ML100220066

Response to Request for Additional Information for the Review of the License Renewal Application - Aging Management Review/Aging Management Program

ML100220066
Person / Time
Site:	Kewaunee
Issue date:	01/21/2010
From:	Hartz L Dominion, Dominion Energy Kewaunee
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
09-777, FOIA/PA-2010-0209
Download: ML100220066 (52)

Text

Dominion Energy Kewaunee, Inc.

5000 Dominion Boulevard, Glen Allen, VA 23060 January 21, 2010 United States Nuclear Regulatory Commission Serial No.: 09-777 Attention: Document Control Desk LR/MWH RO Washington, DC 20555-0001 Docket No.: 50-305 License No.: DPR-43 DOMINION ENERGY KEWAUNEE, INC.

KEWAUNEE POWER STATION RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE KEWAUNEE POWER STATION LICENSE RENEWAL APPLICATION-AGING MANAGEMENT REVIEW/AGING MANAGEMENT PROGRAM By letter dated December 3, 2009 (reference 1), the NRC provided a request for additional information regarding the aging management review results included in the license renewal application (LRA) for Kewaunee Power Station (KPS) (reference 2).

The NRC staff indicated that responses to each request for additional information (RAls) are needed to complete the review of the KPS LRA. Attachment 1 to this letter provides the Dominion Energy Kewaunee Inc. (DEK) responses to each of the RAls submitted by the NRC staff in reference 1.

On October 22, 2009, a conference call was conducted between the NRC and DEK to discuss DEK responses to RAls regarding neutron absorbing materials (Boral/Boron Carbide) in the KPS spent fuel pools. During the teleconference, the NRC staff indicated that additional information associated with the responses to RAls 3.3.2.2.6-1, 3.3.2.2.6-2, and 3.3.2.2.6-3 (provided by DEK letter dated August 6, 2009 (reference 4))

is required for the staff to complete their evaluation. NRC letter dated November 27, 2009 (reference 5) documents the teleconference and the DEK commitment to supplement the responses to these RAls. Attachment 2 to this letter contains the requested information related to neutron absorbing materials in the KPS spent fuel pools.

On December 14, 2009, a telephone conference call was conducted between the NRC and DEK (reference 6) to discuss information submitted by DEK related to the Work Control Process program. The information was submitted in a letter dated September 25, 2009 (reference 7). During the teleconference, the NRC staff indicated that certain tables provided in the letter included inconsistent footnote reference information. to this letter contains replacement tables that correct the footnote references.

In reference 6, the NRC provided a correction to the numbering for one RAI transmitted in reference 1. The corrected numbering is reflected in attachment 1.

Serial No.09-777 Docket No. 50-305 Page 2 of 4 Should you have any questions regarding this submittal, please contact Mr. Paul C.

Aitken at (804) 273-2818.

Very truly yours,

~¥ Vice President - Nuclear Support Services COMMONWEALTH OF VIRGINIA COUNTY OF HENRICO Attachments:

1. Response to Request for Additional Information Regarding the Kewaunee Power Station License Renewal Application.

2. Supplemental Responses to RAls 3.3.2.2.6-1, 3.3.2.2.6-2, and 3.3.2.2.6-3.

3. Amendment to Dominion Energy Kewaunee, Inc. Letter 09-597 for Work Control Process Aging Management Program Supplement Table Corrections.

References:

1. Letter from Samuel Hernandez (NRC) to David A. Heacock (DEK), "Request for Additional Information for the Review of the Kewaunee Power Station License Renewal Application - Aging Management Review/Aging Management Program (TAC No.MD9408)," dated December 3, 2009. [ADAMS Accession No.

ML0932400950]

2. Letter from D. A. Christian (DEK) to NRC, "Kewaunee Power Station Application for Renewed Operating License," dated August 12, 2008. [ADAMS Accession No.

ML082341020]

Serial No.09-777 Docket No. 50-305 Page 3 of 4

3. Letter from Stephen E. Scace (DEK) to NRC, "Response to Request for Additional Information for the Review of the Kewaunee Power Station License Renewal Application - Aging Management Programs," dated August 17, 2009. [ADAMS Accession No. ML092320093]

4. Letter from Leslie N. Hartz (DEK) to NRC, "Response to Request for Additional Information for the Review of the Kewaunee Power Station License Renewal Application - Leak Before Break I Boral," dated August 6, 2009. [ADAMS Accession No. ML092230618]

5. Notes of Teleconference from Samuel Hernandez (NRC) to Dominion Energy Kewaunee, Inc., "Summary of Telephone Conference Call Between Dominion Energy Kewaunee, Inc. and U.S. Nuclear Regulatory Commission to Discuss the Surveillance and Aging Management of Its Neutron Absorbing Material (TAC No.

MD9408)," dated November 27,2009. [ADAMS Accession No. ML093230257]

6. Notes of Teleconference from Samuel Hernandez (NRC) to Dominion Energy Kewaunee, Inc., "Summary of Telephone Conference Call on December 14,2009, Between Dominion Energy Kewaunee, Inc. and U.S. Nuclear Regulatory Commission to Discuss Tables Referenced in the Work Control Process Amendment Letter (TAC No. MD9408)," dated December 16, 2009. [ADAMS Accession No. ML093431339]

7. Letter from Leslie N. Hartz (DEK) to NRC, "Supplemental Information for the Review of the Kewaunee Power Station License Renewal Application - Changes to the Work Control Process Aging Management Program," dated September 25, 2009. [ADAMS . Accession No. ML092710045]

.

Commitments made in this letter:

1. License Renewal Commitment 37 will be added to LRA Table A6.0-1 consistent with the response to RAI 3.2.2.2.2. The new commitment is proposed to support approval of the renewed operating license, and may change during the NRC review period.

2. License Renewal Commitment 38 will be added to LRA Table A6.0-1 consistent with the supplemental response to RAI 3.3.2.2.6-1. The new commitment is proposed to support approval of the renewed operating license, and may change during the NRC review period.

3. License Renewal Commitment 39 will be added to LRA Table A6.0-1 consistent with the supplemental response to RAI 3.3.2.2.6-2. The new commitment is proposed to support approval of the renewed operating license, and may change during the NRC review period.

Serial No.09-777 Docket No. 50-305 Page 4 of 4 cc: u.s. Nuclear Regulatory Commission Regional Administrator, Region III 2443 Warrenville Road Suite 210 Lisle, IL 60532-4532 Mr. P. S. Tam, Senior Project Manager U.S. Nuclear Regulatory Commission One White Flint, Mail Stop 08-H4A 11555 Rockville Pike Rockville, MD 20852-2738 Ms. V. Perin Environmental Project Manager U.S. Nuclear Regulatory Commission Mail Stop 0-11 F1 Washington, DC 20555-0001 Mr. John Daily License Renewal Project Manager U.S. Nuclear Regulatory Commission Mail Stop 0-11 F1 Washington, DC 20555-0001 NRC Senior Resident Inspector Kewaunee Power Station N490 Highway 42 Kewaunee, WI 54216 Public Service Commission of Wisconsin Electric Division P.O. Box 7854 Madison, WI 53707 David Hardtke Chairman - Town of Carlton E2334 Lakeshore Road Kewaunee, WI 54216

Serial No.09-777 Docket No. 50-305 ATTACHMENT 1 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING THE KEWAUNEE POWER STATION LICENSE RENEWAL APPLICATION KEWAUNEE POWER STATION DOMINION ENERGY KEWAUNEE, INC.

Serial No.09-777 Docket No. 50-305 Attachment 1/Page 1 of 23 RAI 82.1.8-4

Background

Exception 1 in license renewal application (LRA) Section B2. 1.8 states that corrosion inhibitors are not used in the Control Room Air Conditioning System because this system interconnects with the Service Water System, which provides an alternate safety-related cooling mode. The applicant stated that periodic testing of this mode would release any inhibitors to the environment. The applicant also stated that, in lieu of the use of corrosion inhibitors, the system is periodically sampled to verify system integrity. The applicant further stated that periodic visual inspections of system components are petformed under the plant-specific Work Control Process (WCP)

Program.

Issue Electric Power Research Institute (EPRI) TR-1007820 allows for the operation of closed cooling water systems without the addition of inhibitors, provided proper water chemistry is maintained. Specifically, EPRI TR-1007820 states that control of dissolved oxygen is particularly important for systems containing copper or copper alloys. The report recommends that dissolved oxygen either be maintained at <100 ppb to stabilize the cuprous oxide film on component sutfaces or that it be maintained at >2000 ppb to stabilize the cupric oxide film. Operation at dissolved oxygen levels between these two limits is specifically warned against, since it results in alternate formation and breakdown of the two oxides and resulting loss of the protective film. The staff notes that the applicant does not state the limits on dissolved oxygen level in the Control Room Air Conditioning System or in which of the two EPRI-recommended dissolved oxygen level regimes this system operates.

Request Please clarify the limits on dissolved oxygen level in the Control Room Air Conditioning System and specify in which of the two EPRI-recommended dissolved oxygen level regimes this system operates. If the limits on dissolved oxygen in the Control Room Air Conditioning System are not maintained within the levels that are recommended by EPRI TR-1007820, provide further details on how inspection procedures under the applicant's WCP are used to verify that corrosion of copper alloy components is not occurring. Include information on water sampling for the presence of dissolved and/or suspended copper indicative of copper alloy corrosion.

