceptable.

acceptable.

Based on the staffs review review and evaluation of the applicant's programs, the staff concludes that the applicant's programs meet SRP-LR applicant's programs SRP-LR Section 3.4.2.2.9 criteria.

criteria. For those lines that apply to LRA Section Section 3.4.2.2.9, the staff determines determines that the LRA is consistent with the GALL Report and that the applicant has demonstrated demonstrated that the effects of aging aging will be adequately adequately managed managed so that the intended function(s) function(s) will be maintained maintained consistent with the CLB during the period period of extended operation, as required by by 10 CFR 54.21 54.21(a)(3).

(a)(3).

3.4.2.2.10 Quality Assurance for Aging Management Nonsafety-Related Components Management of Nonsafety-Related Components Section 3.0.4 provides SER Section provides the staff's evaluation evaluation of the applicant's applicant's QA program.

3.4.2.3 AMRAMR Results That That Are Not Consistent Consistent with or Not Addressed Addressed in the GALL GALL Report In LRA Tables 3.4.2-1 through 3.4.2-8; 3.4.2-8, the staff reviewed reviewed additional details of AMR results for material, environment, AERM, environment, AERM, and AMP combinations not consistent with or not addressed addressed in the the GALL Report.

indicated, via Notes F through J, that the ,

In LRA Tables 3.4.2-1 through 3.4.2-8, the applicant indicated, combination of component component type, material, material, environment, and AERM does not correspondcorrespond to a lineline item in the GALL GALL Report. The applicant applicant provided further information information concerning how the aging effects will be managed. Specifically, Note Note F indicates indicates that the material material for the AMR line itemitem component is not evaluated in the GALL Report. Report. Note G indicates that the environment environment for the the AMR AMR line item component component and material is not evaluated in the GALL GALL Report. Note H indicates indicates that the aging effect for the AMR line item component, material, and environment environment combination combination is not evaluated in the GALL GALL Report. Note II indicates thatthe aging effect effect identified in the GALL Report for the line item component, material, and environment combination combination is not applicable. Note J indicates that neither the component component nor the material material and environment combination for the line line item is evaluated in the GALL Report.

For component type, material, and environment evaluated in the GALL environment combinations not evaluated GALL Report, the staff reviewed reviewed the applicant's applicant's evaluation evaluation to determine whether whether the applicant had demonstrated demonstrated that the aging aging effects will be adequately managed so that the intended adequately managed intended function(s) will bebe consistent with the CLB during the period of extended maintained consistent extended operation. The staffsstaffs evaluation evaluation is discussed discussed in the following sections.

3.4.2.3.1 Steam Steam and Power Power Conversion System - Condensate Condensate System - SummarySummary of Aging Aging Management Evaluation Management Evaluation - LRA Table 3.4.2-1 The staff The staff reviewed LRA Table 3.4.2-1, 3.4.2-1, which summarizes the results of AMRs for the condensatecondensate system component groups.

In LRA In LRA Table Table 3.4.2-1, 3.4.2-1, the applicant proposed proposed to manage manage cracking due to stress corrosion cracking cracking (SCC) for piping and fittings and valve bodies made of copper copper alloy with 15%15% or greater greater zinc zinc exposed exposed to an environment of treatedtreated water (internal)

(internal) using the Water Chemistry Program and the the One-Time Inspection Program.

Program. For these components the applicant applicant cited generic note H, H, indicating that the aging effect is not in the GALL GALL Report for this component, material and 3-359 3-359

environment environment combination.

combination. The applicant applicant also also cited plant-specific note stating cited aa plant-specific stating that the the aging aging effects/mechanisms for copper effects/mechanisms alloy with 15%

copper alloy 15% or greater zinc or greater zinc in aa treated environment with treated water environment with ammonia present ammonia include cracking present include due to SCC.

cracking due The staff staff confirmed confirmed that thethe GALL GALL Report Report does does notnot list cracking due to SCC as cracking due asanan aging aging effect effect applicable for copper applicable copper alloy alloy with with 15% greater zinc 15% or greater zinc exposed treated water. The staff also exposed to treated also:

reviewed selected reviewed selected portions portions of EPRI Report 1010639, EPRI Report "Non-Class 11 Mechanical 1010639, "Non-Class Mechanical Implementation Implementation Guideline and Mechanical Guideline Mechanical

,

Tools, Revision Revision 4, dated dated January January 2006.

2006. The staff noted noted that 11 I

t Section 3.2.2, Section 3.2.2, Appendix A of of the EPRI EPRI report states that that in the presence ammonia or other presence of ammonia other compounds that may ammonium compounds ammonium may be be in used in treated treated water cracking due to SCC can water systems, cracking can occur in copper copper alloys containing containing 15%15% or or greater greater zinc. On On the basis that the aging effecteffect is identified in the EPRI identified EPRI report, the the staff staff finds the applicant's applicant's identification cracking due identification of cracking SeC in due to SCC copper components copper components exposed treated water exposed to treated water acceptable.

acceptable.

applicant's Water Chemistry Program and its evaluation reviewed the applicant's The staff reviewed document~d in evaluation is documented SER Section 3.0.3.2.2. The staff finds that Water Water Chemistry Program, with an enhancement, is Chemistry Program, consistent with GALL AMP XI.M2, "Water Chemistry." The staff consistent staff reviewed the applicant's applicant's One-Inspection Program Time Inspection documented in SER Section 3.0.3.2.14.

Program and its evaluation is documented 3.0.3.2.14. The staff litaff finds that that the applicant's applicant's One-Time Inspection Program Inspection Program consistentis consistent with GALL AMP XI.M32, XI.M32, adequate to detect the presence or note the absence Inspection," and is adequate "One-Time Inspection," absence of cracking cracking due to SCC for components components within the scope program. Based on the staffs scope of the program. staffs determination determination that the Water Water Chemistry Program providesprovides mitigation and and the One-Time Inspection Program One-Time Inspection Program provides detection provides detection for the potential potential aging cracking due to SCC, the staff finds the aging effect of cracking the .

applicant's managing the aging effect of cracking due to SCC in piping and proposed AMPs for managing applicant's proposed fittings and in valve bodies made of copper alloy with 15% 15% or greater exposed to an greater zinc exposed condensate system acceptable.

environment of treated water in the condensate In LRA Table Table 3.4.2-1, 3.4.2-1, the applicant applicant designated Generic Note H for stainless steel piping and designated Generic fittings exposed to a soil (external) environment condensate system because environment in the condensate because the aging effect for the AMR line item component, material, and environment combination is not evaluated evaluated in the GALL GALL Report. The staffstaff reviewed the GALL Report Report and found that the AMR line item, item, piping piping evaluated for a soil (external) and fittings were not evaluated (external) environment material due to '

environment for loss of material influence corrosion. The applicant credits the Buried Piping and Tanks microbiologically influence microbiologically Tanks microbiologically-influenced corrosion.

Inspection Program for managing loss of material due to microbiologically-influenced Inspection The staff reviewed the Buried Piping and Tanks Inspection Program Program and its evaluation is :

documented in SER Section 3.0.3.2.15. The applicant's program provides for opportunistic opportunistic and excavations of stainless steel piping and fittings during the last ten years of the current focused excavations current commencement of the period of extended operation.

license period and within ten years after the commencement The applicant's program also provides for inspection of the exposed exposed piping and fittings that Will will determine if microbiologically-influenced determine if microbiologically-influenced corrosion is causing loss of material. Unacceptable Unacceptable degradation will be corrected degradation applicant's Corrective Action Program. The staff corrected through the applicant's staff microbiologically-influenced corrosion of stainless steel determines that loss of material due to microbiologically-influenced determines adequately managed through the period of extended piping and fittings exposed to soil will be adequately operation because piping will be subject to inspection that will detect loss of material material such that unacceptable degradation any unacceptable corrected.

degradation will be corrected.

appropriately evaluated the AMR review, the staff finds that the applicant has appropriately On the basis of its review, AMR results of material, environment, AERM, and AMP combinations not evaluated in the GALL Report. The staff finds that the applicant has has demonstrated demonstrated that the effects of aging will be be :.

managed so that the intended function(s) will be maintained adequately managed maintained consistent the CLB consistent with the'CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3).

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3.4.2.3.2 Steam Conversion System - Condensers Steam and Power Conversion Condensers and Air Removal System -

Summary Summary of Aging Management Evaluation - LRA Table 3.4.2-2 Management Evaluation The staff reviewed LRA Table 3.4.2-2, which summarizes the results of AMR evaluations evaluations for thethe condensers &

condensers system component

& air removal system component groups.

The applicant applicant designated Note G for aluminum aluminum alloy filter housings housings and Note H for copper copper alloy alloy (Zn less than 15%)

15%) piping and fittings exposed to a lubricating lubricating oil environment in the condensers condensers

& air removal system

& system because because the loss of material material due to the mechanism mechanism of microbiologically-microbiologically-influenced influenced corrosion for the AMR line item component, material, material, and environment combination is environment not evaluated in the GALL GALL Report for the copper copper piping and fittings and the environment environment is not in in the GALL Report Report for the aluminum aluminum alloy filter housings. The staff reviewed the GALL GALL Report and found that the AMRAMR line item, piping and fittings is not evaluated evaluated for a lubricating lubricating oil environment environment for loss of material due to microbiologically-influenced microbiologically-influenced corrosion accordingly Note corrosion and accordingly Note H is appropriate and that the GALL Report does not address address aluminum filter housings housings exposed to to lubricating oil and accordingly accordingly Note Note G is appropriate.

appropriate. The applicant credits the Lubricating Oil Analysis Program and the One-time Inspection Inspection Program Program for managing loss of material material due to pitting, crevice, and MIC. The staff reviewed reviewed the Lubricating Lubricating Oil Analysis Program and the One-Time Inspection Inspection Program and its evaluations are documented documented in SER SectionsSections 3.0.3.2.18 and 3.0.3.2.14, respectively. The staff finds that these programs 1) provide sampling of provide for periodic sampling lubricating oil to maintain contaminants contaminants at acceptable acceptable limits to preclude preclude loss of material due to to pitting, crevice and micrpbiologically-influenced microbiologically-influenced corrosion corrosion and 2)will

2) will provide provide for one-time one-time inspections of select components exposed lubricating oil for loss of material exposed to lubricating material due to pitting, crevice crevice and microbiologically-influenced microbiologically-influenced corrosion at susceptible locations to verify the the effectiveness Lubricating Oil Analysis Program. The staff noted effectiveness of the Lubricating noted that one-time inspection is one-time inspection an acceptable acceptable method to determine determine whether whether or not loss of material is occurring occurring slowly such that intended function will be maintained during the period of extended the intended extended operation. On this basis, the staff finds that the Lubricating Lubricating Oil Analysis Program Program and the One-Time Inspection Program One-Time Inspection are adequate to manage loss loss of material due to pitting, crevice, and microbiologically-influenced microbiologically-influenced corrosion for these aluminum and copper copper alloy components components exposed exposed to lubricating oil through the the period of extended extended operation.

operation.

In LRA Table 3.4.2-2, the applicant applicant stated that for glass flow device and sight Sight glasses glasses in air-gas air-gas wetted environment there are no aging wetted internal environment aging effects requiring requiring management. The applicant applicant referenced footnote referenced footnote "G" for this line item indicating indicating that environment environment is not listed listed in the GALL Report for this material and component Report component combination.

combination.

As indicated in "Corrosion Handbook" by H.H.Uhlig, H.H.Uhlig, the staff noted that glass as a material is impervious to normal plant environments.

impervious environments. This conclusion conclusion is based on industry industry experience experience where the staff noted noted that no failure due to an aging effect of glass components in environments free of environments hydrofluoric hydrofluoric acid, caustics, or hot water have been recorded in industry industry temperatures or during at temperatures during time periods of concern concern for extended extended operation. The staff acknowledges acknowledges that the use of glass in power power plant environments is a design-driven criterion and once selected selected for the environment environment will not have any significant age related degradation, degradation, since air-gas wetted internal environmentenvironment doesdoes not contain hydroflouric hydroflouric acid or caustics. Based Based on this review and on the industry operating operating experience, the staff finds that glass in an air-gas wetted internal environment environment will not have any aging effects requiring aging management.

effects requiring On the basis of its review, the staff finds that the applicant has appropriately evaluated evaluated the AMRAMR results of material, environment, AERM, and AMP combinations combinations not evaluated in the GALL evaluated 3-361

Report. The staff finds that the applicant demonstrated that the effects of aging applicant has demonstrated aging will be be managed so that the intended adequately managed intended function(s) function(s) will be maintained maintained consistent consistent with the CLB for the period of extended operation, operation, as required by 10 10 CFR 54.21 (a)(3).

3.4.2.3.3 Steam Steam and Power Conversion Conversion System - Emergency Feedwater Feedwater System - Summary of Management Evaluation Aging Management Evaluation - LRA Table 3.4.2-3 3.4.2-3 The staff reviewed LRA Table 3.4.2-3, which summarizes the results of AMRs for the emergency feedwater feedwater system component groups.

In LRA Table 3.4.2-3, 3.4.2-3, the applicant applicant proposed proposed to manage cracking cracking due to stress corrosion corrosion cracking (SCC) for valve bodies bodies and flow devices made of copper alloy with 15% 15% or greater zinc exposed to an environment environment of treated (internal) using treated water (internal) using the Water Chemistry Program and the dne- One-Time Inspection Inspection Program.

Program. For these components the applicant cited generic note H, indicating indicating that the aging aging effect effect is not in the GALL ReportReport for this component, material material and environment environment combination.

combination. The applicant applicant also cited a plant-specific plant-specific note stating that the aging effects/mechanisms effects/mechanisms for copper alloy with 15% 15% or greater zinc in a treatedtreated water environment environment include cracking cracking due to SCC.

The staff confirmed confirmed that the GALL Report does not list cracking due to SCC as an aging effect GALL Report applicable for copper alloy with 15%

applicable 15% or greater zinc exposed exposed to treated treated water. The staff also reviewed selected portions of EPRI Report reviewed selected Report 1010639, "Non-Class 1 Mechanical Mechanical Implementation Implementation Guideline Guideline and Mechanical Mechanical Tools, Revision Revision 4, dated January January 2006. The staff noted that Section 3.2.2, Appendix Appendix A of the EPRI report states that in the presence of ammonia ammonia or other ammonium compounds that may be in used in treated ammonium treated water systems, cracking due to SCC can occur in copper alloys containing containing 15% or greater zinc. On the basis that the aging effect is, is identified in the EPRI report, the staff finds the applicant's applicant's identification identification of cracking cracking due to SCC in exposed to treated copper components exposed treated water water to be acceptable.

The staff reviewed reviewed the applicant's applicant's Water Chemistry Program and its evaluation is documented documented in in SER Section 3.0.3.2.2. The staff staff:finds finds that the Water Chemistry Program, Chemistry Program, with an enhancement, consistent with GALL AMP XI.M2, "Water Chemistry." The staff reviewed is consistent reviewed the applicant's applicant's One-Time Inspection Inspection Program Program and its evaluation documented in SER Section evaluation is documented Section 3.0.3.2.14. The~.staff The staff finds that the One-Time Inspection Program is consistent with GALL One-Time Inspection GALL AMP XI.M32, "One-Time XI.M32, "One-Time Inspection," and is adequate Inspection," adequate to detect the presence presence or note note the absence absence of cracking due to SCC to.SCC for components components within the scope of the program. Based on the staff's determination determination that the the Water Chemistry Program provides mitigation and the One-Time Inspection Program One-Time Inspection Program provides provides detection for the potential potential aging effect cracking due to SCC, the staff finds the applicant'~

effect of cracking applicant's proposed AMPs for managing the aging effect of cracking cracking duedue to SCC in valve bodies and flow flow devices made of copper alloy with 15%

devices 15% or greater greater zinc exposed exposed to an environment environment of treated water in the emergency emergency feedwater feedwater system acceptable.

acceptable.

The staff noted noted that for nickel alloy piping and fittings, exposed to an air with borated water leakage leakage (external) environment, the applicant applicant assigned no aging aging effect and therefore therefore no aging management management program was assigned for these component/material/environment component/material/environment combinations.

The staff noted noted that austenitic materials austenitic materials such as nickel alloys are not subject to loss of material or cracking when subjected to this environment environment and these materials materials are used as corrosion resistant replacement materials where replacement where other materials have degraded. degraded. According NP-5769, According to EPRI NP-5769,'

"Degradation and Failure of Bolting in Nuclear Power Plants," Volumes Volumes 1 and 2, April 1988, corrosion resistant materials materials such as austenitic austenitic and martensitic martensitic stainless stainless steels and high strength strength nickel base alloys offer good protection protection against boric acid corrosion.corrosion. Therefore Therefore no aging 3-362 3-362

management program is necessary for nickel alloys in the air with borated management borated water leakage leakage (external)

(external) environment.

In LRA Table 3.4.2-3, the applicant applicant designated designated Note G for aluminum aluminum alloy sight glass housingshousings and Note Note H for copper alloy (Zn less than 15%) 15%) piping fittings and copper copper alloy (Zn greater than 15%) sight glass housings exposed to a lubricating 15%) lubricating oil environment environment in the emergency emergency feedwater feedwater system because because the loss of material material due to microbiologically-influenced microbiologically-influenced corrosion for the AMR AMR

. line item component, material, and environment combination combination is not evaluated evaluated in the GALL Report for the copper piping, fittings and sight glass housings and the environment environment is not in the GALL Report Report for the aluminum alloy sight glass Housings. The staff reviewed reviewed the GALL Report and found that that the AMR line item, copper copper alloy piping, piping, fittings, and sight glass housings housings is not evaluated for a lubricating oil environment evaluated environment for loss of materialmaterial due to microbiologically-influenced microbiologically-influenced corrosion and that the GALL GALL Report does not address aluminum sight glass housings exposed exposed to lubricating oil.

lubricating oil. The applicant credits the Lubricating Lubricating Oil Analysis Program Program and the One-time One-time Inspection Inspection Program for managing managing loss of material material due to pitting, crevice, crevice, and MIC. The staff staff reviewed the Lubricating Lubricating Oil Analysis Program Program and the One-Time One-Time Inspection Program and its its documented in SER Sections 3.0.3.2.18 and 3.0.3.2.14, respectively. The staff evaluations are documented staff finds that these programs programs 1) provide periodic sampling provide for periodic sampling of lubricating oil to maintain maintain acceptable limits to preclude loss of material contaminants at acceptable material due to pitting, crevice crevice and microbiologically-influenced corrosion microbiologically-influenced corrosion and 2) will provideprovide for one-time inspections of select one-time inspections components exposed exposed to lubricating lubricating oil for loss of material due due to pitting, crevice and microbiologically-influenced microbiologically-influenced corrosion at susceptible locations to verify the effectiveness effectiveness of the the Lubricating Oil Analysis Program. The staff noted that one-time inspection is an acceptable acceptable determine whether or not loss of material is occurring method to determine occurring slowly such that the intendedintended function will be maintained duringduring the period of extended extended operation. On this basis, the staff finds finds Lubricating Oil Analysis Program that the Lubricating Program and the One-Time One-Time Inspection Inspection Program Program are adequate to to manage loss of material material due to pitting, crevice, and microbiologically-influenced microbiologically-influenced corrosion for these aluminum aluminum and copper alloy components components exposed to lubricatinglubricating oil through the period of extended operation.

extended operation.

In LRA Table 3.4.2-3, the applicant applicant stated that for steel piping and fittings, and valve bodies in treated treated water environment emergency feedwater environment in the emergency feedwater system, wall thinning due to flow-accelerated accelerated corrosion is not an aging effect requiring management. The applicant applicant referenced footnote "I,"1,2" stating that this system is a single phase system with a temperature temperature below 200 OF OF and additionally, the system operates operates less than 2% of plant operating time.

The staff reviewed EPRI guidelines in NSAC-202L-R2 NSAC-202L-R2 that are referenced referenced in the GALL AMP AMP "Flow-Accelerated Corrosion."

XI.M17, "Flow-Accelerated Corrosion." This document document provides guidelines guidelines for maintaining integrity of steel piping and valves containing high-energy high-energy fluids. The document document considers temperature temperature operating time as criteria for susceptibility and operating susceptibility review review and the temperature temperature below 200 °F, ° F, and operation less than 2% of plant operating operating time is under the limits for non-susceptibility non-susceptibility for single-phase systems. On the basis thati that the emergency emergency feedwater feedwater system is in normal stand-by and operates operates for less than 2% 2% of the plant operating operating time, and the temperature temperature is less than 200 OF, OF, the the staff finds that this system is not a high-energy high-energy fluid system, and therefore, wall thinning due to to flow-accelerated flow-accelerated corrosion is not an aging effect requiring management.

On the basis of its review, the staff finds that the applicant has appropriately appropriately evaluated evaluated the AMR AMR results of material, environment, AERM, AERM, and AMP combinations combinations not evaluated in the GALL Report. The staff finds that the applicant has demonstrated demonstrated that the effectseffects of aging will be be adequately managed so that the intended adequately intended function(s) maintained consistent with the CLB function(s) will be maintained for the period of extended extended operation, as required required by 10 10 CFR 54.21 54.21(a)(3).

(a)(3).

3-363 3-363

3.4.2.3.4 Steam and Power Conversion System - Extraction 3.4.2.3.4 Extraction Steam System - Summary Summary of Aging Management Management Evaluation Evaluation - LRA Table 3.4.2-4 3.4.2-4 '

The staff reviewed LRA Table 3.4.2-4, which summarizes summarizes the results of AMRs for the extraction extraction component groups.

steam system component In LRA Table 3.4.2-4, the applicant proposed to manage manage cracking cracking due to stress corrosion cracking stress corrosion (SCC) for piping and fittings and valve bodies made made of copper alloy with 15% 15% or greater greater zinc zinc exposed to an environment of treated treated water (internal)

(internal) using the Water Chemistry Chemistry Program and the the One-Time Inspection Inspection Program.

Program. For these components, the applicant cited generic H, generic note H, .

indicating that the aging effect is not in the GALL Report indicating Report for this component, material and and environment combination.

combination. The applicant also cited a plant-specific plant-specific note stating that the aging effects/mechanisms for copper alloy with 15%

effects/mechanisms 15% or greater greater zinc in a treated water environment environment include cracking cracking due to SCC.

The staff confirmed that the GALL Report does not list cracking cracking due to SCC as an aging effect applicable applicable for copper alloy with 15%

15% or greater greater zinc exposed to treated water. The staff also reviewed selected portions portions of EPRI Report Report 1010639, "Non-Class 1 Mechanical Mechanical Implementation Implementation Guideline Guideline and Mechanical Mechanical Tools, Revision Revision 4, dated January 2006. The staff noted that Section Section 3.2.2, Appendix A of the EPRI report states that in the presence presence of ammonia ammonia or other ammonium ammonium compounds compounds that may be in used used in treated water water systems, cracking due to SCC SCC can occur in copper copper alloys containing containing 15% 15% or greater greater zinc. On the basis basis that the aging effect is, is ':

identified identified in the EPRI EPRI report, the staff finds the applicant's identification applicant's identification of cracking due to SCC in in copper components exposed components exposed to treated treated water acceptable.

to be acceptable.

The staff reviewed reviewed the applicant's Water Chemistry Chemistry Program Program and its evaluation evaluation is documented documented in in SER Section 3.0.3.2.2. The staff finds that the program, with an enhancement, is consistent consistent with GALL AMP XI.M2, XI.M2, "Water Chemistry." The staff reviewed the applicant's applicant's One-Time Inspection One-Time Inspection Program and its evaluation Program evaluation is documented in SER Section 3.0.3.2.14. The staff finds that the the program is consistent consistent with GALL AMP XI.M32, "One-Time "Olle~Time Inspection,"

Inspection," and is adequate adequate to detect the presence or note the absenceabsence of cracking due to SCC for components components within the scope of the the program. Based Based on the staff's determination determination that the Water Chemistry Water Chemistry Program provides provides !ý mitigation and the One-Time Inspection Program One-Time Inspection Program provides detection detection for the potential potential aging effect of cracking due to SCC, the staff finds the applicant's applicant's proposed AMPs for managing managing the aging cracking due effect of cracking due to SCC in piping and and fittings and valve bodies made of copper copper alloy with 15% or greater zinc exposed 15% exposed to an environment environment of treated water in the extraction extraction steam system to to be acceptable.

acceptable.

In LRA Table Table 3.4.2-4, the applicant proposed to manage manage cracking cracking due to stress corrosion cracking cracking (SCC) for valve bodies and flow devices made of copper alloy with 15% 15% or greater greater zinc exposed to an environment environment of treated water (internal)(internal) using the Water Chemistry Program and the One-Chemistry Program Time Inspection Program.

Program. For these components the applicant cited generic indicating generic note H, indicating that the aging effect is not in the GALL Report for this component, material and environment environment combination.

combination. The applicant also cited a plant-specific note note stating that the aging effects/mechanisms effects/mechanisms for copper alloy with 15%

15% or greater greater zinc in a treated water environment environment include cracking include cracking due due to SCC.

The staff confirmed that the GALL GALL Report does not list cracking cracking duedue to SCC as an aging effect applicable for copper alloy with 15% 15% or greater zinc exposedexposed to treated water. The staff also als9 reviewed selected portions portions of EPRI Report 1010639, "Non-Class 1 Mechanical Mechanical Implementation Implementation Guideline Mechanical Tools, Revision 4, dated January 2006. The staff noted that Guideline and Mechanical 3-364 3-364

Section 3.2.2, Appendix Appendix A of the EPRI report states that in the presence ammonia or other presence of ammonia ammonium compounds that may be in used in treated water systems, cracking due to SCC can occur in copper occur copper alloys containing 15% 15% or greater zinc. On the basis that the aging effect is identified in the EPRI report, the staff finds the applicant's identification of cracking due to SCC in applicant's identification copper components exposed to treated water to be acceptable.

copper acceptable.

In LRA Table 3.4.2-4, the applicant stated that for glass sight glasses in air-gas wetted wetted internal environment there are no aging effects requiring management. The applicant referenced environment referenced footnote footnote "Gil "G" for this line item indicating environment is not listed in the GALL Report indicating that environment Report for this material and component component combination.

H.H.Uhlig, the staff noted that glass as a material is indicated in "Corrosion Handbook" by H.H.Uhlig, As indicated normal plant environments. This conclusion is based on industry experience impervious to normal impervious experience where the staff noted that no failure due to an agingaging effect of glass components environments free of components in environments hydrofluoric acid, caustics, or hot water have been recorded hydrofluoric temperatures or during recorded in industry at temperatures during time periods of concern concern for extended operation. acknowledges that the use of glass in operation. The staff acknowledges design-driven criterion and once environments is a design-driven power plant environments selected for the environment will once selected not have any significant degradation, since air-gas significant age related degradation, air-gas wetted environment does internal environment wetted internal does hydroflouric acid or caustics. Based on this review and on the industry operating not contain hydroflouric operating experience, the staff finds that glass in an air-gas wetted internal experience, environment will not have any internal environment aging effects requiring aging management.

aging On the basis of its review, the staff appropriately evaluated staff finds that the applicant has appropriately evaluated the AMRAMR material, environment, AERM, results of material, AERM, and AMP combinations not evaluated evaluated in the GALL Report. The staff finds that the applicant demonstrated that the effects applicant has demonstrated be effects of aging will be adequately managed so that the intended function(s) will be maintained adequately maintained consistent with the CLB for the period of extended extended operation, as required required by 10 CFR 54.21 (a)(3).

54.21(a)(3).

3.4.2.3.5 Steam and Power 3.4.2.3.5 Power Conversion Feedwater System - Summary of Aging Conversion System - Feedwater Aging Evaluation - LRA Table 3.4.2-5 Management Evaluation Management summarizes the results of AMRs for the feedwater The staff reviewed LRA Table 3.4.2-5, which summarizes feedwater system component groups.

In LRA Table 3.4.2-5, the applicant proposed to manage manage cracking cracking duedue to stress corrosion cracking cracking (SCC) for valve bodies made of copper greater zinc exposed 15% or greater copper alloy with 15% exposed to an environment of treated water (internal) using the Water Chemistry Program and the One-Time water (internal) One-Time Inspection components the applicant cited generic note H, Program. For these components H, indicating that the aging effect is not in the GALL Report for this component, material and environment environment combination. The combination. The applicant also cited a plant-specific applicant effects/mechanisms for copper plant-specific note stating that the aging effects/mechanisms copper environment include alloy with 15% or greater zinc in a treated water environment cracking due include cracking due to SCC.

The staff confirmed that the GALL GALL Report does not list cracking due to SCC as an aging effect applicable for copper alloy with 15%

applicable 15% or greater exposed to treated water. The staff also greater zinc exposed selected portions of EPRI Report 1010639, "Non-Class 1 Mechanical reviewed selected reviewed Implementation Mechanical Implementation Mechanical Tools, Revision 4, dated January Guideline and Mechanical January 2006. The staff noted noted that Section 3.2.2, Appendix A of the EPRI report states that in the presence ammonia or other presence of ammonia ammonium compounds that may ammonium may be in used in treated cracking due to SCC can treated water systems, cracking occur in copper occur copper alloys alloys containing 15% greater zinc. On the basis that the aging effect 15% or greater effect is identification of cracking identified in the EPRI report, the staff finds the applicant's identification cracking due to SCC in in copper copper components exposed to treated water acceptable.

acceptable.

3-365 3-365

Program and its evaluation is documented in applicant's Water Chemistry Program The staff reviewed the applicant's SER Section 3.0.3.2.2. The staff finds that the program, SER Section program, with an enhancement, enhancement, is consistent with GALL AMP XI.M2, "Water GALL 'Water Chemistry." The staff reviewed the applicant's applicant's One-Time Inspection One-Time Inspection Program and its evaluation is documented Program Section 3.0.3.2.14. The staff finds that the documented in SER Section the program consistent with GALL AMP XI.M32, program is consistent Inspection," and is adequate to detect XI.M32, "One-Time Inspection,"

the presence or note the absence of cracking due to SCC for components components within the scope 'of of the the determination that the Water Chemistry Program provides lI Based on the staff's determination program. Based mitigation and andJpethe One-Time One-Time Inspection potential aging ~ffect Inspection Program provides detection for the potential effect of cracking cracking due applicant's proposed AMPs for managing the aging due to SCC, the staff finds the applicant's cracking due to SCC in valve bodies made effect of cracking made of copper copper alloy with 15%

15% or greater zinc zinc environment of treated exposed to an environment exposed feedwater system to be acceptable.

treated water in the feedwater acceptable.

exposed to an air with borated The staff noted that for nickel alloy piping, fittings, thermowells, exposed water leakage applicant assigned no aging effect and therefore no leakage (external) environment, the applicant no aging management management program program was assigned assigned for these component/material/environment component/material/environment combinations.

austenitic materials such nickel alloys are not subject to loss of material or noted that austenitic The staff noted cracking when subjected cracking environment and these materials are used as corrosion resistant subjected to this environment resistant materials where replacement materials materials have degraded. According where other materials According to EPRI 5769, Nuclear Power Plants, Volumes "Degradation and Failure of Bolting in Nuclear Volumes 1 and 2," 2," April 1988,,

1988" martensitic stainless steels and high strength materials such as austenitic and martensitic corrosion resistant materials nickel base alloys offer good protection against boric acid corrosion. ThereforeTherefore no aging management management program necessary for nickel alloys in the air with borated water leakage program is necessary leakage (external) environment.

environment.

Note H for copper alloy (Zn less than 15%)

designated Note The applicant designated exposed to aa 15%) piping fittings exposed environment in the feedwater lubricating oil environment feedwater system because the loss of material due to microbiologically-influenced corrosion for the AMR line item component, material, and microbiologically-influenced environment combination is not evaluated in the GALL GALL Report for the copper piping and fittings.

The staff reviewed the GALL GALL Report and concluded that the AMR line item, copper alloy piping piping and fittings, is not evaluated for a lubricating environment for loss of material due to lubricating oil environment to corrosion . The applicant credits microbiologically-influenced corrosion.

microbiologically-influenced Lubricating Oil Analysis P~pgram credits the Lubricating Program and the One-time Inspection Program for managing managing loss of material and material due to pitting, crevice, <;ind Lubricating Oil Analysis MIC. The staff reviewed the Lubricating Program and the One-Time Analysis Program Inspection; One-Time Inspection' evaluations are documented Program and its evaluations documented in SER Sections 3.0.3.2.18 and 3.0.3.2.14, Sections 3.0.3.2.18 respectively. The staff finds that these programs 1) provide for periodic sampling of lubricating oil to maintain contaminants at acceptable maintain contaminants preclude loss of material due to pitting, crevice acceptable limits to preclude crevice microbiologically-influenced corrosion and 2) and microbiologically-influenced 2) will provide provide for one-time inspections of select one-time inspections components exposed components exposed to lubricating material due to pitting, crevice and lubricating oil for loss of material microbiologically-influenced corrosion at susceptible microbiologically-influenced effectiveness of the susceptible locations to verify the effectiveness the Lubricating Oil Analysis Program. The staff noted that one-time inspection is an acceptable Lubricating acceptable method to determine whether or not loss of material occurring slowly material is occurring slowly such that the intended function function will be maintained maintained during the period of extended operation. The staff extended operation. staff finds that the the Program and the One-Time Lubricating Oil Analysis Program Lubricating One-Time Inspection Inspection Program adequate to manage Program are adequate manage loss of material due to pitting, microbiologically-influenced corrosion for these copper pitting, crevice, and microbiologically-influenced alloy components components exposed through the period of extended exposed to lubricating oil through extended operation. "

On the basis of its review, the staff finds that the applicant has appropriately evaluated the AMR appropriately evaluated AMR results of material, environment, AERM, combinations not evaluated in the GALL AERM, and AMP combinations demonstrated that the effects of aging will be Report. The staff finds that the applicant has demonstrated be 3-366 3-366

adequately managed so that the intended adequately managed intended function(s) maintained consistent with the CLB function(s) will be maintained for the period of extended operation, as required by 10 CFR 54.21(a)(3).

extended operation, Steam and Power Conversion System - Main Generator 3.4.2.3.6 Steam Generator and Auxiliary Auxiliary Systems -

Summary Management Evaluation - LRA Table 3.4.2-6 Summary of Aging Management 3.4.2-6 The staff reviewed LRA Table 3.4.2-6, which summarizes the results of AMR evaluations for the the main generator and auxiliary component groups.

auxiliary systems component In LRA Table 3.4.2-6, the applicant designated designated Note H for copper alloy (Zn less than 15%) 15%) piping, exposed to a lubricating fittings and valves exposed lubricating oil environment environment in the main generator generator and auxiliary system because the loss of material microbiologically-influenced corrosion material due to microbiologically-influenced corrosion for the AMR AMR line item component, material, and environment environment combination is not evaluated in the GALL Report for the copper piping, and fittings. The staff reviewed the GALL Report staff reviewed Report and concluded that the the AMR line item, copper alloy piping, fittings, and valves is not evaluated for a lubricating lubricating oil environment for loss of material environment material due microbiologically-influenced corrosion. The applicant due to microbiologically-influenced credits the Lubricating Lubricating Oil Analysis Analysis Program One-time Inspection Program and the One-time Inspection Program for managing managing loss of material microbiologically influence material due to pitting, crevice, microbiologically influence corrosion. The staff reviewed Lubricating Oil Analysis Program and the One-Time the Lubricating Inspection Program One-Time Inspection Program and its evaluations evaluations 3.0.3.2.18 and 3.0.3.2.14, respectively. The staff finds that documented in SER Sections 3.0.3.2.18 are documented these programs programs 1) provide for periodic periodic sampling lubricating oil to maintain contaminants sampling of lubricating contaminants at preclude loss of material due to pitting, crevice acceptable limits to preclude acceptable crevice and microbiologically-microbiologically-influenced corrosion and 2) influenced components exposed

2) will provide for one-time inspections of select components exposed to lubricating oil for loss of material due to pitting, crevice and microbiologically-influenced lubricating microbiologically-influenced corrosion corrosion effectiveness of the Lubricating Oil Analysis Program. The locations to verify the effectiveness in susceptible locations The staff noted that one-time one-time inspection acceptable method inspection is an acceptable determine whether or not loss of method to determine intended function will be maintained during occurring slowly such that the intended material is occurring during the period of operation. The staff finds that the Lubricating Oil Analysis Program extended operation.

extended Program and the One-Time One-Time Inspection Program are adequate to manage loss of material due to pitting, crevice, Inspection crevice, and corrosion for these copper alloy components microbiologically-influenced corrosion microbiologically-influenced components exposed to lubricating lubricating oil through the period period of extended extended operation.

In LRA Table applicant stated that for glass tank and sight glasses in air-gas wetted Table 3.4.2-6, the applicant environment there are no aging effects requiring management. The applicant internal environment referenced applicant referenced environment is not listed in the GALL footnote "G" for this line item indicating that environment Report for this GALL Report this material material and component combination.

As indicated in "Corrosion Handbook" by H.H.Uhlig, H.H.Uhlig, the staff noted that glass as a material is impervious to normal normal plant environments. This conclusion is based on industry experience where industry experience the staff noted that no failure due to an aging effect of glass componentscomponents in environments environments free of hydrofluoric acid, caustics, or hot water have been recorded in industry at temperatures hydrofluoric temperatures or duringduring time periods of concern for extended acknowledges that the use of glass extended operation. The staff acknowledges glass in power power plant environments design-driven criterion and once environments is a design-driven selected for the environment will once'selected significant age related not have any significant degradation, since air-gas wetted internal environment related degradation, environment does does hydroflouric acid or caustics. Based not contain hydroflouric Based on this review and on the industry operating experience, the staff finds that glass in an air-gas wetted internal environmentenvironment will not have any aging effects requiring aging aging management.