DEK Response The dissolved oxygen level in the Control Room Air Conditioning System is not monitored. The water chemistry parameters monitored for the system, in accordance with the Closed-Cycle Cooling Water System program, include adenosine triphosphate (ATP), conductivity, copper, iron, pH, and suspended solids. The acceptance criteria for these parameters are consistent with EPRI TR-1007820, "Closed Cooling Water

Serial No.09-777 Docket No. 50-305 Attachment 1/Page 2 of 23 Chemistry Guideline." If significant corrosion of copper alloy components were to occur, it would be indicated by elevated copper levels.

In addition, to verify that degradation of the copper alloy components is not occurring, the Control Room Air Conditioning System will be subject to inspection under the One-Time Inspections portion of the Work Control Process program as confirmation of the effectiveness of the Closed-Cycle Cooling Water System program. The One-Time Inspections program will use non-destructive examination techniques (visual and/or volumetric examinations) to monitor the aging effects of the copper alloys in the system.

The combination of routine monitoring for copper content in the Control Room Air Conditioning System cooling water and one-time inspection of the subject copper alloy components ensures that the system is not experiencing significant corrosion of copper alloy components.

Serial No.09-777 Docket No. 50-305 Attachment 1/Page 3 of 23 RAI 3.3.2.1-1

Background

Steel tanks when in contact with soil and or concrete environments, at the inaccessible interface (between soil or concrete), can undergo corrosion and or loss of material. The Generic Aging Lessons Learned (GALL) Report for these aboveground steel tanks recommends such aging effects to be managed through aging management program (AMP) XI.M29, Above Ground Steel Tanks." This AMP discusses how to manage loss of material, general corrosion of the tanks' external viewable surfaces, as well as those that are in inaccessible areas, e.g., at the Interface between soil or concrete at the bottom of the tank. The GALL Report, in order to prevent moisture and water to accumulate under the steel tanks, emphasizes the installation and maintenance of pristine seals around the tanks' bottoms, assuring, thus, the existence and adequacy of a moisture barrier.

Issue In the LRA, Kewaunee Power Station (KPS) indicates aging effects for the Diesel Generator Expansion Tanks will be managed with the GALL Report AMP XI.M36, "External Surfaces Monitoring." This AMP manages loss of material for steel and related corrosion aging effects. The GALL Report, however, recommends for aboveground steel tanks aging effects to be managed with AMP XI.M29. There are significant differences between the two AMPs. The AMP XI.M36 is a condition monitoring program, while AMP XI.M29 is a preventive measures program. XI.M36 is based on visual inspections, periodic walkdowns, with sampling allowed. AMP XI.M29 consists of the same approach for walkdowns and visual inspections. It differs from AMP XI.M36 in the protection mode of surfaces from corrosion (program element, scope of program). AMP XI.M29 recommends paint to be applied at exposed tank surfaces and caulking or sealant at the interface of the tank when supported by a slab or foundation (program element, preventive actions). AMP XI.M36 ascribes to qualification of personnel performing the Inspections. Caulking, sealant, and paint are inspected by AMP XI.M29 vs paint as designated In the AMP XI.M36 (program element, parameters monitored/inspected). In addition to these visually observed quantities, AMP XI.M29 also recommends inspecting personnel to track via ultrasonic testing (UT) the thickness of tank bottoms, when in contact with the ground to assure significant degradation is not occurring (program element, detection of aging effects).

Request

• Are the elevated expansion tanks detached or attached to the ground (concrete slab/foundation)? State their location, elevation, and accessibility for performance of full visual inspections.

• State the frequency of inspections.

Serial No.09-777 Docket No. 50-305 Attachment 1/Page 4 of 23 DEK Response The component type "Expansion Tanks" identified in LRA Table 3.3.2-19 includes the jacket water expansion tanks for the emergency diesel generators and the jacket water expansion tank for the Technical Support Center (TSC) diesel generator.

The emergency diesel generator jacket water expansion tank is mounted on the associated emergency diesel generator skid located in the basement (586 ft. elevation) of the Administration Building. The tank is located approximately 8 ft. above the skid.

The emergency diesel generators are operated on a monthly basis to satisfy Technical Specification surveillance requirements, which provides the opportunity to visually inspect the condition of the tank external surfaces as described in LRA Section B2.1.1 0, External Surfaces Monitoring.

The jacket water expansion tank for the TSC diesel generator is located on the roof of the TSC Building, at the 606 ft. elevation, approximately 7 ft. above the roof. The 14 gallon tank is supported by the steel frame of the TSC diesel generator radiator. The TSC diesel generator is operated on a monthly basis to satisfy Technical Requirements Manual surveillance requirements, which provides the opportunity to visually inspect the condition of the tank external surfaces as described in LRA Section B2.1.10, External Surfaces Monitoring.

These expansion tanks are not in contact with soil or concrete. The expansion tanks are accessible for full visual inspection.

Serial No.09-777 Docket No. 50-305 Attachment 1/Page 5 of 23 RAI 3.3.2.2.3.3-1 Diesel Exhaust Piping

Background

Section 3.3.2.2.3.3, "Cracking due to Stress Corrosion Cracking" and Section 3.3.2.2.7.3, "Loss of Material due to General, Pitting, and Crevice Corrosion" of the Standard Review Plan for License Renewal Applications of Nuclear Power Plants (SRP-LR) identify cracking due to stress corrosion cracking (SCC) and loss of material as aging effects requiring management for steel and stainless steel diesel exhaust piping, piping components, and piping elements exposed to diesel exhaust. The applicant has credited the plant-specific AMP B2.1.32 WCP Program with managing this aging effect for the diesel engine exhaust piping, piping components, and piping elements.

Issue Section A. 1.2.3.4 Detection of Aging Effects of the SRP-LR describes the attributes of an acceptable plant-specific AMP which should be used to manage this aging effect.

The SRP-LR states that aspects such as method or technique, frequency, sample size, etc should be appropriate in order to ensure timely detection of aging effects. LRA Sections 3.3.2.2.3.3 and 3.3.2.2.7.3 describe the inspection frequency to be on an ongoing basis, dependent upon the preventive and corrective maintenance activities required for the components. The staff notes that preventive maintenance activities are typically done based on a schedule set in advance of the maintenance activity being performed. However, the LRA is not clear in defining the preventive maintenance activity schedule for diesel exhaust gas components. The lack of a schedule would bring into question the adequacy of preventive maintenance, as well as the frequency of the accompanying visual examinations to manage the loss of material and cracking aging effects.

Request Please clarify whether or not preventive maintenance will be done and whether or not actual inspections of the diesel exhaust gas components will be done during the scheduled preventive maintenance to manage the loss of material and cracking aging effects.

DEK Response As described in the response to RAJ 82.1.32-2, surveillance and maintenance activities will be identified that perform Internal Surfaces Monitoring inspections for each material-environment combination managed by the program. This will include the diesel exhaust gas components.

Serial No.09-777 Docket No. 50-305 Attachment 1/Page 6 of 23 Though the applicable scheduled surveillance and maintenance activities have not yet been identified, as stated in the Work Control Process program description, Exception 1, Element 4: Detection of Aging Effects (DEK Letter No.09-597 dated September 25, 2009 [ADAMS ML092710045]), an enhanced VT-1 NDE examination of the stainless steel diesel exhaust flexible connection will be performed to identify signs of cracking.

The remaining steel and stainless steel portions of the diesel exhaust will also be visually inspected to identify loss of material in conjunction with the enhanced VT-1 NDE examination of the diesel exhaust flexible connection.

Serial No.09-777 Docket No. 50-305 Attachment 1/Page 7 of 23 RAI 3.4.2.3 Secondary Water Chemistry AMP 8ackground LRA Tables 3.4.2-5, 3.4.2-6, 3.4.2-7, 3.4.2-8, 3.4.2-9, 3.4.2-10, 3.4.2-12, and 3.4.2-14 address the SCC of copper-alloy valves, auxiliary feedwater components, and heating steam components exposed to treated secondary water and/or steam. The applicant proposes to manage this aging effect through the use of its AMPs "Secondary Water Chemistry" and "Work Control Process" (LRA 82.1.28 and 82.1.32). The applicant also states that for the component, material and environment combination listed, the aging effect being considered is not included in the GALL Report (Generic Note H)

Issue In its review of LRA Tables 3.4.2-5, 3.4.2-6, 3.4.2-7, 3.4.2-8, 3.4.2-9, 3.4.2-10, 3.4.2-12, and 3.4.2-14, the staff confirmed that the GALL Report does not address this aging process for the specific components identified by the applicant. The staff also noted that aging management of SCC of specific copper-alloy components in contact with treated secondary water and/or steam is not addressed anywhere as a line item in the GALL Report tables. The staff further noted that the GALL Report states in Table IX.C that "copper-zinc alloys > 15% zinc are susceptible to stress corrosion cracking, selective leaching (except for inhibited brass), and pitting and crevice corrosion.

Additional copper alloys may be susceptible, such as aluminum bronze >8% aluminum. "

Request State whether the copper alloy components discussed in this section of the LRA are or may be susceptible to SCC. If susceptible components are present or are believed to be present, identify the limits on those chemical impurity species controlled by the applicant's Secondary Water Chemistry AMP that might promote SCC in these components.

DEK Response Industry operating experience has identified copper alloys containing greater than 15%

zinc or 8% aluminum as being susceptible to stress corrosion cracking (SCC) in an aqueous environment with dissolved oxygen concentrations greater than 100 ppb.

Equipment specifications identify copper alloys, including brass and bronze, as being acceptable for use in secondary systems at Kewaunee. Specific limits on zinc and/or aluminum content are not always specified. Therefore, SCC was conservatively assumed as an aging effect for copper alloys identified only as brass or bronze in the equipment specifications, since the zinc and/or aluminum content was not specifically specified.