In LRA Table 3.4.2-6, the applicant In applicant stated that for polytetrafluoroethylene polytetrafluoroethylene (PTFE) piping and fittings in treated water and air-indoor environments, there are no aging air-indoor environments, requiring aging effects requiring 3-367 3-367

management. The management. The applicant applicant referenced referenced footnote footnote "F" for this line item indicating indicating that material material is not listed listed in the GALL Report Report for this component component and and environment environment combination.

combination. .

As identified identified in "Engineering "Engineering Materials Materials Handbook Handbook - Engineering Engineering Plastics,"

Plastics," the the staff staff noted noted that that PTFE PTFE is aa thermoplastic thermoplastic member member of of the fluoropolymer fluoropolymer family of plastics and and has aa low coefficient coefficient of friction, excellent excellent insulating insulating properties, and and is chemically inert to most substances.

chemically inert substances. The staffstaff also noted that unlike unlike metals, thermoplastics thermoplastics do not display corrosion display corrosion rates, and rather than and rather than depend depend on an an oxide layer for protection, protection, they dependdepend on chemical chemical resistance resistance to the environments environments to which which they are exposed.

exposed. The The use use of thermoplastics thermoplastics in power power plant environments environments is a design-deslgn-driven driven criterion.

criterion. The The staff staff acknowledges acknowledges that PTFE is an impervious impervious material material and once once selected for the environment environment will not have have any any significant significant ageage related related degradation.

degradation. The staff staff has has not not*

observed any observed any age age related related industry industry experience experience for PTFE PTFE material material in treated treated water water and air-indoor air-indoor environments. Based on this review, the staff staff finds that that for PTFE PTFE piping piping and fittings in treated water water and air-indoor environments air-indoor environments there there are no no aging effects requiring management.

management.

,I On the basis basis of its review, the staff finds that the applicant applicant has appropriately appropriately evaluated evaluated the AMR AMR results of combinations combinations of material, material, environment, environment, AERM, AERM, and AMP not evaluated in the GALL not evaluated Report. The staff finds that the applicant demonstrated that the effects applicant has demonstrated effects of aging aging will bebe

adequately adequately managed, so that the intended functions will be maintained maintained consistent with the CLB eLB for the period period of extended extended operation, required by 10 CFR 54.21(a)(3).

operation, as required 54.21(a)(3).

3.4.2.3.7 3.4.2.3.7 Steam Steam andand Power Power Conversion Conversion SystemSystem - MainMain Steam System - SummarySummary of Aging Aging Management Management Evaluation Evaluation - LRA Table Table 3.4.2-7 3.4.2-7 The staff reviewed LRA Table 3.4.2-7, which summarizes summarizes the results of AMRs for the main steam system component component groups. '

In LRA Table 3.4.2-7, the applicant proposed to manage cracking due to stress corrosion cracking corrosion cracking (SCC) for piping and fittings and valve bodies bodies made of copper alloy with 15% or greater zinc greater zinc exposed to an environment of treated treated water (internal) using the Water Chemistry Chemistry Program and the the One-Time Inspection Program.

One-Time Program. For these components components the applicant applicant cited generic note H, indicating that the aging effect is not in the GALL Report indicating Report for this component, material and ,

environment combination. The applicant environment applicant also cited a plant-specific plant-specific note note stating that the aging effects/mechanisms for copper alloy with 15%

effects/mechanisms 15% or greater greater zinc in a treated water environment include cracking due to SCC.

The staff confirmed that the GALL Report does not list cracking cracking due to SCC as an aging effect applicable for copper alloy with 15% or greater zinc exposed to treated treated water. The staff also selected portions of EPRI Report 1010639, "Non-Class 1 Mechanical reviewed selected Mechanical Implementation Guideline and Mechanical Mechanical Tools, Revision 4, dated January 2006. The staff noted that Section 3.2.2, Appendix A of the EPRI report states that in the presence of ammonia or other other ammonium ammonium compounds that may be used in treated water systems, cracking due to SCC can occur in copper alloys containing 15% 15% or greater zinc. On the basis that the aging effect is identified in the EPRI report, the staff finds the applicant's identification of cracking due to SCC SCC in in copper components exposed to treated water acceptable.

reviewed the applicant's Water Chemistry Program and its evaluation is documented in The staff reviewed in SER Section 3.0.3.2.2. The staff finds that Water Chemistry Program, with an enhancement, is consistent with GALL AMP XI.M2, "Water "Water Chemistry."

Chemistry." The staff reviewed the applicant's One-Time Inspection Program and its evaluation is is documented in SER Section 3.0.3.2.14. The staff finds that the One-Time Inspection Inspection Program is is consistent with GALL AMP XI.M32, "One-Time 3-368 3-368

Inspection," and is adequate Inspection," adequate to detect the presence presence or note note the absence absence of cracking cracking due due to SCC for components components within the scope of the program. Based Based on the staff's determination determination that the the Water Chemistry Program Program provides mitigation mitigation and the One-Time One-Time Inspection ProgramProgram provides provides detection for the potential detection potential aging effect of cracking cracking due to SCC, the staff finds the applicant's applicant's proposed AMPs for managing managing the aging effect of cracking due to SCC in piping and fittings and valve bodies made of copper alloy with 15% 15% or greater greater zinc exposed to an environment environment of treated water in the main steam system acceptable.

acceptable.

In LRA Table 3.4.2-7, the applicant proposed to manage loss of material due to general general corrosion corrosion for carbon steel and low alloy steel piping and fittings and for carbon steel valve bodies exposed to an environment environment of steam (internal) using the Water Chemistry Program. components Program. For these components the applicant cited generic generic note H, indicating that the aging effect is not in the GALL Report Report for this component, material material and environment combination.

environment combination. The applicant plant-specific applicant also cited a plant-specific note stating that the aging aging effects/mechanisms effects/mechanisms for carbon steel and low alloy steel in aa steam environment include environment include loss of material material due to general general corrosion.

The staff noted that in the GALL Report, Volume 1, Table 4, Item 37 provides aging management management results for steel, stainless steel and nickel-based nickel-based alloy piping, piping components, and piping piping elements exposed to steam in the main steam system. The staff also noted that this AMR result result identifies the aging effect as loss of material line identifies material due due to pitting and crevice crevice corrosion corrosion and recommends use cif recommends of the Water Water Chemistry Program to manage manage the aging effect. Because Because the the GALL Report Report line item for these main steam piping components does not explicitly list general corrosion as an aging mechanism mechanism that may cause loss of material in carbon steel piping and and components exposed to a steam environment, the staff finds the applicant's piping components identification of applicant's identification loss of material material due to general general corrosion for for carbon steel valve bodies exposed to a steam environment environment acceptable.

The staff reviewed the applicant's Water Water Chemistry Program Program and its evaluation is documented documented in SER Section 3.0.3.2.2. The staff finds that the program, program, with an enhancement, enhancement, is consistent with GALL AMP XI.M2,XI,M2, "Water Chemistry."

Chemistry." The staff noted noted that in the SRP-LR, Table 3.4-1, 3.4-1, Item 37, the AMP recommended recommended for managing managing the aging effect of loss of material due to pitting and crevice crevice corrosion corrosion for steel piping and fittings in a steam environment is the Water Chemistry steam environment Chemistry Program, Program, alone. The ~taff staff also noted that the applicant proposed proposed to manage the same aging effect due to a different different mechanism (general corrosion) using the same program as recommended recommended in SRP-LR, 3.4-1, item 37. Based Table 3.4-1, Based on the staff's determination determination that the applicant's applicant's Water Chemistry Program is consistent with with the GALL GALL Report AMP and on the SRP-LR's recommendation of the SRP-LR's recommendation the Water Chemistry Program, Program, alone, for managing the aging effect of corrosion corrosion in a steam environment, the staff finds the applicant's proposed proposed AMP for managing managing the aging effecteffect of loss of material due to general material general corrosion in carbon steel and low alloy steel piping and fittings and carbon steel valve bodies exposed to an environment environment of steam in the main steam system to be be acceptable.

On the basis of its review, the staff finds that the applicant applicant has appropriately appropriately evaluated evaluated the AMR AMR results of material, environment, AERM, AERM, and AMP combinations not evaluated evaluated in the GALL Report. The staff finds that the applicant has demonstrated demonstrated that the effects of aging will be be adequately adequately managed so that the intended intended function(s) will be maintained maintained consistent consistent with the CLB extended operation as required by 10 CFR 54.21 (a)(3).

for the period of extended 3-369 3-369

3.4.2.3.8 Steam and Power Conversion 3.4.2.3.8 Conversion System - Steam Turbine Turbine and Auxiliary Systems Systems --;

Management Evaluation - LRA Table Summary of Aging Management Table 3.4.2-8 The staff reviewed reviewed LRA Table 3.4.2-8, which summarizessummarizes the results of AMRs for the steam' steam turbine and auxiliary component groups.

auxiliary systems component In LRA Table 3.4.2-8, 3.4.2-8, the applicant applicant proposed proposed to manage material due to erosion manage loss of material erosion for carbon material for piping and fittings exposed to an external treated steel material environment using the treated water environment the Inspection of Internal Surfaces in Miscellaneous Inspection Miscellaneous Piping and DuctingDucting Components Components Program. The The AMR line items cite GenericGeneric Note H, aging effect is not addressed H, which indicates that the aging addressed in the the GALL Report for this component, material and environment environment combination.

combination.

Based on the staffs review of this AMR item, the staff determined determined that additional information was additional informatior:J was needed regarding the applicant's proposed AMP for this AMR item. In RAI 3.4.2-8-1, applicant's proposed 3.4.2-8-1, dated October 15, 2008 the staff requested that the applicant provide additional October information clarifying additional information clarifying surface of piping and fittings inspection of the internal surface how the inspection will be representative representative of ~ging the aging occurring from the external degradation that would be occurring and degradation treated water environment.

external treated In its response to the RAI dated November 12, 2008, the applicant stated November 12,2008, configuration of stated that the configuration the carbon steel piping and fitting that this AMR line item references.references. Based on the applicant'sapplicant's clarification, noted that the piping and fittings are internal to the main condenser clarification, the staff noted condenser steam material due to erosion on the external subject to loss of material space, but are subject surface of the piping and external surface fittings.

Based on its review, the staff finds the applicant's Based applicant's response to RAI 3.4.2-8-1 acceptable because 3.4.2-8-1 acceptable because the applicant clarified clarified that Inspection Inspection of Internal Surfaces Miscellaneous Piping and Ducting Surfaces in MiscelianeousPiping Components Components Program Program was chosen becausebecause these components are internal to the main condenser condenser steam space, but the external surface surface of these components subject to erosion and exposed to components is subject this environment. The staff's concern described in RAI 3.4.2-8-1 concern described 3.4.2-8-1 is resolved. .

Inspection of Internal reviewed the Inspection The staff reviewed Internal Surfaces oJ Miscellaneous Piping and Ducting' of Miscellaneous Ducting ,:

Components Program and its evaluation is documented Components documented in SER Section 3.0.3.2.17. The staff finds finds Inspection of Internal that the Inspection Internal Surfaces in Miscellaneous Miscellaneous Piping and Ducting Components Components Program Program performs periodic periodic visual inspections surfaces during periodic inspections of internal surfaces periodic system and component surveillance activities or during maintenance activities when the internal surface during maintenance surface is accessible for visual inspections to detect detect aging effects that could result

.result in a loss of the the component's intended function. On the basis of its review, the staff finds intended function. . that because thesethese..

periodically by visual inspections when exposed to an internal inspected periodically components will be inspected environment of treated water they will be adequately environment managed by the Inspection of Internal adequately managed Surfaces in Miscellaneous Miscellaneous Piping and Ducting Components Components Program.

designated Note G for Aluminum Alloy Valve Bodies and Note Table 3.4.2-8, the applicant designated In LRA Table Note exchanger components, pump casings, and H for copper alloy piping, fittings, filter housings, heat exchanger bodies exposed to a lubricating valve bodies environment in the steam turbine and auxiliaries system lubricating oil environment because the aging because effect for the AMR line item component, material, and environment aging effect environment evaluated in the GALL Report combination is not evaluated combination copper alloy components and the Report for the copper the I' environment is not in the GALL environment aluminum alloy components. The staff reviewed the Report for the aluminum GALL Report the GALL Report and found that the AMR line item, piping and and fittings is not evaluated for a lubricating oil environment for loss of material due to pitting, crevice, microbiologically lubricating influence microbiologically influence corrosion and that the GALL Report does not address aluminum Report does aluminum filter housings exposed exposed to* to lubricating lubricating oil and accordingly accordingly Note G is appropriate.

appropriate. The applicant applicant credits the Lubricating Oil 3-370

Analysis Program Program and the One-time Inspection Program for managing loss of material material due to pitting, crevice, microbiologically-influenced corrosion. The staff reviewed crevice, microbiologically-influenced reviewed the Lubricating Lubricating Oil Analysis Analysis Program One-Time Inspection program and its evaluations Program and the One-Time evaluations are documented in in SER Sections 3.0.3.2.18 3.0.3.2.18 and 3.0.3.2.14, respectively. The staff finds that these programs 1) provide for periodic periodic sampling of lubricating lubricating oil to maintain contaminants contaminants at acceptable acceptable limits to preclude loss of material due to pitting, crevice and microbiologically-influenced microbiologically-influenced corrosion and 2) will provide for one-time inspections of select components exposed to lubricating oil for loss of components exposed material due to pitting, pitting, crevice microbiologically-influenced corrosion at susceptible crevice and microbiologically-influenced susceptible locations locations to verify the effectiveness effectiveness of the Lubricating Lubricating Oil Analysis Program.

Program. The staff noted that one-time one-time inspection is an acceptable acceptable method to determine determine whether or not loss of of material occurring material is occurring intended function will be maintained slowly such that the intended maintained during the period of extended operation.

extended operation.

The staff finds that the Lubricating Lubricating Oil Analysis Program and the One-Time Inspection Inspection Program are adequate to manage loss of material due to pitting, crevice, and microbiologically-influenced microbiologically-influenced corrosion for these aluminum aluminum and copper alloy components exposed exposed to lubricating oil through the the period period of extended extended operation.

In LRA Table 3.4.2-8, the applicant stated that for glass sight glasses in air-gas wetted wetted internal environment there are no aging effects requiring management. The applicant referenced environment referenced footnote footnote "G" for this line item indicating that environment is not listed in the GALL Report for this material and component combination.

combination.

As indicated indicated in "Corrosion Handbook" by H.H.Uhlig, the staff noted that that glass as a material material is impervious to normal plant environments. This conclusion is based on industry experience impervious experience where the staff noted that no failure due to an aging effect of .glass glass components in environments environments free of hydrofluoric acid, caustics, or hot water have been recorded in industry hydrofluoric industry at temperatures temperatures or during time periods extended operation. The staff acknowledges periods of concern for extended acknowledges that the use use of glass in power plant environments environments is a design-driven design-driven criterion and once selected for the environment environment will not have any significant age age related degradation, since air-gas air-gas wetted internal environment environment does does not contain hydroflouric hydroflouric acid or caustics. Based on this review and on the industry industry operating operating experience, the staff finds that glass in an air-gas wetted internal internal environment environment will not have have any any aging effects requiring aging management.

On the basis of its review, the staff finds that the applicant applicant has appropriately appropriately evaluated the AMR AMR results of material, environment, AERM, AERM, and AMP combinations not evaluated evaluated in the GALL Report. The staff finds that the applicant has demonstrated demonstrated that the effects of aging will be be adequately managed adequately managed so that the intended function(s) intended function(s) will be maintained consistent maintained consistent with the CLB for the period of extended extended operation, as required required by 10 CFR 54.21(a)(3).

54.21 (a)(3).

3.4.3 Conclusion Conclusion The staff concludes concludes that the applicant applicant has provided provided sufficient information to demonstrate sufficient information demonstrate that the the effects of aging for the steam and power conversion system components conversion system components within the scope of license license renewal and subject to an AMR will be adequately adequately managed so that the intended intended functions functions will be maintained maintained consistent with the CLB for the period of extended operation, extended operation, as required by 10 .

54.21(a)(3).

CFR 54.21 (a)(3).

3-371

3.5 Management of Containments, Aging Management Containments, Structures, and Component Supports Supports This section of the SER documents the staffs review of the applicant's applicant's AMR results for the the containments, structures, and componentcomponent supports of the following:

"

Air Intake Structures Structures

Auxiliary Building

"

"** Circulating Water Pump House Control Building Control Building House

"* Diesel Generator Generator Building Building

"

Dike/Flood Control System "o*

Handling Building Fuel Handling Building

- Intake Screen and Pump House House Intermediate Building Building "oo Intermediate Mechanical Draft Cooling Tower Structures Mechanical Structures "o Miscellaneous Structures Miscellaneous Yard Structures "o Natural Draft Cooling Tower Tower Natural "o Structural Commodities Structural Commodities

"

- Reactor Building (containment)

Reactor

- Generator Building SBO Diesel Generator Building

- Service Building Service Building

0 Component Supports Commodity Group Group

- Structures Substation Structures

- Turbine Building Building

0 UPS Diesel Building Building 3.5.1 Summary Information in the Application Summary of Technical Information Application LRA Section 3.5 provides AMR results for structures, structural structural components, and component compone,nt supports. LRA Table 3.5.1, 3.5.1, "Summary of Aging Management Management Evaluations Evaluations for Structures Structures and Component Supports," is a summary comparison comparison of the applicant's applicant's AMRs with those evaluated evaluated in the in the GALL Report.

GALL Report.

The applicant's applicant's AMRs evaluated and incorporated incorporated applicable applicable plant-specific plant-specific and industry operating operating experience in in the determination determination of AERMs.

AERMs. The plant-specific plant-specific evaluation included included condition reports and discussions discussions with appropriate appropriate site personnel to identify AERMs. The The applicant's applicant's review of industry operating experience operating experience included a review of the GALL Report and operating experience experience issues identified identified since the issuance of the GALL Report.

3.5.2 3.5.2 Evaluation Staff Evaluation The staff The staff reviewed reviewed LRA Section 3.5 to determine Section 3.5 determine whether the the applicant has provided applicant has provided sufficient sufficient information to demonstrate information demonstrate thatthat the the effects effects of aging aging for for the the containment, structures and containment, structures component supports component supports within the scope of license renewal and subject to an AMR, will be be 3-372

consistent with the CLB intended function(s) will be maintained consistent adequately managed so that the intended adequately CLB extended operation, for the period of extended 54.21 (a)(3).

operation, as required by 10 CFR 54.21(a)(3).

--- ----- -The The staff conducedai-review conducted--a review onheAMRsto-coi1firmlheapplicant'sCiaiin nap-li cant's claim that certain

-ofthe AMR-s -to oonfirm-tlhe -AMR~; - -- --

certain-AMRs.

consistent with the GALL Report. The staff were consistent staff did not repeat its review of the matters matters described in the GALL Report; however, the staff did verify that the material presented described presented in the the appropriate GALL Report AMRs. The applicant identified the appropriate LRA was applicable and that the applicant The following programs managing the aging effects for the structures and programs are credited for managing component component supports:

- Structures Monitoring Structures Monitoring Program

- Boric Acid Corrosion

- Selective leaching of Material

- Buried Piping and Tank Inspection

- One-Time Inspection One-Time Inspection

- Water Chemistry Chemistry

- 10 10 CFR Part 50, Appendix J

- ASME Section Section Xl, - IWE XI, Subsection -IWE

- ASME Section XI, Subsection - IWF IWF

0 ASME Section XI, Xl, Subsection -IWL

- IWL

- External Surfaces Surfaces Monitoring Monitoring

- TLAA The staff reviewed the AMRsAMRs to confirm the applicant's identified AMRs were applicant's claim that certain identified were consistent with the GALL Report. The staff did described in not repeat its review of the matters described did not in the GALL Report; presented in the LRA was Report; however, the staff did verify that the material presented was identified the appropriate applicant had identified applicable and that the applicant GALL Report AMRs. Details appropriate GALL Details of evaluation are discussed in SER Section 3.5.2.1 and 3.5.2.2.

the staff's evaluation reviewed the AMRs not consistent with or not addressed in the GALL Report. The The staff also reviewed The evaluated whether all plausible aging effects review evaluated identified and whether the aging effects were identified aging appropriate for the combination of materials effects listed were appropriate environments specified.

materials and environments specified.

discussed in SER Section 3.5.2.3.

evaluation are discussed Details of the staffs evaluation For components whichwhich the applicant claimed were not applicable or required no aging aging .

management, the staff reviewed the AMR AMR line items and the plant's operating experience to operating experience verify the applicant's applicant's claims.

summarizes the staff's evaluation of components, aging effects or mechanisms, Table 3.5-1 summarizes mechanisms, and addressed in the GALL Report.

AMPs listed in LRA Section 3.5 and addressed 3-373 3-373

Table 3.5-1 Table Evaluation for Staff Evaluation 3.5-1 Staff Containments, Structures, for Containments, Structures, and Supports in Component Supports and Component in the GALL the GALL Report Report

ýComponent Groupd jgingý ect AMP in:GALL r : i (GALL Report: Mechanism Report, Further

~

Ea-n.~ ~JAPi:A ~ t,- vluto Item No.) GALo

- - - ~~~Report, -Aedmnt,.<~

Concrete Concrete elements:

elements: Aging of Aging of ISI (IWL) and lSI (IWL) and for for Yes Yes ISI lSI (IWL)

(IWL) for for Consistent with Consistent with I

walls, walls, dome, dome, accessible and accessible and inaccessible inaccessible containment containment GALL Report GALL Report basemat, ring basemat, ring girder, girder, inaccessible inaccessible concrete, an concrete, an concrete concrete (See (See SER SER buttresses, buttresses, concrete areas concrete areas examination of examination of Sections Sections containment containment due due to to representative representative Structures Structures 3.5.2.1.2 and 3.5.2.1.2 and (as (as applicable),

applicable). aggressive aggressive samples samples of of below-below- Monitoring Monitoring 3.5.2.2.1) 3.5.2.2.1)

(3.5.1-1)

(3.5.1-1 ) chemical attack, chemical attack, grade concrete, and grade concrete, and Program for Program for and corrosion of and corrosion of periodic periodic monitoring monitoring groundwater groundwater embedded steel embedded steel of groundwater if of groundwater if monitoring monitoring environment environment isis non- non-aggressive. AA plant aggressive. plant Boric Boric Acid Acid specific program isis to specific program to Corrosion Corrosion evaluated ifif be evaluated be environment environment is is aggressive.

(!ggressive.

Concrete elements; Concrete elements; Cracks Cracks andand Structures Monitoring Yes Structures Monitoring Yes Not Not applicable applicable See SER SeeSER All All distortion due distortion due to to Program. if Program. If aa de-de- Section Section (3.5.1-2)

(3.5.1-2) increased stress increased stress watering system watering system is is 3.5.2.2.1 3.5.2.2.1 levels from levels from upon for relied upon relied for settlement settlement control control of of settlement, settlement, then the then licensee is the licensee is to to ensure ensure proper proper functioning functioning of of the the de- de-watering watering system system through through the the period period of of extended extended operation.

operation.

Concrete elements:

Concrete elements: Reduction in Reduction in Structures Monitoring Yes Structures Monitoring Yes Not Not applicable applicable See See SER SER foundation, foundation, foundation foundation Program Program If If aa de-de- Section Section sub-foundation sub-foundation strength, strength, system is watering system watering is 3.5.2.2.1 3.5.2.2.1 (3.5.1-3)

(3.5.1-3) cracking, cracking, relied upon to relied upon to control control differential differential erosion erosion of of cement cement settlement due settlement due from from porous porous concrete concrete to erosion of to erosion of subfoundations, then subfoundations, then porous concrete porous concrete the licensee the licensee is is to to subfoundation subfoundation ensure ensure proper proper functioning functioning of of the the de- de-watering system watering. system through through the the period period of of extended operation.

extended operation.

Concrete elements:

Concrete elements: Reduction Reduction of of A plant-specific aging A plant-specific aging Yes- Yes Not Not applicable applicable See See SER SER dome, wall, dome, wall, basemat, basemat, strength and strength and management management Section Section ring ring girder, girder, modulus of modulus of program is program is toto be be 3.5.2.2.1 3.5.2.2.1 buttresses, buttresses, concrete due concrete due to to evaluated.

evaluated.

containment, containment, elevated elevated concrete concrete fill-in fill-in temperature temperature annulus annulus (as applicable) applicable)

(3.5.1-4) 1(3.5.1-4) 3-374 3-374

Comrponent Group Aging EffectV`: AMP int GALL 'Further IAMP in'LA tf eo.)~ Mchns NG~ ~ ~ Rpr Evaluation Supplements,. Evaluation 2~3/4~'1R~eport Amendmets' Steel elements:

elements: Loss of material material lSI (IWE) and ISI (IWE) Yes Not applicable applicable Not applicable drywell; torus; due to general, 10 CFR Part 50, to PWRs (See drywell pitting and Appendix J SER SER Section embedded head; embedded crevice 3.5.2.1.1) 3.5.2.1.1 )

shell and sand corrosion pocket regions; drywell drywell support support skirt; torus ring girder; downcomers; down comers; liner liner plate, ECCS suction header, support skirt, region shielded shielded by diaphragm floor, diaphragm suppression suppression chamber chamber (as applicable) 3.5:1-5 (3.5.1-5)

Steel elements: steel Loss of material lSI ISI (IWE)

(IWE) and Yes ISI (IWE) lSI (IWE) and Consistent Consistent with liner, liner anchors, due to general, 10 CFR Part Part 50, 10 CFR Part 50, GALL GALL Report, integral attachments attachments pitting and Appendix JJ Appendix J AppendixJ (See SER (3.5.1-6) crevice crevice Section corrosion corrosion 3.5.2.2.1) 3.5.2.2.1 Prestressed Prestressed Loss of TLAA, evaluated in Yes TLAA Consistent Consistent with with containment tendons containment tendons prestress due due to accordance accordance with GALL Report Report (3.5.1-7) relaxation, 10 CFR 54.21(c) (See SER shrinkage, Section creep, and 3.5.2.2.1) 3.5.2.2.1) elevated elevated temperature tem erature Steel and stainless stainless Cumulative Cumulative TLAA, TLAA, evaluated evaluated in Yes Not applicable applicable Not applicable applicable steel elements: vent fatigue damage damage accordance with accordance to PWRs (See (See line, vent header, (CLB fatigue (CLS 10 10 CFR 54.21(c) SER Section Section vent line bellows; analysis exists) 3.5.2.1.1))

3.5.2.1.1 downcomers; 3.5.1-8 (3.5.1-8)

Steel, stainless steel Cumulative Cumulative TLAA, evaluated evaluated in Yes TLAA - Metal Metal Consistent with elements, dissimilar dissimilar fatigue damage accordance with accordance fatigue GALL Report metal welds: (CLB fatigue (CLS 10 CFR 54.21(c) (See SER penetration sleeves, analysis exists) Section penetration bellows; bellows; 3.5.2.2.1) 3.5.2.2.1) suppression pool shell, unbraced downcomers downcomers (3.5.1-9) 3.5.1-9 3-375 3-375

Component Grop Aging .Effect M nGL Staff Rort SI(GL Mechanism Report Further AMP in R,-

-Evaluation Supplements, Evaluation

-~~~~i -< ..- ~GALL.:i 7Kor mndments

-~~~~ - , Rp Stainless Stainless steel steel Cracking Cracking due due to to lSI (IWE)

ISI (IWE) andand Yes Yes Not Not applicable applicable See See SER SER penetration penetration sleeves, sleeves, stressstress corrosion corrosion 10 10 CFR CFR PartPart 50, 50, Section Section penetration bellows, cracking penetration bellows, cracking Appendix J, Appendix J, and and 3.5.2.2.1 3.5.2.2.1 dissimilar dissimilar metal metal additional additional welds welds appropriate appropriate (3.5.1-10)

(3.5.1-10) examinations/

examinations!

evaluations evaluations for for bellows bellows assemblies assemblies and and dissimilar dissimilar metal metal welds.

welds.

Stainless steel Stainless steel vent vent Cracking due Cracking due to to ISI lSI (IWE)

(IWE) andand Yes Yes Not Not applicable applicable Not applicable Not applicable line bellows, line bellows, stress corrosion stress corrosion 10 CFR Part 10 CFR Part 50, 50, to to BWRs BWRs (See (See (3.5.1-11)

(3.5.1-11) cracking cracking Appendix J,J, and Appendix and SER Section SER Section additional, additional, 3.5.2.1.1).

3.5.2.1.1) .

appropriate appropriate examination/

examination!

evaluation evaluation for for bellows bellows assemblies assemblies and and dissimilar dissimilar metal metal welds.

welds.

Steel, Steel, stainless stainless steel steel Cracking Cracking due due toto ISIlSI (IWE)

(IWE) andand Yes Yes ISI (IWE) and lSI (IWE) and Consistent Consistent with with

elements, elements, dissimilar dissimilar cyclic loading cyclic loading 10 CFR Part 10 CFR Part 50, 50, 10 10 CFR Part 50, CFR Part 50, GALL GALL Report Report metal metal welds:

welds: Appendix J,J, and Appendix and Appendix JJ Appendix (See (See SER SER penetration penetration sleeves, sleeves, supplemented to supplemented to Section Section penetration penetration bellows; bellows; detect fine detect fine cracks cracks 3.5.2.2.1) 3.5.2.2.1) suppression suppression poolpool

shell, shell, unbraced unbraced downcomers downcomers (3.5.1-12) 3.5.1-12 Steel, stainless steel Steel, stainless steel Cracking due Cracking due toto ISIlSI (IWE)

(IWE) andand Yes Yes Not Not applicable applicable Not applicable Not applicable

elements, elements, dissimilar dissimilar cyclic loading cyclic loading 10 CFR Part 10 CFR Part 50, 50, to to PWRs PWRs (See (See metal metal welds:

welds: torus; torus; Appendix Appendix J, J, and and SER Section SER Section vent vent line; line; vent vent supplemented to supplemented to 3.5.2.1.1) 3.5.2.1.1) header; vent line header; vent line detect detectfine fine cracks cracks bellows; bellows; downcomers downcomers (3.5.1-13) 3.5.1-13 Concrete Concrete elements:

elements: Loss Loss of ofmaterial material ISI lSI (IWL). Evaluation Yes (lWL). Evaluation Yes ISI lSI (IWL).

(lWL). Consistent with Consistent with

dome, dome, wall, wall, basemat basemat (scaling, (scaling, isis needed needed for plants for plants GALL GALL Report Report ring ring girder, girder, cracking, cracking, and and that are that are located located inin (See (See SER SER buttresses, buttresses, spalling) spalling) duedue to to moderate to moderate to severe severe Section Section containment containment freeze-thaw freeze-thaw weathering weathering 3.5.2.2.1) 3.5.2.2.1)

(as (as applicable) applicable) conditions conditions (3.5.1-14)

(3.5.1-14) (weathering (weathering index>

index> 100 100day-day-inch/yr) inch/yr)

(NUREG-1557).

NUREG-1557.

3-376 3-376

.Component Group Aging Effect/ AMP in GALL Frte AMinR, Saf (GALLReport Mechanism- Report - Evaluation Supplements, Evaluation

'Item No.)' inGALL. , or, Report Amendments Concrete elements:

Concrete elements: Cracking due to lSI (IWL)

ISI (IWL) for Yes lSI (IWL)

ISI (IWL) Consistent with Consistent dome, walls, dome, expansion expansion andand accessible accessible areas. GALL Report, GALL basemat, ring girder, reaction with None for None (See SER SER buttresses, buttresses, aggregate; aggregate; inaccessible areas inaccessible areas if if Section Section containment, in increase in increase concrete concrete was 3.5.2.2.1) 3.5.2.2.1 )

concrete fill-in concrete porosity, constructed in constructed annulus annulus permeability due permeability due accordance accordance with thethe applicable).

(as applicable), to leaching to of leaching of recommendations in recommendations (3.5.1-15)

(3.5.1-15) calcium calcium ACI201.2R.

ACI 201.2R.

h droxide hydroxide Seals, gaskets, and ISI (IWE) sealing lSI Loss of sealing (IWE) and and No ISI lSI (IWE)

(IWE) and Consistent Consistent with with moisture barriers moisture barriers and leakage and leakage 10 10 CFR Part 50, 10 10 CFR Part 50, GALL Report, (3.5.1-16)

(3.5.1-16) through Appendix J Appendix Appendix J Appendix (See SER containment due containment 3.5.2.1)

Section 3.5.2.1) deterioration to deterioration of joint seals, gaskets, and moisture barriers barriers (caulking, (caulking, flashing, and other sealants) other sealants Personnel Personnel airlock, Loss of leak 10 CFR Part 50, No App. J and Consistent with equipment hatch and equipment hatch tightness in Appendix J and plant Plant Technical Technical GALL Report, CRD hatch hatch locks, closed position Technical Specification Specification (See SER hinges, and closure due to Specifications Specifications program program Section 3.5.2.1 Section 3.5.2.1))

mechanisms mechanisms mechanical mechanical wear (3.5.1-17) of locks, hinges hinges and closure mechanisms mechanisms Steel penetration Loss of material lSI (IWE) and ISI (IWE) No IWE, and App. J Consistent with IWE, sleeves and general, 10 CFR Part 50, due to general, GALL Report, GALL*

dissimilar metal pitting, pitting, and Appendix J (See SER welds; personnel welds; crevice 3.5.2.1))

Section 3.5.2.1 airlock, equipment corrosion hatch and CRD hatch 3.5.1-18 (3.5.1-18)

Steel elements: Cracking due to lSI ISI (IWE)

(IWE) and No No Not applicable applicable Not applicable stainless steel stress corrosion 10 CFR Part 50, to BWRs (See(See suppression cracking Appendix J SER Section chamber shell (inner 3.5.2.1.1) 3.5.2.1.1) surface)

(3.5.1-19)

Steel elements: Loss of material lSI (IWE) and ISI (IWE) No applicable Not applicable applicable Not applicable suppression due general, 10 CFR Part 50, due to general, to BWRs (See to chamber liner pitting, pitting, and Appendix J SER Section (interior surface) crevice 3.5.2.1.1))

3.5.2.1.1 (3.5.1-20) corrosion 3-377 3-377

,Component Group Aging Effect/ AMP in GALL F (GALL Report, Mechanis~m ReportFuhe AMinRAStf

<UItm b.:Ev'aluation, Supplements,, Evaluation:,

iriGALL' or '

Report Amendments Steel Steel elements: Fretting or lock lSI ISI (IWE)

(IWE) No Not applicable applicable Not applicable applicable head and drywell head drywell up due due to to BWRs (See downcomer pipes downcomer mechanical wear SER Section (3.5.1-21))

1(3.5.1-21 3.5.2.1.1) 3.5.2.1.1)

Prestressed Loss of material material ISI (IWL) lSI (IWL) No ISI (IWL) lSI (IWL) Consistent with containment:

containment: due to corrosion corrosion GALL Report, tendons and tendons (See SER anchorage anchorage Section 3.5.2.1) 3.5.2.1) components components (3.5.1-22)

(3.5.1-22)

All Groups Groups except Monitoring Yes Cracking, loss of Structures Monitoring Structures Structures Consistent with Consistent Group interior and Group 6: interior bond, and bond; and loss Program Monitoring Monitoring GALL GALL Report above above grade exterior of material material Program Program (See SER concrete (spalling, Section (3.5.1-23) scaling) due to Boric Acid 3.5.2.1.3) 3.5.2.1.3) corrosion corrosion of Corrosion embedded steel embedded All Groups except Increase Increase in Structures Structures Monitoring Yes Structures Consistent with Consistent with Group 6: interior and porosity porosity and Program Program Monitoring Monitoring GALL Report I above grade exterior permeability, permeability, Program Program (See SER concrete cracking, loss of cracking, Section (3.5.1-24) material material Boric Acid 3.5.2.1.4)

(spalling, (spalling, Corrosion scaling) scaling) due to aggressive aggressive chemical attack chemical attack All Groups Groups except Monitoring Yes Loss of material Structures Monitoring Structures Structures with Consistent with.

Group 6: steel steel due to corrosion Program. If If Monitoring GALL Report components: all protective coatings Program (See SER structural steel steel are relied upon to Section (3.5.1-25) manage the effects manage 3.5.2.2.2) 3.5.2.2.2) of aging, the Structures Monitoring Structures Monitoring Program is to include include address provisions to address protective coating coating monitoring and monitoring maintenance.

maintenance.

All Groups except Monitoring Yes Loss of material Structures Monitoring Structures Consistent with Consistent with Group Group 6: accessible (spalling, Program. Evaluation Program. Evaluation Monitoring Monitoring GALL Report and inaccessible scaling) and needed for plants is needed Program (See SER concrete: foundation cracking due to that are locatedlocated in Section (3.5.1-26) freeze-thaw moderate to severe 3.5.2.2.2) weathering weathering conditions conditions (weathering index

> 100 day-inch/yr)

I (NUREG-1557).

(NUREG-1557):

3-378

G oe m'G onr~ u Ag gE ffeictli AM P in GA LL " t f Copoen Gru IgurhriMPigL

.' (GALL Report Mechanism Report . . Fi

)Evaluation Supplements, Evaluation.;,

Ite i GALL

,1n :.or Reprt Amendments, Groups except All Groups except Cracking due to Cracking Structures Monitoring Yes Structures Monitoring Yes Structures Structures Consistent with Consistent Group 6: accessible accessible expansion due due Program. None Program. None for Monitoring Monitoring GALL Report, Report, inaccessible and inaccessible reaction with to reaction inaccessible areas inaccessible if areas if Program Program (See (See SER SER interior/exterior interior/exterior aggregates aggregates concrete was concrete was Section Section concrete concrete constructed constructed in in 3.5.2.2.2) 3.5.2.2.2)

(3.5.1-27)

(3.5.1-27) accordance with accordance with the the recommendations in recommendations in 201.2R-77.