Impurities in the Treated Water and/or Steam - Secondary environment are maintained within industry standard limits as described in LRA Section 82.1.28, Secondary Water

Serial No.09-777 Docket No. 50-305 Attachment 1/Page 8 of 23 Chemistry. Action Level limits are established as part of this program to limit dissolved oxygen concentration in this environment to less than 100 ppb during plant operation.

Serial No.09-777 Docket No. 50-305 Attachment 1/Page 9 of 23 RAI3.1.2.2.7 Vessel Flange Leakage Monitor Lines

Background

In LRA Table 3.1.2-1, the applicant proposes to manage cracking/SCC in the stainless steel vessel flange leakage monitor lines exposed to primary reactor coolant water through the use of its AMPs, "Primary Water Chemistry" and "Work Control Process (WCP)" (LRA B2.1.24 and B2.1.32). The vessel flange leak monitor lines require management so leakage from them, if it occurred, has no adverse impact on other components inside containment. SRP-LR Section 3.1.2.2.7 requires that a plant-specific AMP be evaluated to ensure this aging effect is adequately managed, since existing programs may not be capable of mitigating or detecting crack initiation and growth due to SCC in the vessel flange leak monitor line.

Issue The applicant states that the service environment for this austenitic stainless steel component is primary water. However, the staff noted in its review that the normal internal environment for the flange leakage monitor line is air, and the line would see reactor coolant only when there is a leak at the inner reactor vessel closure flange D-ring. The staff determined that the applicant's Primary Water Chemistry program is of little value in mitigating SCC in a line that is intermittently exposed to stagnant reactor coolant, particularly when that coolant is subject to the absorption of oxygen and possible concentration of other impurities from the environment in the line. The staff also noted that control of the water chemistry in the stagnant coolant intermittently present in the line is extremely difficult under any water chemistry program. The staff therefore concluded that effective management of degradation due to SCC for this component must be accomplished primarily through periodic inspection rather than through water chemistry control. The staff questions the efficacy the applicant's WCP Program, which it proposes to be an alternative to XI. M32, to detect crack initiation in the components under consideration.

Request LRA Section 3.1.2.2.7.1 utilizes the Primary Water Chemistry and the WCP AMPs.

Hence, leakage occurring after a one-time inspection will not be discovered and its impact on other components will not be assessed. Provide additional justification to demonstrate that the applicant's WCP AMP is effective on an ongoing basis in detecting cracks in the vessel flange leakage monitor lines exposed to treated primary coolant water. The justification should include a summary of industry experience with flawed vessel flange leak detection lines to demonstrate that failure of these lines is unlikely to occur.

Serial No.09-777 Docket No. 50-305 Attachment 1/Page 10 of 23 DEK Response For the reactor vessel flange leakage monitor lines, the One-Time Inspection program within the Work Control Process program, as described in DEK letter 09-597 dated September 25, 2009 [ADAMS ML092720184], will provide verification of the effectiveness of the Primary Water Chemistry program for management of cracking due to stress corrosion cracking. The One-Time Inspection program within the Work Control Process program, which is consistent with NUREG-1801, Generic Aging Lessons Learned (GALL) Report,Section XI.M32, "One-Time Inspection," uses NDE techniques that have been determined to be effective for the identification of stress corrosion cracking in stainless steel. The inspections will be conducted to verify that unacceptable degradation is not occurring for material and environment combinations that include stainless steel in primary treated water. Indications of degradation would result in an engineering review of the condition through the Corrective Action Program and could result in further corrective actions, such as an expansion of the inspection scope, and a periodic inspection plan.

During normal operation, these lines are typically dry, and are only internally exposed to primary water should the vessel flange leak due to O-ring failure. In that case, potential RCS leakage would be limited by the 3/16 inch diameter orifice in the reactor pressure vessel flange. During refueling, the lines are filled with water when the reactor cavity is flooded and drained prior to plant heat-up.

A review of industry operating experience identified two instances of cracking due to SCC in these lines. Calvert Cliffs (1994) and Davis-Besse (2002) identified transgranular stress corrosion cracking (TGSCC) in these lines. The TGSCC was attributed to high concentrations of chlorides coupled with stagnant water at high temperatures in the reactor vessel flange leakage monitor lines. As a corrective measure, both stations revised procedures to ensure that the lines are drained prior to plant heat-up to mitigate the conditions that contributed to the SCC. Kewaunee procedures already require draining the lines prior to plant heat-up, which prevents the conditions and environment for SCC as identified in the industry OE. A review of Kewaunee plant-specific operating experience identified no instances of cracking due to SCC for reactor vessel flange leakage monitor lines.

Therefore, the One-Time Inspection program within the Work Control Process, which provides for verification of the effectiveness of Primary Water Chemistry program, provides an inspection that either verifies that unacceptable degradation is not occurring or results in additional actions that assure the intended function of affected components will be maintained during the period of extended operation.

Serial No.09-777 Docket No. 50-305 Attachment 1/Page 10 of 23 DEK Response For the reactor vessel flange leakage monitor lines, the One-Time Inspection program within the Work Control Process program, as described in DEK letter 09-597 dated September 25, 2009 [ADAMS ML092720184], will provide verification of the effectiveness of the Primary Water Chemistry program for management of cracking due to stress corrosion cracking. The One-Time Inspection program within the Work Control Process program, which is consistent with NUREG-1801, Generic Aging Lessons Learned (GALL) Report,Section XI.M32, "One-Time Inspection," uses NDE techniques that have been determined to be effective for the identification of stress corrosion cracking in stainless steel. The inspections will be conducted to verify that unacceptable degradation is not occurring for material and environment combinations that include stainless steel in primary treated water. Indications of degradation would result in an engineering review of the condition through the Corrective Action Program and could result in further corrective actions, such as an expansion of the inspection scope, and a periodic inspection plan.

During normal operation, these lines are typically dry, and are only internally exposed to primary water should the vessel flange leak due to O-ring failure. In that case, potential RCS leakage would be limited by the 3/16 inch diameter orifice in the reactor pressure vessel flange. During refueling, the lines are filled with water when the reactor cavity is flooded and drained prior to plant heat-up.

A review of industry operating experience identified two instances of cracking due to SCC in these lines. Calvert Cliffs (1994) and Davis-Besse (2002) identified transgranular stress corrosion cracking (TGSCC) in these lines. The TGSCC was attributed to high concentrations of chlorides coupled with stagnant water at high temperatures in the reactor vessel flange leakage monitor lines. As a corrective measure, both stations revised procedures to ensure that the lines are drained prior to plant heat-up to mitigate the conditions that contributed to the SCC. Kewaunee procedures already require draining the lines prior to plant heat-up, which prevents the conditions and environment for SCC as identified in the industry OE. A review of Kewaunee plant-specific operating experience identified no instances of cracking due to SCC for reactor vessel flange leakage monitor lines.

Therefore, the One-Time Inspection program within the Work Control Process, which provides for verification of the effectiveness of Primary Water Chemistry program, provides an inspection that either verifies that unacceptable degradation is not occurring or results in additional actions that assure the intended function of affected components will be maintained during the period of extended operation.

Serial No.09-777 Docket No. 50-305 Attachment 1/Page 11 of 23 RAI 3.2.2.2.2 - Loss of Material Due to Cladding Breach

Background

SRP-LR Section 3.2.2.2.2 notes that loss of material due to cladding breach could occur for pressurized-water reactor steel pump casings with stainless steel cladding exposed to treated borated water, and recommends further evaluation of a plant-specific AMP to ~

ensure that the aging effect is adequately managed. The corresponding section of the KPS LRA notes that the failures in the referenced U. S. Nuclear Regulatory Commission Information Notice pertained to manufacturing at the Pacific Pump Division of Dresser Industries and were not related to aging. The KPS LRA continued by stating that the safety injection pumps at the KPS were manufactured by Sulzer Bingham, and since there was no operating experience related to loss of material due to cladding breach in Sulzer Bingham pumps, this item was not applicable.

Issue According to the KPS USAR Table 6.2-6, the safety injection pumps are carbon steel forgings with stainless steel cladding. The lack of operating experience related to loss of material due to cladding breach in Sulzer Bingham pumps is an insufficient basis to ensure that this aging effect is being managed.

Although the information notice in question may have specifically cited the Pacific Pump Division of Dresser Industries, information notices are used to inform the nuclear industry of recently-identified, significant operating experience that may have generic applicability. In doing so, specific examples of the phenomenon in question are included; however, these examples should not be viewed as a limitation on applicability.

The conditions which resulted in the corrosion of the listed pumps could exist for other carbon steel pumps with stainless steel cladding, and therefore, they could similarly corrode unless an aging management program is implemented. The GALL Report recommends further evaluation of a plant-specific Aging Management Program, which meets the acceptance criteria described in Branch Technical Position RLSB-1.

Request Provide a plant-specific AMP, which meets the acceptance criteria described in Branch Technical Position RLSB-1, to ensure that this aging effect, the loss of material due to cladding breach, for the pumps in question, is adequately managed.

DEK Response The response to RAJ 3.3.2.2.14-1 (DEK letter 09-680 dated November 13, 2009

[ML093170751]) stated that the industry issue related to charging pump cladding breach (Reference NRC Information Notices (IN) 80-38, Cracking in Charging Pump Casing Cladding, and 94-63, Boric Acid Corrosion of Charging Pump Casing Caused by

Serial No.09-777 Docket No. 50-305 Attachment 1/Page 12 of 23 Cladding Cracks) is not applicable to Kewaunee's Sulzer-Bingham safety injection pumps because the cladding breach that occurred in the industry was the result of the manufacturing process used for these Dresser Industries - Pacific Pump Division charging pumps.

However, to address NRC staff concerns, a visual (VT-1) examination of one safety injection pump will be performed as a leading indicator prior to the period of extended operation to ensure there are no signs of stainless steel cladding cracking or corrosion.

As described in IN 94-63, visible rust-like stains may be indicative of a cladding breach and corrosion of the underlying carbon steel casing material. If degradation is identified, the condition will be entered into the Corrective Action Program and an engineering evaluation will be performed to determine necessary actions.

The following commitment will be added to LRA Appendix A, USAR Supplement, Table A6.0-1 :

Item Commitment Source Schedule 37 Perform a VT-1 visual examination of the Letter 09-777 Prior to the stainless steel cladding of a safety Response to Period of injection pump for indications of cracking RAI 3.2.2.2.2. Extended or corrosion due to cladding breach. Operation

Serial No.09-777 Docket No. 50-305 Attachment 1/Page 13 of 23 RAI 82.1.32-1

Background

In Dominion Energy Kewaunee, Inc. (DEK) Letter No.09-597, dated September 25, 2009, the applicant amended its LRA to change the WCP from a plant-specific AMP to an AMP that is consistent with GALL Report AMP XI.M32, "One- Time Inspection" (with an enhancement). For those AMR line items in the LRA in which the Primary Water Chemistry Program (LRA AMP B2.1.24), Secondary Water Chemistry Program (LRA AMP B2.1.28), Closed-Cycle Cooling Water Program (LRA AMP B2.1.8), Fuel Oil Chemistry Program (LRA AMP B2. 1.14), or Lubricating Oil Analysis Program (LRA AMP B2. 1. 17) the applicant identifies that the WCP will be used to verify these program's effectiveness and that the sample size of the one-time inspections will be based on an assessment of material, environment, plausible aging effects and operating experience.

Issue Although the applicant's sampling basis is consistent with the sampling basis statement in GALL Report AMP XI.M32, the staff notes that it does not clearly establish what the applicant's sampling basis would be because (1) the AMP that is credited in the AMR line items manage multiple materia/-environment-aging effect combinations and (2) the applicant did not clearly establish whether the representative sample will be chosen from each "unique" materia/-environment-aging effect combination or will the representative sample be chosen from the collection of all materia/-environment-aging effect combination. In addition, the staff felt that additional explanations were needed on the type of factors that would be used to select component or structure locations for the one-time examinations. In addition, KLR-1336 indicates that methodology in EPRI Report No. 107514 may be used to select the sample of components that are inspected on a periodic basis under the WCP.

Request For those AMR line items in the LRA that credit the Primary Water Chemistry Program, Secondary Water Chemistry Program, Closed-Cycle Cooling Water Program, Fuel Oil Chemistry Program, or Lubricating Oil Analysis Program, clarify whether the WCP will inspect a representative sample of the component or structure populations for each "unique" materia/-environment-aging effect combination that is managed or whether some other type of sampling basis will be used. If another sampling basis is used, please justify its use.

Clarify which type of engineering, design, operational or operating experience considerations (e.g. stagnant areas for evidence of corrosion, high velocity flow areas for evidence of erosion or wear, etc.) will be used to select the representative sample of components for the one-time Inspections.

Serial No.09-777 Docket No. 50-305 Attachment 1/Page 14 of 23 Explain why these considerations are considered sufficient to justify the sample of components that are selected, particularly if a given sample is used to represent more than one materia/-environment-aging effect combination in the AMR tables of the LRA.

In addition, justify how the methodology in EPRI Report No. 107514 can be applied to the selection of components at Kewaunee Station, when the methodology in the report is only limited to component inspections in a limited number of systems of the Calvert Cliffs nuclear power station and when the report may only be relevant to PWR facilities that are part of the Combustion Engineering Owners Group.

DEK Response The One-Time Inspection program within the Work Control Process program will be implemented to perform inspections of a representative sample of plant SSCs in order to confirm the effectiveness of the Primary Water Chemistry, Secondary Water Chemistry, Closed-Cycle Cooling Water, Fuel Oil Chemistry, and Lubricating Oil Analysis programs. Management of aging effects by chemistry control programs has historically been effective, and degradation is not expected. The One-Time Inspection program will use a representative sampling approach to provide verification that degradation is not occurring. Sample size and location will be based on an assessment of the materials of fabrication, operating environments, plausible aging effects and operating experience associated with SSCs within the scope of the One-Time Inspection program.

The representative sample size and inspection locations will be determined based on the materials of fabrication for component groups for which chemistry program effectiveness verification is required. A sample size will be established for each material, based on the total population, consistent with the methodology discussed in Section 4, "Sampling Program Description" of EPRI TR-107514, Age.;.Related Degradation Inspection Method and Demonstration In Behalf of Calvert Cliffs Nuclear Power Plant License Renewal Application. For each material-based sample set, representative inspections will be performed for each operating environment in which in-scope equipment is exposed. All applicable aging effects will be evaluated during each inspection such that, in total, each unique combination of material, environment, and aging effect will be evaluated by the One-Time Inspection program inspections.

The specific inspection locations will be identified considering the bounding or leading components most susceptible to aging based on time in service, severity of operating conditions, and lowest design margins. In determining the leading components, factors such as the potential for aging due to component geometry (Le., pipe versus valve body) and environmental factors (e.g., stagnant or low flow areas) will be considered.

The One-Time Inspections sample size and inspection locations will be developed to ensure that a representative sample of material-environment combinations is selected

Serial No.09-777 Docket No. 50-305 Attachment 1/Page 15 of 23 with a focus on inspecting leading indicator components. This approach provides assurance that the aging of the components are being adequately managed.

As noted above, the methodology discussed in EPRI TR-107514 will be used only to determine the required sample size for the One-Time Inspections. Although the report is limited to component inspections in a limited number of systems at the Calvert Cliffs plant, the methodology provided in Section 4 of the report for determining the required sample size to obtain a desired confidence level as a function of population size is independent of reactor design and can be appropriately applied for determining the required sample size for Kewaunee.

Serial No.09-777 Docket No. 50-305 Attachment 1/Page 16 of 23 RAI 82.1.32-2

Background

In DEK Letter No.09-597, dated September 25, 2009, the applicant amended its LRA to change the WCP from a plant-specific AMP to an AMP that is consistent with GALL Report AMP XI.M38, "Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components" (with noted exceptions and an enhancement).

Issue The "detection of aging effects" element in GALL Report AMP XI.M38 states that locations for inspection should be chosen to include conditions likely to exhibit the aging effects and that the inspection intervals should be established such that they provide for timely detection of degradation. The staff has noted that the Dominion Technical Report KLR-1336 does not specifically establish or justify what the sample populations, sample sizes, and inspection frequencies would be for the periodic examinations that are performed in accordance with the WCP because the program is defined as a new, GALL-based program for the LRA.

Request Clarify why the visual examinations of those components that are actually scheduled for periodic maintenance are considered to be representative of those components that may not be inspected during the period of extended operation. Clarify how the results of the inspections will be applied to the population of components that may not be inspected under the program if aging is detected in the inspected components and how potential aging in the non-inspected will be addressed.

DEK Response Consistent with the NUREG-1801, Generic Aging Lessons Learned (GALL) Report,Section XI.M38, "Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components," the Internals Surfaces Monitoring program inspections will be performed during scheduled surveillance and maintenance activities, as part of the Work Control Process program described in DEK letter 09-597 dated September 25, 2009 [ADAMS ML092710045].

For each material-environment combination, sufficient internal surfaces inspections will be performed during scheduled surveillance and maintenance activities to provide an overall assessment of any aging degradation that may be occurring. A review of the scheduled surveillance and maintenance actiVities will be performed to select activities that will provide a set of inspections that will be representative of the components in the program. The review will consider component materials; operating environments; industry and plant-specific operating experience; engineering evaluations of equipment

Serial No.09-777 Docket No. 50-305 Attachment 1/Page 17 of 23 performance; and susceptibility to aging due to time in service, severity of operating conditions, and lowest design margins.

The selected scheduled surveillance and maintenance activities will be performed on a repetitive basis. The use of recurring surveillance and maintenance activities provides the ability to detect aging of the material-environment combination prior to loss of function.

Aging detected during the Internal Surfaces Monitoring program inspections will be documented and evaluated for applicability to similar components (Le., same material-environment combinations) within the total component population in accordance with the Corrective Action Program. An engineering review will be performed to evaluate the condition, the extent of the condition, and the need for corrective actions. The extent of the condition may require the inspection of additional plant equipment.

Implementation of the Internal Surfaces Monitoring program at Kewaunee will require Engineering personnel to: (1) review the program inspection results to identify any new aging effects not previously considered, (2) monitor and/or perform walkdown activities to verify adequate identification and documentation of aging effects and initiation of corrective actions, (3) perform trending of inspection results, and (4) review site operating experience through the plant corrective action program to ensure that aging effects are addressed.

The combination of the Corrective Action Program evaluations and the engineering reviews discussed above provides reasonable assurance that the impact of identified aging will be considered for non-inspected components.

Serial No.09-777 Docket No. 50-305 Attachment 1/Page 18 of 23 RAJ 82.1.32-3

Background

In DEK Letter No.09-597, dated September 25, 2009, the applicant amended its LRA to change the WCP from a plant-specific AMP to an AMP that is consistent with GALL Report AMP XI.M38, "Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components" (with noted exceptions and an enhancement).