ACI 201.2R-77.

Groups 1-3, Groups 5-9: All 1-3, 5-9: All Cracks and and Monitoring Yes Structures Monitoring Structures Yes Structures Structures Consistent with (3.5.1-28) distortion due to distortion Program. If a de-Program. Monitoring Monitoring GALL Report, increased stress stress watering system is Program (See SER SER levels from relied upon for Section settlement settlement control of settlement, 3.5.2.2.2) licensee is then the licensee ensure proper to ensure proper functioning of the de-watering system through the period period ofof extended operation.

operation.

Groups 1-3, 5-9:

Groups 1-3, 5-9: Reduction in in Monitoring Yes Structures Monitoring Not applicable applicable Not Applicable Applicable foundation foundation foundation Program. If If a de- to TMI-1 (See (3.5.1-29) strength, watering system system is SER Section cracking, relied upon upon for 3.5.2.2.2) differential differential control of settlement, settlement due settlement then the licensee is to erosion of proper to ensure proper porous concrete functioning of the de-subfoundation subfoundation watering system through the period period of extended operation.

operation.

Lock-up due to beam Lock-up Group 4: radial beam ISI (IWF) lSI (IWF) or Yes ISI (IWF) or lSI (IWF) Consistent with seats in in BWR wear Monitoring Structures MonitOring Structures Structures GALL Report, drywell; RPV support Program Monitoring Monitoring (See SER shoes for PWR with Program Program Section nozzle supports; 3.5.2.2.2) generator steam generator supports (3.5.1-30) 1(3.5.1-30) 3-379

Goups 1-3, 5, In

'Agin Effect!/ AMP in GALL, (GALL'Report Mechanism' ReportFute AMinL, Saf Item 'No.) Evaluation Supplements,, Evaluation,

-- inGdAL or,

__________ R'port Aedments Groups 1-3, Groups 1-3, 5,5,7-9:

7-9: Increase in Increase in Structures Monitoring Structures Monitoring Yes Yes Structures Structures Consistent with Consistent with below-grade below-grade porosity and porosity and Program; Program; Monitoring Monitoring GALL Report, GALL Report, concrete concrete permeability, permeability, examination of examination of Program Program (See SER (See SER components, such components, such asas cracking, loss cracking, loss ofof representative representative Section Section exterior walls exterior walls below below material material samples of samples of below-below- 3.5.2.2.2) 3.5.2.2.2) grade and grade and foundation foundation (spalling, (spalling, grade concrete, and (3.5.1-31)

(3.5.1-31) scaling),

scaling), periodic monitoring periodic monitoring aggressive aggressive of groundwater, if if the the chemical attack; chemical environment is is non-non-cracking, loss cracking, loss of of aggressive. A A plant plant bond, and loss bond,andloss specific program is is to of material of evaluated ifif be evaluated (spalling, environment isis environment scaling), aggressive.

aggressive.

corrosion of embedded steel embedded steel Groups 1-3, Groups 1-3, 5, 5, 7-9:

7-9: Increase in Increase in Structures Monitoring Yes Structures Structures Consistent with exterior above exterior above andand porosity and porosity and Program for Monitoring Monitoring Report, GALL Report, below below grade grade permeability, permeability, accessible areas.

accessible Program (See SER SER reinforced reinforced concrete concrete and loss and loss of of None for Section foundations foundations strength due strength due to to inaccessible areas if if 3.5.2.2.2)

(3.5.1-32)

(3.5.1-32) leaching of leaching of concrete was concrete was calcium constructed constructed in in hydroxide hydroxide accordance accordance with the the recommendations recommendations in in ACI 201.2R-77.

ACI201.2R-77.

Groups Groups 1-5: concrete Reduction 1-5: concrete Reduction of A plant-specific plant-specific aging aging Yes Not Not applicable applicable See SER SER (3.5.1-33)

(3.5.1-33) strength and management management Section modulus due due to to program program is to be 3.5.2.2.2 elevated elevated evaluated evaluated temperature temperature

,

Group Group 6:6: concrete; concrete; Increase Increase in in Inspection Inspectioh of Water- Yes Yes Structures Structures Consistent Consistent with with all all porosity porosity and and Control Control Structures Structures or Monitoring Monitoring GALL GALL Report, Report, (3.5.1-34)

(3.5.1-34) permeability, permeability, FERC/US FERC/US Army Army Program Program (See (See SER SER cracking, cracking, loss loss ofof Corps Corps of Engineers Engineers Section Section material material due due to to dam inspections inspections and and 3.5.2.2.2) 3.5.2.2.2) aggressive aggressive maintenance maintenance chemical chemical attack; attack; programs programs andand forfor cracking, cracking, loss loss ofof inaccessible inaccessible bond, bond, loss loss of concrete, concrete, anan material material due due to to examination examination of of corrosion corrosion of of representative representative embedded embedded steel steel samples samples of of below-grade grade concrete, concrete, andand periodic periodic monitoring monitoring .'

of of groundwater, groundwater, ifthe the environment environment is is non-non-aggressive.

aggressive. A A plant plant specific specific program program isis to to be be evaluated evaluated if if environment environment is is aggressive.

aggressive.

3-380 3-380

Goupl, A1g rcomponent t AL Further, AMP in LRA, Staff (GALL Report Mechan ism 'Rport tNEvaluation Supplements, Evaluation

- A < in GALLA orA

__________ -~Report -Amend mýents Group 6: exterior Loss of material Loss Inspection of Water- Yes Structure Consistent with and below above and (spalling, (spalling, Structures or Control Structures Monitor Program GALL Report grade concrete scaling) and scaling) FERC/US Army (See SER foundation cracking due to Corps of Engineers Section (3.5.1-35) freeze-thaw freeze-thaw dam inspections and 3.5.2.2.2) maintenance maintenance programs. Evaluation Evaluation is needed for for plants plants that that are located in in moderate to severe moderate severe weathering weathering conditions conditions (weathering index

> 100 day-inch/yr) day-inch/yr)

NUREG-1557.

(NUREG-1557).

Group 6: all Cracking due to Accessible areas:

Accessible Yes Structures Consistent with accessible and accessible expansion /I Inspection of Water- Monitoring Monitoring GALL Report inaccessible reaction with Structures or Control Structures Program (See SER reinforced concrete aggregates aggregates FERC/US Army FERC/US Section (3.5.1-36) Corps of Engineers Engineers 3.5.2.2.2) 3.5.2.2.2) dam inspections inspections and and maintenance programs.

programs. None for for inaccessible areas ifif inaccessible concrete was concrete was constructed constructed in accordance accordance with the the recommendations in recommendations in ACI 201.2R-77.

201.2R-77.

Group Group 6: exterior Increase in Increase accessible areas, Yes For accessible Structures Consistent with above and below porosity and Inspection of Water-Inspection Monitoring Monitoring GALL Report, grade reinforced reinforced permeability, permeability, Control Structures Structures or Program (See SER concrete foundation concrete foundation loss of strength strength FERC/US Army Section interior interior slab due due to leaching leaching Corps of of Engineers Engineers 3.5.2.2.)

(3.5.1-37) of calcium calcium dam inspections inspections and and hydroxide hydroxide maintenance programs. None None for for inaccessible areas if inaccessible concrete concrete was was constructed constructed in accordance accordance with the the recommendations in recommendations 201.2R-77.

ACI 201.2R-77.

Groups Groups 7, 8: tank Cracking duedue to A plant-specific plant-specific aging aging Yes Not applicable Not applicable Not Applicable Applicable liners liners stress corrosion corrosion management management to TMI-1 (See (3.5.1-38)

(3.5.1-38) cracking; loss of cracking; program program is to to be SER SER Section Section material material due due to evaluated evaluated 3.5.2.2.2) 3.5.2.2.2) pitting and and crevice crevice corrosion corrosion 3-381

Component Group Agi-ng Effectl 'ý,AMP".in GAL'L_ FterýM i R, tf (GALL Re-pd'rt-' M'Mechansm Report

,.Evaluation Supplemrents, Evaluation~

Itm , ,in GALL o I,_____,______e -Report Amendments Support members; Loss of material Structures Monitoring Yes Structures Monitoring Structures Structures Consistent Consistent with with welds; bolted bolted due to general general Program Program Monitoring Monitoring GALL Report, connections; connections; support and pitting Program (See SER anchorage to anchorage corrosion 3.5.2.1)

Section 3.5.2.1) building structure structure (3.5.1-39) 3.5.1-39 Building Building concrete at Reduction in Structures Monitoring Yes Structures Structures Consistent with locations locations of concrete concrete anchor anchor Program Monitoring Monitoring GALL Report, expansion expansion and capacity due to capacity Program Program (See SER SER grouted anchors; local concrete concrete Section Section 3.5.2.1) 3.5.2.1 )

grout pads for degradation, degradation, support base plates plates service-induced service-induced (3.5.1-40) cracking or other concrete aging aging mechanisms mechanisms Vibration isolation Reduction or Reduction Monitoring Yes Structures Monitoring Structures Consistent Consistent with elements loss of isolation isolation Program Program Monitoring Monitoring GALL Report, (3.5.1-41)

(3.5.1-41) function, Program (See SER radiation radiation Section 3.5.2.1) 3.5.2.1) hardening, hardening, temperature, temperature, humidity, humidity, sustained vibratory loading_

vibrato loadin Groups B1.1, B1.2, B1.1, B1.2, Cumulative Cumulative TLAA, evaluated evaluated in Yes Yes Not applicable Not applicable Not applicable applicable and B1.3: support fatigue damage accordance accordance with to TMI-1 members: anchor anchor (CLB fatigue 10 CFR 54.21(c) (See SER bolts, welds analysis exists) Section 3.5.2.2.

(3.5.1-42) 2) 1-3, 5, 6: all Groups 1-3; Cracking due to Masonry Masonry Wall No Structures Consistent with.

Consistent with, masonry masonry block walls restraint Program Program Monitoring Monitoring GALL GALL Report (3.5.1-43) shrinkage, Program (See SER creep, and Section aggressive aggressive 3.5.2.1.5) environment environment Group 6: elastomer Loss of sealing Structures Monitoring No Structures Structures Consistent with with:

seals, gaskets, and due to Program Program Monitoring GALL Report, moisture barriers deterioration of deterioration Program Program (See SER (3.5.1-44) seals, gaskets, Section Section 3.5.2.1) 3.5.2.1) and moisture moisture barriers (caulking, flashing, andand other sealants) sealants Group 6: exterior Loss of material Inspection of Water- No Inspection Structures Consistent Consistent with with, above and below due to abrasion, Control Structures Structures or Monitoring GALL Report, '

grade concrete cavitation FERC/US Army Program (See SER (SeeSER foundation; foundation; interior Corps of Engineers Engineers Section 3.5.2.1) 3.5.2.1) slab dam inspections inspections and (3.5.1-45) 3.5.1-45 maintenance maintenance 3-382

iComponent, Groupil AiiigE ii . i~*

CmoetGop ging:Effecti' AMP im GALL FurIther APin'LRA, Staff (GALL Report' 2 Mcaim .Report '

~&~Ev6U I~~. aluti on t;uippIements,, ,-Evaluation Rel~ortAmenments, Group 5: fuel fuel pool pool Cracking Cracking due due to Water Water Chemistry Chemistry and and No Water Chemistry Consistent Water Chemistry Consistent with with liners stress corrosion corrosion monitoring monitoring of of spent spent Control Control Program Program GALL GALL Report, (3.5.1-46) cracking; loss of of fuel fuel pool water water level level (See SER SER material material due to in in accordance accordance with Section Section 3.5.2.1) 3.5.2.1) and pitting and technical technical crevice crevice specifications and specifications and corrosion corrosion leakage from leakage from thethe leak leak chase chase channels.

channels.

Group 6: all metal metal Loss of material material Inspection Inspection of Water- No Consistent Consistent with with structural members members due due to general general Control Control Structures Structures or GALL GALL Report (3.5.1-47) (steel (steel only), FERC/US FERC/US Army Structures Structures (See SER pitting and and Corps Corps of Engineers Engineers Monitoring Monitoring Sections Sections crevice crevice inspections and dam inspections Program Program 3.3.2.1.3, 3.3.2.1.3, corrosion corrosion maintenance.

maintenance. If If 3.2.2.1.4) 3.2.2.1.4) protective coatings protective coatings are relied uponupon to manage aging, manage protective coating protective coating monitoring and monitoring maintenance maintenance provisions should be provisions should be included. _

Group Group 6: earthen earthen Loss of material, material, IInspection nspectionof of Water- No No Structures Structures Consistent Consistent with water control control loss of form due Control Structures or Monitoring Monitoring GALL Report, structures - dams, structures to erosion, FERC/US Army Program Program (See SER embankments, embankments, settlement, Corps of Engineers 3.5.2.1)

Section 3.5.2.1) reservoirs, channels, channels, sedimentation, sedimentation, inspections and dam inspections canals, and ponds frost action, action, maintenance maintenance (3.5.1-48) waves, currents, programs programs surface runoff, Seepage See a e members; Support members; Loss of material Water Chemistry and No Chemistry Consistent with Water Chemistry with welds; bolted due to general, lSI ISI (IWF)

(IWF) and IWF GALL Report, connections; support pitting, and Program (See SER anchorage to crevice Section 3.5.2.1) 3.5.2.1) building structure structure corrosion (3.5.1-49) 3.5.1-49 3-383

Component Group Aging Effect/ AMP in GALL-. Frth AMP in Staf

~; Reort~

GAL Itm o)-

Mchanism >Report.,-. -

valu6ation. Suoplemibnt;-~ ',-Evaluation,,

-.- inGALL .1 or%

Report-- Ameildmentsd Groups B2, Groups B2, and B4:84: Loss ofof material Structures Monitoring No Structures No Inspection of Inspection Consistent Consistent with with galvanized steel, galvanized steel, due toto pitting Program Program Internal Internal GALL GALL Report Report aluminum, stainless aluminum, crevice and crevice Surfaces Surfaces inin (See (See SER SER steel support steel support corrosion Miscellaneous Miscellaneous Sections Sections members; welds; members; Piping and Piping 3.5.2.1.6 3.5.2.1.6 and and bolted connections; Ducting Ducting 3.4.2.1.3, 3.4.2.1.3, support anchorage support anchorage to Components Components 3.3.2.1.3, 3.3.2.1.3, building structure building structure 3.2.2.1.4) 3.2.2.1.4)

(3.5.1-50)

(3.5.1-50) Aboveground Aboveground Steel Tanks External External Surfaces Surfaces Monitoring Monitoring Program Structures Structures Monitoring Monitoring Pro ram Program Group B1.1: high Cracking due to Bolting Integrity No Not Applicable Applicable Not Applicable strength low-alloy stress corrosion to TMI-1 TMI-1 bolts cracking; loss of (See SER (3.5.1-51))

(3.5.1-51 material due to Section Section general general 3.5.2.1.1) 3.5.2.1.1) corrosion Groups B2, and B4: Loss of Monitoring No Structures Monitoring Structures Consistent with Consistent sliding support support mechanical mechanical Program Monitoring Monitoring GALL Report, bearings bearings andand sliding function due due to Program Program (See SER SER support support surfaces surfaces corrosion, corrosion, Section 3.5.2.1)

Section 3.5.2.1)

(3.5.1-52)

(3.5.1-52) distortion, distortion, dirt, overload, overload, fatigue fatigue due to vibratory and cyclic cyclic thermal loads loads Groups Groups B1.1, B1.1, B1.2, B1.2, Loss of material material ISI (IWF) lSI (IWF) No No IWF IWF Program Program Consistent Consistent with!

with:

and B1.3: support support due to to general general GALL GALL Report, Report, members:

members: welds; welds; and pitting (See SER bolted connections; connections; corrosion corrosion Section 3.5.2.1)

Section 3.5.2.1) support support anchorage anchorage to to building structure structure (3.5.1-53) 3.5.1-53 I

Groups Groups B1.1, B1.1, B1.2, B1.2, Loss ofof ISl lSI (IWF)

(IWF) No No ISI lSI (IWF)

(IWF) Consistent with' Consistent with I and and B1.3:

B 1.3: constant constant mechanical mechanical GALL GALL Report, and and variable variable load load function function due due to (See SER SER spring spring hangers; hangers; corrosion, corrosion, Section Section 3.5.2.1),

3.5.2.1) guides; guides; stops; stops; distortion, distortion, dirt, dirt, (3.5.1-54)

(3.5.1-54) overload, overload, fatigue fatigue due due to to vibratory and and cyclic cyclic thermal thermal loads loads 3-384 3-384

Comonet Goup Agng ffetl MPintA~ Further AMP in LRA-, 7Staff.

(GALL Report Mechanism* -Report* E valdýiua teNo)Evaluation Supplements, Eautirý inGdALL or

____________Re'p9 rt Amendments.

Steel, galvanized Steel, galvanized Loss of of material Boric Acid material Boric Acid Corrosion Corrosion NoNo Boric Acid Boric Consistent with Consistent with steel, and aluminum steel, aluminum due to boric acid due Corrosion Corrosion GALL GALL Report, Report, support members; support members; corrosion corrosion (See SER welds; bolted welds; bolted Section 3.5.2.1)

Section 3.5.2.1) connections; support connections; anchorage to anchorage building structure structure (3.5.1-55)

Groups B1.1, B1.1, B1.2, B1.2, Loss of of lSI (IWF)

ISI (IWF) No No lSI ISI (IWF)

(IWF) Consistent with Consistent and B1.3: sliding mechanical mechanical GALL Report, GALL Report, surfaces function due to function (See SER (3.5.1-56) corrosion, corrosion, Section 3.5.2.1)

Section 3.5.2.1) distortion, dirt, distortion, overload, fatigue overload, fatigue due to vibratory due vibratory and cyclic and cyclic thermal loads thermal loads Groups B1.1, Groups B1.1, B1.2, Reduction or Reduction lSI (IWF)

ISI (IWF) No No Not applicable applicable Not applicable applicable and B1.3:

and B 1.3: vibration loss of isolation loss to TMI-1 TMI-1 (See isolation elements function, function, SER Section SER (3.5.1-57)

(3.5.1-57) radiation radiation 3.5.2.1.1) 3.5.2.1.1 )

hardening, hardening, temperature, humidity, sustained sustained loading vibratory loadin!:]

vibratory Galvanized steel and None None None No None Consistent Consistent with aluminum support GALL GALL Report, members; welds; (See SER bolted connections; connections; Section 3.5.2.1)

Section 3.5.2.1) anchorage to support anchorage building structure exposed to air -

indoor uncontrolled uncontrolled (3.5.1-58)

Stainless steel None None No None Consistent with support support members; members; GALL Report, welds; bolted (See SER connections; connections; support Section 3.5.2.1)

Section 3.5.2.1) anchorage to anchorage building structure structure (3.5.1-591 (3.5.1-59)

The staff's staffs review of the containments, structures, and component component support groups followed several approaches. One approach, documented documented in SER Section 3.5.2.1, 3.5.2.1, discusses the staff's review of AMR results for components the applicant indicated are consistent with the GALL Report and require no further evaluation. Another approach, documented documented in SER Section 3.5.2.2, discusses the staff's review review of AMR results for components the applicant applicant indicated are consistent with the GALL Report Report and for which further evaluation is recommended.

documented in SER Section 3.5.2.3, discusses the staff's A third approach, documented staffs review of AMR AMR 3-385

results for components the applicant indicated indicated are not consistent with, or not addressed addressed in, thethe GALL Report. The staffs review of AMPs credited to manage or monitor aging effects of the the containments, structures, and component component supports documented in SER Section 3.0.3.

supports is documented 3.5.2.1 3.5.2.1 AMRAMR Results That That Are Consistent Consistent with the GALLGALL Report Report LRA Section 3.5.2.1, 3.5.2.1, identifies the materials, environments, and AERMs.

AERMs. The applicant identified the following programs that manage the effects of aging related to structures and component supports:

- Structures Structures Monitoring Monitoring Program Program

- Boric Acid Corrosion Corrosion

° Selective Selective Leaching of Material

- Buried Buried Piping Piping and Tank Inspection Inspection 00 One-Time Inspection One~Time

o Water Chemistry 0 0 10 CFR Part 50, Appendix J 0 o ASME ASME Section XI, Subsection --IWE XI, Subsection IWE

- ASME ASME Section Xl, XI, Subsection Subsection - IWF IWF

- ASME ASME Section Xl, Subsection --IWL XI, Subsection IWL

.-o External Surfaces Monitoring Monitoring

- Water Chemistry

- TLAA In LRA Tables 3.5.2-1 through 3.5.2-20, InLRA 3.5.2-20, the applicant applicant summarized AMRs for structures and component supports component indicated AMRs claimed supports and indicated claimed to be consistent consistent with the GALL Report.

For component evaluated in the LRA for which component groups evaluated which the applicant claimed consistency consistency with the GALL Report and for which the GALL Report Report does not recommend further evaluation, evaluation, the the staff's review determined plant-specific components groups were bounded by the determined whether the plant-specific the GALL Report evaluation.

evaluation. .

For each AMR line item the applicant noted noted how the information information in the tables aligns with the the information in the GALL GALL Report. The staff reviewed those AMRs with notes A through E indicating how the AMR is consistent with the GALL Report.

Note A indicates that the AMR line item is consistent with the GALL Report for component, .*

material, environment, and aging aging effect. In addition, the AMP is consistent with the GALL Report AMP. The staff audited audited these line items to verify consistency consistency with the GALL Report and the the validity of the AMR for the site-specific site-specific conditions. -

Note B indicates indicates that the AMR AMR line item is consistent with the GALL GALL Report Report for component, material, environment, enVironment, and aging effect. In addition, the AMP takes some exceptions exceptions to the.:

the,ý GALL Report AMP. The staff audited these line items to verify consistencyconsistency with the GALL '

Report and verified verified that the identified identified exceptions to the GALL GALL AMPs havehave been reviewed and accepted. The staff also determined determined whether whether the applicant's AMP was consistent with the GALL Report AMP and whether whether the AMR was valid for the site-specific site-specific conditions.

3-386

Note C indicates that the component component for the AMR line item, although different different from, is consistent consistent with the GALL Report for material, environment, and aging effect. In addition, the staff verified verified that the AMP is consistent with the GALL Report AMP. This note indicates that the applicant applicant was unable to find a listing of some system componentscomponents in the GALL Report; however, the the applicant identified a different applicant identified different component with the same material, environment, aging effect, and AMP as the component component under review. The staff audited audited these line items to verify consistency with the GALL Report. The staff also determined different determined whether the AMR line item of the different component component was applicable applicable to the component component under review and whether the AMR was valid for the site-specific site-specific conditions.

Note D D indicates indicates that the component for the AMR line item, although different different from, is consistent with the GALL Report Report for material, material, environment, and aging effect. In addition, the AMP takes takes exceptions to the GALL Report AMP. The staff audited these line items to verify some exceptions consistency with the GALL consistency GALL Report. The staff verified whether whether the AMR line item of the different component was applicable component applicable to the component component under review and verified whether the identified identified exceptions to the GALL Report AMPs have been reviewed exceptions reviewed and accepted.

accepted. The staff also whether the applicant's determined whether applicant's AMP was consistent with the GALL Report Report AMP and whether the AMR was valid for the site-specific whether conditions.

site-specific conditions.

Note E indicates indicates that the AMR AMR line item is consistent with the GALL Report Report for material, environment, and aging aging effect, but credits aa different AMP. The staff audited these line items to to verify consistency with the GALL Report. The staff also determineddetermined whether the credited AMP AMP would manage manage the agingaging effect consistently consistently with the GALL GALL Report AMP and whether

'lNhether the AMR AMR was valid for the site-specific conditions.

The staff reviewed reviewed the information information in the LRA, as documented documented in the SERSER Section 3.5.2.1.

3.5.2.1. The The staff did not repeat repeat its review of the matters described in the GALL Report; Report; however, the staffstaff did verify that the material material presented in the LRA was applicable applicable and that the applicant identified applicant identified the appropriate GALL GALL Report AMRs. The staff's evaluation is discussed below.

3.5.2.1.1 AMR Results IdentifiedIdentified as Not Applicable Applicable LRA Table 3.5.1 ItemsItems 5, 8, 11, 11, 13, 19, 20, and 21 are identified as "Not Applicable" because because they apply only to BWR BWR containments. The staff confirmed that the applicant identified identified the correct items as being applicable for this reason.

being not applicable LRA Table 3.5.1, Items 51 and 57 are identified as "Not Applicable" since the component, 3.5.1, Items material, and environment combination does not exist at TMI-1. TMI-1. For each of these line items, the the staff reviewed the LRA and the applicant's supporting documents, and confirmed the applicant's applicant's claim that the component, material,material, and environment environment combination combination does not exist at TMI-1. Since TMI-1. Since TMI-1 TMI-1 does not have the component, material, and environment environment combination combination for these Table Table 1 line items, the staff finds that these AMRs are not applicable to TMI-1. TMI-1.

3.5.2.1,2 Aging of Accessible Accessible and Inaccessible Inaccessible Concrete Areas Due to Aggressive Chemical Attack, and Corrosion of Embedded Embedded Steel LRA Table 3.5.1, Item 3.5.1-1 states that the ASME Section 3.5.1, Item Section XI, Subsection Subsection IWL Program Program will be be used used to manage manage aging effects aggressive chemical attack, effects due to aggressive attaCk, and corrosion of embedded steel of reactor building (containment) reinforced concrete in accessibleaccessible areas. The LRA also states that the Boric Acid Corrosion Corrosion Program will also be used used to manage manage the aging aging effect/mechanism in areas subject to borated water leakage. During the review of LRA Tables effect/mechanism Tables 3-387 3-387

3.5.2-1 through 3.5.2-1 through 3.5.2-20, 3.5.2-20, the staff noted the staff that for the AMR noted that points to results line that points AMR results to item item 3.5.1-1 3.5.1-1 in LRA in LRA Table Table 3.5.1, 3.5.1, the applicant applicant included included fourteen fourteen groups groups that reference reference NoteNote E E and plant-1 plant-'

specific Note specific Note 1 or Note Note 55 (depending (depending on on the which both the table), which both state "The aging aging effects/mechanisms of reinforced effects/mechanisms reinforced concrete concrete in an airair with borated water with borated leakage environment water leakage environment include cracking, include cracking, loss of of bond, and and loss of material scaling)/corrosion of embedded material (spalling, scaling)/corrosion embedded effects/mechanisms are These aging effects/mechanisms steel. These managed by the Boric are managed Corrosion Program."

Boric Acid Corrosion The staff reviewed the AMR staff reviewed results lines AMR results lines referenced Note E, referenced to Note plant-specific Note E, plant-specific Note 1 and and Note Note 5, determined that the component and determined environment, and material, environment, component type, material, effect are consistent and aging effect consistent corresponding line of the with the corresponding with the GALL Report; however, where the GALL GALL Report; Report recommends GALL Report recommE}ndsSection XI, AMP XI.S2, "ASME Section AMP Subsection IWL,"

XI, Subsection IWL," the applicant has the applicant has additionally proposed using additionally proposed using the Boric Acid the Program. The GALL Acid Corrosion Program. GALL Report Report line item referenced is for concrete item referenced concrete .

buttresses, containment, etc.,

elements: walls, basemat, buttresses, elements: therefore, the etc., and therefore, GALL Report the GALL recommends recommends AMP XI.S2. The applicant stated that the AMR result line items that reference The applicant reference itemitem 3.5.1-1 in LRA Table Table 3.5.1, 3.5.1, are also located located in the areas subject to borated water leakage, leakage, and, therefore, the Boric Acid Corrosion Program was also credited.

Corrosion Program The staff reviewed the Boric credited. The Boric Corrosion Program and ASME Acid Corrosion ASME Section Section XI, Subsection Program and found that both Subsection IWL Program require visual inspections periodic basis to manage inspections on a periodic aggressive chemical manage aggressive attack due to chemical attack to!l borated water leakage. On the basis performed, the staff periodic visual inspections are performed, basis that periodic staff applicant's additional finds the applicant's use of the Boric Acid Corrosion Program additional use Program to be acceptable.

Based on aa review of the programs programs identified determines that the applicant's identified above, the staff determines applicant's proposed programs managing the aging acceptable for managing programs are acceptable effects in the applicable aging effects applicable components. The staff concludes components. concludes that the applicant demonstrated that the effects of aging applicant has demonstrated for these components will be adequately adequately managed intended function(s) managed so that their intended function(s) will be be maintained consistent with the CLB during the period of extended maintained operation, as required extended operation, required by 10 CFR 54.21 (a)(3).

Cracking, Loss of Bond, and Loss of Material 3.5.2.1.3 Cracking, 3.5.2.1.3 Material (spalling, scaling) Due to Corrosion of Embedded Steel" Steel .

discussion section of LRA Table 3.5.1, In the discussion applicant stated 3.5.1, Item 3.5.1-23, the applicant stated that cracking, loss of bond, and loss of material corrosion of embedded material (spalling, scaling) due to corrosion embedded steel is Structures Monitoring Program. The Boric managed by the Structures managed Boric Acid Corrosion Program will also be be used to manage the aging effect/mechanism effect/mechanism in areas areas subject subject to borated water leakage. During During LRA Tables 3.5.2-1 through 3.5.2-20, the staff noted that for the AMR results line the review of LRATables line 3.5.1, item 3.5.1-23, for twenty-six groups pointing to Table 3.5.1, grbups the applicant included a referen,ce to reference Note E and plant-specific Note 1, "the aging 1, which states "the aging effects/mechanisms reinforced effects/mechanisms of reinforced concrete in an air with borated water leakage environment include include cracking, loss of bond, and scaling)/corrosion of embedded steel. These aging loss of material (spalling, scaling)/corrosion aging managed by the Boric Acid Corrosion Program."

effects/mechanisms are managed effects/mechanisms The staff reviewed the AMR results lines referenced to Note E, plant-specific plant-specific Note 1, and determined that the component type, material, environment, and aging effect are consistent with the corresponding corresponding line of the GALL Report; however, where the GALL Report Report recommends recommends AMP XI.S6, "Structures Monitoring Program," the applicant has additionally proposed using the the Boric Acid Corrosion Program. The GALL Report Boric referenced is reinforced concrete, Report line item referenced and therefore, the GALL Report recommends AMP XI.S6. The applicant stated that the AMR AMR reference LRA Table 3.5.1 item 3.5.1-23 are also result line items that reference also located in the areas subject to borated water leakage, and, and, therefore, the Boric Acid Corrosion Program was also reviewed the Boric Acid Corrosion Program and Structures Monitoring credited. The staff reviewed Monitoring 3-388

Program and Program and foundfound that that both both require inspections on visual inspections require visual periodic basis on aa periodic basis to to manage manage aggressive aggressive chemical chemical attack attack due due to to borated borated water water leakage.

leakage. On On the the basis basis thatthat periodic periodic visual inspections inspections are are performed, performed, the the staff staff finds finds thethe applicant's applicant's additional additional use use ofof thethe Boric Boric Acid Acid Corrosion Corrosion Program Program to to bebe acceptable.

acceptable.

Based Based on on aa review review of of the the programs programs identified identified above,above, the the staff staff determines determines that that thethe applicant's applicant's proposed programs are acceptable for managing proposed programs are acceptable for managing the aging effects in the applicable the aging effects in the applicable components.

components. The The staffstaff concludes concludes that that thethe applicant applicant has has demonstrated demonstrated that that the the effects effects of of aging aging for for these these components components will will be be adequately adequately managed managed so so that that their their intended intended function(s) function(s) will will be be maintained maintained consistent consistent with with thethe CLBCLB during during the the period period of of extended extended operation, operation, as as required required by by 10 10 CFR CFR 54.21 54.21 (a)(3).

3.5.2.1.4 3.5.2.1.4 Increase Increase in in Porosity Porosity and and Permeability, Permeability, Cracking, Cracking, Loss Loss of of Material Material (spalling, (spalling, scaling) scaling)

Due to Aggressive Due to Aggressive Chemical Attack Chemical Attack In In the the discussion discussion section section of of LRALRA Table Table 3.5.1, 3.5.1, item item 3.5.1-24, 3.5.1-24, the the applicant applicant statedstated that that increase increase in in porosity and permeability, cracking, loss of material (spalling, porosity and permeability, cracking, loss of material (spalling, scaling) due to aggressive scaling) due to aggressive chemical chemical attackattack is is managed managed by by the the Structures Structures Monitoring Monitoring Program.

Program. The The Boric Boric Acid Acid Corrosion Corrosion Program Program will will also also be be used used to to manage manage the the aging aging effect/mechanism effect/mechanism in in areas areas subject subject to to borated borated water water leakage.

leakage. During During the the review review of of LRA LRA Tables Tables 3.5.2-1 3.5.2-1 through through 3.5.2-20, 3.5.2-20, the the staff staff noted noted that that for for the AMR results line pointing to Table 3.5.1, item 3.5.1-24, the AMR results line pointing to Table 3.5.1, item 3.5.1-24, for twenty-six groups the applicant for twenty-six groups the applicant included included aa reference reference to to Note Note EE and and plant-specific plant-specific Note Note 55 or or 66 (depending (depending on on thethe table),

table), which which states "the aging effects/mechanisms of reinforced states "the aging effects/mechanisms of reinforced concrete in an air with borated waterconcrete in an air with borated water leakage leakage environment include environment include cracking, cracking, loss loss ofof bond, bond, and and lossloss of of material material (spalling, (spalling, scaling)/corrosion scaling)/corrosion of of embedded embedded steel. steel. These These aging aging effects/mechanisms effects/mechanisms are are managed managed by by the the Boric Boric Acid Acid Corrosion Corrosion Program."

Program." .

The The staff staff reviewed reviewed the the AMRAMR resultsresults lines lines referenced referenced to to Note Note E, E, plant-specific plant-specific Note Note 55 and and 6,6, and and determined that the component type, material, environment, determined that the component type, material, environment, and aging effect are consistent with and aging effect are consistent with the the corresponding corresponding line line of of the the GALLGALL Report; Report; however, however, where where the the GALLGALL Report Report recommends recommends AMP AMP XI.S6, XI.S6, "Structures "Structures Monitoring Monitoring Program,"

Program," the the applicant applicant has has additionally additionally proposed proposed using using thethe Boric Acid Corrosion Program. The GALL Report line Boric Acid Corrosion Program. The GALL Report line item referenced is reinforced concrete, item referenced is reinforced concrete, and and therefore, therefore, the the GALL GALL Report Report recommends recommends AMP AMP XI.S6.

XI.S6. TheThe applicant applicant stated stated that that the the AMR AMR result result line line items items that that reference reference LRA LRA table table 3.5.1 3.5.1 item item 3.5.1-24 3.5.1-24 are are alsoalso located located in in the the areas areas subject subject to to borated borated water water leakage, leakage, and, and, therefore, therefore, the the Boric Boric Acid Acid Corrosion Corrosion Program Program was was also also credited. The staff reviewed the Boric Acid Corrosion credited. The staff reviewed the Boric Acid Corrosion Program and Structures Monitoring Program and Structures Monitoring Program Program and and found found that that both both require require visual visual inspections inspections on on aa periodic periodic basisbasis to to manage manage aggressive chemical attack due to borated water aggressive chemical attack due to borated water leakage. On the basis that periodic leakage. On the basis that periodic visual visual inspections inspections are are performed, performed, the the staff staff finds finds thethe applicant's applicant's additional additional use use of of thethe Boric Boric Acid Acid Corrosion Corrosion ProgramProgram to to bebe acceptable.

acceptable.

Based Based on on aa review review of of the the programs programs identified identified above,above, the the staff staff determines determines that that thethe applicant's applicant's proposed programs are acceptable for managing proposed programs are acceptable for managing the aging effects in the applicable the aging effects in the applicable components.

components. The The staffstaff concludes concludes that that thethe applicant applicant has has demonstrated demonstrated that thqt the the effects effects of of aging aging for these components will be adequately managed so for these components will be adequately managed so that their intended function(s) will be that their intended function(s) will be maintained maintained consistent consistent with with thethe CLBCLB during during the the period period of of extended extended operation, operation, as as required required by by 10 10 CFR CFR 54.21(a)(3).

54.21(a)(3).

3-389 3-389

3.5.2.1.5 3.5.2.1.5 Cracking Cracking Due to Restraint Shrinkage, Creep, and Aggressive Aggressive Environment Environment for Masonry Block Walls Masonry Walls In the discussion discussion section of LRA Table 3.5.1, applicant stated that cracking 3.5.1, item 3.5.1-43, the applicant cracking due to restraint restraint shrinkage, creep, and aggressive aggressive environment environment is managed by: by: Structures Structures Monitoring Program. The Boric Acid Corrosion Program will also be used to manage Monitoring manage the aging effect/mechanism in areas subject to borated water leakage. During the review of LRA Tables effecUmechanism Tables through 3.5.2-20, the staff noted that for the AMR 3.5.2-1 through AMR results line pointing 3.5.1, pointing to Table 3.5.1, item 3.5.1-43, included a reference to Note E and plant-specific 3.5.1-43, for one group the applicant included plant-specific Note Note 6, which states effects/mechanisms of reinforced concrete in an air with borated ;

states "the aging effects/mechanisms water leakage environment cracking, loss of bond, and loss of material environment include cracking, material (spalling, scaling)/corrosion scaling)/corrosion of embedded embedded steel. These aging effects/mechanisms are managed by the aging effects/mechanisms the Boric Acid Corrosion Program."

plant-specific Note 6, and referenced to Note E, plant-specifiC The staff reviewed the AMR results lines referenced determined determined that the component component type, material, environment, and aging effect are consistent aging consistent with corresponding line of the GALL Report; however, the corresponding where the GALL GALL Report recommends recommends applicant has additionally Monitoring Program," the applicant AMP XI.S6, "Structures Monitoring additionally proposed using the the Boric Acid Corrosion Program.