Issue The staff noted that the "detection of aging effects" element in GALL Report AMP XI. M38 states that the applicant should identify and justify the inspection technique used for detecting the aging effects of concern. The staff has noted that, although the applicant's basis document appropriately identifies that enhanced VT-1 techniques will be used to monitor for cracking by SCC, the applicant does not identify which type of specific visual inspection techniques would be used to monitor for loss of material or for reduction of heat transfer capability by fouling.

Request Clarify whether the visual inspection techniques that have been specified to detect for loss of material (corrosion, wear, erosion, etc.) and for reduction of heat transfer capability (fouling) during implementation of the one-time inspections of the program (i.e., the inspections that will be performed in accordance with GALL Report AMP XI. M32) also apply to the monitoring of these aging effects/mechanisms for the periodic inspections of the program (i.e., the inspections that will be performed in accordance with GALL Report AMP XI.M38). In addition, confirm that visual inspection techniques would be coupled with ,physical manipulation methods on applicable elastomeric components to monitor for cracking, crazing, discoloration, swelling, tackiness, or other aging effect parameters.

DEK Response Visual inspections that have been specified by the One Time Inspection program to detect loss of material (corrosion, wear, erosion, etc.) and reduction of heat transfer capability (fouling) are VT-1 and VT-3 examinations governed by the requirements of the Kewaunee non-destructive examination program. These examinations are performed by qualified NDE inspectors consistent with NUREG-1801, Generic Aging Lessons Learned (GALL) Report,Section XI.M32, "One-Time Inspection." The visual inspections to detect loss of material (corrosion, wear, erosion, etc.) and reduction of heat transfer capability (fouling) for the Internal Surfaces Monitoring program are performed by Maintenance Department personnel during routine maintenance and surveillance activities consistent with NUREG-1801,Section XI.M38, "Inspection of Internal Surfaces in Miscellaneous Piping and DUCting Components." These Internal Surfaces Monitoring inspections are not VT-1 or VT-3 visual examinations.

Serial No.09-777 Docket No. 50-305 Attachment 1/Page 19 of 23 As discussed in DEK letter 09-597 dated September 25, 2009 [ADAMS ML092710045],

Work Control Process Program Description, Exception 1, Element 4: Detection of Aging Effects, the visual inspection techniques that will be used by personnel implementing the Internal Surfaces Monitoring program are capable of detecting loss of material due to corrosion and reduction of heat transfer due to fouling by observing localized discoloration and surface irregularities such as rust, scale, deposits, surface pitting, surface discontinuities, and coating degradation. Maintenance personnel at Kewaunee are subject to a training and qualification program. As part of this program, personnel will receive specific training to provide the knowledge necessary to identify and document the effects of aging. Only personnel appropriately qualified through the Maintenance training program will perform Internal Surfaces Monitoring program inspections.

Physical manipulation of elastomeric components through the Internal Surfaces Monitoring program also includes visual inspections to monitor for cracking, crazing, discoloration, swelling, tackiness, or other aging effect parameters.

Serial No.09-777 Docket No. 50-305 Attachment 1/Page 20 of 23 RAI 82.1.32-4

Background

In DEK Letter No.09-597, dated September 25,2009, the applicant amended its LRA to change the WCP from a plant-specific AMP to an AMP that is consistent with GALL Report AMP XI.M38, "Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components" (with noted exceptions and an enhancement).

Issue The "acceptance criteria" element in GALL Report AMP XI. M38 states that acceptance criteria are established in the maintenance and surveillance procedures or other established plant procedures, and that, if the results are not acceptable, the corrective action program is implemented to assess the material condition and determine whether the component intended function is affected. The applicant states that the acceptance criterion is "no unacceptable wear, corrosion, cracking, change in material properties (for materials and non-metallics) or significant fouling. "

Request Clarify the intent (meaning) of the phrase "no unacceptable wear, corrosion, cracking, change in material properties (for materials and non-metallics) or significant fouling."

Specifically clarify whether the intent is to establish acceptance criterion in which no evidence of wear, corrosion, cracking, change in material properties, or significant fouling is acceptable, or whether the intent is to establish an acceptance criterion in which a certain amount of wear, corrosion, cracking, change in material properties, or significant fouling may be permitted as long as it is within the bounds that are established in implementing procedures.

DEK Response The intent of the phrase "no unacceptable wear, corrosion, cracking, change in material properties for elastomers, or fouling" included in DEK letter 09-597 dated September 25, 2009 [ADAMS ML092710045], under the Work Control Process program description, Exception 1, Element 6: Acceptance Criteria is that a certain amount of wear, corrosion, cracking, change in material properties, or fouling may be permitted as long as it is within the bounds that are established in implementing procedures.

Serial No.09-777 Docket No. 50-305 Attachment 1/Page 21 of ~3 RAI83.2-4a Background/Issue The applicant responded to RAI B3.2-4 in a letter dated August 17, 2009. The last paragraph of the response to RAI B3.2-4 states, "The differential temperature (L\ T) between the pressurizer and the reactor coolant loop is determined through a calculated plant computer data point that subtracts the greater of reactor coolant loop A or loop B wide range temperature from the pressurizer water temperature. "

However, in subtraction, the larger the deduction, the smaller the net will be. It follows that the L\ T (i.e., the net) calculated in accordance with the formula stated above is smaller than what you would get if you were subtracting the smaller of TA or TB from the pressurizer water temperature. Therefore, the L\ T values you obtained are non-conservative, considering that, L\ T represents potential of stress due to stratification and insurge/outsurge.

Request

• Demonstrate that the formula as described for the L\ T calculation is conservative.

• The need of correction of the L\ T data was identified in August 2006 but Westinghouse Commercial Atomic Power (WCAP)-12841 and WCAP-12842 that helped to close the Bulletin 88-11 request concerning the issue on the surge line stratification and insurge/outsurge for KPS were prepared in 1991. Justify that the WCAP analyses remain valid since the L\ T data, which the WCAP analyses based upon, are changed due to the corrections demanded by the 2006 incident.

DEK Response The pressurizer-to-reactor coolant loop differential temperature (11T) is used to indicate the relative severity of plant heatup and cooldown transients for thermal cycle tracking purposes. The 11T value is not used directly as an input to pipe or component stress determinations. The 11T is normally measured between the pressurizer and reactor coolant loop '8' hot leg since that is where the surge line connects the pressurizer to the reactor coolant system. However, in the event that the reactor coolant loop '8' hot leg temperature data point is out of service (as indicated by an abnormally low or zero reading), an acceptable approximation can be obtained by substituting the reactor coolant loop 'A' hot leg temperature data point.

The evaluations performed and documented in WCAP-12841 (and WCAP-12842, which is the non-proprietary version), Structural Evaluation of the Kewaunee Pressurizer Surge Line, Considering the Effects of Thermal Stratification, did not use the subject pressurizer-to-reactor coolant loop 11T data as an input. Therefore, the erroneously high

Serial No.09-777 Docket No. 50-305 Attachment 1/Page 22 of 23 l:1T indications had no effect on the results of these evaluations or the resolution of NRC Bulletin 88-11, Pressurizer Surge Line Thermal Stratification.

Serial No.09-777 Docket No. 50-305 Attachment 1/Page 23 of 23 RAI4.3-2a Background/Issue The applicant responded to RAI 4.3-2 in a letter dated August 17, 2009. The response to RAI 4.3-2 does not provide the historical dissolved oxygen data for the first 10 years of the plant history (1974 - 1984), although it covered the most recent 25 years.

Request

• Provide justification that, for the first 10 years of the plant operation (1974 through 1984), the KPS dissolved oxygen concentration in the reactor coolant system coolant was maintained at or below 0.05 ppm level.

DEK Response As discussed in the response to RAI 4.3-2 (DEK letter 09-469 dated August 17, 2009

[ADAMS ML092320093]), Kewaunee maintains an elevated hydrogen concentration in the reactor coolant during normal operation to ensure a low concentration of dissolved oxygen (DO). Reactor coolant chemistry data recorded since 1984 were reviewed and showed that DO is typically less than 0.005 ppm. The plant has operated with elevated hydrogen concentration since initial operations in 1973. Therefore, the DO concentrations during normal plant operation for the 1973 to 1984 operating period are expected to be consistent with the DO data recorded since 1984.

Serial No.09-777 Docket No. 50-305 ATTACHMENT 2 SUPPLEMENTAL RESPONSES TO RAls 3.3.2.2.6-1, 3.3.2.2.6-2, and 3.3.2.2.6-3 KEWAUNEE POWER STATION DOMINION ENERGY KEWAUNEE, INC.

Serial No.09-777 Docket No. 50-305 Attachment 2/Page 1 of 5 NRC Request On October 22, 2009, the U. S. Nuclear Regulatory Commission (NRC or the staff) conducted a conference call (teleconference) with representatives from Dominion Energy Kewaunee, Inc. (DEK). The purpose of the teleconference was to discuss DEK responses to the staff's requests for additional information (RAls) regarding the Kewaunee Power Station (KPS) Neutron Absorbing Material (Boral/Boron Carbide).

In a letter dated July 7, 2009 (Agencywide Documents and Access Management System [ADAMS] Accession Number ML091190389), the staff submitted its RAls related to KPS neutron absorbing material. In the RAI letter, the staff had three requests that were related to the Boral and Boron Carbide (RAls 3.3.2.2.6-1, 3.3.2.2.6-2, and 3.3.2.2.6-3). DEK responded to the staff's RAls on a letter dated August 6, 2009 (ADAMS Accession Number ML092230618). During the teleconference, the staff indicated that the responses to RAls 3.3.2.2.6-1, 3.3.2.2.6-2, and 3.3.2.2.6-3 did not provide enough information for the staff to make its evaluation. The main issue discussed during the teleconference is summarized below.