Program. The GALL Report referenced is reinforced concrete, Report line item referenced concrete, recommends AMP XI.S6. The applicant and therefore, the GALL Report recommends applicant stated that the AMR AMR references LRA Table 3.5.1 item 3.5.1-43 result line item that references 3.5.1-43 is also located located in the areas areas leakage, and, therefore, the Boric Acid Corrosion Program was also subject to borated water leakage, Corrosion Program credited. The staff reviewed the Boric Acid Corrosion Program and Structures Monitoring Structures Monitoring inspections on a periodic performing visual inspections Program and found that both are performing Program manage periodic basis to manage chemical attack due to borated water leakage. On the basis that periodic visual aggressive chemical visual:

inspections are performed, the staff finds the applicant's additional use of the Boric Acid applicant's additional Acid Program to be acceptable.

Corrosion Program Based on a review of the programs identified above, the staff determines programs identified applicant's determines that the applicant's programs are acceptable proposed programs managing the aging effects acceptable for managing effects in the applicable applicable components. The staff concludes that the applicant has demonstrated demonstrated that the effects of aging aging adequately managed for these components will be adequately intended function(s) will be managed so that their intended be maintained consistent with the CLB during the period of extended operation, maintained operation, as required by 10 CFR 54.21(a)(3).

Material Due to Pitting and Crevice Corrosion 3.5.2.1.6 Loss of Material 3.5.2.1.6 discussion section of LRA Table 3.5.1, In the discussion 3.5.1 , item 3.5.1-50, the applicant stated that loss of material due to pitting and crevice crevice corrosion is managed Structures Monitoring Program. The managed by Structures The External Surfaces Monitoring Program will also be used to to*monitor material due to pitting monitor loss of material pitting component insulation jacketing.

crevice corrosion of piping and component and crevice jacketing. During the review of LRA Tables 3.5.2-1 through 3.5.2-20, the staff noted Tables 3.5.2-1 noted that for the AMR results line pointing to Table Table 3.5.1, item 3.5.1-50, for two groups the applicant 3.5.1, applicant included included a reference to Note E and Note 4 or Note 5 which both state, "the aging effects of aluminum (Note 4) or plant-specific Note or!

stainless steel steel (Note 5) in this environment include loss of material due to pitting and crevice crevice corrosion. effects/mechanisms are managed corrosion. These aging effects/mechanisms managed by the ExternalExternal Surfaces Monitoring Surfaces Monitor:ing Program."

referenced to Note reviewed the AMR results lines referenced The staff reviewed plant-specific Note 4 and N9te Note E, plant-specific Note 5, and determined component type, material, environment, and aging effect are consistent determined that the component consistent corresponding line of the GALL Report; however, where with the corresponding where the GALL Report recommends Report recommends 3-390

AMP XI.S6, "Structures Monitoring Monitoring Program," the applicant applicant has proposed using the Extemal External Monitoring Program to monitor loss of material Surfaces Monitoring material due to pitting and crevice corrosion of piping and component component insulation jacketing.

jacketing. The staff reviewed reviewed the Structures Monitoring Monitoring Program and External Program External Surfaces Surfaces Monitoring Monitoring Program, Program, and found that both of the programs are performing visual inspections performing inspections on a periodic periodic basis to manage manage loss of material due to pitting and crevice corrosion. On the basis that periodic visual inspections inspections are performed, performed, the staff finds the the applicant's use of the External Surfaces MonitoringMonitoring Program to be acceptable.

Based on aa review of the programs programs identified, identified, the staff determines determines that the applicant's proposed applicant's proposed programs are acceptable acceptable for managing the aging effect in the applicable applicable components. The staff staff concludes that the applicant demonstrated that the effects applicant has demonstrated effects of aging for these components components will be adequately adequately managed so that their intended function(s) will be maintained maintained consistent with the CLB during the period of extended extended operation, operation, as required required by 1010 CFR 54.21(a)(3).

3.5.2.2 AMR AMR Results That That Are Consistent Consistentwith the GALL GALL Report, Report, for for Which Further Further EvaluationIs Recommended Evaluation In LRA Section 3.5.2.2, the applicant further evaluates evaluates aging management, recommended by management, as recommended the GALL Report, for the containments, containments, structures, and component supports, and provides provides information concerning information concerning how it will manage manage aging effects effects in the following three areas:

(1) PWR and BWR containments:

- aging of inaccessible inaccessible concrete concrete areas areas

- cracks cracks and distortion duedue to increased stress stress levels from settlement; reduction of settlement; reduction foundation strength, cracking, and differential differential settlement settlement due to erosion of porous porous concrete subfoundations subfoundations ifif not covered by the Structures Monitoring Structures Monitoring Program

" reduction of strength and modulus of concrete structures due to elevated temperature temperature

"* loss of material due to general, pitting, and crevice corrosioncorrosion

"* loss of prestress due to relaxation, relaxation, shrinkage, creep, and elevated temperature temperature

- cumulative fatigue damage damage

" cracking due to SCC

- cracking due to cyclic loading loading

- loss of material material (scaling, cracking, and spalling) spalling) due to freeze-thaw

" cracking cracking due to expansion and reactionreaction with aggregate aggregate and increase increase in porosity and permeability permeability due to leaching leaching of calcium hydroxide calcium hydroxide 3-391

(2)

(2) Safety-related and other structures Safety-related component supports:

structures and component

- aging of structures covered by the Structures structures not covered Structures Monitoring Monitoring Program

- aging management management of inaccessible inaccessible areas areas

- reduction of strength and modulus of concrete concrete structures due to elevated temperature temperature

- aging management management of inaccessible inaccessible areas for Group 6 structures structures

- cracking cracking due due to SCC and and loss of material material due to pitting and crevice corrosion corrosion

- aging of supports not covered covered by the Structures Structures Monitoring Program 9* cumulative cumulative fatigue damage damage due to cyclic loading (3)

(3) management of nonsafety-related QA for aging management components nonsafety-related components For component component groups evaluated in the GALL Report for which the applicant claimed applicant had claimed consistency with the GALL Report and for which the GALL consistency recommends further GALL Report recommends further evaluation, the staff audited audited and reviewed the applicant's evaluations and reviewed evaluations to determine determine whether whether they adequately address adequately address those issues and reviewed reviewed the applicant's applicant's further evaluations against the the criteria in SRP-LR SRP-LR Section 3.5.2.2. Details of the staff's audit are documented documented in the Audit and Review Review Report. The staffs staff's evaluation evaluation of the aging effects effects is discussed discussed in the following sections.

3.5.2.2.1 PWR and BWR ContainmentsContainments The staff reviewed reviewed LRA Section 3.5.2.2.1 against the criteria in SRP-LR SRP-LR Section 3.5.2.2.1.

Section 3.5.2.2.1.

Againg Aging of Inaccessible Inaccessible Concrete Areas. The staff reviewed LRA Section Section 3.5.2.2.1.1 3.5.2.2.1.1 using thethe procedures of SRP-LR review procedures SRP-LR Section 3.5.2.2.1.1.

3.5.2.2.1.1.

LRA Section Section 3.5.2.2.1.1 3.5.2.2.1.1 states states that the ASME Section Section Xl, XI, Subsection Subsection IWL Program is used used. toto manage manage aging effects effects due aggressive chemical attack, and corrosion of embedded due to aggressive embedded steel of reactor reactor building (containment) reinforced concrete. In addition, the applicant applicant stated that the' the I Boric Acid Corrosion Program is also used used to manage the aging effect/mechanism areas effect/mechanism in areas subject to borated borated water leakage. The applicant further stated that historical historical chemistry chemistry results of groundwater groundwater water samples have have confirmed confirmed that groundwater groundwater remains non-aggressive to remains non-aggressive to concrete. Groundwater Groundwater water is periodically periodically monitored as required by the Structures Monitoring Structures Monitoring

Program, Program, and a representative representative sample of below-grade below-grade concr~te concrete will be inspected ifif excavated for any reason. . ,

SRP-LR Section 3.5.3.2.1.1 states that increases increases in porosity porosity and permeability, cracking, cracking, loss of material (spalling, scaling) due aggressive chemical attack, and cracking, due to aggressive cracking, loss of bond, and loss of material (spalling, scaling) scaling) due to corrosion of embedded embedded steel could occur in inaccessible inaccessible areas of concrete and steel containments. SRP-LR SRP-LR Section 3.5.2.2.1.1 further states that the existing program relies on ASME Section Section XI, Subsection IWL to manage manage these these 3-392 3-392

aging aging effects. The TMI-1 TMI,.1 ASME ASME Section XI, XI, Subsection Subsection IWL described described in LRA Section Section B.2.1.25 is an existing program that is consistent consistent with all elements of GALL AMP X1.S2 X1 .S2 "ASME Section XI, XI, Subsection IWL."

IWL." The staffs staff's review of the applicant's ASME Section Xl, Subsection IWL isSection XI, documented in SER Section 3.0.3.1.6.

documented '

SRP-LR 3.5.2.2.1.1 also states that the GALL Report recommends further evaluation of SRP-LR Section 3.5.2.2.1.1 plant-specific plant-specific programs to manage the aging aging effects for inaccessible inaccessible areas ifif the environment environment is aggressive.

aggressive. To ensure*

ensure. non-aggressive non-aggressive groundwater groundwater chemistries, the GALL Report suggests suggests thethe periodic periodic groundwater inspection for chlorides, sulfates, and pH. The staff noted that the groundwater inspection the groundwater performed by the Structures groundwater monitoring is performed Structures Monitoring Monitoring Program. The staffs staffs review of the applicant's applicant's Structures Structures Monitoring Program including periodic periodic monitoring of groundwater groundwater is documented 3.0.3.2.21.

documented in SER Section 3.0.3.2.21.

The staff reviewed the LRA. The staff noted that the sampling results from 1996 presented presented in the LRA, which indicated groundwater pH range of 6.1 - 6.7, a chloride range of 3.5 - 210 indicated a groundwater 210 ppm, and a sulfate range of 14.1 14.1 - 410 ppm. During its Structures Monitoring Program AMP Structures Monitoring AMP audit, the staff asked the applicant (RAI B.2.1.28-1, applicant (RAI B.2.1.28-1, dated October 7, 2008) to provide the dated October the frequency frequency of periodic sampling sampling and the results for the last two samplings of groundwater. In the the letter dated October 30,2008, 30, 2008, the applicant applicant stated stated that the groundwater groundwater sampling for pH, pH, chloride, and sulfate concentrations concentrations will be t>e performed every every 5 years during the period of extended operation. The applicant also demonstrated extended demonstrated the last two groundwater samplings groundwater samplings include one sample taken in 2007 and three taken in 2005, which showed a pH range of 7.4 include 7.4- -

7.8, a chloride range of 42.4 - 65.5 ppm, and a sulfate range of 27-53.3. Based on the above above assertions, the staff confirmed that the below-grade below-grade environment at TMI-1 is non-aggressive non-aggressive (pH

> 5.5, Chlorides Chlorides < 500 ppm, and Sulfates <1500 ppm).

The staff noted noted that TMI-1 TMI-1 concrete concrete is designed designed in accordance accordance with American Concrete Institute Institute (ACI) 318-63 (ACI) 318-63 and constructed constructed in accordance accordance with ACI 301-66. In the LRA, the applicant stated containment concrete that containment water-to-cement ratio of 0.44 with a 5000 psi compressive concrete has a water-to-cement compressive that the 0.44 water-to-cement strength. The staff confirmed thatthe water-to-cement ratio of TMI-1 containment containment concrete recommendation of ACI 201.2R-77 for a water-to-cement meets the recommendation water:-to-cement ratio of less than 0.50 for a dense concrete with a low permeability.

On the basis of its review, the staff finds the AMR results to be consistent with the GALL Report.

The staff agrees agrees that a plant specific aging management management program program is not required required for for inaccessible areas of the reactor inaccessible below-grade concrete reactor building (containment) below-grade concrete for the aging effects increases in porosity and permeability, cracking, effects of increases cracking, loss of material material (spalling, scaling) due to aggressive chemical chemical attack, and cracking, cracking, loss of bond, and loss of material material (spalling, scaling) scaling) due to corrosion of embedded embedded steel because because (1) the groundwater groundwater water environment environment is confirmed confirmed not aggressive to concrete, (2) the inspection frequency groundwater chemistries frequency of groundwater chemistries as required by the Structures Monitoring Monitoring Program agrees with the recommendation recommendation of the GALL Report, and (3) the concrete being constructed meets the intent of ACI 201.2R 201.2R for durability.

Based Based on aa review review of the programs programs identified above, the staff concluded concluded that the applicant has has met the criteria of SRP-LR Section 3.5.2.2.1.1.

3.5.2.2.1.1. For those line items that apply to LRA Section 3.5.2.2.1.1, the staff determined 3.5.2.2.1.1, determined that the LRA is consistent with the GALL GALL Report and the the applicant has has demonstrated demonstrated that the effects effects of aging aging will be adequately adequately managed managed so that the the intended functions will be maintained intended maintained consistent consistent with the CLB duringduring the period of extended operation, operation, as required required by 10 CFR 54.21(a)(3).

54.21(a)(3).

3-393 3-393

Cracks Cracks and and Distortion Distortion due due to Increased Increased Stress Stress Levels Levels from Settlement:

Settlement; Reduction Reduction of of Foundation Foundation Strength, Cracking Strength. Cracking and Differential Settlement Differential Settlement due to Erosion of Porous Concrete Erosion of Porous Concrete' Subfoundations, Subfoundations. if Not Covered Covered by by Structures Structures Monitoring Monitoring Program.

Program. The The staff reviewed reviewed LRA LRA Section Section 3.5.2.2.1.2 3.5.2.2.1.2 using using the the review procedures procedures of SRP-LRSRP-LR Section Section 3.5.2.2.1.2.

3.5.2.2.1.2.

LRA Section Section 3.5.2.2.1.2 3.5.2.2: 1.2 states that the the cracks and distortion distortion due to increased increased stress stress levels levels from from settlement; settlement; reduction reduction of foundation foundation strength, cracking cracking and and differential differential settlement settlement duedue to erosion erosion of of porous porous concrete concrete subfoundations subfoundations are not not aging effects requiring requiring management because (1) management because the (1)the reactor building building (containment) base foundation is foundation founded founded on bedrock bedrock and no settlement has no settlement has been been experienced, experienced, (2) (2) the containment containment base foundation foundation is not not constructed constructed of porous concrete concrete the, and (3) the containment containment does does not employ employ aa de-watering de-watering system system for control of of settlement.

SRP-LR SRP-LR Section 3.5.2.2.1.2 3.5.2.2.1.2 states that cracks and distortion distortion due due to increased increased stress levels levels from from settlement settlement could could occur in concrete and steel in concrete steel containments.

containments. Also, reduction reduction of foundation foundation strength, strength, cracking, cracking, and differential differential settlement due to erosion of porous porous concrete concrete subfoundations subfoundat!ons could occur in all types types of containments.

containments. The existing program relies on the Structures Structures Monitoring Program to manage Monitoring Program manage these aging aging effects.

effects. SRP-LR 3.5.3.2.1.1 further states SRP-LR Section 3.5.3.2.1.1 states that the GALL recommends no further GALL Report recommends further evaluation if this activity is within the scope scope of the the applicant's structures applicant's structures monitoring monitoring program.

program. The staff reviewed reviewed the Structures Monitoring Structures Monitoring Program Program andand its evaluation evaluation is documented documented in SER Section 3.0.3.2.21.

Section 3.0.3.2.21.

On the basis of its review, the staff staff finds that cracks cracks and and distortion due to increased increased stress levels IEwels from settlement; reduction reduction of foundation foundation strength, cracking and differential settlement differential settlement due to to erosion of porous porous concrete concrete subfoundations subfoundations are are not applicable applicable aging effects because because conditions conditions necessary for the aging necessary aging effects, such as soil environment and flowing water environment, as as described in associated associated AMR line items of the GALL Report, Volume 2, do not exist. Therefore, the staff finds that no further evaluation is required.

Reduction of Strength Reduction Strength and Modulus Modulus of Concrete Concrete Structures Structures duedue to Elevated Temperature. The The staff reviewed reviewed LRA Section 3.5.2.2.1.3 3.5.2.2.1.3 using the review procedures procedures of SRP-LR SRP-LR Section 3.5.2.2.1.3 3.5.2.2.1.3 The applicant applicant stated in LRA Section 3.5.2*2.1.33.5.2~2.1.3 that during normal plant operation, containment containment general area temperatures concrete general temperatures do not exceed 150 150 OF of and local area temperatures do not exceed 200 OF.

exceed SRP-LR Section 3.5.2.2.1.3 states that reduction of strength and modulus of concrete SRP-LR concrete due to elevated temperatures elevated temperatures could occur in PWR and BWR concrete concrete and steel containments. The The GALL Report recommends further evaluation of a plant-specific aging management progralTl program ifif containment components any portion of the concrete containment components exceedsexceeds specified temperature temperature limits, i.e.,

general area temperature general temperature greater than 66°C 66 °C (150 (150 OF) and local area temperature greater greater than 93 -C (200 OF).

93°C °F).

The staff reviewed the LRA and noted noted that TMI-1 Technical Specification Specification and UFSAR UFSAR limit the the bulk air temperature inside the building, which is maintained by re-circulating air through cooling cooling coils, to 130 OF for areas above above elevation 320' and 120 of OF below this elevation during norm'alnormal Regarding local area temperatures, plant operation. Regarding temperatures, the staff also noted that process process penetrations in the reactor building wall are are provided with a cooling system to limit concrete concrete temperature below 200 of.

temperature OF. On the basis of its review, the staff finds that reduction of strength and modulus of concrete due to elevated temperatures temperatures are not not applicable applicable aging effects because because 3-394

necessary for the aging effects, such as elevated the conditions necessary elevated temperatures, do not exist.

Therefore, the staff finds that no further evaluation evaluation is required.

Loss of Material Material due to General, General, Pitting and Crevice Crevice Corrosion.

Corrosion. The staff reviewed LRA Section 3.5.2.2.1.4 using the review procedures of SRP-LR Section 3.5.2.2.1.4.

3.5.2.2.1.4 LRA Section 3.5.2.2.1.4 3.5.2.2.1.4 addresses loss of material due to general, pitting and crevice corrosion crevice corrosion for steel elements elements of accessible and inaccessible inaccessible areas areas of containments, stating that the ASME ASME Section XI, Subsection IWE program and the 10 Appendix J program 10 CFR Part 50, Appendix program are used to manage aging of accessible Containment manage Containment steel elements. For inaccessible inaccessible areas, the applicant applicant stated in the LRA that the loss of material material due to corrosion corrosion is assured acceptable because assured to be acceptable because (1) the design of the TMI-1 concrete concrete in accordance accordance with ACI 318-63 and construction AC1318-63 construction inin accordance with ACI 301-66 provide accordance provide a good quality quality dense concrete concrete with a low permeability, (2) (2) the interior concrete concrete is monitored monitored to ensure that it is free of penetrating penetrating cracks that provide aa path for water seepage forwater seepage to the containment liner, (3) the moisture monitored for aging moisture barrier is monitored aging effects by the ASME Section XI, XI, Subsection IWE Program; this will be performedperformed every refueling refueling outage, and (4) IWE inspections have IWE inspections have concluded concluded that the existing existing liner corrosion corrosion is acceptable.

SRP-LR Section Section 3.5.2.2.1.4 3.5.2.2.1.4 states that loss of material due to general, pitting and crevice crevice corrosion corrosion could occur occur in steel elements of accessible and inaccessible inaccessible areas for all types of PWR and BWR containments. SRP-LR Section 3.5.2.2.1.4 further further states that the existing existing program relies on ASMEASME Section XI, Xl, Subsection Subsection IWE, and 10 CFR Part 50, Appendix J, to to manage this aging effect. LRA Section B.2.1.24 describes the existing ASME Section Xl, B.2.1.24 describes XI, Subsection Subsection IWE program program as consistent, with exception, exception, with GALL GALL AMP XI.S1XI,S1 "ASME Section XI, XI, Subsection IWE." LRA Section B.2.1.27 describes the existing 10 Subsection IWE." 10 CFR Part 50, Appendix Appendix J program as consistent consistent with GALL AMP XI.S4 XI,S4 "10 CFR Part 50, Appendix J." SRP-LR SRP-LR Section Section 3.5.2.2.1.4 also states that the GALL Report recommends further evaluation 3.5.2.2.1.4 plant-specific evaluation of plant-specific programs to manage this aging effect for inaccessible inaccessible areas if corrosion is significant.

After reviewing reviewing the LRA, including the related AMPs with onsite basis document, related TMI-1 operating operating experience, experience, and discussions discussions with the applicant's applicant's technical staff, the staff found that the liner thickness thickness corrosion rate was noticeable from the operating experience of the ASME operating experience ASME Section XI, Subsection Subsection IWE Program. From the LRA Section on the ASME Section XI, Xl, Subsection Subsection IWE Program, the staff also noted that the applicant IWE Program, applicant committed committed to replacing replacing the the existing steam generators generators with new Once Through Generators (OTSGs) prior to entering Through Steam Generators entering the period of extended operation. Repair/replacement extended operation. Repair/replacement of reactor building liner plate, removed for access purposes, will be done in accordance accordance with ASME Section XI, XI, Subsection IWE. During the onsite onsite AMP audit, the applicant applicant also indicated that the liner will be restored (weld repair) to full nominal nominal thickness thickness at all locations identified as below 90% before entering entering the extended operation period. In RAI B.2.1.24-2, dated October 7, 2008, the staff requested requested that the the applicant provide additional information provide additional information to confirm confirm this and provide provide the proposed schedule for for completion.

The staff's staffs review of the ASME Section XI, Xl, Subsection Subsection IWE Program including the applicant's applicant's response to RAI B.2.1.24-2 is addressed addressed and documented documented in the SER Section 3.0.3.2.19. The The staff further noted noted from review review of the 10 CFR Part Part. 50, Appendix J Program that there there were no no instances instances of Appendix J test failures due to causes other than valve or flange seat leakage. For For these failures, all conditions evaluated and corrected in accordance conditions were evaluated accordance with the 10 10 CFR Part 50, Appendix Appendix J program. The staffs staff's review of the 10 CFR Part 50, Appendix J is documented in SER Section 3.0.3.1.7.

documented 3-395 3-395

determines that loss of material due to general On the basis of its review, the staff determines general pitting and crevice corrosion is an aging effect for steel elements elements of accessible accessible and inaccessible areas of inaccessible areas containments for the period of extended operation. The staff finds that applicant's inspections applicant's inspections and tests in accordance accordance with the ASME ASME Section XI, XI, Subsection IWE Program and the the 10 CFR Part 50, Appendix J Program material due to general manage loss of material Program to manage general pitting and crevice corrosion are adequate because (1) the aging effect has been effectively crevice corrosion effectively monitored and managed under the programs for accessible accessible containment containm~nt containment steel elements, and (2) containment concrete in contact with the embedded embedded containment liner was designed, designed, constructed, constructed, and inspected in accordance applicable ACI and ASTM standards, which provide for a good accordance with applicable permeability concrete, hence corrosion for inaccessible quality, dense, well cured, and low permeability inaccessible areas is not expected to be significant. Therefore, the staff agrees areas agrees that no additional plant-specific program is required.

plant-specific program Based on a review of the programs identified above, the staff concluded concluded that the applicant has has met the criteria of SRP-LR SRP-LR Section 3.5.2.2.1.4. For those line items that apply to LRA Section determined that the LRA is consistent with the GALL Report and the 3.5.2.2.1.4, the staff determined 3.5.2.2.1.4, the applicant. demonstrated that the effects applicant, has demonstrated adequately managed effects of aging will be adequately managed so that the the intended functions will be maintained intended consistent with the CLB during maintained consistent during the period of extended extended operation, as required by 10 CFR 54.21(a)(3).

Loss of Prestress Prestress due to Relaxation, Relaxation, Shrinkage, Creep, and Elevated Elevated Temperature.

Temperature. The staff staff reviewed procedures of SRP-LR 3.5.2.2.1.5 using the review procedures reviewed LRA Section 3.5.2.2.1.5 SRP-LR Section 3.5.2.2.1.5.

In LRA Section 3.5.2.2.1.5, the applicant stated stated that loss of prestress prestress forces due to relaxation, prestressed concrete containment.

temperature is a TLAA for prestressed shrinkage, creep, and elevated temperature SRP-LR Section 3.5.2.2.1.5 states that loss of prestress forces due to relaxation, shrinkage, SRP-LR shrinkage',

temperature for PWR prestressed elevated temperature creep, and elevated prestressed concrete containments and BWR Mark IIII concrete containments containments is a TLAA as defined in 10 prestressed concrete containments prestressed 10 CFR 54.3. TLAAs are requiredrequired to be evaluated in accordance evaluated accordance with 10 CFR 54.21(c).

TMI-1 containment is prestressed Therefore, loss of prestress forces due prestressed concrete. Therefore, due to I elevated temperature relaxation, shrinkage, creep, and elevated Containment is a TLAA temperature for the TMI-1 Containment TLAA defined in 10 CFR 54.3. The applicant's accordance with 10 CFR 54.21(c) applicant's TLAA evaluation in accordance 54.21(c) is discussed in LRA Section 4.7. The staff'sstaffs review of the applicant's evaluation of this TLAA is documented in the SER Section documented Section 4.7.

Cumulative Fatigue Damage. The staff reviewed 3.5.2.2.1.6 using the review reviewed LRA Section 3.5.2.2.1.6 I procedures of SRP-LR Section 3.5.2.2.1.6.

procedures In LRA Section evaluation of metal fatigue fqr applicant stated that the TLAA evaluation Section 3.5.2.2.1.6, the applicant for bellows (Fuel penetration bellows penetration transfer canal (Fuel transfer canal penetration) accordance with 10 CFR 54.21(c) is penetration) in accordance discussed in LRA Section 4.5. Penetration sleeves and dissimilar welds are evaluated discussed evaluated in LRA subsection subsection 3.5.2.2.1.8.

SRP-LR Section 3.5.2.2.1.6 SRP-LR 3.5.2.2.1.6 states that ifif included in the current licensing basis, fatigue fatigue analyses of suppression analyses (including welded suppression pool steel shells (including (including penetrations (including welded joints) and penetrations dissimilar metal welds, and penetration penetration sleeves, dissimilar penetration bellows) for all types of PWR and penetration bellows)

BWR containments and BWR vent header, vent line bellows, and downcomersare BWR containments downcomers are TLAAs as defined in 10 CFR 54.3.

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SER Section SER Section 4.5 4.5 documents documents the the staffs staff's review applicant's TLAA review of the applicant's evaluation of metal TLAA evaluation fatigue for fatigue for penetration penetration bellows.

bellows.

Cracking due Cracking due to Stress Stress Corrosion Cracking (SCC). The Corrosion Cracking reviewed LRA The staff reviewed Section 3.5.2.2.1.7 LRA Section 3.5.2.2.1.7 using the review review procedures procedures of SRP-LR SRP-LR Section Section 3.5.2.2.1.7.

3.5.2.2.1.7.

LRA Section 3.5.2.2.1.7, In LRA 3.5.2.2.1.7, the the applicant stated that SCC is not applicant stated applicable aging effect for not an applicable TMI-1 containment the TMI-1 containment penetration penetration sleeves, sleeves, penetration dissimilar metal penetration bellows, and dissimilar metal welds, since the penetration since bellows, and penetration bellows, penetration sleeves, penetration and dissimilar metal welds welds are notnot subject subject to an aggressive chemical environment.

aggressive chemical environment.

SRP-LR Section SRP-LR Section 3.5.2.2.1.7 cracking due states that cracking 3.5.2.2.1.7 states SCC of stainless due to SCC penetration stainless steel penetration penetration bellows, and sleeves, penetration and dissimilar metal welds could occur in all types of PWR and dissimilar metal BWR containments.

containments. Cracking Cracking duedue to SCC could also also occur in stainless steel steel vent line bellows bellows for BWR containments.

containments. The existing existing program program relies on the ASME Section Xl, Subsection IWE XI, Subsection IWE Program and Program and the 10 CFR Appendix J Program to manage this aging CFR Part 50, Appendix aging effect. The GALL recommends further Report recommends Report appropriate examinations/evaluations additional appropriate further evaluation of additional examinations/evaluations implemented implemented to detect these aging effects aging effects for stainless steel penetration sleeves, penetration penetration bellows bellows and dissimilar metal metal welds, and and stainless steel vent line bellows.

The staff acknowledged that stainless steel must staff acknowledged temperature (greater subject to both high temperature must be subject than 140 OF) OF) and and an aggressive aggressive chemical environment NUREG-1833 susceptible to SCC. NUREG-1833 environment to be susceptible "Technical Bases for Revision to the license license Renewal Renewal Guidance Guidance Documents" states states "In "In general, general, SCC very rarely occursoccurs in austenitic stainless stainless steels below 140 140 OF. Although SCC has been of. Although observed oxygenated borated water observed in stagnant, oxygenated water systems at lower temperatures than this lower temperatures this OF threshold, all of these instances 140 of instances have identified identified aa significant presence of contaminants presence contaminants specifically chlorides) in the failed components. With a harsh enough environment (halogens, specifically environment (significant contamination), SCC can occur in austenitic stainless steel at ambient temperature.

(significant However, these conditions However, considered event driven, conditions are considered driven, resulting from a breakdown breakdown of chemistry controls." The staff noted that the containment chemistry containment penetration sleeves, penetration bellows, and dissimilar metal bellows, metal welds are not subject to an aggressive chemical chemical environment. On On the basis of its review, the staff agreesagrees that cracking due to SCC for the containment penetration containment penetration penetration bellows, and dissimilar metal welds is not applicable sleeves, penetration applicable to TMI-1 since the the conditions necessary temperature (greater than 140 OF) and exposure to an necessary for SCC, both high temperature aggressive aggressive environment, do not simultaneously exist.

Cracking due to Cyclic Loading. The staff reviewed LRA Section 3.5.2.2.1.8 using the review Cracking procedures of SRP-LR Section 3.5.2.2.1.8.

procedures 3.5.2.2.1.8.

In LRA Section 3.5.2.2.1.8, the applicant stated that the ASME Section XI, Xl, Subsection IWE as described in the LRA described B.2.1.24, and 10 CFR 50, Appendix J as described in the LRA B.2.1.27 described manage cracking due to cyclic loading of the containment are used to manage containment penetration sleeves sleeves including the closure plates. The applicant further stated that plant operating operating experience experience has not penetration sleeves or the closure plates as aa concern and leakage identified cracking of penetration leakage through the reactor building during pressure testing conducted accordance with 10 CFR conducted in accordance Part 50, Appendix J, meets exceeds TS requirements. In meets or exceeds applicant stated that In addition, the applicant penetration bellows are evaluated for cumulative fatigue damage in LRA LRA Section 3.5.2.2.1.6.

SRP-LR Section 3.5.2.2.1.8 states that cracking due to cyclic loading of suppression suppression pool steel pool steel and stainless steel shells (including welded joints) and penetrations (including penetration sleeves, dissimilar metal welds, and penetration bellows) could occur for all types of 3-397 3-397

containments and BWR vent header, vent line bellows and downcomers.

containments SRP-LR Section downcomers. SRP-LR 3.5.2.2.1.8 also states that the existing program relies on the ASME Section XI, Subsection Subsection IWE IWE Program and the 10 10 CFR Part 50, Appendix J Program to manage manage this aging effect. However, VT-3 visual inspection may not detect fine cracks. The GALL Report recommends VT-3 recommends further further detection of this aging effect.

evaluation for detection evaluation ASME Section The ASME Section Xl, Program and the 10 CFR Part 50, Appendix J Program XI, Subsection IWE Program Program are existing programs that are consistent consistent with all elements of GALL AMP XI.S1, Section XI.S1, "ASME Section XI, Subsection IWE," and GALL AMP XI.S4, "10 CFR Part 50, Appendix Xl, Appendix J," respectively. The The staff's reviews of the ASME Section Xl, Subsection IWE program and the 10 CFR Part 50, ,'

XI, Subsection Appendix J program are documented documented in SER Sections 3.0.3.2.19 and 3.0.3.1.7 respectively.

The staff reviewed the AMR AMR andand its associated AMPs. During associated AMPs. During the onsite review of the onsitereview the associated associated AMPs, the staff also interviewed interviewed applicant's technical personnel.

personnel. The staff confirmed confirmed that TMI-1 TMI-1 operating experience events related identify any events experience did not identify loading induced related to cyclic loading cracking of containment containment components. Metal penetration bellows is a TLAA. SER Metal fatigue for penetration Section 4.5 documents the staff's review of the applicant'sapplicant's TLAA TLAA evaluation.

evaluation.

On the basis of ofits applicant's Section Xl, its review, the staff finds that applicant's XI, Subsection Subsection IWE and 10 CFR Part 50, Appendix J to manage the aging effect of cracking due to cyclic loading loading of steel, stainless steel elements and dissimilar penetration sleeves agrees with the dissimilar welds in penetration the recommendation recommendation of the GALL Report. The staff also agrees agrees that the applicant's evaluation is acceptable TMI-1 operating experience acceptable since TMI-1 penetration sleeves or cracking of penetration experience did not identify cracking or plates as a concern.

the closure plates concern.

Based on a review of the programs identified above, the staff concluded that the applicant programs identified applicant hashas met the criteria of SRP-LR Section 3.5.2.2.1.8. For those line items that apply to LRA Section Sectkm 3.5.2.2.1.8, the staff determined the LRA is consistent with the GALL determined that theLRA GALL Report and the the demonstrated that the effects of aging will be adequately applicant has demonstrated managed so that the adequately managed the maintained consistent with the CLB during the period of extended intended functions will be maintained operation, operation, as required by 10 10 CFR 54.21 (a)(3).

(Scaling., Cracking, and Spalling) due Loss of Material (Scaling, due to Freeze-Thaw. The staff reviewed LRA Section procedures of SRP-LR Section 3.5.2.2.1.9.

Section 3.5.2.2.1.9 using the review procedures '

weathering conditions are considered TMI-1 is located in an area in which weathering applicant considered severe. The appl'icant stated in LRA Section 3.5.2.2.1.9 ASME Section Xl, existing ASME 3.5.2.2.1.9 that the existing XI, Subsection Program is Subsection IWL Program used to manage loss of materialmaterial (scaling, cracking, and spalling) freeze-thaw of spalling) due to freeze-thaw "

containment concrete elements. For inaccessible accessible containment accessible inaccessible areas, the applicant further stated management because its significant and requires no aging management that the aging effect is not significant containment concrete containment concrete structures structures were designed, constructed, and inspectedinspected in -accordance accordance ,withwith applicable ACI and ASTM standards, which provide applicable ACl provide for a good quality, dense, well cured, ahd and applicant also committed in the LRA that inaccessible permeability concrete. The applicant low permeability concrete inaccessible concrete will be inspected if exposed for any reason, as required by the Structures Structures Monitoring Monitoring Program.

Section 3.5.2.2.1.9 SRP-LR Section material (scaling, cracking, and spalling) due to 3.5.2.2.1.9 states that loss of material freeze-thaw could occur in PWR and BWR concrete freeze-thaw concrete containments. The SRP-LR states that SRP-LR also states the existing program relies on ASME ASME Section Subsection IWL to manage this aging effect.

Section XI, Subsection The SRP-LR further states states that the GALL recommends further GALL Report recommends further evaluation aging evaluation of this aging effect for plants located in moderate plants located moderate to severe weathering conditions.

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The LRA describes describes the existing ASME ASME Section XI, Subsection Subsection IWL Program as consistent with GALL AMP Xl XI S2 "ASME Section XI, Subsection IWL." The staffs staffs review of the ASME Section Section XI, Subsection XI, documented in SER Section Subsection IWL Program is documented Section 3.0.3.1.6.

The staff reviewed the LRA. The staff confirmed that the Section Xl, Subsection IWL Program Section XI, Program is management of the aging effect for accessible credited for aging management credited accessible containment containment concrete concrete elements. The staff also noted that the Structures Monitoring Monitoring Program will include include examination examination of exposed concrete concrete for age-related degradation degradation when a below-grade below-grade concrete component component becomes accessible accessible through excavation.

excavation.

The staff further found the concrete concrete mix design addressed freeze-thaw design addressed freeze-thaw damage damage potential by by water-to-cement ratio and sufficient air content for structures subject using low water-to-cement subject to freezing freezing and thawing.

thawing. The staff noted that the air content content of the containment concrete concrete varied varied from 2.5 % to 8

%, which exceeds recommendation of 3%

exceeds the GALL recommendation 3% to 6%. However, according according to ACI 201.2R 201.2R "Guide to Durable Durable Concrete," for concrete exposed to freezing and thawing, air content of 4.5 to concrete exposed recommended for severe exposure, and air content of 3.5 to 6 is recommended 7.5 is recommended recommended for moderate exposure. In addition, tolerance on air content of 1.5 % is allowed. Therefore, moderate Therefore, the staff staff found that the concrete concrete is consistent with the air content recommendation of ACl content recommendation ACI 201.2R-77 201.2R-77 forfor concrete resistant to freezing and thawing. In addition, the staff also noted that containment containment concrete has a water-to-cement water-to-cement ratio of 0.44 with a 5000 psi compressive compressive strength. The staffstaff confirmed that 0.44 water-to-cement water-to-cement ratio of TMI-1 containment containment concrete concrete meets meets the the recommendation of ACl recommendation ACI 201.2R-77 201.2R-77 for a water-to-cement water-to-cement ratio of less than 0.50 for a densedense concrete with a low permeability.

permeability.

On the basis of its review, the staff finds that loss of material material (scaling, cracking, cracking, and spalling) spalling) due to freeze-thaw freeze-thaw is not a significant aging significant aging effect for concrete concrete elements of the containment containment because the absence because absence of the significant aging effects effects is confirmed from the operating operating experience experience under the existing ASME Section XI, XI, Subsection Subsection IWL Program. The staff also finds the the applicant's evaluation evaluation acceptable acceptable because because (1) the containment containment concrete is designed, constructed, and inspected inspected in accordance accordance with applicable applicable ACI and ASTM standards and meets the intent of ACI 201.2R-77 recommended by the GALL Report, and (2) the Structures 201.2R-77 as recommended Structures Monitoring Program will include Monitoring include examination examination of exposed concrete for age-related degradation exposed concrete degradation when a below-grade below-grade concrete component becomes concrete component becomes accessible excavation.

accessible through excavation.

Based on a review of the programs programs identified above, the staff concluded that the applicant has has met the criteria of SRP-LR SRP-LR Section 3.5.2.2.1.9. For those line items that apply apply to LRA Section 3.5.2.2.1.9 the staff determined determined that the LRA is consistent consistent with the GALL Report Report and the the applicant demonstrated that the effects of aging applicant has demonstrated adequately managed aging will be adequately managed so that the the intended intended functions functions will be maintained maintained consistent with the CLB during the period of extended extended operation, as required by 10 10 CFR 54.21(a)(3).

54.21 (a)(3).

Crackinq due to Expansion Cracking Expansion and Reaction Reaction with AqgqreQate, Aggregate, and Increase Increase in Porosity and Permeability Permeability due to Leachinq Leaching of Calcium Hydroxide.

Hydroxide. The staff reviewed LRA Section 3.5.2.2.1.10 using the review procedures 3.5.2.2.1.10 procedures of SRP-LR Section 3.5.2.2.1.10.

In LRA Section 3.5.2.2.1.10, the applicant stated that the applicant's applicant's existing AMP ASME ASME Section XI, Subsection IWL program is used to manage cracking cracking due to expansion expansion and reaction reaction with aggregate, and increase increase in porosity and permeability permeability due to leaching hydroxide leaching of calcium hydroxide for accessible TMI-1 Containment concrete concrete elements.

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,

For inaccessible inaccessible areas, the applicant applicant further evaluated cracking due to expansion evaluated that the cracking expansion and reaction with aggregate, and increase in porosity porosity and permeability due to leaching of calcium calcium hydroxide is not significant and requires requires no aging management because aging management because (1) TMI-1 TMI-1 containment containment concrete concrete is designed and constructed to meet ACI and ASTM Standards Standards and meets the intent intent of ACI 201.2R, and (2) aggregates aggregates were tested in accordance Specifications C 29-60, accordance with ASTM Specifications C 40-66, C 127-59, 127-59, C 128-59, and C 139-63 to confirm that the aggregates are not reactive.

C128-59, However, the applicant applicant committed inaccessible concrete committed that inaccessible concrete will be inspected inspected for cracking and increase in porosity and permeability increase permeability if excavated excavated for any reason, as required by the TMI-1 TMI-1 .

Structures Monitoring Monitoring Program.

SRP-LR Section SRP-LR Section 3.5.2.2.1.10 3.5.2.2.1.10 states that cracking due to expansion expansion and reaction reaction with aggregate, and increase increase in porosity and permeability due to leaching leaching of calcium hydroxide hydroxide could occur in concrete elements elements of concrete concrete and steel containments. SRP-LR Section 3.5.2.2.1.10 3.5.2.2.1.10 also states states that the existing existing program program relies on ASME SectionSection XI, Subsection Subsection IWL to manage manage these aging effects. The LRA describes the existing existing ASME Section Xl, Subsection IWL Program as XI, Subsection as consistent with GALL GALL AMP XI.S2 "ASME Section XI, Subsection Section XI, Subsection IWL."IWL." The staffs staff's review of the of!the ASME Section XI, Xl, Subsection IWL Program is documented documented in SER Section 3.0.3.1.6.

3.0.3.1.6. The GALL Report recommends further evaluation Report recommends if concrete evaluation if concrete was not constructed constructed in accordance accordance with the the recommendations in ACI 201.2R-77.

recommendations The staff reviewed the LRA including including the AMR and the associated associated AMPs. During the on-site interviewed applicant's review the staff also interviewed applicant's technical personnel. From review of the associated AMPs and operating operating experience, experience, the staff confirmed that these aging effects are not significant significant at TMI-1.

TMI-1. As discussed above in SER Sections 3.5.2.2.1.1 and 3.5.2.2.1.9, TMI-1 3.5.2.2.1.9, the TMI-1 containment concrete meets the recommendations containment recommendations of ACI 201.2R-77 201.2R-77 as suggested suggested by the GALL water-to-cement ratio, air content, and aggregate on water-to-cement aggregate reactivity issues.

On the basis of its review, the staff finds that cracking due to expansion expansion and reaction with aggregate, increase increase in porosity permeability due to leaching porosity and permeability leaching of calcium calcium hydroxide hydroxide are not plausible aging aging effects for concrete elements elements of containments because because (1) the containment containment' concrete is designed, constructed, concrete designed, constructed, and inspected in accordance accordance with applicable ACI and applicable and ASTM standards standards meets the recommendations recommendations of ACI 201.2R-77, 201.2R-77, and (2) the absence of the aging effects effects is confirmed under under the existing ASME Section XI, Subsection IWL Program as as recommended by the GALL Report. Therefore, recommended Therefore, the staff concluded concluded that, the applicant applicant has met the criteria of SPR-LR Section 3.5.2.2.1.10 for further evaluation.

Section 3.5.2.2.1.10 evaluation.

Based on a review of the programs programs identified identified above, the staff concluded that the applicant has has met the criteria criteria of SRP-LR Section 3.5.2.2.!1.10.

3.5.2.2.1.10. For those line items that apply to LRA Section 3.5.2.2.1.10, 3.5.2.2.1.10, the staff determined determined that the LRA is consistent with the GALL Report and the GALL Report the I' applicant demonstrated that the effects of aging will be adequately applicant has demonstrated adequately managed managed so that the the intended intended functions functions will be maintained maintained consistent consistent with the CLB during the period of of extended operation, as required by 10 CFR 54.21(a)(3).

operation, 3.5.2.2.2 Safety-Related Safety-Related and Other Structures Structures and Component Component Supports Supports The staff reviewed reviewed LRA Section Section 3.5.2.2.2 3.5.2.2.2 against against the criteria in SRP-LR Section Section 3.5.2.2.2.

Aging of Structures Not Covered by Structures Structures Monitoring Monitoring Program. The staff reviewed LRA LRA Section Section 3.5.2.2.2.1 against the criteria in SRP-LR Section 3.5.2.2.2.1.

3.5.2.2.2.1.

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In LRA Section 3.5.2~2.2.1 3.5.2.2.2.1,, the applicant applicant stated stated that the GALL structure Groups Groups 2, 7, 8, and 9 do not exist. The Structures Monitoring described in the LRAis Monitoring Program described manage LRA.is credited to manage aging effects applicable to Groups Groups 1, 3, 4, and 5 structures. Even if if the aging management aging management review did not identify aging effects requiring management, accessible accessible structures structures will be be monitored monitored through the Structures Monitoring Monitoring Program. The applicant applicant stated that aging effects effects not requiring management management are (1) scaling, cracking, spalling increase in porosity and spalling and increase permeability due to leaching permeability leaching of calcium hydroxide for Groups 1, 3, 4, and 5 structures, (2) loss calcium hydroxide loss of material and cracking due to freeze-thaw freeze-thaw for Group 4 structures and (3) reduction reduction in foundation strength, cracking, cracking, and differential differential settlement settlement due to erosion of porous concrete concrete subfoundation for Groups subfoundation Groups 1, 3, 4, and 5 structures.

3.5.2.2.2.1 states that the GALL Report SRP-LR Section 3.5.2.2.2.1 Report recommends recommends further evaluation of certain structure/aging structure/aging effect combinations if they are not covered by the structures monitoring monitoring program. This includes (1) cracking, loss of bond, and loss of material material (spalling, scaling) scaling) due to to corrosion corrosion of embedded embedded steel for Groups 1-5, 7, 9 structures; (2) increase increase in porosity and permeability, cracking, loss of material material (spalling, scaling) due to aggressive chemical attack for (spalling, scaling) for Groups 1-5, 7,9 7, 9 structures; structures; (3) loss of material material due to corrosion for Groups 1-5, 7, 8 structures; (4) loss of material material (spalling, scaling) scaling) and cracking cracking due to freeze-thaw freeze-thaw for Groups Groups 1-3, 5, 7-97-9 structures; structures; (5) cracking due to expansion expansion and reaction with aggregates aggregates for Groups 1-5, 7-9 Groups 1-5, structures; structures; (6) cracks and distortion distortion due to increased increased stress levelslevels from settlement settlement for Groups Groups 1-3, 5-9 structures; and (7) reduction in foundation strength, cracking, cracking, differential differential settlement due due to erosion of porous concrete subfoundation subfoundation for Groups 1-3, 5-9 structures. The GALL Report recommends recommends furtherfurther evaluation only for structure/aging structure/aging effect combinations combinations that are not within the structures monitoring program. In addition, SRP-LR structures monitoring SRP:-LR Section 3.5.2.2.2.1 also states that lock up due to wearwear could occur for Lubrite Lubrite radial beam seats in BWR drywell, drywell, RPV support shoes support shoes for PWR with nozzle generator supports, and other nozzle supports, steam generator bearings other sliding support bearings and sliding support support surfaces. The existing program relies on the Structures existing program Structures Monitoring Monitoring Program or the ASME Section Section XI,Xl, Subsection IWF Program Program to manage manage this aging effect. The GALL Report recommends recommends further evaluation only for structure/aging structure/aging effect combinations that are not within the lSIISI (IWF)

(IWF) or structures monitoring monitoring program.

The staff staff noted noted the GALL structure Groups Groups 2, 7,8, 7, 8, and 9 do not exist. The staff further further noted applicant's Structures Monitoring that the applicant's Program is credited for aging management Monitoring Program management of these effects/mechanisms for the affected effects/mechanisms concrete structures affected concrete structures and structural components components even even ifif the the aging management management review did not identify aging effects requiring management. The staff's staff's review of the Structures Monitoring Program is documented Structures Monitoring documented in SER Section Section 3.0.3.2.21.

3.0.3.2.21.

Additional Additional reviews of specific aging effects/mechanisms are discussed below.

aging effects/mechanisms (1) Cracking, Cracking, Loss of Bond, and Loss of Material (Spalling, Scaling) Due to Corrosion of Embedded Steel for Groups 1-5, 7, and 9 Structures Embedded Structures The staff's reviews reviews for cracking, cracking, loss of bond, and loss of material (spalling, scaling) scaling) duedue to corrosion of embedded embedded steel for inaccessible inaccessible concrete areas of containments, below-grade inaccessible inaccessible concrete concrete areas areas of Groups 1, 3, and 5 structures, structures, and below-grade inaccessible concrete below-grade inaccessible concrete areas areas of Group 6 Structures are documented Structures documented in SER SER Sections 3.5.2.2.1.1, 3.5.2.2.2.4.1 respectively. The staff's review 3.5.2.2.1.1, 3.5.2.2.2.2.4, and 3.5.2.2.2.4.1 review of of Monitoring Program is documented the Structures Monitoring documented in SER Section 3.0.3.2.21.

3.0.3.2.21. The staff staff confirmed confirmed that Groups 1 and 3-5, structures (structure Groups Groups 2, 7, 8, and 9 do not exist TMI-1) subject to this AMR are all in-scope at TMI-1) in-scope of the Structures Structures Monitoring Program.

Program.

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Therefore, the staff agrees agrees that the criteria of SRP-LR SRP-LR Section 3.5.2.2.2.1 3.5.2.2.2.1 have been met, and no further evaluation evaluation is required.

(2)

(2) Increase in Porosity and Permeability, Cracking, Increase Cracking, Loss of Material Material (Spalling, Scaling) Due Due to Aggressive Chemical Chemical Attack for Groups 1-5, 7, and 9 Structures Structures The staffs reviews for increase in porosity and permeability, cracking, loss of material scaling) due to aggressive (spalling, scaling) inaccessible concrete aggressive chemical attack for inaccessible concrete areas areas of below-grade inaccessible containments, below-grade inaccessible concrete concrete areas of Groups 1, 3, and 5 structures, and below-grade below-grade inaccessible inaccessible concrete areas of Groups 6 Structures are documenteddocumented in SER Sections 3.5.2.2.1.1, Sections 3.5.2.2.1.1, 3.5.2.2.2.2.4, and 3.5.2.2.2.4.1, 3.5.2.2.2.4.1, respectively. The staffs staffs review of the Structures Monitoring Monitoring Program Program is documented documented in SER Section 3.0.3.2.21.

3.0.3.2.21.

The staff confirmed that Groups 1 and 3-5, structures structures (structure Groups 2, 7, 8, and 9 do do not exist at TMI-1)

TMI-1) subject to this AMR AMR are all in-scope of the Structures Monitoring Monitoring :

Program. Therefore, the staff agrees that the criteria of SRP-LR SRP-LR Section Section 3.5.2.2.2.1 havehave been met, and no further evaluation is required.

(3) Loss of Material Material Due to Corrosion for Groups 1-5, 7, and 8 Structures Structures The staffs review for loss of material due to general, general, pitting and crevice corrosion for steel elements elements of containments is documented documented in SER Section 3.5.2.2.1.4. The staff's review of the Structures Monitoring Monitoring Program is documented documented in SER Sections 3.0.3.2.21.

3.0.3.2.21.

The staff finds that Groups Groups 1, and 3-5 structures (structure (structure Groups 2, 7, 8, and 99 do 'not not exist at TMI-1)

TMI-1) subject to this AMR are all in-scope of the Structures Monitoring Monitoring Program. Therefore, Program. Therefore, the staff agrees agrees that the criteria of SRP-LR Section 3.5.2.2.2.1 3.5.2.2.2.1 have have been met, and no further evaluation evaluation is required.

required. .

(4) Loss of Material (Spalling, Scaling) and Cracking Due to Freeze-Thaw for Groups to. Freeze-Thaw Groups 1-3, 5, and 7-9 Structures Structures The staffs staffs reviews for loss of material material (spalling, scaling) scaling) and cracking cracking due to freeze-thaw freeze1thaw for concrete concrete containments, below-grade inaccessible concrete areas below-grade inaccessible areas of Groups 1, 3, and 5 structures, structures, and below-grade below-grade inaccessible inaccessible concrete concrete areas of Groups Groups 6 Structures are documented in SER Sections 3.5.2.2.1.9, documented 3.5.2.2.2.2.1 and 3.5.2.2.2.4.2, 3.5.2.2.1.9, 3.5.2.2.2.2.1 respectiv~:ly.

3.5.2.2.2.4.2, respectively.

The staffs review of the Structures Structures Monitoring Monitoring Program Program is documented documented in SER Section 3.0.3.2.21. The staff found that this is not an applicable 3.0.3.2.21. applicable aging aging effect for Group 4 structures structures because Group 4 structures structures are inside Reactor Building and protected the Reactor protected from repeated freeze-thaw. The staff confirmed confirmed that Groups 1, 3 and 55 structures structures (structure Groups 2, 7, 8, and 9 do not exist at TMI-1)TMI-1) subject to this AMR AMR are all Monitoring Program. Therefore, the staff agrees in-scope of the Structures Monitoring agrees that the the criteria of SRP-LR Section 3.5.2.2.2.1 3.5.2.2.2.1 have been met, and no further evaluation evaluation is required.

(5) Cracking Due to Expansion Expansion and Reaction Reaction with Aggregates for Groups Groups 1-5 and 7-9 7-9 Structures Structures The staffs staffs reviews for cracking cracking due to expansion expansion and reaction with aggregates aggregates for containments, below-grade concrete elements of containments, below-grade inaccessible inaccessible areas of Groups Groups 1, and 3-5 structures, below-grade inaccessible structures, and below-grade inaccessible reinforced concrete concrete areas of Groups 6 structures structures are documented in SER Sections 3.5.2.2.2.4.3 Sections 3.5.2.2.1.10, 3.5.2.2.2.2.2, and 3.5.2.2.2.4.3 respectively. The staffs review of the Structures Structures Monitoring Monitoring Program is documented documented in in 3-402

SER Section 3.0.3.2.21.

3.0.3.2.21. The staff finds that Groups 1, and 3-5 structures (structure Groups 2, Groups 7, 8, and 2,7,8, and 99 do do not exist at not exist at TMI-1)

TMI-1) subject subject to this AMR AMR are all in-scope of the the Structures Monitoring Program. Therefore, the staff agrees that the criteria of SRP-LR SRP-LR Section 3.5.2.2.2.1 3.5.2.2.2.1 have been been met, and no further evaluation evaluation is required.

(6) Cracks and Distortion Due to Increased Settlement for Groups Increased Stress Levels from Settlement Groups 1-3 and 5-9 Structures Structures staffs reviews for cracks The staffs cracks and distortion increased stress levels from distortion due to increased settlement for containment containment and below-grade inaccessible areas of Groups 1, and 3, and below-grade inaccessible 3.5.2.2.1.2 and 3.5.2.2.2.2.3, respectively.

documented in SER Sections 3.5.2.2.1.2 5 structures are documented The staffs staff's review of the Structures Monitoring Program documented in SER Section Program is documented 3.0.3.2.21. Groups 1, 3, 5, and 6 structures (structure Groups staff finds that Groups 3.0.3.2.21. The staff Groups 2, 7, 8, 2,7,8, TMI-1) subject to this AMR are all in-scope and 9 do not exist at TMI-1) Structures in-scope of the Structures Monitoring Program. Therefore, Monitoring agrees that the criteria of SRP-LR Therefore, the staff agrees SRP-LR Section Section 3.5.2.2.2.1 have been met, and no further evaluationevaluation is required.

(7) Foundation Strength, Cracking, and Differential Settlement Reduction in Foundation Settlement Due to Erosion Erosion of Porous Concrete Subfoundation for Groups Groups 1-3 and 5-9 Structures Structures reduction in foundation strength, cracking, and differential The staffs reviews for reduction subfoundation for containment and settlement due to erosion of porous concrete subfoundation settlement inaccessible areas of Groups 1, below-grade inaccessible below-grade and 5 structures 1, and 3, and structures are documented documented in SER Sections 3.5.2.2.1.2 3.5.2.2.1.2 and 3.5.2.2.2.2.3, respectively. The staff's review of the the documented in SER Section Structures Monitoring Program is documented 3.0.3.2.21. The staff Section 3.0.3.2.21. staff determined through reviews that reduction determined cracking, reduction in foundation strength, cracking, and settlement due to erosion of porous concrete subfoundation differential settlement differential subfoundation for Groups 1, 3, structures are not plausible aging effects 5, and 6 structures absence of porous concrete effects due to the absence concrete subfoundation. The staff noted that even if the aging management subfoundation. management review did not identify accessible structures effects requiring management, accessible aging effects monitored through the structures will be monitored the Structures Monitoring Program. Therefore, the staff agrees that the criteria of SRP-LR Structures SRP-LR Section 3.5.2.2.2.1 have been met, and no further evaluation Section evaluation is required (8)

(8) Lockup Due to Wear for Lubrite Lockup Lubrite Radial Beam Seats in BWR Drywell and and Other Sliding Other Sliding Surfaces Support Surfaces SRP-LR Section SRP-LR 3.5.2.2.2.1 also states that lockup due to wear could occur for Lubrite Section 3.5.2.2.2.1 Lubrite radial beam seats in BWR drywell,drywell, RPV support shoes for PWR with nozzle supports, steam generator supports, and other other sliding support bearings and sliding support surfaces. The existing program relies on the Structures Monitoring Program and ASME ASME Section XI, Subsection IWF to manage this aging effect. The GALL GALL Report recommends Report recommends evaluation only for structure/aging further evaluation combinations that are not within the ISI structure/aging effect combinations lSI (IWF) or Structures Structures Monitoring Program.

In LRA Section 3.5.2.2.2.1, In applicant stated that RPV support shoes and steam 3.5.2.2.2.1, the applicant generator supports do not include sliding surfaces.

generator surfaces. The Structures Structures Monitoring Program and the ASME Section XI, Subsection IWF program are used to manage manage lock-up lock-up due to surfaces provided for supports for Main Steam relief valves, heat wear for the sliding surfaces heat exchanger supports, and floor beam seats.

exchanger 3-403

required for concludes that no further evaluation is required On the basis of its review, the staff concludes due to wear because lock up due because the structure/aging effect combinations are within the structure/aging effect the applicant's Structures applicant's Structures Monitoring Program and ASME Section Xl, Monitoring Program XI, Subsection IWF IWF program.

program.

On the basis of its review, the staff concluded that the applicantapplicant has met the criteria criteria of SRP-LR SRP-LR Section 3.5.2.2.2.1. 3.5.2.2.2.1, the staff 3.5.2.2.2.1. For those line items that apply to LRA Section 3.5.2.2.2.1, staff consistent with the GALL Report and the applicant determined that the LRA is consistent applicant hashas demonstrated demonstrated that the effects effects of aging will be adequately managed managed so that the intended maintained consistent with the CLB during the period of functions will be maintained extended operation, as as required by 10 CFR 54.21(a)(3).

Aging Managementof Inaccessible Areas. The staff reviewed LRA Section Management of Inaccessible Section 3.5.2.2.2.2 against SRP-LR Section 3.5.2.2.2.2.

the criteria in SRP-LR 3.5.2.2.2.2.

(1) TMI-1 is located located in an areaarea in which weathering conditions are considered severe. The which weathering The material (scaling, 3.5.2.2.2.2.1 that loss of material applicant stated in LRA Section 3.5.2.2.2.2.1 cracking, and (scaling, cracking" spalling) due to freeze-thaw freeze-thaw in below-grade below-grade inaccessible concrete areas for structure inaccessible concrete structure Groups 1, 3, and 5 (structure Groups 2, 7, 8, and 9 do not exist at TMI-1) TMI-1) is notnot management because requires no aging management significant and requires concret~ structures at TMI-1 because concrete TMI-1 designed, constructed, were designed, accordance with applicable inspected in accordance constructed, and inspected applicable ACI and ASTM standards, which which provide for a good quality, dense, well cured, and low low permeability permeability concrete. The TMI-1 concrete freeze-thaw damage concrete mix design addressed freeze-thaw damage aggregate soundness for structures subject to entrained air and aggregate potential by using entrained freezing and thawing. However, the applicant committed that inaccessible freezing inaccessible concrete will be inspected if exposed for any reason, as required by TMI-1 Structures if exposed Monitoring Structures Monitoring Program.

The staff reviewed LRA Section Section 3.5.2.2.2.2.1 against the criteria in SRP-LR Section 3.5.2.2.2.2.1, which states that loss of material (spalling, 3.5.2.2.2.2.1, scaling) and cracking due to (spalling, scaling) freeze-thaw freeze-thaw could occur in below-grade inaccessible concrete areas of Groups 1-3, 65 below-grade inaccessible concrete and 7-9 structures. The GALL Report recommends recommends further evaluation of this aging effect inaccessible areas of these Groups of structures for plants located for inaccessible located in moderate to weathering conditions.

severe weathering reviewed the LRA. The staff noted that the Structures The staff reviewed Monitoring Program Structures Monitoring Program Iwillwill include examination of exposed include exposed concrete degradation when a age-related degradation concrete for age-related concrete component becomes below-grade concrete below-grade becomes accessible through excavation.

excavation. The staff staff further noted the TMI-1 concrete TMI-1 concrete mix design addressed freeze-thaw damage potential by freeze-thaw damage potential structures subject to freezing and thawing. The staff found using sufficient air content for structures found that the air content of TMI-1 containment concrete concrete varied from 2.5% to 8%, which ~!.

recommendation of 3% to 6%. However, according exceeds the GALL recommendation according to ACI 201.2R 201.2R Durable Concrete," for concrete exposed "Guide to Durable exposed to freezing and thawing, air content content of 3.5 to 7.5 is recommended.

recommended. In tolerance on air content of 1.5%

In addition, tolerance 1.5% is allowed.

Therefore, the staff found that the TMI-1 concrete is consistent with the air content Therefore, content .

recommendations of ACI 201.2R-77 recommendations 201.2R-77 for concrete resistant to freezing and thawing. '

On the basis of its review, the staff agrees TMI-1, loss of material (scaling, agrees that for TMI-1, cracking, and spalling) due to freeze-thaw spalling) due freeze-thaw is not a significant aging significant aging effect effect for Groups 1, 3, and 5 because the absence of the strudure Groups inaccessible areas for structure inaccessible the significant aging effects confirmed from the operating experience effects is confirmed experience under the existing existing 3-404 3-404

Monitoring Program. The staff also finds the applicant's Structures Monitoring acceptable applicant's evaluation acceptable because (1) the TMI-1 concrete mix design addressed freeze-thaw damage potential freeze-thaw damage potential by by using entrained entrained air and aggregate soundness for structures structures subject to freezing and thawing in accordance accordance with applicable ACI ACl and ASTM ASTM which meet the intent of ACl ACI 201.2R-77 201.2R-77 for moderate moderate to severe exposure as recommended by the GALL, and (2) the (2) the Structures Structures Monitoring Program will include examination examination of exposed exposed concrete concrete for age-related degradation when a below-grade age-related degradation below-grade concrete' concretecomponent becomes accessible component becomes accessible through excavation.

Based Based on a review of the programs identified identified above, the staff concluded that the the applicant applicant has met the criteria of SRP-LR SRP-LR Section 3.5.2.2.2.2.1.

3.5.2.2.2.2.1. For those line items items that that apply to LRA Section Section 3.5.2.2.2.2.1, 3.5.2.2.2.2.1, the staff determined determined that the LRA is consistent with the GALL Report and the applicant has demonstrated demonstrated that the effects of aging will be be adequately managed so that the intended adequately managed intended functions will be maintained maintained consistent with the CLB during the period of extended operation, as required required by 10 CFR 54.21 (a)(3).

(2) In LRA Table 3.5.1, 3.5.1, Item 3.5.1-27, the applicant stated that the existing Structures Structures Monitoring Program Monitoring Program is used to manage cracking cracking of interior/exterior interibr/exterior concrete concrete due to to expansion and reaction reaction with aggregate aggregate for accessible and inaccessible inaccessible areas areas regardless regardless of aging mechanism. For below-grade below-grade inaccessible concrete areas, the applicant further evaluated in LRA Section 3.5.2.2.2.2.2 that the cracking evaluated cracking due to expansion expansion and reaction with aggregate aggregate is not significant significant and requires no aging management management because because (1) The The containment containment concrete is designed designed and constructed constructed to meet ACI and ASTM Standards Standards and meets the intent of ACI 201.2R, and (2) aggregates accordance with aggregates were tested in accordance with ASTM Specifications Specifications C 29-60, C 40-66, C 127-59, C 128-59, and C 139-63 to confirm that the aggregates aggregates meet ACI requirements. However, the applicant committed that that inaccessible concrete inaccessible concrete will be inspected inspected for cracking cracking if if excavated excavated for any reason, as as required by the Structures Monitoring Monitoring Program.

The staff reviewed LRA Section 3.5.2.2.2.2.2 against the criteria criteria in SRP-LR SRP-LR Section 3.5.2.2.2.2.2, 3.5.2.2.2.2.2, which states that cracking due to expansionexpansion and reaction with aggregatesaggregates could occur in below-grade below-grade inaccessible inaccessible concrete concrete areas for Groups 1-5 and 7-9 7-9 structures. The GALL Report recommends further Report recommends further evaluation of inaccessible inaccessible areas areas of these Groups of structures if if concrete concrete was not constructed in accordance accordance with the the recommendations in ACI 201.2R-77.

recommendations 201.2R-77.' ' .

The staff reviewed the LRA including including the AMR and the associated Monitoring associated Structures Monitoring Program. The staff noted Program. noted from NUREG-1611 NUREG-1611 "Aging Management Management of Nuclear Nuclear Power Power Plant Containment Containment for License Renewal" that reaction reaction with aggregates aggregates in inaccessible inaccessible areas would also occur in accessible areas because because aggregates were aggregates were used in construction construction of both accessible accessible and inaccessible inaccessible areas. The existing StructuresStructures Monitoring Program requires requires periodic examination of accessible periodic examination accessible concrete concrete surfaces and inspection of inaccessible inaccessible concrete areas for cracking cracking if excavated for any reason.

On the basis of its review, the staff agrees that crackingcracking due to expansion expansion and reactionreaction aggregate is not a significant with aggregate significant aging effect effect for concrete concrete elements elements because the the absence of the significant significant aging effects is confirmed from the operating operating experience experience under under the existing Structures Structures Monitoring Program.

Program. The staff also finds the applicant's applicant's evaluation acceptable acceptable because (1) the aggregates aggregates were tested in accordance accordance with ASTM Specifications, Specifications, (2) the Structures Monitoring Program Monitoring Program will detect detect the aging effects in the the accessible areas, which will trigger additional evaluation accessible evaluation of accessible accessible and inaccessible inaccessible 3-405

areas, and and (3)

(3) the inaccessible inaccessible areasareas will bebe examined examined by by the Structures Structures Monitoring Monitoring Program when Program when the areas areas are available available for inspection due to future excavation.

inspection due future excavation.

Based Based onon a review review of the the programs programs identified identified above, above, the staff staff concluded concluded thatthat the the applicant has applicant has met met the criteria criteria of of SRP-LR SRP-LR Section 3.5.2.2.2.2.2.

3.5.2.2.2.2.2. For thosethose line line items items that apply apply to LRA Section Section 3.5.2.2.2.2.2, 3.5.2.2.2.2.2, the staff staff determined determined that that the LRA is consistent consistent with with the the GALL GALL Report and the applicant applicant has demonstrated demonstrated that the effects effects of aging will be be adequately adequately managed managed so that the the intended intended functions functions will be maintained maintained consistent consistent with with the the CLB during during the period period of extended extended operation, operation, as required by 10 CFR CFR 54.21(a)(3).

(3)

(3) The The applicant applicant stated stated inin the LRA Section Section 3.5.2.2.2.2.3 3.5.2.2.2.2.3 that (1) the the foundation foundation of structure structure Groups 1, 4, and and 5 is founded founded on on bedrock bedrock andand no settlement settlement has has been been experienced, experienced, Group 33 structures structures whose foundations foundations are founded founded on soil are subject to cracks cracks andand distortion distortion due due to increased increased stress stress levels levels from settlement settlement and and in scope of the Structures Structures Monitoring Program, Program, (2) (2) the foundation foundation is not constructed constructed of porous concrete, concrete, and and (3) the the plants plants design design does does not employ employ a de-watering de-watering system for control of settlement.

settlement.

The staff reviewed reviewed LRA SectionSection 3.5.2.2.2.2.3 3.5.2.2.2.2.3 against the criteria in SRP-LR Section 3.5.2.2.2.2.3, which 3.5.2.2.2.2.3, which states that cracks cracks and and distortion due due to increased increased stress levels from from settlement and reduction of foundation foundation strength, cracking, cracking, and differential settlement due differential settlement due to erosion erosion of porous concrete concrete subfoundations subfoundations could could occur in below-grade below-grade inaccessible inaccessible concrete areas concrete areas of Groups Groups 1-3, 5 and 7-9 structures. LRA Section Section 3.5.2.2.2.2.3 3.5.2.2.2.2.3 states states that the existing program relies on the Structures existing program Monitoring Program to manage Structures Monitoring manage these these aging effects. TheThe TMI-1 TMI-1 Structures Monitoring Program Structures Monitoring Program described described in LRA Section Section B.2.1.28 is an existing existing program program that is consistent with all elements of the Structures Structures' Monitoring Monitoring Program in the GALL, GALL, when the enhancements enhancements are incorporated incorporated in the the program. The staffs review of the applicant'sapplicant's Structures Monitoring Monitoring Program is documented documented in SER Section 3.0.3.2.21. 3.5.2.2.2.2.3 further states 3.0.3.2.21. SRP-LR Section 3.5.2.2.2.2.3 states that the GALL Report Report recommends no further evaluation evaluation if this activity is within the scope of the applicant's structures structures monitoring monitoring program.

program.

The staff staff* has reviewed the LRA including the AMR and its associated associated AMP. The staff staff confirmed that the TMI-1 base foundation is not constructed of porous confirmed porous concrete concrete below grade. The staff further confirmed confirmed that the associated AMP Structures Monitoring Monitoring Program is credited for aging management of these effects effects for the affected concrete structures and structural components, and will include include examination examination of exposed exposed concrete concrete age-related degradation for age-related degradation when a below-grade below-grade concrete component becomes concrete component becomes accessible during excavation.

excavation.

On the basis of its review, the staff finds that cracks and distortion due to increased increased stress levels from settlement; reduction of foundation strength, cracking differential cracking and differeriltial settlement due to'erosion of porous concrete subfoundations subfoundations are not plausible aging effects in below~grade below-grade inaccessible inaccessible concrete areas of Groups Groups 1 and 5 structures structures (structure Groups 2, 7, 8, and 9 do not exist at TMI-1) because TMI-1) because conditions necessary for necessarY the aging effects, such as a soil environment as described in associated AMR line items items of the GALL Report, Volume 2, do not exist. The staff also finds that these aging effects effects TMI-1 concrete area of Group could affect TMI-1 Group 3 structures whose foundation is founded on soil. However, the applicant's Structures Monitoring Program is credited for aging management of these effects for the affected concrete structures and structural management components for structure Group 3. Therefore, the staff finds that no further evaluation is required.

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Based Based on a review of the programs identified above, the staff concluded that the the applicant has met the criteria of SRP-LR Section applicant Section 3.5.2.2.2.2.3. For those line items that apply to LRA Section 3.5.2.2.2.2.3, 3.5.2.2.2.2.3, the staff determined determined that the LRA is consistent with the GALL Report GALL Report and the applicant has demonstrated demonstrated that the effects of aging will be be adequately managed adequately managed so that the intended functions will be maintained maintained consistent consistent with the CLB during the period extended operation, period of extended required by 10 CFR 54.21 (a)(3).

operation, as required (4) The applicant stated that inaccessible inaccessible below-grade below-grade reinforced concrete for Group 1, 3, and 5 structures is not subject to an aggressive aggressive environment environment because because historical chemistry results of groundwater groundwater water samples have confirmed confirmed that groundwater groundwater is non-aggressive. Groundwater non-aggressive. Groundwater water is periodically monitored monitored as required by the the Structures Monitoring Monitoring Program. The applicantapplicant committed committed to perform examinations examinations of exposed concrete for age-related degradation degradation when a below-grade below-grade concrete component component accessible through excavation.

becomes accessible excavation.

The staff reviewed reviewed LRA Section Section 3.5.2.2.2.2.4 3.5.2.2.2.2.4 against the criteria criteria in SRP-LR Section Section 3.5.2.2.2.2.4, which states states that increase in porosity and permeability, cracking, cracking, loss of scaling) due to aggressive material (spalling, scaling) aggressive chemical chemical attack; attack; and cracking, cracking, loss ofof bond, and loss of material (spalling, scaling) scaling) due due to corrosion of embedded steel steel could occur occur in below-grade inaccessible inaccessible concrete areas of Groups 1-3, 5 and and 7-9 structures.

The GALL Report recommends recommends further evaluationevaluation of plant specific programs specific programs to manage manage the aging effects effects for inaccessible inaccessible areas if the environment environment is aggressive.

To ensure non-aggressive non-aggressive groundwater groundwater chemistries, chemistries, the GALL GALL Report suggests suggests thethe performance performance of periodic groundwater inspection for chlorides, sulfates, and pH.

groundwater inspection pH. The staff staff noted noted that the applicant's groundwater groundwater inspection program program is performed by the the applicant's Structures Monitoring applicant's Monitoring Program described described in LRA Section B.2.28. The staff's staffs review of the applicant's applicant's Structures Structures Monitoring Monitoring Program, including periodic monitoringmonitoring .of of groundwater, is documented groundwater, documented in SER Section 3.0.3.2.21.

Section 3.0.3.2.21.

The staff reviewed the LRA including the AMR AMR and its associated associated AMP. The staff noted that the sampling sampling results from 1996 presented presented in the LRA, which indicated a groundwater pH range of 6.1-6.7, a chloride groundwater chloride range of 3.5-210 3.5-210 ppm, and a sulfate range range 14.1-410 ppm. In RAI B.2.1.28-1, of 14.1-410 B.2.1.28-1, dated October 7,2008, 7, 2008, the staff requested that the the applicant provide additional applicant information concerning the frequency of periodic sampling additional information and the results for the last two sampling sampling of groundwater. .

In its response to the RAI dated October 30, 2008, the applicant applicant stated stated that the the groundwater sampling groundwater sampling for pH, chloride, and sulfate concentrations sulfate concentrations will be performed performed every 5 years during the period of extended operation. The applicant applicant also demonstrated demonstrated the last two groundwater groundwater samplings include include one sample taken in 2007 and three taken in 2005, which showed a pH range of 7.4-7.8, a chloride range range of 42.4-65.5 42.4-65.5 ppm, and a sulfate sulfate range of 27-53.3. The staff confirmed that the below-grade below-grade environment environment at TMI-1 TMI-1 non-aggressive (pH greater than 5.5, Chlorides less than 500 ppm, and Sulfates less is non-aggressive less than 1500 ppm). The staff's concern described described in RAI B.2.1.28-1.

B.2.1.28-1 is resolved.