Need of a Program to assess the material condition of the neutron absorbing material

• The applicant does not have a program to assess the material condition of the Boral in the KPS spent fuel pool and transfer canal. The staff indicated that to have reasonable assurance that the aging of the material would be adequately managed during the period of extended operation, a program describing the frequency and attributes that would be monitored needs to be submitted for review. The staff believes that operating experience indicating that no degradation of the neutron absorbing material at KPS is not sufficient basis to conclude that degradation would not occur in the future.

As a result of the discussions, DEK indicated that they will supplement their responses to RAls 3.3.2.2.6-1, 3.3.2.2.6-2, and 3.3.2.2.6-3 to provide additional information to the staff regarding the use and implementation of a program to monitor and assess the condition of the neutron absorbing materials for Kewaunee.

RAI 3.3.2.2.6-1 Supplemental Response The existing boron carbide surveillance program, which includes neutron attenuation testing as described in the response to RAI 3.3.2.2.6-1 (DEK letter 09-451 dated August 6, 2009 [ADAMS ML092230618]), will continue to be performed during the period of extended operation. The testing will be performed every 3 years.

Serial No.09-777 Docket No. 50-305 Attachment 2/Page 2 of 5 The following commitment will be added to LRA Appendix A, USAR Supplement, Table A6.0-1 :

Item Commitment Source Schedule 38 The boron carbide surveillance Letter 09-777 During the program, which includes neutron Supplemental Period of attenuation testing, will continue to be Response to Extended performed during the period of RAI 3.3.2.2.6-1. Operation extended operation every 3 years.

Serial No.09-777 Docket No. 50-305 Attachment Z/Page 3 of 5 RAI 3.3.2.2.6-2 Supplemental Response As described in LRA Section 2.3.3.2, Boral is utilized as a neutron absorber in the Kewaunee fuel transfer canal pool storage racks. These racks consist of 215 cells and were placed in service September 2001. As discussed in the response to RAI 3.3.2.2.6-2 (DEK letter 09-451, dated August 6, 2009 [ADAMS ML092230618]), a review of plant-specific and industry operating experience did not identify any reason to conclude that degradation of the capability of the Boral spent fuel storage rack neutron absorber to perform its intended function would be expected with continued service. However, absent an additional basis to support that degradation will not occur in the future, Kewaunee will establish a surveillance program to monitor the performance of the Boral neutron absorber during the period of extended operation or, alternatively, will re-perform the Spent Fuel Pool Criticality Analysis such that no credit is taken for Boral in the spent fuel storage racks.

The surveillance program for these racks will consist of a periodic determination of the areal density of the Boral neutron absorber using an in-situ inspection technique (such as the currently available BADGER system). The initial test of Boral areal density will be performed prior to 2017 on at least five storage cells. This surveillance program plan is justified based on the following:

• There is no industry operating experience indicating a failure of Boral to attenuate neutrons in non-flux trap design storage racks.

• The Boral storage racks at Kewaunee have been in service for less than ten years, which is insufficient time for the occurrence of significant corrosion or other degradation of the Boral sheets.

• The racks contain relatively cool spent fuel assemblies, limited to those discharged from the reactor during or prior to the 1984 refueling outage, resulting in a less aggressive low temperature water environment near the racks.

• The gamma/neutron fluence to which the Boral is exposed from these assemblies is significantly less than from recently discharged fuel assemblies such that any effect of the neutron or gamma fluence from stored fuel assemblies on the Boral sheets is expected to be minor and evenly distributed.

Selection of the cells to be tested will consider those cells that are known to have routinely. been occupied with spent fuel. This will ensure that the test results will either bound or be fully representative of the untested rack cells.

The surveillance program will be perfQrmed every 10 years following the initial testing.

Kewaunee will continue to monitor industry operating experience related to Boral, and any necessary actionswill be initiated through the Corrective Action Program.

Serial No.09-777 Docket No. 50-305 Attachment 2/Page 4 of 5 The following commitment will be added to LRA Appendix A, USAR Supplement, Table A6.0-1 :

Item Commitment Source Schedule 39 A surveillance program will be Letter 09-777 Prior to 2017.

implemented to perform verification that Supplemental Surveillance the Boral spent fuel storage rack Response to program will neutron absorber B-1 0 areal density is RAI 3.3.2.2.6-2. be performed maintained within the bounds of the every 10 spent fuel pool criticality analysis. years Alternatively, the criticality analysis for thereafter.

the spent fuel pool will be revised to eliminate credit for the Boral neutron absorber material.

Serial No.09-777 Docket No. 50-305 Attachment 2/Page 5 of 5 RAI 3.3.2.2.6-3 Supplemental Response See the supplemental response to RAI 3.3.2.2.6-2 above.

Serial No.09-777 Docket No. 50-305 ATTACHMENT 3 AMENDMENT TO DOMINION ENERGY KEWAUNEE, INC. LETTER 09-597 FOR WORK CONTROL PROCESS AGING MANAGEMENT PROGRAM SUPPLEMENT TABLE CORRECTIONS KEWAUNEE POWER STATION DOMINION ENERGY KEWAUNEE, INC.

Serial No.09-777 Docket No. 50-305 Attachment 3/Page 1of 16 NRC Request On December 14, 2009, the U.S. Nuclear Regulatory Commission (NRC or the staff) conducted a telephone conference call (teleconference) with representatives from Dominion Energy Kewaunee, Inc (DEK). The purpose of the teleconference was to discuss the information presented by DEK on several tables of their Work Control Process Amendment letter dated September 25, 2009.

During the teleconference, the staff stated that information is missing from tables 3.3.2-6, 3.3.2-8, 3.3.2-14, 3.3.2-15, 3.3.2-19, 3.3.2-20, 3.3.2-22, 3.3.2-26, 3.3.2-27, 3.3.2-28, 3.4.2-1, 3.4.2-9, 3.4.2-10, 3.4.2-12, and 3.5.2-4. Specifically, the above mentioned tables make reference to footnotes that are not defined in the license renewal application (LRA) or the amendment letter.

As a result of the discussions, DEK indicated that they will amend the affected tables and that the information to be referenced in the amended tables would be available on the LRA.

DEK Supplemental Response DEK letter 09-597, dated September 25, 2009 [ADAMS ML092710045], submitted supplemental information for changes to the Work Control Process aging management program. Changes to LRA Table 2s were provided in Attachment 2 Part B: "LRA Section 3 Changes" in the table titled "Changes to LRA Table 3.x.2-y (Table 2)."

Some of the numeric footnotes in the "Notes" column of the table were incorrect and not consistent with the LRA "Notes." The numeric Notes should have been identical to those in the LRA, since there were no changes to the numeric Notes as part of the Letter 09-597 submittal.

To correct the erroneous numeric Notes provided in Letter 09-597, the attached table replaces the Letter 09-597, Attachment 2, Part B table "Changes to LRA Table 3.x.2-y (Table 2)" in its entirety. There are no other changes to this table other than to correct the numeric Notes.

Serial No.09-777 Docket No. 50-305 Attachment 3/Page 2 of 16 Chan{les to LRA Table 3.x.2-y (Table 21 Component Material Environment Aging Effect I Mechanism Aging NUREG-1801 Table 1 Item Notes LRA Page Type Management Vol. 2 Number Program Reference Table 3.2.2-2: Engineering Safety Features - Safety Injection - Aging Management Evaluation Pipe Stainless Raw water Loss of material/pitting, crevice, and Work Control ~ ~ H~;2 3-192 Steel microbiologically influenced Process corrosion Table 3.3.2-3: Auxiliary Systems - Spent Fuel Pool Cooling - Aging Management Evaluation Spent Fuel Pool Steel Raw water Loss of material/general, pitting, Work Control A-004 ~ H~ 3-324 Heat Exchanger crevice, galvanic, and Process Shell microbiologically influenced corrosion, and foulina Spent Fuel Pool Stainless Raw water Loss of material/pitting, crevice, and Work Control ~ ~ H~ 3-324 Heat Exchanger Steel microbiologically influenced Process Tubes corrosion, and foulina Spent Fuel Pool Stainless Raw water Loss of material/pitting, crevice, and Work Control ~ ~ H~ 3-325 Heat Exchanger Steel microbiologically influenced Process Tubesheet corrosion, and foulinq Table 3.3.2-6: Auxiliary Systems - Service Water - Aging Management Evaluation Filter Housings Stainless Raw water Loss of material/pitting and crevice Work Control VII.C1 15 ~ H~ 3-331 SWto Steel corrosion, and fouling Process chlorination pumps Flexible Hoses Stainless Raw water Loss of material/pitting and crevice Work Control VII.C1 15 ~ H~ 3-332 Steel corrosion, and foulina Process Flow Switches Copper Raw water Loss of material/pitting, crevice, and Work Control VII.C109 ~ H~;1 3-333 Alloys microbiologically influenced Process corrosion, and foulina Orifices Stainless Raw water Loss of material/pitting and crevice Work Control VII.C1 15 ~ H ~;1 3-333 Steel corrosion, and fouling Process Pipe Copper Raw water Loss of material/pitting, crevice, and Work Control VII.C109 ~ H~;1 3-334 Alloys microbiologically influenced Process corrosion, and foulina Sight Flow Copper Raw water Loss of material/pitting, crevice, and Work Control VII.C1 09 ~ H ~;1 3-337 Indicators Alloys microbiologically influenced Process corrosion, and fouling Standpipes Steel Raw water Loss of material/general, pitting, Work Control VII.C1 19 ~ H~;1;2 3-338 crevice, and microbiologically Process influenced corrosion, fouling, and lining-coating degradation