On the basis of its review, the staff finds that the AMR results consistent consistent with the GALL Report. The staff agrees that a plant specific specific aging management management program is not required for below-grade inaccessible concrete below-grade inaccessible concrete areas of the TMI-1 TMI-1 Group 1, 3, and 5 (structure Groups 2, 7, 8, and 9 do not exist) structures manage aging effects of increases in structures to manage porosity and permeability, cracking, loss of material (spalling, (spalling, scaling) scaling) due to aggressive aggressive 3-407

chemical attack, chemical attack, and and cracking, cracking, loss loss of bond, bond, and loss loss ofof material material (spalling, scaling) due (spalling, scaling) due corrosion of embedded to corrosion steel because embedded steel because (1) (1) the groundwater water environment groundwater water environment is confirmed not confirmed not aggressive concrete; (2) aggressive to concrete; (2) the inspection inspection frequency frequency of groundwater groundwater chemistries chemistries asas required required byby thethe Structures Structures Monitoring Program agrees Monitoring Program agrees with thethe recommendation of the GALL; and recommendation (3) the applicant and (3) applicant committed committed to perform perform examinations examinations of exposed exposed concrete age-related degradation concrete for age-related below-grade concrete degradation when aa below-grade concrete component becomes component accessible through excavation.

becomes accessible excavation.

Based on on aa review the programs review of the identified above, the staff concluded programs identified concluded that the the applicant applicant has met met the criteria SRP-LR Section criteria of SRP-LR 3.5.2.2.2.2.4. For those line items that Section 3.5.2.2.2.2.4. that apply to LRA apply 3.5.2.2.2.2.4, the LRA Section 3.5.2.2.2.2.4, determined that the LRA is consistent the staff determined consistent with Report and the the GALL Report the applicant applicant has demonstrated that the effects has demonstrated effects of aging will be be adequately adequately managed managed so so that that the intended intended functions will be maintained consistent with be maintained with the CLB during during thethe period period of extended extended operation, required by 10 CFR operation, as required CFR 54.21(a)(3).

54.21 (a)(3).

(5)

(5) In LRA Section In applicant stated that the cracking Section 3.5.2.2.2.2.5, the applicant cracking due due to expansion expansion and reaction with aggregate, increase in porosity and permeability aggregate, and increase permeability due to leaching leaching of calcium hydroxide in below-grade inaccessible concrete below-grade inaccessible requires no aging concrete areas requires management concrete is designed because (1) the concrete management because constructed to meet ACI and designed and constructed Standards and meets the intent of ACI 201.2R, and (2)

ASTM Standards ASTM aggregates were (2) the aggregates were accordance with tested in accordance with ASTM Specifications C 29-60, C 40-66, C 127-59, C 128-59, ASTM Specifications 128-59, and C 139-63 confirm that the aggregates 139-63 to confirm aggregates meet meet ACI requirements.

The reviewed LRA Section 3.5.2.2.2.2.5 The staff reviewed 3.5.2.2.2.2.5 against criteria in SRP-LR against the criteria SRP-LR Section states that increase 3.5.2.2.2.2.5, which states increase in porosity and permeability, and loss of strength due to leaching of calcium hydroxide could occur in below-grade inaccessible below-grade inaccessible structures. SRP-LR states Groups 1-3, 5 and 7-9 structures.SRP-LR concrete areas of Groups states that the GALL :

Report Section 3.5.2.2.2.2.5 recommends further evaluation evaluation of this aging effecteffect for for inaccessible areas of these Groups inaccessible concrete was not constructed Groups of structures ifif concrete constructed in accordance recommendations in ACI 201.2R-77.

accordance with the recommendations The GALL Report Report states that an aging management management program is not necessary necessary for reinforced concrete is exposed to flowing water, if inaccessible areas, even ifif reinforced inaccessible if there there is documented evidence documented evidence that confirms the in-place concrete concrete was constructed constructed in in .

recommendations in ACI 201.2R-77.

accordance with the recommendations accordance reviewed the LRA. The staff noted that concrete structures are designed in .

The staff reviewed accordance with ACI 318-63 and constructed in accordance accordance accordance with ACI 301-66. The ,

Portland cement conforms to ASTM C-150, Type II, Portland Ii, modified for low heat of hydration.

Neither calcium chloride nor any admixtures Neither admixtures containing calcium chloride or other chlorides, sulfides, or nitrates were used.

The staff also noted that leaching of calcium hydroxide hydroxide from reinforced reinforced concrete concrete becomes significant only if the concrete is exposed exposed to flowing water; however, the TMI-1 TMI-1 concrete components below grade for Groups 1, 1, 3, 4,4, and 5 structures (structure Groups Groups 2, 7, 8, and 9 do not exist at TMI-1) exposed to flowing water.

TMI-1) are not exposed On the basis of its review, the staff agrees that increase increase in porosity and permeability due due hydroxide are not applicable aging effects for concrete elements to leaching of calcium hydroxide of Groups 1, 1, 3, 4, and 5 structures structures (structure Groups 2, 7, 8, and 9 do not not exist at TMI-1)

TMI-1) concrete components below grade are not exposed to flowing water.

because the concrete water.

3-408

managing the effect Therefore, managing Therefore, effect of increase increase in porosity and in porosity permeability, and loss of and permeability, of strength due strength due to to leaching leaching of calcium calcium hydroxide hydroxide areare not required for concrete not required concrete in inaccessible areas.

inaccessible areas.

Strength and Modulus Reduction of Strengqth Reduction Modulus of Concrete Concrete Structures Structures duedue to Elevated Temperature. The Elevated Temperature. The staff reviewed staff reviewed LRA Section 3.5.2.2.2.3 against Section 3.5.2.2.2.3 against the the criteria in SRP-LR SRP-LR Section 3.5.2.2.2.3.

applicant stated in The applicant LRA Section in LRA Section 3.5.2.2.2.3 concrete structures Group 1, 3-5 concrete 3.5.2.2.2.3 that Group structures are maintained below the 150 maintained 150 OF threshold for general of threshold general areas areas and underunder 200 OF local areas.

of for local SRP-LR Section 3.5.2.2.2.3 SRP-LR 3.5.2.2.2.3 states strength and states that reduction of strength and modulus of concrete concrete due to to elevated temperatures elevated temperatures could occur in in PWR and BWR Group Group 1-5 concrete structures. For any 1-5 concrete concrete elements concrete elements that exceed exceed specified specified temperature further evaluations temperature limits, further evaluations are recommended. SRP-LR recommended. Section 3.5.2.2.2.3 SRP-LR Section also states the GALL Report 3.5.2.2.2.3 also Report recommends recommends furtherfurther evaluation of a plant-specific evaluation plant-specific program safety-related and other program if any portion of the safety-related concrete other concrete structures exceeds specified structures specified temperature temperature limits, i.e., general general area temperature temperature greatergreater than than 66°C 66 °C (150 OF) and local area temperature (150 OF) greater than 93 0C temperature greater °C (200 OF).

OF).

The staff reviewed reviewed the LRALRA and found that no portion concrete structures in-scope concrete portion of the in-scope structures and concrete at TMI-1 concrete TMI-1 exceeds temperature limits, which are 150 specified temperature exceeds specified 150 of general area and

°F for general 200 ofOF for local area. Therefore, Therefore, this agingaging effect applicable to TMI-1.

effect is not applicable TMI-1.

basis of its review, the staff On the basis strength and modulus of concrete due staff finds that reduction of strength due to elevated elevated temperatures temperatures are applicable aging effects are not applicable because the conditions effects to TMI-1 because conditions necessary for the aging effects, elevated temperatures, do not exist. Therefore, necessary finds Therefore, the staff finds further evaluation is required.

that no further required.

Aging Management Inaccessible Areas for Group 6 Structures. The staff reviewed LRA Management of Inaccessible LRA Section 3.5.2.2.2.4 against against the criteria in SRP-LR Section 3.5.2.2.2.4.

Section 3.5.2.2.2.4 states that the GALL Report recommends further evaluation for SRP-LR Section inaccessible areas of certain inaccessible certain Group structure/aging effect Group 6 structure/aging combinations as identified effect combinations identified below, whether or not they are covered whether accordance with the GALL Report, Chapter inspections in accordance covered by inspections Chapter XI.S7, "Regulatory Guide 1.127, Inspection Inspection of Water-Control Water-Control Structures Associated Nuclear Associated with Nuclear Power Plants" or the FERC/US Army Corp of Engineers dam inspections and maintenance. maintenance.

The staff's review and evaluation evaluation of aging management inaccessible areas for Group 6 management of inaccessible structures are addressed as follows.

structures (1) 3.5.2.2.2.4.1 states that for inaccessible LRA Section 3.5.2.2.2.4.1 below-grade reinforced concrete inaccessible below-grade for Group 6 structures, a plant specific aging management program is not required to manage the aging effects of increase in porosity and permeability, cracking, loss of manage material scaling)/aggressive chemical attack; material (spalling, scaling)/aggressive attack; and cracking, loss of bond, and scaling)/corrosion of embedded steel because the environment material (spalling, scaling)/corrosion loss of material is not aggressive, which is confirmed by groundwater test results. A by the historical groundwater A below-grade concrete representative sample of below-grade representative if excavated inspected, if excavated concrete will be inspected, for any groundwater monitoring will be done as required by the Structures reason, and periodic groundwater Structures Monitoring Program.

Monitoring criteria in SRP-LR Section 3.5.2.2.2.4.1 against the criteria The staff reviewed LRA Section 3.5.2.2.2.4.1 3.5.2.2.2.4.1, which states that increase 3,5.2.2.2.4.1, increase in porosity and permeability, cracking, loss of 3-409

material (spalling, scaling)/aggressive scaling)/aggressive chemical attack; and cracking, loss of bond, and apd embedded steel could occur scaling)/corrosion of embedded loss of material (spalling, scaling)/corrosion occur in below-grade below-grade inaccessible inaccessible concrete areas areas of Group Group 6 structures.

structures. The GALL Report Report recommends recommends further evaluation evaluation of plants-specific programsprograms to manage these aging aging effects in inaccessible inaccessible areas if if the environment is aggressive.

The staff has reviewed reviewed the LRA including the AMR AMR and associated AMP. The staff The staff confirmed that the containment containment concrete concrete structures are designed accordance with ACl designed in accordance ACI

~18-63 318-63 and constructed in accordance accordance with ACI ACl 301-66. From inspection results, the the staff also validated that the groundwater chemistry at TMI-1 is not aggressive. The staff groundwater chemistry staff noted that the applicant's groundwater groundwater inspections inspections .are performed under are performed under the applica~t's applicant's Monitoring Program. The staff's review of the Structures Monitoring Program Structures Monitoring including periodic monitoring of groundwater documented in SER Section 3.0.3.2.21.

groundwater is documented 3.0.3.2.21.

On the basis of its review, the staff finds that the IncreaseIncrease in porosity and permeability, cracking, loss of material cracking, scaling)/aggressive chemical attack; and cracking, material (spalling, scaling)/aggressive cracking, loss of bond, and loss of material material (spalling, scaling)/corrosion embedded steel could scaling)/corrosion of embedded could occur in below-grade occur below-grade inaccessible inaccessible concrete areas of Group 6 structures are not plausible concrete areas plausible aging effects because (1) the inspections of groundwater aging groundwater and raw water chemistries chemistries confirm that the environment confirm is not aggressive; (2) the inspection frequency of inspection frequency groundwater chemistries groundwater required by the Structures Monitoring Program agrees chemistries as required agrees ~ith with recommendation of the GALL Report; the recommendation committed to perform Report; and (3) the applicant committed examinations of exposed examinations concrete for age-related exposed concrete age-related degradation below-grade degradation when a below-grade.

concrete component becomes accessible concrete excavation, therefore, the staff finds accessible through excavation, fi'lds that no further evaluation evaluation is required. .

Based on a review of the programs identified above, the staff concluded that the the applicant applicant has met the criteria of SRP-LR SRP-LR Section 3.5.2.2.2.4.1.

3.5.2.2.2.4.1. For those line items that items that determined that the that the LRA is 3.5.2.2.2.4.1 the staff determined apply to LRA Section 3.5.2.2.2.4.1 consistent with the GALL consistent Report and the applicant GALL Report demonstrated that the effects applicant has demonstrated effects of aging will be adequately managed so that the intended functions will be maintained adequately managed maintained I'i consistent with the CLB during the period consistent extended operation, as required period of extended required by 10 CFR 54.21 (a)(3).

54.21(a)(3).

(2) located in an area in which weathering TMI-1 is located considered severe. For weathering conditions are considered below-grade below-grade inaccessible concrete inaccessible concrete areas for Structure Group 6, the applicant applicant stated in in LRA Section 3.5.2.2.2.4.2 Section 3.5.2.2.2.4.2 that the loss of material (scaling, cracking, cracking, and spalling) due due freeze-thaw is not significant and requires no aging management to freeze-thaw management becausebecause concrete concrete TMI-1 were designed, constructed, and inspected structures at TMI-1 structures accordance with inspected in accordance with standards, which provide for a good quality, dense, well applicable ACI and ASTM standards, cured, and low permeability concrete. The TMI-1 concrete addressed concrete mix design addressed damage potential by using entrained air and aggregate freeze-thaw damage freeze-thaw aggregate soundness soundness for applicant committed to inspect thawing. However, the applicant structures subject to freezing and thawing.

inaccessible concrete ifif exposed for any reason, inaccessible as in accordance Structures accordance with the Structures Monitoring Program.

Program.

3.5.2.2.2.4.2 against the criteria The staff reviewed LRA Section 3.5.2.2.2.4.2 SRP-LR Section criteria in SRP-LR 3.5.2.2.2.4.2, which states that loss of material (spalling, scaling) cracking due to scaling) and cracking to freeze-thaw could occur freeze-thaw occur in below-grade inaccessible concrete areas below-grade inaccessible areas of Group 6 structures. The GALL Report recommends further evaluation of this aging effect for, for inaccessible areas for plants located in moderate inaccessible moderate to severe weathering weathering conditions.

3-410 3-410

The staff noted that the applicant's Structures Structures Monitoring Monitoring Program, which requires requires periodic periodic visual inspection, will be used to managemanage loss of material material (spalling, scaling) and cracking due to freeze-thaw in accessible water-control structures accessible areas of water-control structures (Group 6 structures.) The staff structures.) staff also noted that the Structures Monitoring Monitoring Program will include include examination examination of exposed concrete concrete for age-related degradation when age-related degradation below-grade when* a below-grade concrete component becomes accessible concrete component accessible during excavation.

excavation. In NUREG-161 NUREG-1611, staff 1, the staff notes that any freeze-thaw freeze-thaw degradation degradation would initially initially appear in the exposed concrete concrete structure.

The staff further found the concrete concrete mix design addressed addressed freeze-thaw damage damage potential by using sufficient sufficient air content content for structures subject to freezing and thawing. The staff staff noted that the air content of containment containment concrete varied from 2.5% to 8%, which exceeds the GALL recommendation of 3%

GALL recommendation 3% to 6%. However, according to ACl However, according 201.2R ACI 201.2R "Guide to Durable Concrete," for concrete concrete exposed exposed to freezing and thawing, air content of 3.5 to 7.5 is recommended.

recommended. In addition, tolerance on air content 1.5% is allowed.

content of 1.5%

Therefore, Therefore, the staff found that the TMI-1 concrete is consistent consistent with the air contents contents recommendation of ACl recommendation ACI 201.2R-77 for concrete resistant to freezing and thawing. thawing.

On the basis of its review, the staff agrees that loss of material material (scaling, cracking, cracking, and spalling) due to freeze-thaw freeze-thaw is not a significant significant aging effect for below-grade below-grade inaccessible inaccessible concrete areas of Group 6 structures structures because the absence absence of significant aging effects is confirmed from the operating experience experience under under the existing Structures Monitoring Monitoring Program. The staff also finds the applicant's evaluation acceptable acceptable because because (1) the the TMI-1 concrete mix design addressed freeze-thaw damage freeze-thaw damage potential by using entrained air and aggregate soundness structures subject soundness for structures subject to freezing freezing and thawing in in accordance with applicable accordance ACl and ASTM standards applicable ACI standards and meets the intent of ACI moderate to severe 201.2R-77 for moderate recommended in the GALL severe exposure as recommended GALL Report; (2)

Structures Monitoring Program will include the Structures include examination examination of the accessible accessible concrete concrete age-related degradation; structures for age-related degradation; and (3) the applicant applicant will examine examine thethe inaccessible areas during any future excavations in accordance inaccessible accordance with the provisions provisions of the applicant's Structures Monitoring applicant's Structures Monitoring Program. .

Based on a review of the programs programs identified identified above, the staff concluded that the the applicant met the criteria of SRP-LR applicant has metthe Section 3.5.2.2.2.4.2. For those line items that SRP-LR Section apply to LRA Section 3.5.2.2.2.4.2, the staff determined that the LRA is consistent with the GALL Report Report and the applicant demonstrated that the effects of aging will be applicant has demonstrated be adequately adequately managed managed so that the intended functions will be maintained maintained consistent with with the CLB during the period of extended extended operation, operation, as required required by 10 CFR 54.21(a)(3).

(3) In LRA Section 3.5.2.2.2.4.3, the applicant stated that the Structures In Structures Monitoring Monitoring Program will be used to manage manage cracking cracking due due to expansion expansion and reaction with aggregate, and increase in porosity and permeability, and loss of strength increase strength due leaching of calcium due to leaching hydroxide of reinforced hydroxide reinforced concrete in accessible areas areas of water-control water-control. structures structures (Group 6 structures). The applicant applicant evaluated these aging effects, stating that they are not not below-grade inaccessible significant in below-grade inaccessible reinforced reinforced concrete concrete areas of Group 6 structuresstructures and requires no aging management management because (1) the concrete concrete is designed and constructed to meet ACI and ASTM Standards Standards and meets the intent intent of ACI 201.2R, and aggregates were tested in accordance (2) the aggregates accordance with ASTM Specifications Specifications C 29-60, .

C 40-66, C 127-59, C 128-59, and C 139-63 to confirm that the aggregates aggregates meet ACI requirements. However, However, the applicant has committed to inspect the inaccessible inaccessible 3-411 3-411

concrete structures for cracking and increase in porosity permeability ifif excavated porosity and permeability for any reason, in accordance with the Structures Monitoring in accordance Monitoring Program.

Program.

3.5.2.2.2.4.3 against the criteria in The staff reviewed LRA Section 3.5.2.2.2.4.3 in SRP-LR Section 3.5.2.2.2.4.3, which states that cracking due to expansion expansion and reaction with aggregates aggregates and increase increase inin porosity and permeability, and loss of strength due to leaching of calcium hydroxide hydroxide could occur in in below-grade inaccessible reinforced below-grade inaccessible reinforced concrete concrete areas of Group 6 structures. The GALL Report recommends recommends further evaluation of inaccessibl¢ inaccessible areas areas if constructed in if concrete was not constructed accordance with the recommendations in accordance recommendations in in ACl 201.2R-77.

ACI201.2R-77.

reviewed the LRA including the AMR and the associated The staff reviewed Structure ,

associated AMP Structure Monitoring Program. In NUREG-161 In NUREG-1611, 1, the staff notes that reaction with aggregates aggregates in in inaccessible areas would also occur in inaccessible in accessible areas because the same aggregates aggregates were used in in construction of both accessible and inaccessible inaccessible areas. The existing existing Structure Monitoring Program requires Structure Monitoring examination of accessible concrete requires periodic examination concrete surfaces and inspection surfaces inspection of inaccessible areas for cracking if concrete areas inaccessible concrete excavated for any if excavated reason.

On the basis of its review, the staff agrees cracking due to expansion agrees that cracking expansion and reaction with aggregate aggregate is not a significant aging effect for in below-grade inaccessible reinforced in below-grade inaccessible concrete areas of Group 6 structures because concrete because the absenceabsence of the significant aging i confirmed from the operating experience effects is confirmed experience under under the existing Structure Monitoring Program. The staff also finds that the applicant's Monitoring acceptable applicant's evaluation acceptable aggregates were tested in because (1) the aggregates because accordance with ASTM in accordance ASTM Specifications, and Program includes periodic Monitoring Program (2) the Structures Monitoring periodic examination of accessible accessible '

concrete surfaces, and (3) examination of the exposed concrete concrete concrete areas when a concrete component becomes below-grade concrete below-grade accessible through excavation.

becomes accessible excavation.

The GALL Report states that that an aging management management program is not necessary necessary for for inaccessible areas, even if inaccessible reinforced concrete if reinforced exposed to flowing water, if concrete is exposed if there is evidence that confirms the in-place documented evidence documented in-place concrete was constructed in in accordance with the recommendations accordance ACl 201.2R-77. The staff noted that the TMI-1 recommendations in ACI201.2R-77.

concrete structures are designed in accordance with ACl in accordance constructed in ACI 318-63 and constructed in accordance with ACI 301-66.

accordance 301-66.The Portland cement The Portland cement conforms to ASTM C-150, Type II, II, modified for low heat of hydration.

hydration. Neither calcium calcium chloride nor any admixtures admixtures i containing calcium chloride or other chlorides, sulfides, or nitrates were used. The staff staff also noted from the AMR results in LRA Tables 3.5.2-6 "Dike/Flood Control System" and 3.5.2-8 "Intake Screen and Pump House" that the below-grade inaccessible reinforced below-grade inaccessible areas of Group 6 structures are not exposed to flowing water.

concrete areas On the basis of its review, the staff agrees increase in agrees that increase porosity and permeability due in porosity due leaching of calcium hydroxide is not a significant to leaching significant aging effect effect for below-grade below-grade inaccessible reinforced concrete areas of Group inaccessible reinforced Group 6 structures because the concrete structures because concrete components components below grade are not exposed to flowing water. Therefore, managing the Therefore, managing effect of increase increase inin porosity and permeability, and loss of strength due to leaching of hydroxide are not required for concrete in calcium hydroxide in inaccessible inaccessible areas.

Based on aa review of the programs identified above, the staff concluded concluded that the applicant has has 3.5.2.2.2.4.3. For those line items met the criteria of SRP-LR Section 3.5.2.2.2.4.3. items that apply to LRA Section determined that the LRA is consistent 3.5.2.2.2.4.3 the staff determined consistent with the GALL Report and the GALL Report the 3-412 3-412

demonstrated that the effects of aging will be adequately managed applicant has demonstrated managed so that the the intended functions intended functions will be maintained consistent with the CLB during the period of extended maintained consistent operation, as required by 10 CFR 54.21 (a)(3).

Cracking due to Stress Corrosion Cracking Cracking Cracking and Loss of Material Material due to Pitting Crevice Pitting and Crevice Corrosion. The staff reviewed LRA Section Section 3.5.2.2.2.5 3.5.2.2.2.5 using the review procedures procedures of SRP-LRSRP-LR Section 3.5.3.2.2.5.

In LRA Section Section 3.5.2.2.2.5, 3.5.2.2.2.5; the applicant applicant stated that itit does not have Group 7 and 8 stainless stainless steel tank liners.

SRP-LR Section 3.5.2.2.2.5 3.5.2.2.2.5 states that cracking due to stress corrosion cracking and loss of material due to pitting and crevicecrevice corrosion could occur for Group 7 and 8 stainless steel tank liners exposed exposed to standing water. The GALL Report Report recommends recommends further evaluation evaluation of plant-specific programs plant-specific programs to manage these aging effects.

The staffs review of the LRA indicated indicated that TMI-1 TM I-1 does not have Group 7 and 8 stainless steel tank liners. Therefore, this AMR AMR is not applicable to TMI-1.

TMI-1.

On the basis of its review, the staff finds that cracking due to stress corrosion corrosion cracking and loss loss of material material due to pitting and crevice corrosion crevice corrosion that could occur for Group 7 and 8 stainless steel stainless steel tank liners exposed to standing standing water are not applicable since there there are no Group 7 and 8 stainless steel tank liners at TMI-1.TMI-1.

Aging Aging of Supports Not Covered by Structures Monitoring Program. The staff reviewed Structures Monitoring reviewed LRA LRA Section 3.5.2.2.2.6 procedures of SRP-LR Section 3.5.3.2.2.6.

3.5.2.2.2.6 using the review procedures 3.5.3.2.2.6.

3.5.1-39, 3.5.1-40 and 3.5.1-41 of LRA Table 3.5.1, In Items 3.5.1-39,3.5.1-40 3.5.1, the applicant applicant stated that the the Structures Monitoring Program Structures Monitoring Program is used to manage manage (1) loss of material material due to general and pitting pitting corrosion for support members; support members; welds; bolted connections; support anchorage anchorage to building building structure, (2)(2) reduction reduction in concrete anchor capacity due to local concrete anchor local concrete concrete degradation/service-induced cracking degradation/service-induced cracking or other concrete aging mechanisms mechanisms in building concrete concrete at locations locations of expansion expansion and grouted anchors; grout grout pads for support base plates, and and (3) reduction or loss of isolation function/radiation function/radiation hardening, hardening, temperature, humidity, sustained vibratory vibratory loading for vibration vibration isolation elements. Therefore, the applicant provided provided no further further evaluation.

SRP-LR Section 3.5.2.2.2.6 states that the GALL Report Section 3.5.2.2.2.6 Report recommends evaluation of recommends further evaluation certain component support/aging certain component combinations ifif they are not covered by the structures support/aging effect combinations structures monitoring program. includes (1) loss of material program. This includes material due due to general and pitting corrosion, corrosion, for Groups Groups B2-B5 supports; (2) reduction in concrete (2) reduction concrete anchor capacity due to degradation degradation of the the surrounding surrounding concrete, for Groups B1-B5 supports; and (3) reductionlloss reduction/loss of isolation function function degradation of vibration isolation elements, for Group B4 supports. Further due to degradation Further evaluation evaluation is necessary necessary only for structure/aging structure/aging effect combinations not covered by the structures monitoring structures monitoring program.

The staff has reviewed reviewed the LRA. The staff confirmed that the component support/aging effect combinations of (1) loss of material due to general and pitting corrosion, for Groups B2-B5 B2-B5 supports; (2)(2) reduction reduction in concrete anchor capacity due to degradation of the surrounding concrete anchor surrounding concrete, for Groups Groups B1-B5 supports; reduction/loss of isolation function due to supports; and (3) reductionlloss degradation degradation of vibration vibration isolation elements, for Group Group B4 supports; are all covered by the the 3-413 3-413

Structures Monitoring Structures Monitoring Program. Therefore, the staff determined determined that no further evaluation evaluation is required.

required.

Based on a review of the programs programs identified above, the staff concluded concluded that the applicant applicant hashas met the criteria of SRP-LR SRP-LR Section 3.5.2.2.2.6. For those line items that apply apply to LRA Section 3.5.2.2.2.6 the staff determined 3.5.2.2.2.6 determined that the LRA is consistent consistent with the GALL Report and the GALL Report the .

applicant has demonstrated demonstrated that the effects of aging will be adequately managed so that the adequately managed the intended functions will be maintained intended maintained consistent consistent with the CLB during the period of extended extended operation, as required by 10 10 CFR 54.21(a)(3).

54.21 (a)(3).

Cumulative Fatigue Damage due to Cyclic Loading. The staff reviewed LRA Section 3.5.2.2.2.7 3.5.2.2.2.7 using the review procedures procedures of SRP-LR Section 3.5.3.2.2.7.

In LRA LRA Section 3.5.2.2.2.7, the applicant stated that TMI-1TMI-1 current licensing licensing basis contains no no fatigue analysis for component component supports supports members, anchor bolts, and welds of Groups B1.1,ý Groups B1.1, B1.2, and B1.3 component component supports.

SRP-LR SRP-LR Section 3.5.2.2.2.7 3.5.2.2.2.7 states that fatigue of component support members, anchor anchor bolts, and welds for Groups Groups B1.1, B1.1, B1.2, and B1.3 component component supports is a TLAA as defined defined inin 10 CFR 54.3 only if a CLB fatigue analysis exists. TLAAs are required to be evaluated in in accordance accordance with 10 10 CFR 54.21(c).

The staff has reviewed reviewed the LRA Section 3.5.2.2.2.7. The staff noted that no fatigue analyses analyses were identified identified as TLAAs because there is no CLB fatigue analysis analysis for component component support members, anchor anchor bolts, and welds for Groups B1.1,B1.1, B1.2, and B1.3. Therefore, cumulative Therefore, cumulative.

fatigue damage damage due to cyclic loading for Groups B1.1, B1.1, B1.2, and B1.3 component component supports is not a TLAA TLAA as defined defined in 10 CFR 54.3.

3.5.2.2.3 Quality Assurance for Aging Management Management of Nonsafety-Related Nonsafety-Related Components Components SER Section 3.0.4 provides the staff's evaluation evaluation of the applicant's applicant's QA program.

3.5.2.3 AMR AMR Results That That Are Not Consistent Consistentwith or or Not Addressed Addressed in the GALL GALL Report In LRA Tables 3.5.2-1 through 3.5.2-20, the staff reviewed additional details details of AMR results for material, environment, environment, AERM, AERM, and AMP combinations combinations not consistent with or not addressed addressed.in in the GALL GALL Report.

In LRA Tables Tables 3.5.2-1 through 3.5.2-20, the applicant indicated, indicated, via Notes F through J, that the the combination of component type, material, material, environment, and AERM AERM does not correspond to a line item in the GALL Report. The applicant provided further information information concerning concerning how the the aging effects will be managed. Specifically, NoteNote F indicates indicates that the material material for the AMR liheline item component component is not evaluated in the GALL Report. Note G indicates indicates that the environment for the AMR AMR line item component and material evaluated in the GALL material is not evaluated GALL Report. NoteNote H

. indicates indicates that the aging effect for the AMR AMR line item component, material, and environment environment combination evaluated in the GALL Report. Note I indicates combination is not evaluated indicates that the aging effect identified identified in the GALL Report for the line item component, material, and environment combination environment combination is not applicable. Note J indicates indicates that neither the component component nor the material material and environment environment combination for the line item is evaluated in the GALL Report.

combination 3-414 3-414

For component type, material, material, and environment combinations not evaluated environment combinations evaluated in the GALL Report, the staff staff reviewed the applicant's applicant's evaluation determine whether the applicant had evaluation to determine had

. demonstrated demonstrated that the aging aging effects effects will be adequately managed intended function(s) managed so that the intended will be maintained consistent with the CLB during the period period of extended staffs extended operation. The staffs discussed in the following sections.

evaluation is discussed Structures and Component Supports - Air Intake 3.5.2.3.1 Structures Intake Structure - Summary of Aging Management Evaluation Management Evaluation - LRA Table 3.5.2-1 The ~taff staff reviewed LRA Table 3.5.2-1, summarizes the results of AMR which summarizes 3.5.2-1, which AMR evaluations the evaluations for the air intake component groups.

intake structures component In LRA Table 3.5.2-1, applicant identified 65 unique component/material/environment/aging 3.5.2-1, the applicant componentlmaterial/environmentlaging groups for the Air Intake Structures. Forty three have AMR results consistent with effectlAMP groups effect/AMP GALL, as identified by reference reference to Notes A through E. The staff confirmed that the references references to LRA Table 1 and the GALL GALL Report Volume IIII line items are appropriate.

appropriate.

applicant proposed to manage reinforced For ten component types, the applicant concrete material, aging reinforced concrete permeability, loss of strength/leaching porosity and permeability, effect increase in porosity hydroxide, and strength/leaching of calcium hydroxide, cracking, material by using the Structures Monitoring Program. The cracking, loss of bond, and loss of material The staff's review of the Structures Monitoring Program documented in SER Section Program is documented 3.0.3.2.21.

Section 3.0.3.2.21.

These line items reference Note G. The staff finds that the credited AMP is appropriate, appropriate, because the Structures because Structures Monitoring inspections on a periodic basis to requires visual inspections Monitoring Program requires strength/leaching of calcium hydroxide in each case. Since manage loss of strength/leaching manage Since the applicant has has committed committed to an appropriate management program for the period of extended appropriate aging management extended operation, operation, the staff finds these AMR results to be acceptable.

component types, the applicant proposed to manage reinforced For six component reinforced concrete material, aging concrete material, aging effect loss of material material (spalling, scaling) cracking/freeze-thaw, by using scaling) and cracking/freeze-thaw, using the Structures Structures Monitoring Program. The staffs Monitoring staffs review of the Structures Monitoring Program Structures Monitoring documented in Program is documented Note 2, states plant-specific Note 3.0.3.2.21. These line items reference Note H and plant-specific SER Section 3.0.3.2.21. states effects/mechanisms of exterior "the aging effects/mechanisms "the exterior below concrete in a groundwater/soil below grade concrete groundwater/soil material (spalling/scaling) environment include loss of material cracking due to freeze-thaw. These (spalling/scaling) and cracking These managed by the Structures effects/mechanisms are managed

. aging effects/mechanisms Structures Monitoring Program. The Structures Monitoring Program. Structures Monitoring Program is appropriate Monitoring (spalling/scaling) and appropriate in this situation since loss of material (spalling/scaling) grade concrete above the frost freeze-thaw is still present for exterior below grade cracking due to freeze-thaw credited AMP is appropriate, because line." The staff finds that the credited Structures Monitoring because the Structures Monitoring inspections on a periodic basis to manage Program requires visual inspections Program material and cracking manage loss of material applicant has committed to an appropriate due to freeze-thaw. Since the applica[1t management appropriate aging management program for extended operation, the staff finds these AMR the period of extended forthe AMR results to be be acceptable.

acceptable.

management program to manage applicant proposed no aging management component types, the applicant For six component manage GALL (reinforced concrete material, II1.A3-5 (reinforced concrete material, GALL Item III.A3-5 item 3.5.1-31), aging effect none. These line These line plant-specific Note 1, which reference Note II and plant-specific items reference applicable which states "the aging effect is not applicable because the environment because disagrees with the applicant's environment is not aggressive." The staff disagrees AMR applicant's AMR conclusion that there are no aging effects requiring management extended management for the period of extended operation for these groups. However, the staff finds the applicant has enhanced enhanced the Structures Structures (Commitment # 28) to perform Monitoring Program (Commitment Monitoring groundwater sampling for perform groundwater non-aggressiveness once every five years. Since the applicant has committed non-aggressiveness committed to perform 3-415 3-415

groundwater groundwater sampling sampling in an appropriate appropriate aging aging management management program program for the the period period of extended extended operation, operation, the staff findsfinds these AMR results to be acceptable. acceptable.

On On the basis basis of its review, the the staff finds that that the applicant applicant has has appropriately appropriately evaluated evaluated the AMR AMR results of material, environment, environment, AERM, AERM, and and AMP combinations combinations for the Air Intake Intake Structures Structures not not evaluated evaluated in in the the GALL GALL Report. The The staff finds finds that thethe applicant applicant has demonstrated demonstrated thatthat the the effects effects of aging aging will be be adequately adequately managed managed so that the intended intended function(s) function(s) will be maintained maintained consistent consistent with the CLB for the period period ofof extended extended operation, operation, as required required byby 10 10 CFR 54.21(a)(3).

3.5.2.3.2 3.5.2.3.2 Structures Structures and Component Component Supports - Auxiliary Building - Summary Summary of Aging Aging Management Evaluation - LRA Management Evaluation LRA Table 3.5.2-23.5.2-2 The The staff reviewed LRA Table staff reviewed Table 3.5.2-2, whichwhich summarizes summarizes the results of AMR AMR evaluations evaluations for the the auxiliary building component component groups.

In LRA In LRA Table Table 3.5.2-2, the applicant identified identified 113113 unique componentJmaterial/environmentJaging component/material/environment/aging effect/AMP effectJAMP groupsgroups for the Auxiliary Auxiliary Building. Ninety-eight Ninety-eight have AMR results consistent with with GALL, as identified reference to Notes A through E. The staff confirmed that the references identified by reference references to Table Table 11 and GALL Volume IIII line items itemsare are appropriate.

For six component For component types, the applicant applicant proposed proposed to manage reinforced concrete concrete material, aging effect loss of material (spalling, (spalling, scaling) and cracking/freeze-thaw, cracking/freeze-thaw, by using the Structures Structures .

Monitoring Monitoring Program. The staffs staffs review of the Structures Monitoring Program is documented Monitoring Program documented in in SER Section SER 3.0.3.2.21. These line items reference Section 3.0.3.2.21. reference Note H H and plant-specific plant-specific Note 3, whicQ which "the aging effects/mechanisms states lithe effects/mechanisms of exterior below grade concrete concrete in in a groundwater/soil (spalling/scaling) and cracking due to freeze-thaw. These environment include loss of material (spalling/scaling) These effects/mechanisms are managed aging effects/mechanisms managed by the StructuresStructures Monitoring Program. The Structyres Structures Monitoring Program Monitoring Program is appropriate in this situation since loss of material (spalling/scaling)

(spalling/scaling) ahd and cracking due to freeze-thaw freeze-thaw is still present present for exterior below grade concrete concrete above the frost line." The staff finds that the credited AMP is appropriate, line." Monitoring appropriate, because the Structures Monitoring Program requires visual inspections on a periodic periodic basis to manage manage loss of material (spalling/scaling) and (spalling/scaling) and cracking cracking due to freeze-thaw. Since Since the applicant applicant has committed to an appropriate aging management program for the period of extended operation, appropriate operation, the staff finds finds these AMR results to be acceptable.

For eight For eight component types, the applicant proposed proposed no aging management program to manage manage GALL Item III,A3-5 III.A3-5 (reinforced concrete material, item 3.5.1-31), aging effect none. These line line items reference Note II and plant-specific items plant-specific Note 1, 1, which states liThe "The aging effect is not applicable applicable environment is not aggressive." The staff disagrees because the environment disagrees with the applicant's AMR I applicant's AMR conclusion that there are no aging effects requiring management for the period of extended conclusion operation for these groups. However, the staff finds the applicant applicant has enhanced Structures enhanced the Structures Monitoring Monitoring Program (Commitment # 28) to perform groundwater sampling for non-aggressiveness once every 5 years. Since the applicant has committed to perform non-aggressiveness groundwater sampling in in an appropriate appropriate aging managementmanagement program for the period of extelT\dedextended operation, the staff finds these AMR results to be acceptable.

For one For one component component type, the applicant proposed to manage manage roofing material, material, aging effect loss of weatherproofing integrity due to cracking, organic decomposition, separation, shrinkage, wear, and wear, and weathering, weathering, by by using using the*

the'Structures Monitoring Program.

Structures Monitoring Program. The The staff's staff's review of the the Structures Monitoring Structures Monitoring Program is documented documented in in SER Section 3.0.3.2.21.

3.0.3.2.21. These line items items 3-416 3-416

reference reference NoteNote J. The The staff staff finds finds that the credited credited AMP is is appropriate, appropriate, because because thethe Structures Structures Monitoring Monitoring Program Program requires requires visual inspections inspections on on aa periodic periodic basis basis to manage manage loss loss of of weatherproofing weatherproofing integrity integrity due due to cracking, cracking, organic organic decomposition, decomposition, separation, separation, shrinkage, wear, and and weathering.

weathering. SinceSince the applicant applicant hashas committed committed to an appropriate appropriate aging aging management management program program for the period of extended operation, the period extended operation, the staff staff finds these AMR AMR results results to be*

be acceptable.

acceptable.

On the basis of its review, the staff finds that the applicant has has appropriately appropriately evaluated evaluated the AMRAMR results results of material, material, environment, environment, AERM,AERM, and AMP AMP combinations combinations for the Auxiliary Building Building not evaluated evaluated in the GALL GALL Report. The staff staff finds that that the applicant applicant has has demonstrated demonstrated thatthat the the effects of aging will be adequately adequately managed managed so that the the intended intended function(s) function(s) will be maintained maintained consistent with with the CLB for the the period of extended extended operation, operation, as required required byby 10 CFR 54.21(a)(3).

54.21(a)(3). .

3.5.2.3.3 Structures 3.5.2.3.3 Structures and Component Component Supports Supports - Circulating Circulating Water Water Pump House - Summary Summary of Aging Management Management Evaluation Evaluation - LRA Table Table 3.5.2-3 3.5.2-3 The staff reviewed reviewed LRA LRA Table 3.5.2-3, which summarizessummarizes the results of AMR evaluations evaluations for the the circulating circulating water pump house house component component groups.

In LRA Table Table 3.5.2-3, the applicant applicant identified identified 7171 unique component/material/environment/aging componentlmaterial/environmentlaging effect/AMP effectiAMP groups for the Circulating Circulating Water Pump House.

House. Fifty-six have have AMR results consistent consistent with GALL, as identified identified by reference reference to Notes Notes A through E. The staff confirmed confirmed that thethe references to Table 1 and GALL Volume references Volume II II line line items are appropriate.

For six component types, the applicant proposed proposed to manage reinforced concrete concrete material, material, aging aging effect increase in porosity effect increase porosity and permeability, loss of strength/leaching hydroxid~,. by strengthlleaching of calcium hydroxide, using the Structures Monitoring Program. The staffs review of the Structures staffs review Monitoring Structures Monitoring Program is documented documented in SER Section Section 3;0.3.2.21.

3.0.3.2.21. These line items reference Note G. The G.The staff finds that the credited AMP is appropriate, appropriate; because the Structures Monitoring Program Structures Monitoring Program inspections on a periodic requires visual inspections periodic basis to manage manage loss of strengthlleaching strength/leaching of calcium calcium hydroxide. Since the applicant has committed committed to an appropriate appropriate aging management management program-for program*for the period period of extended operation, the staff finds these AMR results to be acceptable.

For three component types, the applicant proposed to manage manage reinforced concrete material, reinforced concrete material, aging effect loss of material (spalling, scaling) scaling) and cracking/freeze-thaw, cracking/freeze-thaw, by using the Structures Structures Monitoring Monitoring Program. The staff's review of the Structures Monitoring Program is documented in in 3.0.3.2.21. These line items reference SER Section 3.0.3.2.21. reference Note H and plant-specific plant-specific Note 2, which "the aging effects/mechanisms states "the effects/mechanisms of exterior below grade concrete in a groundwater/soil environment include loss of material material (spalling/scaling)

(spalling/scaling) and cracking due to freeze-thaw. These effects/mechanisms are managed by the Structures Monitoring Program. The Structures aging effects/mechanisms Structures Monitoring Program is appropriate appropriate in this situation since loss of material (spalling/scaling)

(spalling/scaling) and cracking cracking due to freeze-thaw freeze-thaw is still present for exterior below grade concrete concrete above the frost line." The line."The staff finds that the credited AMP is appropriate, because because the Structures Monitoring Monitoring Program requires visual inspections on a periodic basis to manage loss of material Program (spalling/scaling) and cracking due to freeze-thaw. Since the applicant has committed to an (spalling/scaling) appropriate aging management appropriate management program for the period period of extended operation, the staff finds finds these AMR results to be acceptable.

For two component types, the applicant proposed to manage manage reinforced concrete material, scaling)/corrosion of aging effect cracking, loss of bond and loss of material (spalling, scaling)/corrosion .

3-417 3-417

embedded steel, by using the Structures Structures Monitoring Program. staffs review of the Program. The staff's the Structures Monitoring Program is documented Program documented in in SER Section 3.0.3.2.21.

3.0.3.2.21. These line items items reference Note H and plant-specific plant-specific Note 3, which states "The aging effects/mechanisms effects/mechanisms of above grade exterior exterior concrete concrete in in a water-flowing environment include water-flowing environment include cracking, loss of bond and loss of material material (spalling, scaling)/corrosion scaling)/corrosion of embedded steel. These aging aging effects/mechanisms managed by the Structures effects/mechanisms are managed Monitoring Program." The staff finds that Structures Monitoring the credited AMP is appropriate appropriate because Monitoring Program requires visual because the Structures Monitoring inspections on a periodic basis to manage cracking, loss of bond and loss of material material due to corrosion of embedded embedded steel. Since the applicant applicant has committed to an appropriate appropriate aging .

management management program for the period period of extended operation, the staff finds these AMR results to be acceptable.

For three component component types, the applicant applicant proposes no aging management management program to manage manage GALL Item III.A3-5 (reinforced concrete III.A3-5 (reinforced concrete material, material, item 3.5.1-31), aging effect none. These line line reference Note items reference Note I and plant-specific plant-specific Note Note 1, which states "The "The aging effect is not appliqable applicable because the environment because environment is not aggressive." The staff disagrees disagrees with the applicant's AMR AMR '

conclusion that there are no aging effects requiring management management for the period of extended operation for these groups. However, the staff finds the applicant operation enhanced the Structures applicant has enhanced Structures Monitoring Program (Commitment Monitoring Program (Commitment # 28) to perform groundwater groundwater sampling for for non-aggressiveness once every five years. Since the applicant has committed to perform non-aggressiveness groundwater sampling in groundwater in an appropriate appropriate aging management management program for the period of extended extended operation, operation, the staff finds these AMR results to be acceptable.

For one component type, the applicant applicant proposed to manage manage roofing material, material, aging effect loss of weatherproofing weatherproofing integrity due to cracking, cracking, organic organic decomposition, separation, shrinkage, wear, and weathering, by using the StructuresStructures Monitoring Monitoring Program. The staff's review of the the Structures Monitoring Program Structures Monitoring Program is documented documented in in SER Section 3.0.3.2.21.

3.0.3.2.21. These line items items reference Note Note J. The staff finds that the credited AMP is appropriate, appropriate, because because the Structur~s Structures Monitoring Program Program requires visual inspections inspections on a periodic basis to manage loss of periodic basis weatherproofing integrity due to cracking, organic decomposition, weatherproofing decomposition, separation, shrinkage, wear, and weathering.

weathering. Since the applicant applicant has committed to an appropriate management appropriate aging management program for the period of extended operation, the staff finds these AMR results to be be acceptable.

acceptable.

On the basis of its review, the staff finds that the applicant has appropriately appropriately evaluated evaluated the AMR AMR results of material, material, environment, AERM,AERM, and AMP combinations combinations for the Circulating Pump Circulating Water P'Ump House not evaluated evaluated in in the GALL Report. The staff finds that the applicant has demonstrated demonstrated that the effects of aging will be adequately adequately managed so that the intended function(s) will be be maintained maintained consistent with the CLB for the period of extended operation, operation, as required by by 10 CFR 54.21(a)(3).

3.5,2.3.4 Structures 3.5.2.3.4 Structures and Component Supports - Control Building - Summary Summary of Aging Aging Management Evaluation Management Evaluation - LRA Table 3.5.2-4

-

The staff reviewed LRA Table 3.5.2-4, which which summarizes summarizes the results of AMR evaluations evaluations for the the control building component groups.

In LRA Table 3.5.2-4, the applicant In applicant identified identified 75 unique component/material/environment/aging componenUmaterial/environmenUaging effect/AMP groups for the Control Building. Fifty-nine effecUAMP Fifty-nine have have AMR results consistent with GALL, as identified by reference to Notes A through E. The The staff confirmed that the references references to .

Table 1 and GALL GALL Volume IIII line items are appropriate.

3-418 3-418

six component For six component types, the applicant applicant proposed reinforced concrete manage reinforced proposed to manage material, aging concrete material, aging effect loss of material (spalling, scaling) effect loss material (spalling, scaling) and and cracking/freeze-thaw, cracking/freeze-thaw, by by using using the the Structures Structures Monitoring Program. The Monitoring Program. The staffs staff's review review of the Structures of the Structures Monitoring Program is Monitoring Program is documented documented in 3.0.3.2.21. These Section 3.0.3.2.21.

SER Section SER These line items reference Note items reference Note H and plant-specific Note 3, which and plant-specific states "the aging effects/mechanisms states effects/mechanisms of exterior grade concrete exterior below grade concrete inin a groundwater/soil environment include environment include loss of material material (spalling/scaling) and cracking (spalling/scaling) and due to freeze-thaw. These cracking due These aging effects/mechanisms aging effects/mechanisms are are managed managed by by the Structures Program. The Monitoring Program.

Structures Monitoring The Structures Structures Monitoring Program Monitoring appropriate in Program is appropriate in this situation since loss situation since loss of material (spalling/scaling) and material (spalling/scaling) cracking due to freeze-thaw cracking freeze-thaw is still present is still present for exterior below grade for exterior grade concrete above the frost concrete above frost the credited line." The staff finds that the credited AMP is appropriate, because the Structures appropriate, because Monitoring Structures Monitoring Program requires visual Program inspections on a periodic visual inspections basis to manage loss periodic basis loss of material (spalling/scaling) and (spalling/scaling) cracking due and cracking due to freeze-thaw. applicant has freeze-thaw. Since the applicant has committed committed to to an an management program for the period appropriate aging management appropriate period of extended operation, of extended the staff finds operation, the finds these AMR results to be acceptable.

acceptable.

component types, the applicant For nine component applicant proposed management program proposed no aging management program to manage manage GALL It~m II1.A1-5 (reinforced concrete Item III.A1-5 (reinforced concrete material,material, item 3.5.1-31), aging effect none. These line line items reference plant-specific Note 1, which states reference Note I and plant-specific states "The aging effect is not applicable applicable because the environment because disagrees with the applicant's aggressive." The staff disagrees environment is not aggressive." applicant's AMRAMR conclusion that there effects requiring there are no aging effects management for the period of extended requiring management groups. However, the operation for these groups.

operation the staff finds the applicant has enhanced enhanced the Structures Structures Monitoring (Commitment # 28)

Program (Commitment Monitoring Program 28) to perform groundwater sampling perform groundwater sampling forfor non-aggressiveness non-aggressiveness once once every five years. Since the applicant committed to perform applicant has committed groundwater groundwater sampling appropriate aging sampling in an appropriate management program for the period of extended aging management operation, the staff finds these AMR results to be acceptable.

operation, acceptable.

proposed to manage roofing material, aging effect loss applicant proposed For one component type, the applicant loss integrity due to cracking, organic decomposition, separation, shrinkage, weatherproofing integrity of weatherproofing wear, and weathering, by using the Structures Monitoring Monitoring Program. The staff's review review of thethe Structures Structures Monitoring Monitoring Program is documented 3.0.3.2.21. These documented in SER Section 3.0.3.2.21. items These line items reference Note J. The staff finds that the credited AMP is appropriate, reference Structures appropriate, because the Structures Monitoring requires Program requires Monitoring Program visual inspections on a periodic basis to manage manage loss of weatherproofing integrity due to cracking, organic decomposition, separation, shrinkage, wear, weatherproofing and weathering. Since the applicant has committed appropriate aging management .

committed to an appropriate program for the period of extended operation,operation, the staff finds these AMR results to be be acceptable.

acceptable.

On the basis of its review, the staff finds that the applicantapplicant has appropriately appropriately evaluated the AMR AMR results of material, environment, AERM, and AMP combinations for the Control Building not evaluated in the GALL Report. The staff finds that the applicant has demonstrated demonstrated that the the adequately managed so that the intended function(s) will be maintained effects of aging will be adequately maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 10 CFR 54.21(a)(3).

3.5.2.3.5 Structures and Component Supports - Diesel Generator Generator Building Building - Summary of Management Evaluation - LRA Table 3.5.2-5 Aging Management reviewed LRA Table 3.5.2-5, which summarizes The staff reviewed summarizes the results of AMR evaluations for the the diesel generator building component groups.

3-419 3-419

In lRA LRA Table 3.5.2-5, the applicant identifiedidentified 59 unique component/material/environment/aging component/material/environment/aging effect/AMP effect/AMP groups for the Diesel Generator Generator Building. Fifty-six have have AMR AMR results consistent consistent with GALL, as identified by reference reference to Notes A through E. The staff confirmed that the references references to Table 1 and GALL VolumeVolume IIII line items are appropriate.

For one component component type, the applicant proposed to manage manage reinforced reinforced concrete material, material, aging effect effect loss of material material (spalling, (spalling, scaling) and cracking/freeze-thaw, cracking/freeze-thaw, by using the Structures Structures .

Monitoring Program. The staffs staff's review of the Structures Monitoring Monitoring Program is documented documented in SER Section 3.0.3.2.21.

3.0.3.2.21. These line items reference reference Note H H and plant-specific Note Note 2, which which states "the aging effects/mechanisms effects/mechanisms of exterior exterior below below grade concrete groundwater/soil concrete in a groundwater/soil environment include loss of material (spalling/scaling) environment (spalling/scaling) and cracking due to freeze-thaw. These These aging effects/mechanisms effects/mechanisms are managed managed by the Structures Monitoring Program. The Structures Monitoring Program. Structures Monitoring Monitoring Program appropriate in this situation Program is appropriate situation since loss of material (spalling/scaling)

(spalling/scaling) andal7ld cracking due cracking due to freeze-thaw freeze-thaw is still present for exterior exterior below below grade concrete concrete above the frost line." The staff finds that the credited AMP is appropriate, because because the Structures Monitoring Structures Monitoring Program Program requires visual inspections inspections on a periodic periodic basis to manage manage loss of material (spalling/scaling) and cracking due to freeze-thaw. Since the applicant (spalling/scaling) applicant has committed to appropriate aging management appropriate management programs for the period of extended operation, operation, the staff finds finds acceptable.

these AMR results to be acceptable.

For one component component type, the applicant proposed proposed no aging management management program to manage manage GALL Item III.A3-5 II1.A3-5 (reinforced (reinforced concrete concrete material, item 3.5.1-31), aging effect aging effect none. These line line items reference reference Note I I and plant-specific plant-specific Note 1, which states "the aging effect applicable effect is not applicable because the environment environment is not aggressive." The staff disagrees with the applicant's AMR AMR conclusion conclusion that there are no aging effects management for the period of effects requiring management extendedli of extended:

operation operation for these groups. However, the staff finds the applicant has enhanced Structures enhanced the Structures Monitoring Program Program (Commitment (Commitment # 28) to perform groundwater groundwater sampling sampling forfor non-aggressiveness non-aggressiveness once every five years. Since the applicant applicant has committed committed to perform groundwater groundwater sampling in an appropriate appropriate aging management program management program for the period of extended operation, operation, the staff finds these AMR results to be acceptable.

For one component component type, the applicantapplicant proposed to manage roofing material, aging effect loss 1oss of weatherproofing weatherproofing integrity due to cracking, organic decomposition, separation, shrinkage, wear, and weathering, weathering, by using the StructuresStructures Monitoring Program. The staff's review of the the Structures Monitoring Structures Monitoring Program is documented documented in SER Section 3.0.3.2.21. These line items Section 3.0.3.2.21. items reference Note reference Note J. The staff finds that the credited AMP is appropriate, because because the Structures Structures Monitoring Monitoring Program requires requires visual inspections on a periodic basis to manage loss of weatherproofing integrity due to cracking, organic weatherproofing decomposition, separation, organic decomposition, separation, shrinkage, wear, and weathering. Since the applicant has committed committed to an appropriate appropriate aging management management program for the period of extendedextended operation, the staff finds these AMR results to be be acceptable.

On the basis of its review, the staff finds that the applicant has appropriately evaluated the AMR appropriately evaluated AMR results of material, environment, AERM, AERM, and AMP combinations for the Diesel Generator Generator Building not evaluated evaluated in the GALL GALL Report. The staff finds that the applicant has demonstrated demonstrated that the effects effects of aging will be adequately adequately managed managed so that the intended function(s) function(s) will be, be maintained maintained consistent consistent with the CLB for the period of extended extended operation, as required required byby 10 CFR 54.21(a)(3).

3-420 3-420

3.5.2.3.6 Structures 3.5.2.3.6 Component Supports - Dike/Flood Control Structures and Component Control System - Summary of Management Evaluation - LRA Table Aging Management Table 3.5.2-6 3.5.2-6 which summarizes the results of AMR evaluations for the 3.5.2-6, which The staff reviewed LRA Table 3.5.2-6, the dikelflood control system component dike/flood component groups.

In LRA Table component/material/environment/aging Table 3.5.2-6, the applicant identified 39 unique componentlmaterial/environmentlaging effectlAMP groups for the Dike/Flood Control System. Thirty-three have AMR results consistent effect/AMP GALL, as identified by reference to Notes A through E. The staff confirmed with GALL, confirmed that thethe appropriate.

references to Table 1 and GALL Volume IIII line items are appropriate.

references For two component applicant proposed to manage reinforced concrete component types, the applicant concrete material, material, aging effect loss of material material (spalling, scaling) and cracking/freeze-thaw, (spalling, scaling) cracking/freeze-thaw, by using the Structures Structures Monitoring Program.

Monitoring Program. The staff's staffs review of the Structures Monitoring Program is documented Monitoring Program documented in SER Section 3.0.3.2.21. These line items reference Section 3.0.3.2.21. plant-specific Note 3, which reference Note H and plant-specific states "the aging effects/mechanisms effects/mechanisms of exterior exterior below grade concrete in a groundwater/soil grade concrete environment include loss of material environment include material (spalling/scaling)

(spalling/scaling) and cracking cracking due to freeze-thaw. These effects/mechanisms are managed aging effects/mechanisms managed by the Structures Monitoring Program. The Structures Monitoring Program. Structures situation since loss of material appropriate in this situation Monitoring Program is appropriate Monitoring (spalling/scaling) and material (spalling/scaling) cracking due to freeze-thaw cracking present for exterior below grade concrete above the frost freeze-thaw is still present line." The staff finds that the credited AMP is appropriate, appropriate, because Structures Monitoring because the Structures Monitoring periodic basis to manage loss of material inspections on a periodic Program requires visual inspections (spalling/scaling) and cracking due to freeze-thaw. Since the applicant has committed (spalling/scaling) committed to an management program appropriate aging management appropriate extended operation, the staff finds program for the period of extended finds these AMR AMR results to be acceptable.

acceptable.

For two component proposed to manage reinforced concrete material, component types, the applicant proposed material, aging effect cracking, loss of bond and loss of material material (spalling, scaling}/corrosion scaling)/corrosion of embedded embedded steel, by using the Structures Monitoring staffs review Monitoring Program. The staff's review of the the Structures Monitoring Structures Program is documented Monitoring Program items 3.0.3.2.21. These line items documented in SER Section 3.0.3.2.21.

reference Note H and plant-specific effects/mechanisms of plant-specific Note 4, which states "the aging effects/mechanisms water-flowing environment above grade exterior concrete in a water-flowing include cracking, loss of bond environment include bond and and loss of material (spalling, scaling}/corrosion embedded steel. These aging scaling)/corrosion of embedded aging managed by the Structures effects/mechanisms are managed effects/mechanisms Monitoring Program." The staff finds that Structures Monitoring the credited AMP is appropriate, because because the Structures Monitoring Program requires visual inspections on a periodic inspections basis to manage loss of bond and* loss of material (spalling, scaling) and embedded steel. Since the applicant has committed to an appropriate due to corrosion of embedded appropriate aging management program for the period of extended management extended operation, the staff finds these AMR results to be acceptable.

component types, the applicant For two component proposed no aging management applicant proposed management program to manage manage GALL Item III.A6-3 concrete material, item 3.5.1-34), aging effect (reinforced concrete II1.A6-3 (reinforced effect none. These line These line plant-specific Note 2, which states "the aging effect items reference Note I and plant-specific applicable effect is not applicable environment is not aggressive."

because the environment because disagrees with the applicant's AMR aggressive." The staff disagrees AMR conclusion that there are no aging effects effects requiring management extended management for the period of extended operation for these groups. However, the staff finds the applicant operation applicant has enhanced the Structures Structures (Commitment # 28)

Program (Commitment Monitoring Program Monitoring groundwater sampling for

28) to perform groundwater non-aggressiveness once every five years. Since the applicant has committed non-aggressiveness committed to perform appropriate aging management groundwater sampling in an appropriate groundwater program for the period of extended management program operation, the staff finds these AMR results to be acceptable.

operation, 3-421

On the basis of its review, the staff finds that the applicant applicant has appropriately appropriately evaluated evaluated the AMR AMR results of material, environment, AERM, and AMP combinations Dike/Flood Control .

combinations for the Dike/Flood System not evaluated in the GALL Report. The staff finds that the applicant has demonstrated demonstrated that the effects of aging will be adequately adequately managed that the intended function(s) will be managed so thatthe be maintained consistent with the CLB for the period of extended operation, as required by maintained consistent 10 10 CFR 54.21(a)(3).

Component Supports 3.5.2.3.7 Structures and Component Supports- Handling Building - Summary

- Fuel Handling Summary of Aging Management Evaluation - LRA Management LRA Table 3.5.2-7 3.5.2-7 The staff reviewed LRA Table Table 3.5.2-7, which summarizes the results of AMR evaluations evaluations for the the fuel handling building component groups.

applicant identified 107 unique component/material/environment/aging In LRA Table 3.5.2-7, the applicant componenVmaterial/environmenVaging effecVAMP groups for the Fuel Handling Building. Ninety have AMR results consistent with effect/AMP groups with GALL, as identified by reference confirmed that the references Notes A through E. The staff confirmed reference to Notes references to Table 1 and GALL GALL Volume IIII line items are appropriate. .

For six component types, the applicantapplicant proposed to manage reinforced concrete material, aging reinforced concrete aging effect loss of material material (spalling, scaling) scaling) and cracking/freeze-thaw, Structures '

cracking/freeze-thaw, by using the Structures !

Monitoring Program. The staffs review of the Structures Program is documented Structures Monitoring Program documented in in SER Section 3.0.3.2.21.

3.0.3.2.21. These line items reference plant-specific Note 4, which reference Note H and plant-specific exterior below grade effects/mechanisms of exterior states "the aging effects/mechanisms concrete in a groundwater/so~1 grade concrete groundwater/soil include loss of environment include environment of material (spalling/scaling) and cracking material (spalling/scaling) cracking due to freeze-thaw. These These aging effects/mechanisms effects/mechanisms are managed managed by the Structures Monitoring Program. The Structures Structures Monitoring Structures appropriate in this situation Monitoring Program is appropriate Monitoring situation since loss of material (spalling/scaling) and material (spalling/scaling) ard cracking due to freeze-thaw exterior below freeze-thaw is still present for exterior grade concrete below grade concrete above the frost appropriate, because the Structures credited AMP is appropriate, line." The staff finds that the credited Monitoring Structures Monitoring Program requires visual inspections on a periodic basis to manage Program manage loss of material (spalling, scaling) and and cracking due applicant has committed to appropriate, due to freeze-thaw. Since the applicant aging management management programs for the period of extended extended operation, the staff finds these AMR AMR results to be acceptable.

acce"ptable. "

For eight component types, the applicant proposes no aging management applicant proposes program to manage management program manage III.A5-5 (reinforced GALL Item III.A5-5 (reinforced concrete material, item 3.5.1-31), aging effect concrete material, effect none. These line line plant-specific Note 1, reference Note II and plant-specific items reference 1, which which states "the aging effect is not applicable applicable because the environment is not aggressive."

because disagrees with the applicant's AMR .-

aggressive. " The staff disagrees conclusion that there are no aging effects requiring requiring management of extended management for the period ot"extended operation for these groups. However, the staff finds the applicant operation applicant has enhanced Structures enhanced the Structures (Commitment # 28) to perform groundwater Program (Commitment Monitoring Program Monitoring groundwater sampling for non-aggressiveness once every five years. Since the applicant non-aggressiveness applicant has committed to perform groundwater groundwater sampling in an appropriate appropriate aging management program for the period of extended management operation, the staff finds these AMR results to be acceptable; operation, acceptable.

component types, the applicant For two componenttypes, proposed no aging management applicant proposed management program to manage manage II1.A5-13 (stainless steel fuel pool liner material, GALL Item III,A5:-13 3.5.1-46), aging effect material, item 3.5.1-46), effect none.

reference Note II and plant-specific These line items reference Note 3, which states "Stress corrosion plant-specific Note corrosion temperature is less than 140 applicable since the spent fuel pool temperature cracking is not applicable OF." The st~ff 140 of. staff reviewed the applicant's applicant's basis documents documents and the UFSAR, and found the spent fuel pool temperature is less than 140 of.

temperature OF. Therefore, stress corrosion cracking is not applicable. For loss corrosion cracking loss of material/pitting material/pitting and crevice applicant is using the Water crevice corrosion, the applicant Water Chemistry Program to to 3-422 3-:422

manage GALL Item III.A5-13 manage III.A5-13 (stainless steel fuel pool liner material, item 3.5.1-46). The staff's staffs review of the Water Water Chemistry Chemistry Program is documented documented in SER Section Section 3.0.3.2.2. The staff finds finds that the credited AMP is appropriate, because because the Water Chemistry Chemistry Program monitors and controls the chemical environments of the TMI-1 chemical environments TMI-1 primary primary cycle and secondary secondary cycle systems systems such that aging effects of system system components are minimized. Aging effects include include loss of material/pitting and crevice material/pitting crevice corrosion. Since the applicant has committed to use the appropriate appropriate aging management management programs for the period extended operation, the staff finds these AMR period of extended AMR results to be acceptable.

acceptable.

For one component type, the applicant proposed to manage manage roofing material, material, aging effect effect loss loss weatherproofing integrity of weatherproofing integrity due to cracking, organic decomposition, decomposition, separation, shrinkage, wear, and weathering, weathering, by using the Structures Structures Monitoring Monitoring Program. The staff's review of the the Structures Monitoring Program Structures Monitoring Program is documented documented in SER Section 3.0.3.2.21. These line items Section 3.0.3.2.21. items reference Note J. The staff finds that the credited AMP is appropriate,appropriate, because because the Structures Structures Monitoring Program Monitoring Program requires visual inspections on a periodic periodic basis to manage manage loss of weatherproofing integrity due to cracking, weatherproofing cracking, organic decomposition, separation, shrinkage, wear, organic decomposition, and weathering. Since the applicant has committed committed to appropriate appropriate aging aging management programs management programs for the period of extended extended operation, the staff finds these AMR results to be acceptable.

On the basis of its review, the staff finds that the applicant has appropriately evaluated the AMR appropriately evaluated AMR results of material, environment, AERM, and AMP combinations combinations for the Fuel Handling Building Handling Building not evaluated in the GALL Report. The staff finds that the applicant applicant has demonstrated demonstrated that the the effects of aging will be adequately managed so that the adequately managed the-intended intended function(s) will be maintained consistent with the CLB for the period of extendedextended operation, as required by 10 CFR 54.21(a)(3).

54.21 (a)(3). .

3.5.2.3.8 Structures and Component Component Supports - Intake Intake Screen and Pump Pump House - Summary of Aging Management Management Evaluation - LRA Table 3.5.2-8 !

The staff reviewed The reviewed LRA LRA Table 3.5.2-8, which summarizes the results of AMR evaluations for the the intake intake screen and pump house component groups.

component In LRA Table 3.5.2-8, the applicant applicant identified 111 component/material/environment/aging 111 unique component/material/environment/aging effect/AMP groups for the Intake effect/AMP Intake Screen Screen and Pump House. Ninety-oneNinety-one have results have AMR results consistent with GALL, as identified identified by reference to Notes A through E. The staff confirmed confirmed that that references to Table 1 and GALL Volume II the references II line items are appropriate.

For five component component types, the applicant proposed to manage manage reinforced concrete material, aging aging effect cracking, loss of bond.

bond and loss of material (spalling/scaling/corrosion (spalling/scaling/corrosion of embedded steel, by using the Structures Monitoring Monitoring Program. The staff's staffs review of the Structures Structures Monitoring Program documented in SER Section 3.0.3.2.21.

Program is documented reference Note 3.0.3.2.21. These line items reference Note G and plant-specific plant-specific Note 7, which states "the aging aging effects/mechanisms effects/mechanisms of interior concrete in a water-flowing environment water-flowing environment include include cracking, loss of bond and loss of material (spalling, (spalling, scaling)/corrosion scaling)/corrosion of embedded embedded steel. These aging effects/mechanisms effects/mechanisms are managed by the the Structures Monitoring Structures Monitoring Program." The staff finds that the credited AMP is appropriate, because the Structures Monitoring Monitoring Program Program requires visual inspections on a periodic basis to manage manage loss of material (spalling/scaling) material (spalling/scaling) due to corrosion corrosion of embedded embedded steel. Since the applicant applicant hashas committed to an appropriate appropriate aging management management programprogram for the period of extended operation, operation, the staff finds these AMR AMR results to be acceptable.

3-423 3-423

For five component types, the applicant proposed proposed to manage reinforced concrete material, aging effect loss of material (spalling, scaling) scaling) and cracking/freeze-thaw, cracking/freeze-thaw, by using the Structures Structures Monitoring Program. The staffs review of the Structures Monitoring Monitoring Monitoring Program Program is documented documented in in SER Section 3.0.3.2.21.

3.0.3.2.21. These line itemsitems reference plant-specific Note 5, whic~

reference Note H and plant-specific which states "the aging effects/mechanisms effects/mechanisms of exterior below grade concrete concrete in groundwater/soil in a groundwater/soil environment include loss of material (spalling/scaling) environment include (spalling/scaling) and cracking due to freeze-thaw.

freeze-thaw. These These aging effects/mechanisms effects/mechanisms are managed by the Structures Monitoring Monitoring Program. The Structures Structures Monitoring Program is appropriate in in this situation since loss of material (spalling/scaling)

(spalling/scaling) and cracking cracking due to freeze-thaw is still present for exterior below grade concrete above the frost line." The staff finds that the credited AMP is appropriate, because because the Structures Monitoring Monitoring Program requires visual inspections on a periodic basis to manage loss of material material (spalling, scaling) and cracking cracking due to freeze-thaw. Since the applicant has committed to an appropriate appropriate management program aging management program for the period of extended extended operation, the staff finds these AMR AMR results to be acceptable.

component types, the applicant proposed to manage For four component manage reinforced concrete material, material, .

aging effect cracking, loss of bond and loss of material (spallirig,(spalling, scaling)/corrosion scaling)/corrosion of embedded steel, by using the Structures Monitoring Monitoring Program. The staffs review of the the Structures Monitoring Program Structures Program is documented documented in SER Section 3.0.3.2.21. These line items Section 3.0.3.2.21. items.

reference Note H reference H and plant-specific plant-specific Note Note 6, which states "the aging effects/mechanisms effects/mechanisms of above grade exterior concrete concrete in in a water-flowing water-flowing environment includeinclude cracking, loss of bond and loss of material material (spalling, scaling)/corrosion of embedded scaling)/corrosion of embedded steel. These aging effects/mechanisms are managed effects/mechanisms managed by the Structures Structures Monitoring Monitoring Program." The staff finds that the credited AMP is appropriate, because the Structures Monitoring appropriate, because Monitoring Program requires visual inspections on a periodic basis to manage material (spalling, manage loss of material (spalling, scaling) scaling) due to corrosion corrosion of embedded embedded steel. Since the applicant applicant has committed committed to appropriate appropriate aging management management programs for the period of extended operation,operation, the staff finds these AMR results to be be acceptable.

acceptable.

For five component types, the applicant proposed no aging management management program to manage manage III.A6-3 (reinforced GALL Item III.A6-3 (reinforced concrete concrete material, item 3.5.1-34), aging effect effect none. These line line items reference Note II and plant-specific plant-specific Note 2, which states "the aging effect is not applic~ble applicable because the environment environment is not aggressive." The staff disagrees disagrees with the applicant's AMR AMR .

conclusion conclusion that there are no aging effects requiring managementmanagement for the period of extended operation operation for these groups. However, the staff finds the applicant has enhanced the Structures Structures Monitoring Program (Commitment Monitoring (Commitment # 28) to perform groundwater groundwater sampling for :

non-aggressiveness once every five years. Since non-aggressiveness Since the applicant applicant has committed to perform groundwater groundwater sampling in in an appropriate appropriate aging management management program for the period of extended extended operation, operation, the staff finds these AMR find~ these AMR results results to to be be acceptable.

acceptable.

For one component applicant proposed to manage roofing material, aging effect loss component type, the applicant loss of weatherproofing weatherproofing integrity due to cracking, organic decomposition, decomposition, separation, shrinkage, :

wear, and weathering, weathering, by using the Structures Structures Monitoring Program. The staff's review of the the Structures Monitoring Structures Monitoring Program Program is documented documented in in SER Section 3.0.3.2.21.

3.0.3.2.21. These line items items reference Note J. The staff finds that the credited AMP is appropriate, reference appropriate, because the Structures Structures Monitoring Program requires visual inspections Monitoring inspections on a periodic periodic basis to manage manage loss of weatherproofing integrity due to cracking, weatherproofing integrity cracking, organic decomposition, decomposition, separation, separation, shrinkage, wear, and weathering. Since Since the applicant applicant has committed to an appropriate appropriate aging management management program for the program the period of of extended extended operation, operation, the staff finds these AMR results to be be acceptable.

acceptable.

3-424 3-424

On the basis of its review, the staff finds that the the applicant appropriately evaluated applicant has appropriately evaluated the AMR AMR results of material, environment, AERM, AERM, and AMP combinations combinations for the Intake Screen Screen and Pump House not evaluated in the GALL GALL Report. The staff finds that the applicant has has demonstrated demonstrated that the effects of aging aging will be adequately adequately managed managed so that the intended intended function(s) will be maintained maintained consistent with the CLB for the period of extended extended operation, as as required by 10 CFR 54.21(a)(3).

required 3.5.2.3.9 Structures Structures and Component Supports - Intermediate Intermediate Building - Summary Summary of AgingAging Management Evaluation Management Evaluation -- LRA Table 3.5.2-9 The staff staff reviewed LRA Table Table 3.5.2-9, which summarizes summarizes the results results of AMR evaluations for the the intermediate building component intermediate component groups.

In LRA Table 3.5.2-9, the applicant component/material/environment/aging applicant identified 118 unique component/materiallenvironment/aging effect/AMP groups effect/AMP groups for the Intermediate Intermediate Building. Eighty-nine have AMR AMR results consistent with identified by reference GALL, as identified reference to NotesNotes A through E. The staff confirmed that the references references to Table 1 and GALL GALL Volume Volume IIII line items are appropriate.

For fourteen component component types, the applicant applicant proposed to manage reinforced concrete material, aging effect effect cracking, cracking, loss of of bond and loss of material material (spalling, scaling)/corrosion scaling)/corrosion of embedded embedded steel, by using the Structures Monitoring Monitoring Program.

Program. The staffs review of the the Structures Monitoring Program is documented documented in SER Section 3.0.3.2.21.

3.0.3.2.21. These line items items reference Note G. The staff finds that the credited AMP is appropriate, appropriate, because the Structures Structures Monitoring Program requires visual inspections on a periodic basis to manage Monitoring manage loss of bond and loss of material material (spalling, scaling) due to corrosion of embedded steel. Since Sinc~ the applicant has has committed to an appropriate appropriate aging management management program program for the period of extended extended operation, the staff finds these AMR results to be acceptable. acceptable.

For seven component component types, the applicant proposed proposed to manage manage reinforced concrete material, aging effect loss of material material (spalling, scaling) and cracking/freeze-thaw, cracking/freeze-thaw, by using the Structures Structures Monitoring Program. The staffs Monitoring staffs review of the Structures Structures Monitoring Monitoring Program is documented documented in in SER Section 3.0.3.2.21. These line items reference Note H Section 3.0.3.2.21. H and plant-specific plant-specific Note 3, which which states "the aging effects/mechanisms effects/mechanisms of exterior below grade concrete in a groundwater/soil environment environment include loss of material (spalling/scaling)

(spalling/scaling) and cracking due to freeze-thaw.

freeze-thaw. These These aging effects/mechanisms effects/mechanisms are managed managed by the Structures Structures Monitoring Program.