Serial No.09-777 Docket No. 50-305 Attachment 3/Page 3 of 16 Changes to LRA Table 3.x.2-yJTable 2)

Component Material Environment Aging Effect / Mechanism . Aging NUREG-1801 Table 1 Item Notes LRA Page Type Management Vol. 2 Number Program Reference Strainer Copper Raw water Loss of material/pitting, crevice, and Work Control VII.C1 09 ~ He;1 3-339 Housings Alloys microbiologically influenced Process corrosion, and foulinq Strainer Steel Raw water Loss of material/general, pitting, Work Control VII.C1 19 ~ He;1;2 3-339 Housings crevice, and microbiologically Process influenced corrosion, fOUling, and lininq-coating deqradation Tubing Copper Raw water Loss of material/pitting, crevice, and Work Control VII.C109 ~ H e;1 3-340 Alloys microbiologically influenced Process corrosion, and foulinq Tubing Stainless Raw water Loss of material/pitting and crevice Work Control VII.C1 15 ~ He;1 3-340 Steel corrosion, and fouling Process Tubing Steel Raw water Loss of material/general, pitting, Work Control VII.C1 19 ~ He;1;2 3-341 crevice, and microbiologically Process influenced corrosion, fouling, and Iinina-coatina dearadation Valves Copper Raw water Loss of material/pitting, crevice, and Work Control VII.C1 09 ~ H e;1 3-341 Alloys microbiologically influenced Process corrosion, and foulina Valves Stainless Raw water Loss of material/pitting and crevice Work Control VII.C1 15 ~ He;1 3-342 Steel corrosion, and foulina Process Valves Steel Raw water Loss of material/general, pitting, Work Control VII.C1 19 ~ He;1;2 3-342 crevice, and microbiologically Process influenced corrosion, fOUling, and lining-coating degradation Table 3.3.2-8: Auxiliary Systems - Station and Instrument Air - Aging Management Evaluation Aftercoolers Steel Raw water Loss of material/general, pitting, Work Control A-004 ~ He 3-356 Shell crevice, galvanic, and Process microbiologically influenced corrosion, and fouling Aftercoolers Copper Raw water Loss of material/pitting, crevice, Work Control A-OOa ~ He 3-357 Tubes Alloys galvanic, and microbiologically Process influenced corrosion, and foulina Aftercoolers Copper Raw water Reduction of heat transfer/fouling Work Control A-fJ+2 ~ He 3-357 Tubes Allovs Process Aftercoolers Steel Raw water Loss of material/general, pitting, Work Control A-004 ~ He 3-357 Tubesheets crevice, galvanic, and Process microbiologically influenced corrosion, and fouling

Serial No.09-777 Docket No. 50-305 Attachment 3/Page 4 of 16 Chanaes to LRA Table 3.x.2-v (Table 2)

Component Material Environment Aging Effect / Mechanism Aging NUREG-1801 Table 1 Item Notes LRA Page Type Management Vol. 2 Number Program Reference Compressors Steel Raw water Loss of material/general, pitting, Work Control ~ ~ H e;1 3-358 Housing crevice, and microbiologically Process influenced corrosion, fouling, and lininQ-coatinQ deQradation Traps Steel Air-moist Loss of material/general and pitting Work Control ¥J.h.Q.-@ ~ He 3-366 corrosion Process Traps Steel Raw water Loss of material/general, pitting, Work Control ~ ~ He;1 3-366 crevice, and microbiologically Process influenced corrosion, fouling, and lining-coatinQ deQradation Table 3.3.2-9: Auxiliary Systems - Chemical and Volume Control - Aging Management Evaluation Boric Acid Steel Raw water Loss of material/general, pitting, Work Control A-004 ~ He 3-371 Evaporator crevice, galvanic, and Process Distillate microbiologically influenced Sample Cooler corrosion, and fouling Shell Boric Acid Stainless Raw water Loss of material/pitting, crevice, and Work Control ~ ~ He 3-372 Evaporator Steel microbiologically influenced Process Distillate corrosion, and fouling Sample Cooler Tubing Table 3.3.2-13: Auxiliary Systems - Auxiliary Building Ventilation - Aging Management Evaluation Fan Coil Units Steel Raw water Loss of material/general, pitting, Work Control ~ ~ He 3-429 Drip Pans crevice, and microbiologically Process influenced corrosion, and fouling Table 3.3.2-14: Auxiliary Systems - Reactor Building Ventilation - Aging Management Evaluation Containment Stainless Raw water Loss of material/pitting and crevice Work Control ~ ~ He 3-435 Fan Coil Units Steel corrosion Process Drip Pan Drip Pans Steel Raw water Loss of material/general, pitting, Work Control ~ ~ He 3-435 Shroud Cooling crevice, and microbiologically Process Coils influenced corrosion, and fouling Pipe Stainless Raw water Loss of material/pitting and crevice Work Control ~ ~ He 3-438 Steel corrosion Process Table 3.3.2-15: Auxiliary Systems - Turbine Building and Screenhouse Ventilation - Aging Management Evaluation Fan Coil Units Copper Raw water Loss of material/pitting, crevice, Work Control A-Gea ~ H e;1 3-443 Cooling Alloys galvanic, and microbiologically Process Coils/Fins influenced corrosion, and fouling Fan Coil Units Copper Raw water Reduction of heat transfer/fouling Work Control ~ ~ H e;1 3-443 Cooling Alloys Process Coils/Fins

Serial No.09-777 Docket No. 50-305 Attachment 3/Page 5 of 16 Chanaes to LRA Table 3.x.2-y (Table 2)

Component Material Environment Aging Effect / Mechanism Aging NUREG-1801 Table 1 Item Notes LRA Page Type Management Vol. 2 Number Program Reference Fan Coil Units Steel Raw water Loss of material/general, pitting, Work Control ~ ~ He 3-444 Drip Pans crevice, and microbiologically Process influenced corrosion, and foulina Table 3.3.2-17: Auxiliary Systems - Technical Support Center Ventilation - Aging Management Evaluation Air Conditioning Steel Air-indoor Loss of material/general corrosion Work Control 'I.llh+-Q8 ~ He 3-451 Units uncontrolled Process Compressor Air Conditioning Steel Raw water Loss of material/general, pitting, Work Control ~ ~ He 3-451 Units crevice, and microbiologically Process Condenser Drip influenced corrosion, and fouling Pan Air Handling Steel Raw water Loss of material/general, pitting, Work Control ~ ~ He 3-452 Units Battery crevice, and microbiologically Process Room Coil Drip influenced corrosion, and fouling Pan Table 3.3.2-18: Auxiliary Systems - Fire Protection - Aging Management Evaluation Flexible Hoses Stainless Air-moist Loss of material/pitting and crevice Work Control AP-OO:I- ~ He 3-460 Steel corrosion Process Tubing Stainless Air-moist Loss*of material/pitting and crevice Work Control AP-OO:I- ~ He 3-466 Steel corrosion Process Valves Stainless Air-moist Loss of material/pitting and crevice Work Control AP-OO:I- ~ He 3-469 Steel corrosion Process Table 3.3.2-19: Auxiliary Systems - Diesel Generator - Aging Management Evaluation Flexible Stainless Treated water- Loss of material/pitting and crevice Work Control ~ ~ He;1;3 3-479 Connections Steel closed cycle corrosion Process includes cooling braided hoses Pipe Steel Raw water Loss of material/general, pitting, Work Control VII.H222 ~ He;2;4 3-485 crevice, and microbiologically Process influenced corrosion, fouling, and lining-coating dearadation Pumps Jacket Steel Treated water- Loss of material/general, pitting, Work Control VII.H2 2~ ~ H e;1;3 3-486 water cooling closed cycle and crevice corrosion Process cooling Radiator Tubes Copper Treated water- Loss of material/pitting, crevice, and Work Control VII.H208 ~ He;1;3 3-487 Alloys closed cycle galvanic corrosion Process cooling Sight Glass Stainless Treated water- Loss of material/pitting and crevice Work Control ~ ~ H e;1;3 3-488 Steel closed cycle corrosion Process cooling Table 3.3.2-20: Auxiliary Systems - Circulating Water - Aging Management Evaluation

Serial No.09-777 Docket No. 50-305 Attachment 3/Page 6 of 16 Changes to LRA Table 3.x.2-y (Table 2)