Program. The Structures Structures Monitoring Monitoring Program appropriate in this situation since loss of material (spalling/scaling)

Program is appropriate (spalling/scaling) and cracking due to freeze-thaw freeze-thaw is still present for exterior below grade concrete concrete above the frost line." The staff finds that the credited credited AMP is appropriate appropriate in each case, because the Structures Structures Monitoring Program requires visual inspections Monitoring Program inspections on a periodic basis to manage manage loss of material (spalling, scaling) scaling) and cracking due due to freeze-thaw.

freeze-thaw. Since the applicant has committed to an appropriate aging management appropriate management program program for the period of extended extended operation, operation, the staff finds finds these AMR results to be acceptable.

acceptable.

For seven component component types, the applicant applicant proposed no aging management program to manage management program manage GALL Item II1.A3-5 (reinforced concrete material, III.A3-5 (reinforced material, item 3.5.1-31), aging effect none. These line line items reference reference Note I and plant-specific plant-specific Note 1, which states "The aging aging effect is not applicable applicable because the environment environment is not aggressive." The staff disagrees with the applicant's applicant's AMRAMR conclusion conclusion that there are no aging effects requiring management management for the period of extended extended operation operation for these groups. However, the staff finds the applicant has enhanced Structures enhanced the Structures Monitoring Program (Commitment # 28)

Program (Commitment perform groundwater

28) to perform groundwater sampling sampling for non-aggressiveness non-aggressiveness once once every five years. Since the applicantapplicant has committed committed to perform 3-425 3-425

groundwater appropriate aging management program sampling in an appropriate groundwater sampling program for the period of extended operation, the staff finds these AMR AMR results to be acceptable.

For one component type, the applicant proposed to manage roofing material, material, aging effect loss of weatherproofing weatherproofing integrity due to cracking, decomposition, separation, shrinkage, cracking, organic decomposition, shrinkage, '

wear, and weathering, by using the Structures Monitoring Program. The staff's review the review of the Structures Monitoring Monitoring Program is documented documented in SER Section 3.0.3.2.21.

3.0.3.2.21. These line items items, reference Note J. The staff finds that the credited AMP is appropriate, reference appropriate, because Structures because the Structures Monitoring Program Monitoring Program requires visual inspections on a a periodic basis to manage loss of .

weatherproofing integrity weatherproofing integrity due to cracking, organic decomposition, separation, shrinkage, wear, cracking, organic and weathering. Since the applicant has committed committed to an appropriate management '

appropriate aging management operation, the staff finds these AMR results to be extended operation, program for the period of extended be acceptable.

acceptable.

On the basis of its review, the staff finds that the applicant has appropriately evaluated the AMR appropriately evaluated AMR results of material, environment, environment, AERM, and AMP combinations for the Intermediate Building Intermediate Building not evaluated in the GALL Report. The staff finds that the applicant demonstrated that the applicant has demonstrated the effects adequately managed so that the intended function(s) will be maintained effects of aging will be adequately maintained consistent period of extended operation, as required consistent with the CLB for the period required by by 10 CFR 54.21(a)(3).

3.5.2.3.10 Structures and Component 3.5.2.3.10 Structures Mechanical Draft Cooling Component Supports - Mechanical Cooling Tower Structures Structures- -

Management Evaluation - LRA Table Summary of Aging Management Table 3.5.2-10 3.5.2-10 The staff reviewed LRA Table Table 3.5.2-10, which summarizes the results of AMR evaluations evaluations for the mechanical dooling tower structures component groups.

mechanical draft cooling In LRA Table Table 3.5.2-10, the applicant identified 52 unique applicant identified component/material/environment/aging unique"componentlmaterial/environmentlaging effect/AMP groups for the Mechanical effect/AMP groups Mechanical Draft Cooling Cooling Tower Tower Structures. Thirty-two have AMR AMR identified by reference to Notes A through E. The staff consistent with GALL, as identified results consistent staff references to Table 1 and GALL Volume IIII line items are appropriate.

confirmed that the references appropriate.

For six component types, the applicant proposed proposed to manage manage reinforced concrete concrete material, aging material, aging effect cracking, loss of bond and loss of material {spalling, (spalling, scaling)/corrosion embedded steel scaling)/corrosion of embedded strength/leaching of calcium hydroxide, increase in porosity and permeability, loss of strength/leaching and increase hydroxide, by by using the Structures Monitoring Program. The staff's review of the Structures Structures Monitoring Monitoring Structures Monitoring Program Program is documented in SER Section 3.0.3.2.21. 3.0.3.2.21. These line items reference Note G. The The staff finds that the credited credited AMP is appropriate, because because the Structures Monitoring Program Program inspections on a periodic basis to manage loss of material (spalling, scaling),:

requires visual inspections due scaling),!due to corrosion of embedded embedded steel and increase porosity and permeability, loss of strength due increase in porosity due leaching of calcium hydroxide. Since the applicant has committed to leaching committed to an appropriate aging appropriate aging management management program for the period of extended extended operation, the staff finds these AMR results to to be acceptable.

eleven component types, the applicant proposed For eleven proposed to manage reinforced concrete material, concrete materifll, aging effect loss of material (spalling, scaling) and cracking/freeze-thaw, by using the Structures Structures Monitoring Program. The staff's Monitoring staffs review of the Structures Monitoring Program is documented documented in in 3.0.3.2.21. These line items reference SER Section 3.0.3.2.21. plant-specific Note 3, which reference Note H and plant-specific "the aging states "the effects/mechanisms of exterior aging effects/mechanisms below grade concrete in a groundwater/soil exterior below groundwater/soil environment include loss of material environment (spalling/scaling) and cracking due to freeze-thaw. These material (spalling/scaling) aging effects/mechanisms aging managed by the Structures Monitoring effects/mechanisms are managed Struct~res Program. The Structures Monitoring Program.

3-426 3-426

appropriate in this situation since loss of material (spalling/scaling)

Monitoring Program is appropriate (spalling/scaling) and cracking cracking due to freeze-thaw freeze-thaw is still present for exterior exterior below below grade concrete concrete above the frost line." The staff finds that the credited AMP is appropriate in each case because the Structures Structures Monitoring Program performs Monitoring performs visual inspections on a periodic basis to manage manage loss of material (spalling, (spalling, scaling) and cracking due to freeze-thaw. Since the applicant applicant has committed to an appropriate management program for the period of extended operation, the staff finds appropriate aging management finds these AMR AMR results to be acceptable.

acceptable.

For three component component types, the applicant applicant proposed no aging management management program to manage manage GALL Item GAll Item III.A3-5 (reinforced (reinforced concrete concrete material, material, item 3.5.1-31), aging effect none. These line line items reference reference Note II and plant-specific plant-specific Note 1, 1, which which states "the aging effect is not applicable applicable because because the environment is not aggressive." The staff disagrees disagrees with the applicant's applicant's AMR AMR conclusion that there are no aging effects requiring management management for the period period of extended extended operation for these groups. However, the staff finds the applicant operation applicant has enhanced enhanced the Structures Structures Monitoring Program Monitoring Program (Commitment (Commitment # 28) groundwater sampling

28) to perform groundwater sampling for non-aggressiveness once every five years. Since the applicant non-aggressiveness applicant has committed to perform groundwater sampling in an appropriate groundwater appropriate aging management management programprogram for the period of extended extended operation, the staff finds these AMR results to be acceptable. acceptable.

On the basis of its review, the staff finds that the applicant has appropriately appropriately evaluated the AMR AMR results of material, material, environment, AERM, AERM, and AMP combinations for the Mechanical Mechanical DraftDraft Cooling Tower Structures not evaluated evaluated in the GAllGALL Report. The staff finds that the applicant demonstrated that the effects of aging will be adequately managed so that the intended has demonstrated function(s) function(s) will be maintained maintained consistent consistent with the ClB CLB for the period of extended extended operation, operation, as required required by 10 CFR 54.21(a)(3).

54.21 (a)(3).

3.5.2.3.11 3.5.2.3.11 Structures and Component Supports - Miscellaneous Miscellaneous Yard Structures Structures - Summary Summary of

. Management Evaluation Aging Management Evaluation -lRA

- LRA Table 3.5.2-11 3.5.2-11 The staff reviewed reviewed LRA lRA Table 3.5.2-11, 3.5.2-11, which summarizes summarizes the results of AMR evaluationsevaluations for the miscellaneous miscellaneous yard structures componentcomponent groups.

LRA Table 3.5.2-11, In lRA 3.5.2-11, the applicant applicant identified identified 74 unique component/material/environment/aging component/materiallenvironment/aging effect/AMP effect/AMP groups for the MiscelianeousYard Miscellaneous Yard Structures. Fifty-eight Fifty-eight have have AMR results results consistent consistent with GALL, as identified identified by reference reference to Notes A through E. The staff confirmed that the references references to Table Table 1 and GALL Volume II II line items are appropriate.

appropriate~

For eight component component types, the applicant proposed proposed to manage manage reinforced reinforced concrete material, aging effect loss of material (spalling, (spalling, scaling) and cracking/freeze-thaw, cracking/freeze-thaw, by using the StructuresStructures Monitoring Program. The staffs Monitoring staffs review of the Structures Structures Monitoring Program is documented documented in in 3.0.3.2.21. These SER Section 3.0.3.2.21. reference Note H and plant-specific These line items reference plant-specific Note 2, which which "the aging effects/mechanisms states "the effects/mechanisms of exterior below grade grade concrete in aa groundwater/soil environment include include loss of material (spalling/scaling)

(spalling/scaling) and cracking cracking due to freeze-thaw. These aging effects/mechanisms aging effects/mechanisms are managed by the Structures Monitoring Program. The StructuresStructures Monitoring Program is appropriate Monitoring appropriate in this situation since loss of material (spalling/scaling)

(spalling/scaling) and cracking cracking due to freeze-thaw freeze-thaw is still present present for exterior exterior below below grade concrete above the frost line." The staff finds that the credited AMP is appropriate in each case because the Structures Structures Monitoring Monitoring Program Program requires visual inspections inspections on a periodic basis to manage manage loss of material (spalling, (spalling, scaling) and cracking due to freeze-thaw. Since the applicant applicant has committed committed to an appropriate aging management appropriate management program for the period of extended extended operation, the staff staff finds finds these AMR results to be acceptable.

acceptable.

3-427 3-427

For eight component component types, the applicantapplicant proposed no aging management management program to manage manage GALL GALL Item III.A3-5 (reinforced concrete III.A3-5 (reinforced concrete material, item item 3.5.1-31), aging aging effect none. These line line items reference reference Note II and plant-specific plant-specific Note 1, 1, which states "the "the aging effect is not applicable applicable because the environment because environment is not aggressive." The staff disagrees disagrees with the applicant's applicant's AMR AMR conclusion that there are no aging effects requiring management management for the period of extended extended operation for these groups. However, the staff finds the applicant operation applicant has enhanced enhanced the Structures Structu'tes Monitoring Program Program (Commitment (Commitment # 28) to perform groundwater groundwater sampling for non-aggressiveness non-aggressiveness once every five years. Since the applicant has committed committed to perform, perform groundwater groundwater sampling in an appropriate appropriate aging management management program for the period period of extended extended operation, the staff finds these AMR results to be acceptable. acceptable.

On the basis of its review, the staff finds that the applicant has appropriately evaluated evaluated the AMRAMR results of material, environment, AERM, and AMP combinations combinations for the Miscellaneous Miscellaneous Yard evaluated in the GALL Report. The staff finds that the applicant has Structures not evaluated has demonstrated demonstrated that the effects effects of aging will be adequately adequately managed managed so that the intended intended function(s) function(s) will be maintained consistent with the CLB for the period maintained consistent period of extended extended operation, as as required by 10 CFR 54.21(a)(3).

54.21(a)(3).

Structures and Component 3.5.2.3.12 Structures Component Supports - Natural Draft Draft Cooling Tower Tower - Summary of Aging Management Evaluation - LRA Table 3.5.2-12 Management Evaluation 3.5.2-12 The staff reviewed LRA Table 3.5.2-12, which summarizes the results of AMR evaluations evaluations for for component groups.

the natural draft cooling tower component In LRA Table 3.5.2-12, the applicant identifiedidentified 28 unique component/material/environment/aging componentlmaterial/environmentlaging effect/AMP groups effectlAMP groups for the Natural Draft Cooling Tower. Twenty-two have AMR results results ,

consistent with GALL, as identified identified by reference reference to Notes Notes A through E. The staff confirmed that the references to Table 1 and GALL GALL Volume Volume IIII line items are appropriate.

appropriate.

For two component component types, the applicant applicant proposed to manage reinforced concrete concrete material, material, aging effect cracking, loss of bond and loss of material (spalling, scaling)/corrosion scaling)/corrosionof of embedded steel, by using the Structures Monitoring Program. The staff's review of the Structures Monitoring the Structures Monitoring Program is documented Structures 3.0.3.2.21. These line items documented in SER Section 3.0.3.2.21. items reference Note H reference H and plant-specific plant-specific Note 3, which states "the aging effects/mechanisms effects/mechanisms of above above grade exterior exterior concrete concrete in a water-flowing water-flowing environment environment include cracking, loss of bond and loss of material material (spalling, (spalling, scaling)/corrosion scaling)/corrosion of embedded embedded steel. These aging aging effects/mechanisms effects/mechanisms are managed by the Structures Monitoring Monitoring Program." The staff finds that the credited credited AMP is appropriate, appropriate, because the Structures Monitoring Program Program requires visual inspections on a periodic basis to manage manage loss of bond and loss of material (spalling, scaling) scaling) due to corrosion of embedded embedded steel. Since the applicant applicant has committed committed to an appropriate appropriate aging aging management program for the period of extended management extended operation, operation, the staff finds these AMR results to be acceptable.

For two component types, the applicant proposed to manage reinforced reinforced concrete material, aging effect effect loss of material material (spalling, scaling) scaling) and cracking/freeze-thaw, cracking/freeze-thaw, by using the Structures Structures Monitoring Monitoring Program. The staff's review of the Structures documente~ in Monitoring Program is documented SER Section 3.0.3.2.21.

3.0.3.2.21. These line items reference reference Note H and plant-specific Note 4, which which "the aging effects/mechanisms states "the effects/mechanisms of exterior exterior below below grade concrete in a groundwater/SOil grade concrete groundwater/soil include loss of material (spalling/scaling) environment include (spalling/scaling) and cracking due to freeze-thaw. These Th~se aging effects/mechanisms effects/mechanisms are managed by the Structures Monitoring Program. Program. The Structures Structures 3-428

Monitoring Program Monitoring Program is appropriate in this situation situation since loss of material material (spalling/scaling)

(spalling/scaling) and cracking cracking due to freeze-thaw freeze-thaw is still present for exterior below grade grade concrete above the frost line." The staff finds that the credited AMP is appropriate appropriate in each each case because because the Structures Structures Monitoring Program Monitoring Program requires requires visual inspections on a periodic basis to manage manage loss of material (spalling, scaling) and cracking cracking due to freeze-thaw. Since the applicant applicant has committed to an appropriate appropriate aging management management program for the period of extended extended operation, operation, the staff finds finds these AMR results to be acceptable.

For two component types, the applicant proposed proposed no aging management management program to manage manage GALL Item III.A3-5 III.A3-5 (reinforced (reinforced concrete material, item 3.5.1-31), aging effect concrete material, effect none. These These line line items reference reference Note Note I and plant-specific plant-specific Note 1, which states "the aging effect is not applicableapplicable because because the environment environment is not aggressive." The staff disagrees with the applicant's AMR AMR conclusion conclusion that there are no aging effects effects requiring management management for the period of extended extended operation operation for these groups. However, However, the staff finds the applicant has enhanced the Structures Structures (Commitment # 28) to perform groundwater Monitoring Program (Commitment groundwater sampling for non-aggressiveness non-aggressiveness once every five years. Since the applicant applicant has committed committed to perform groundwater sampling in an appropriate groundwater appropriate aging management management program for the period of extended extended operation, the staff finds these AMR results to be acceptable.

acceptable.

On the basis of its review, the staff staff finds that the applicant has appropriately appropriately evaluated the AMR AMR results of material, environment, AERM,AERM, and AMP combinations for the Natural combinations Natural Draft Cooling Tower not evaluated in the GALL Report. The staff finds that the applicant has demonstrated that the effects effects of aging will be adequately adequately managed so that the intended function(s) function(s) will bebe maintained consistent maintained consistent with the CLB for the period of extendedextended operation, as required required by 10 CFR 54.21(a)(3).

10 CFR 3.5.2.3.13 Structures Structures and Component Supports - Structural Structural Commodities - Summary Summary of Aging Management Management Evaluation - LRA Table 3.5.2-13 3.5.2-13 The staff reviewed reviewed LRA Table 3.5.2-13, which summarizes the results of AMR evaluations evaluations for the structural commodities commodities component component groups.

In LRA Table 3.5.2-13, the applicant identified identified 109 unique component/material/

componenUmaterial/

environment/aging effect/AMP groups for the structural commodities. Eighty-eight have AMR environmenUaging effecUAMP AMR results consistent consistent with GALL, GALL, as identified by reference reference to Notes A through E. The staff staff confirmed references to Table 1 and GALL Volume IIII line items confirmed that the references items are appropriate.

appropriate.

For one component type, the applicant proposed to manage applicant proposed manage aluminum aluminum (insulation (insulation jacketing) jacketing) material, aging effect loss of material/pitting and crevice corrosion, by using the External Surfaces Monitoring Program. The staff's review of the External Surfaces Surfaces Monitoring Surfaces Monitoring Monitoring Program is documented in SER Section 3.0.3.2.16. These line items reference documented reference Note Note H, H, and plant-specific plant-specific Note Note 4, which states "the agingaging effects effects of aluminum aluminum in this environment environment include loss of material due to pitting and crevice crevice corrosion. effects/mechanisms are managed corrosion. These aging effects/mechanisms managed by the the External Surfaces Monitoring External Monitoring Program." The staff finds that the External Surfaces Monitoring Surfaces Monitoring Program requires visual inspections on a periodic basis to manage loss of material due Program due to pitting pitting and crevice corrosion; crevice' corrosion; therefore, the credited credited AMP is appropriate appropriate in each case. Since the the applicant applicant has committed to an appropriate appropriate aging management management programprogram for the period of of extended extended operation, the staff finds these AMR results to be acceptable. acceptable.

For eight component component types, the applicant applicant proposed proposed to manage material, aging effect manage grout material, effect cracking/shrinkage cracking/shrinkage and aggressive environment, by using the Structures Monitoring Monitoring Program.

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The staffs staffs review review ofof the Structures Structures Monitoring Monitoring Program Program isis documented documented in in SER Section Section 3.0.3.2.21. These 3.0.3.2.21. These line items items reference reference NoteNote H,H, and plant-specific Note 6, and plant-specific 6, which which states ~ging states "the aging effects/mechanisms effects/mechanisms of of grout grout inin this environment environment include include cracking cracking due due to shrinkage shrinkage andand aggressive aggressive environment.

environment. These These aging aging effects/mechanisms effects/mechanisms are are managed managed by the the Structures Structures Monitoring Program."

Monitoring Program." The staff finds that that the Structures Monitoring Program Structures Monitoring Program requires requires visual inspections inspections on a periodic periodic basis basis to manage cracking due to shrinkage manage cracking shrinkage and aggressive aggressive environments; environments; therefore therefore the credited credited AMPAMP is appropriate appropriate in each each case. Since Since the applicant applicant has has committed committed to an appropriate aging management an appropriate aging management program program for the period of extended the period extended operation, the staff finds these AMR results results to be acceptable.

acceptable.

. .

For For one component component type, the the applicant proposed to manage applicant proposed manage PVC PVC (conduit) material, aging material, aging none, and none none for management management program.

program. The staff reviewed the the LRA, LRA, license design basis basis documents, EPRI 1002950 Structural EPRI 1002950 Structural Tools, Revision Revision 1, August 2003, 2003, and the GALLGALL Report Report and found that these these materials materials do not perform perform oror support any license license renewal renewal intended intended functions functions that satisfy satisfy the scoping scoping criteria of 10 10 CFR 54.4(a). Therefore, aging management management for these these .

materials materials is not required.

required.

For eleven eleven component types, the applicantapplicant proposed to manage manage asbestos, calcium silicate, .

fiberglass, and Nukon Nukon (insulation)

(insulation) material, aging none, and none for management management program.

program.

The The staff reviewed the LRA, license design design basis documents, documents, EPRI 10029501002950 Structural Structural Tools, Revision Revision 1, August 2003, and the GALL GALL Report and found that these materials materials do not perform perform or support any license renewal intended license renewal functions that satisfy the scoping criteria of intended functions 10 10 CFR 54.4(a). Therefore, aging management management for these materialsmaterials is not not required.

required.

On the basis of its review, the staff finds that the applicant has appropriately evaluated evaluated the ~MRAMR results of material, material, environment, environment, AERM, and AMP combinations for the Structural Commodities Commodities not evaluated in the GALL Report. The staff finds that the applicant has demonstrated demonstrated that the the adequately managed effects of aging will be adequately managed so that.the intended function(s) will be maintained maintained consistent with the CLB for the period of extended operation, operation, as required required by 10 CFR 54.21 (a)(3).

3.5.2.3.14 3.5.2.3.14 Structures Structures and Component Supports - Reactor Reactor Building - Summary Summary of Aging Aging Management Evaluation Management Evaluation - LRA Table 3.5.2'-143.5.2-14 The staff reviewed LRA Table 3.5.2-14, which summarizes summarizes the results of AMR evaluationsevaluations for the reactor building (containment) component groups.

In LRA Table 3.5.2-14 the applicant identified 352 unique component/material!

component/material/

environment/aging effect/AMP environment/aging effect/AMP groups for the Reactor Building (Containment). Three hundred have AMR results consistent with GALL, as identified by reference reference to Notes A through E. The The staff confirmed that the references references to Table 1 and GALL GALL Volume IIII line items are appropriate.

For two component component types, the applicant proposed to manage manage epoxy material, material, aging effect 16ssloss of sealing/deterioration sealing/deterioration of seals, gaskets, and moisture barriers (caulking, flashing, and other

<

sealants), byby using the 10 10 CFR Part 50, Appendix J Program. The staff's review of the 10 CFR Part 50, Appendix J Program is documented documented in SER Section 3.0.3.1.7. These line items items reference Note F. The staff finds that the 10 CFR Part 50, Appendix J Program reference Program performs the the leakage testing on a periodic basis to manage loss of sealing/deterioration containment leakage sealing/deterioration of seals, gaskets, and moisture barriers; therefore, therefore, the credited AMP is appropriate in each case. Sir:)ce Since appropriate aging management program for the period of the applicant has committed to an appropriate extended operation, the staff finds these AMR AMR results to be acceptable.

3-430

component types, the applicant For three component applicant proposed to manage reinforced concrete material, reinforced concrete material, aging effect effect loss of material (spalling, scaling) cracking/freeze-thaw, by using the Structures scaling) and cracking/freeze-thaw, Structures Monitoring Program. The staffs Monitoring Monitoring Program is documented staff's review of the Structures Monitoring documented in SER Section 3.0.3.2.21. These line items reference Section 3.0.3.2.21. reference Note H and plant-specific plant-specific Note 7, which which states "the aging effects/mechanisms effects/mechanisms of exterior exterior below grade concrete in a groundwater/soil environment include include loss of material material (spalling/scaling)

(spalling/scaling) and cracking cracking due to freeze-thaw. These These aging effects/mechanisms effects/mechanisms are managed managed by the Structures Monitoring Program. The Structures Structures Monitoring Program is appropriate Monitoring appropriate in this situation situation since loss of material (spalling/scaling)

(spalling/scaling) and cracking cracking due to freeze-thaw freeze-thaw is still present for exterior below grade concrete above the frost line." The staff finds that the credited appropriate in each case because the Structures credited AMP is appropriate Structures Monitoring Program requires visual inspections on a periodic Monitoring periodic basis to manage loss of material (spalling, scaling) and cracking due to freeze-thaw. Since the applicant applicant has committed to an appropriate aging management management program for the period of extended extended operation, operation, the staff finds finds these AMR results to be acceptable.

For five component component types, the applicant proposed no aging managementprogram management program to manage manage II1.A3-5 (reinforced GALL Item III.A3-5 (reinforced concrete concrete material, item 3.5.1-31), aging effect none. These line These line items reference reference Note II and plant-specific plant-specific Note 2, which states "the aging effect is not applicable applicable because the environment is not aggressive."

aggressive." The staff disagrees with the applicant's applicant's AMR AMR conclusion conclusion that there are no aging effects effects requiring management management for the period of extended operation operation for these groups. However, the staff finds the applicant has enhanced the Structures Structures Monitoring Program Monitoring Program (Commitment (Commitment # 28) to perform perform groundwater groundwater sampling for non-aggressiveness once every non-aggressiveness every five years. Since the applicant has committed to perform groundwater sampling in an appropriate groundwater appropriate aging management management program for the period of extended extended operation, the staff finds these AMR results to be acceptable. acceptable.

For seven seven component types, the applicant applicant proposed no aging management management program program to manage manage GALL GALL Item II.A1-4 (reinforced concrete material, concrete material, item 3.5.1-1), aging aging effect none. These line line items reference reference Note I and plant-specific plant-specific Note 2, which states "the aging effect is not applicable applicable because the environment is not aggressive." The staff disagrees disagrees with the applicant's applicant's AMR AMR conclusion conclusion that there are no aging effects requiring management management for the period of extended operation operation for these groups. However, the staff finds the applicant applicant has enhanced enhanced the Structures Structures Monitoring Program Program (Commitment (Commitment # 28) to perform groundwater groundwater sampling for non-aggressiveness once every five years. Since the applicant has committed to perform non-aggressiveness groundwater groundwater sampling in an appropriate appropriate aging management management program for the period of extended extended operation, the staff finds these AMR results to be operation, the staff finds these AMR results to be acceptable. acceptable.

For twenty-two component types, the applicant twenty-two component applicant proposed proposed to manage carbon steel; dissimilardissimilar (3.5.1-18) materials, metal welds (3.5.1-18) materials, aging effect effect loss of material general general corrosion, by using ASME ASME Section Xl,XI, Subsection Subsection IWE IWE and 1010 CFR Part 50, Appendix J programs. The staffs staff's review of thethe ASME Section XI, Subsection Subsection IWE and 10 CFR Part 50, Appendix J Programs are documented documented in SER Section 3.0.3.2.19 3.0.3.2.19 and 3.0.3.1.7 respectively. These line items reference reference Note II and plant-specific Note 6, which which states "loss of material due to pitting and crevice corrosion corrosion is not applicable applicable for this material material and environmental environmental combination."

combination." The staff finds that the credited credited AMPs are appropriate, because because the ASME Section XI, XI, Subsection Subsection IWE and 10 CFR Part 50, Programs require visual inspections and pressure testing on a periodic Appendix J Programs periodic basis to manage loss of material manage material general general corrosion. Since the applicant applicant has committed to appropriate appropriate aging management management programs for the period period of extended operation, the staff finds these AMR AMR results to be acceptable.

acceptable.

3-431

For thirteen component component types, the applicant applicant proposed no aging aging management management program to manage stainless steel; dissimilar metal welds (3.5.1-10 {II.A3-2}) effect non~.

material, aging effect

{11.A3-2}) material, none.

reference Note II and plant-specific These line items reference plant-specific Note 12, 12, which corrosion which states "Stress corrosion applicable to stainless steel; dissimilar cracking is not applicable cracking environments of air with dissimilar metal welds in environments borated leakage and air-indoor." The staff disagrees borated water leakage AMR conclusion applicant's AMR disagrees with the applicant's conclusion that there are no aging effects effects requiring requiring management management for the period period of extended operation for extended operation for these groups. On December December 11, applicant to provide the technical 11, 2008, the staff asked the applicant recommendation (RAI basis for not following the GALL Report recommendation (RAI 3.5.2-14-0).

In the response e-mail dated December 12, (ML083500505) the applicant 12, 2008 (ML083500505) applicant stated that the TMI-1 line items listed (3.5.1-10 (3.5.1-10 {II.A3-2}) associated aging management

{11.A3-2}) do not have an associated management program applicable aging effect because there is no applicable program credited because effect identified requires identified that requires applicant also stated that at TMI-1, management. The applicant TMI-1, these Reactor Building penetration penetration components are associated components associated with the Reactor Building but are actually located inside the located the Auxiliary Building, Fuel Handling Building and Turbine Building.

adjoining Auxiliary Building. The applicant applicant further penetration closure plates and welds are exposed to the stated that the exterior surface of these penetration the environments inside each of these adjoining buildings, and the interior surface air environments surface is exposed to to an air environment inside the annulus of the penetration, environment inside penetration, separated Reactor Building separated from the Reactor Building environment by a flexible bellows assembly on the end of the penetration environment penetration inside the Reactor applicant further stated that the only environments Building. The applicant Building. the evaluation are the environments that required evaluation air-indoor environment and the air with borated water leakage leakage environment. The applicant again a!gain environments do not have chloride stated that these environments sufficient to promote chloride or sulfate levels sufficient stress promote stress applicant further stated that the review of cracking, as stated in the LRA. The applicant corrosion cracking, applicable operating experience applicable operating experience has not identified cracking of any stainles~

identified stress corrosion cracking stainless steel components or dissimilar metal air-indoor environment or an air with borated metal welds in an air-indoor leakage environment. The applicant stated that this is also consistent water leakage water consistent with other other environments where no (uncontrolled) environments NUREG-1801 line items for stainless steel in air-indoor (uncontrolled)

NUREG-1801 no aging effects are identified.

identified.

Since no aging effects applicant concluded that no aging management effects are identified, the applicant management needed. The staff reviewed the applicant responses, and found them acceptable program is needed.

program acceptable because they are consistent with the GALL GALL Report air-indoor (uncontrolled)

Report for stainless steel in air-indoor (uncontrolled) environments where no aging effects are identified.

environments identified.

applicant has appropriately evaluated On the basis of its review, the staff finds that the applicant AMR evaluated the ..;\MR results of material, environment, AERM, combinations AERM, and AMP combinations for the Reactor Building Building evaluated in the GALL Report. The staff finds that the applicant (Containment) not evaluated (Containment) has applicant has adequately managed so that the intended effects of aging will be adequately demonstrated that the effects demonstrated intended maintained consistent with the CLB for the period of extended function(s) will be maintained function(s) extended operation, as required by 1010 CFR 54.21(a)(3). .

Component Supports - SBO Diesel Generator Structures and Component 3.5.2.3.15 Structures 3.5.2.3.15 Generator Building - Summary of Aging Management Evaluation - LRA Table 3.5.2-15 Management Evaluation 3.5.2-15 reviewed LRA Table 3.5.2-15, which summarizes The staff reviewed summarizes the results of AMR evaluations for AMR evaluations generator building component groups.

the SBO diesel generator groups.

Table 3.5.2-15, the applicant In LRA Table identified 39 unique component/material/environment/aging applicant identified componenVmaterial/environmenVaging effect/AMP groups for the SBO Diesel Generator effecVAMP Generator Building. Thirty-three have Building. Thirty-three have AMR results results reference to Notes A through E. The staff confirmed identified by reference consistent with GALL, as identified confirmed that references to Table 1 and GALL Volume the references Volume IIII line items are appropriate.

appropriate.

3-432

For two component types, the applicant proposed to manage reinforced concrete material, material, aging effect loss of material (spalling, scaling) scaling) and cracking/freeze-thaw, cracking/freeze-thaw, by using the Structures Structures Monitoring Program. The staff's Monitoring staffs review of the Structures Monitoring Monitoring Program Program is documented documented in in SER Section 3.0.3.2.21.

3.0.3.2.21. These line items reference reference Note H and plant-specific plant-specific Note 2, which states "the aging effects/mechanisms of exterior aging effects/mechanisms exterior below grade concrete in a groundwater/soil grade concrete groundwater/soil environment environment include include loss of material (spalling/scaling) and cracking material (spalling/scaling) cracking due to freeze-thaw. These aging effects/mechanisms are managed aging effects/mechanisms managed by the Structures Monitoring Monitoring Program. The Structures Structures Monitoring Program is appropriate Monitoring appropriate in this situation situation since loss of material material (spalling/scaling)

(spalling/scaling) and cracking due to freeze-thaw freeze-thaw is still present for exterior concrete above the frost exterior below grade concrete line." The staff finds that the credited appropriate in each case credited AMP is appropriate because the Structures case because Structures Monitoring Program requires visual inspections on a periodic Monitoring periodic basis to manage manage loss of material (spalling, scaling) and cracking cracking due to freeze-thaw. Since the applicant has committed to an appropriate aging management management program for the period of extended extended operation, operation, the staff finds finds these AMR acceptable.

AMR results to be acceptable.

For three component component types, the applicant proposed no aging management applicant proposed management program to manage manage GALL ItemItem III.A3-5 (reinforced concrete material, item 3.5.1-31), aging (reinforced concrete aging effect effect none. These line line

.items reference Note II and plant-spec'ific items reference plant-specific Note 1, which states "the aging effect is not applicableapplicable because because the environment is not aggressive." The staff disagrees with the applicant's AMR AMR conclusion conclusion that there are no aging effects effects requiring management management for the period of extended operation operation for these groups. However, the staff finds the applicant has enhanced enhanced the Structures Structures Monitoring Program (Commitment # 28) to perform Program (Commitment perform groundwater groundwater sampling sampling forfor non-aggressiveness non-aggressiveness once every five years. Since the applicant applicant has committed to perform groundwater groundwater sampling in an appropriate appropriate aging management program aging management program for the period of extended operation, the staff finds these AMR results to be acceptable. .

For one component component type, the applicant applicant proposed proposed to manage roofing material, aging effect loss loss of weatherproofing weatherproofing integrity due due to cracking, organic decomposition, separation, shrinkage, wear, and weathering, by using the StructuresStructures Monitoring Monitoring Program. The staff's review of the. the, Structures Monitoring Program Structures Monitoring Program is documented documented in SER Section Section 3.0.3.2.21.

3.0.3.2.21. These line items items reference Note J. The staff finds that the credited AMP is appropriate, because the Structures Structures Monitoring Program Program requires visual inspections inspections on a periodic periodic basis to manage manage loss of weatherproofing integrity due weatherproofing due to cracking, cracking, organic decomposition, decompOSition, separation, separation, shrinkage, shrinkage, wear, and weathering. Since the applicant applicant has committed to an appropriate appropriate aging management management program for the period of extended extended operation, the staff finds these AMR results to be be acceptable.

acceptable.

On the basis of its review, the staff finds that the applicant has has appropriately evaluated the AMR appropriately evaluated AMR results of material, environment, AERM, and AMP combinations combinations for the SBO SSO Diesel Generator Generator Building not evaluated evaluated in the GALL Report. The staff finds that the applicant applicant has demonstrated that the effects of aging will be adequately adequately managed managed so that the intended intended function(s) will be be maintained consistent maintained consistent with the CLB for the period of extended period extended operation, as required required byby 10 10 CFR 54.21(a)(3).

3.5.2.3.16 Structures and Component Component Supports Supports - Service Service Building - Summary Summary of AgingAging Management Evaluation Management Evaluation - LRA Table 3.5.2-16 3.5.2-16 The staff reviewed LRA Table 3.5.2-16, summarizes the results of AMR evaluations 3.5.2-16, which summarizes evaluations for the service building component component groups.

3-433 3-433

LRA Table In LRA Table 3.5.2-16, 3.5.2-16, the applicant identified the applicant unique component/material/environment/aging identified 32 unique component/materiallenvironment/aging effect/AMP groups for the Service Building. Twenty-seven have effect/AMP groups for the Service Building. Twenty-seven AMR results consistent have AMR consistent with witli GALL, as identified GALL, identified by reference to Notes by reference through E. The Notes A through The staff confirmed that staff confirmed that the references references Table 1 and to Table GALL Volume and GALL Volume II II line items are appropriate.

line items appropriate.

component types, the applicant For two component applicant proposed proposed to manage concrete material, manage reinforced concrete material, aging effect loss of aging material (spalling, of material (spalling, scaling) cracking/freeze-thaw, by using the Structures scaling) and cracking/freeze-thaw, Structures Monitoring Program. The staff's Monitoring Program. The staffs review review of the Structures Structures Monitoring Monitoring Program Program is documented documented in SER Section Section 3.0.3.2.21.

3.0.3.2.21. These These line itemsitems reference plant-specific Note Note H and plant-specific reference Note Note 3, which which states "the aging effects/mechanisms states effects/mechanisms of exterior exterior below below grade concrete in aa groundwater/soil grade concrete groundwater/soil environment include environment (spalling/scaling) and material (spalling/scaling) include loss of material and cracking due to freeze-thaw. These cracking due These effects/mechanisms are aging effects/mechanisms aging managed by the Structures are managed Monitoring Program. The Structures Structures Monitoring Structures Program is Monitoring Program Monitoring appropriate in this situation since is appropriate since loss of of material (spalling/scaling) and material (spalling/scaling) cracking due cracking freeze-thaw is still present for exterior due to freeze-thaw exterior below above the concrete above grade concrete below grade the frost frost credited AMP is appropriate, line." The staff finds that the credited appropriate, because Structures Monitoring because the Structures Monitoring inspections on a periodic Program requires visual inspections Program manage loss of material (spalling, basis to manage periodic basis scaling) freeze-thaw. Since cracking due to freeze-thaw.

scaling) and cracking applicant has committed to an appropriate Since the applicant appropriate aging management management program for the period of extended extended operation, these AMR staff finds these operation, the staff AMR results to be acceptable.

acceptable.

For two component component types, the applicant proposed management program to manage aging management proposed no aging manage GALL GALL Item III.A3-5 (reinforced concrete II1.A3-5 (reinforced concrete material, material, item 3.5.1-31), aging aging effect effect none. These line line items reference Note I and reference Note plant-specific Note and plant-specific Note 1, which states "the aging effect effect is not applicable applicable because the because the environment environment is not disagrees with the applicant's not aggressive." The staff disagrees

ML092950449

Text

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