Component Material Environment Aging Effect / Mechanism Aging NUREG-1801 Table 1 Item Notes LRA Page Type Management Vol. 2 Number Program Reference Chlorine Steel Raw water Loss of material/general, pitting, Work Control VILC310 ~ He;3 3-499 Monitoring crevice, and microbiologically Process Water Pump influenced corrosion, fouling, and lining-coating degradation Circulating Steel Raw water Loss of material/general, pitting, Work Control VILCa 10 ~ He;3 3-499 Water Pumps crevice, and microbiologically Process influenced corrosion, fouling, and lining-coating degradation Condensers Steel Raw water Loss of material/general, pitting, Work Control VILCa 10 ~ He;3 3-500 Waterboxes crevice, and microbiologically Process influenced corrosion, fouling, and Iinina-coatina degradation Flow Elements Stainless Raw water Loss of material/pitting and crevice Work Control '!ILCa 07 ~ He 3-500 Steel corrosion Process Flow Indicators Copper Raw water Loss of material/pitting, crevice, and Work Control A-Q44 ~ He 3-501 Alloys microbiologically influenced Process corrosion, and fouling Flow Indicators Stainless Raw water Loss of material/pitting and crevice Work Control VILCa 07 ~ He 3-501 Steel corrosion Process Pipe Stainless Raw water Loss of material/pitting and crevice Work Control VILCa 07 ~ He 3-502 Steel corrosion Process Pipe Steel Raw water Loss of material/general, pitting, Work Control '!ILCa 10 ~ He;2;3 3-503 crevice, and microbiologically Process influenced corrosion, fouling, and Iinina-coatina dearadation Recirculating Steel Raw water Loss of material/general, pitting, Work Control VILCa 10 ~ He;3 3-503 Water Pump crevice, and microbiologically Process influenced corrosion, fouling, and lining-coating degradation Tubing Copper Raw water Loss of material/pitting, crevice, and Work Control A-Q44 ~ He 3-504 Alloys microbiologically influenced Process corrosion, and fouling Tubing Stainless Raw water Loss of material/pitting and crevice Work Control VILCa 07 ~ He 3-504 Steel corrosion Process Tubing Steel Raw water Loss of material/general, pitting, Work Control VILCa 10 ~ He;3 3-504 crevice, and microbiologically Process influenced corrosion, fouling, and Iinina-coatina dearadation Valves Copper Raw water Loss of material/pitting, crevice, and Work Control A-Q44 ~ He 3-504 Alloys microbiologically influenced Process corrosion, and fouling

Serial No.09-777 Docket No. 50-305 Attachment 3/Page 7 of 16 Chanaes to LRA Table 3.x.2-v (Table 2)

Component Material Environment Aging Effect I Mechanism Aging NUREG-1801 Table 1 Item Notes LRA Page Type Management Vol. 2 Number Program Reference Valves Stainless Raw water Loss of material/pitting and crevice Work Control VII.CJ 07 ~ He;2 3-505 Steel corrosion Process Valves Steel Raw water Loss of material/general, pitting, Work Control VII.CJ 10 ~ He;3 3-505 crevice, and microbiologically Process influenced corrosion, fouling, and Iinino-coatino deoradation Table 3.3.2-21: Auxiliary Systems - Gaseous Waste Processing and Discharge - Aging Management Evaluation Filter Housings Stainless Air-moist Loss of material/pitting and crevice Work Control AP-W ~ He 3-507 Steel corrosion Process Heat Steel Raw water Loss of material/general, pitting, Work Control ~ ~ He 3-508 Exchangers crevice, and microbiologically Process Shell influenced corrosion, and foulino Heat Copper Raw water Loss of material/pitting, crevice, and Work Control A-Q44 ~ He 3-509 Exchangers Alloys microbiologically influenced Process Tubes corrosion, and fouling Heat Steel Raw water Loss of material/general, pitting, Work Control ~ ~ He 3-509 Exchangers crevice, and microbiologically Process Tubesheet influenced corrosion, and fouling Moisture Steel Raw water Loss of material/general, pitting, Work Control ~ ~ He 3-510 Separators crevice, and microbiologically Process influenced corrosion, and fouling Orifices Stainless Air-moist Loss of material/pitting and crevice Work Control AP-W ~ He 3-510 Steel corrosion Process Orifices Stainless Raw water Loss of material/pitting, crevice, and Work Control ~ ~ He 3-510 Steel microbiologically influenced Process corrosion Pipe Stainless Air-moist Loss of material/pitting and crevice Work Control AP-W ~ He 3-511 Steel corrosion Process Pipe Stainless Raw water Loss of material/pitting, crevice, and Work Control ~ ~ He 3-511 Steel microbiologically influenced Process corrosion Strainer Stainless Raw water Loss of material/pitting, crevice, and Work Control ~ ~ He 3-512 Housings Steel microbiologically influenced Process corrosion Tubing Stainless Air-moist Loss of material/pitting and crevice Work Control AP-W ~ He 3-512 Steel corrosion Process Valves Copper Raw water Loss of material/pitting, crevice, and Work Control A-Q44 ~ He 3-513 Alloys microbiologically influenced Process corrosion, and fouling Valves Stainless Air-moist Loss of material/pitting and crevice Work Control AP-W ~ He 3-513 Steel corrosion Process

Serial No.09-777 Docket No. 50-305 Attachment 3/Page 8 of 16 Changes to LRA Table 3.x.2-y (Table 2)

Component Material Environment Aging Effect / Mechanism Aging NUREG-1801 Table 1 Item Notes LRA Page Type Management Vol. 2 Number Program Reference Valves Stainless Raw water Loss of material/pitting, crevice, and Work Control AP--Oa5 ~ H~ 3-513 Steel microbiologically influenced Process corrosion Waste Gas Steel Raw water Loss of material/general, pitting, Work Control ~ ~ H~ 3-514 Compressors crevice, and microbiologically Process influenced corrosion, and foulinq Table 3.3.2-22: Auxiliary Systems - Liquid Waste Processing and Discharge - Aaina Management Evaluation Deaerated Stainless Raw water Loss of material/pitting, crevice, and Work Control ~ ~ H~ 3-516 Drains Tank Steel microbiologically influenced Process corrosion Deaerated Stainless Raw water Loss of material/pitting, crevice, and Work Control ~ ~ H~ 3-516 Drains Tank Steel microbiologically influenced Process Pump corrosion Distillate Cooler Stainless Air-moist Loss of material/pitting and crevice Work Control ~ ~ H ~;1 3-517 Shell Onlv Steel corrosion Process Evaporator Stainless Air-moist Loss of material/pitting and crevice Work Control AP-004- ~ H ~;1 3-517 Condenser Steel corrosion Process Shell Onlv Filter Housings Stainless Raw water Loss of material/pitting, crevice, and Work Control ~ ~ H~ 3-517 Steel microbiologically influenced Process corrosion Flexible Hoses Elastomers Raw water Hardening and loss of Work Control AP-Q7§ ~ H~ 3-518 strenqth/elastomer deqradation Process Flexible Hoses Elastomers Raw water Loss of material/erosion Work Control AP-G+e ~ H~ 3-518 Process Flow Elements Stainless Raw water Loss of material/pitting, crevice, and Work Control ~ ~ H~ 3-518 Steel microbiologically influenced Process corrosion Flow Orifices Stainless Raw water Loss of material/pitting, crevice, and Work Control AP-Oaa ~ H~ 3-518 Steel microbiologically influenced Process corrosion Flow Stainless Raw water Loss of material/pitting, crevice, and Work Control ~ ~ H~ 3-519 Transmitters Steel microbiologically influenced Process corrosion Laundry and Stainless Raw water Loss of material/pitting, crevice, and Work Control AP-Oaa ~ H~ 3-519 Hot Shower Steel microbiologically influenced Process Tanks corrosion Laundry Pump Stainless Raw water Loss of material/pitting, crevice, and Work Control AP-Oaa ~ H~ 3-520 Steel microbiologically influenced Process corrosion

Serial No.09-777 Docket No. 50-305 Attachment 3/Page 9 of 16 Changes to LRA Table 3.x.2-v (Table 2)

Component Material Environment Aging Effect I Mechanism Aging NUREG-1801 Table 1 Item Notes LRA Page Type Management Vol. 2 Number Program Reference Level Switches Stainless Air-moist Loss of material/pitting and crevice Work Control AP-QS.i ~ He 3-520 Steel corrosion Process Level Switches Stainless Raw water Loss of material/pitting, crevice, and Work Control AP-Q5§ ~ He 3-520 Steel microbiologically influenced Process corrosion Pipe Stainless Air-moist Loss of material/pitting and crevice Work Control AP-QS.i ~ He 3-521 Steel corrosion Process Pipe Stainless Raw water Loss of material/pitting, crevice, and Work Control AP-Q5§ ~ He 3-521 Steel microbiologically influenced Process corrosion Pipe Steel Raw water Loss of material/general, pitting, Work Control ~ ~ He 3-521 crevice, and microbiologically Process influenced corrosion, and fouling Sludge Stainless Raw water Loss of material/pitting, crevice, and Work Control AP-Q5§ ~ He 3-523 Interceptor Steel microbiologically influenced Process Pump corrosion Sludge Stainless Raw water Loss of material/pitting, crevice, and Work Control AP-Gaa ~ He 3-523 Interceptor Steel microbiologically influenced Process Tank corrosion Standpipes Steel Raw water Loss of material/general, pitting, Work Control ~ ~ He 3-523 crevice, and microbiologically Process influenced corrosion, and fouling Strainer Stainless Raw water Loss of material/pitting, crevice, and Work Control AP-Q5§ ~ He 3-524 Housings Steel microbiologically influenced Process corrosion Sump Tank Stainless Raw water Loss of material/pitting, crevice, and Work Control AP-Q5§ ~ He 3-524 Pumps Steel microbiologically influenced Process corrosion Sump Tanks Stainless Raw water Loss of material/pitting, crevice, and Work Control AP-Q5§ ~ He 3-524 Steel microbiologically influenced Process corrosion Tubing Stainless Air-moist Loss of material/pitting and crevice Work Control AP-QS.i ~ He 3-525 Steel corrosion Process TUbing Stainless Raw water Loss of material/pitting, crevice, and Work Control AP-Q5§ ~ He 3-525 Steel microbiologically influenced Process corrosion Valves Stainless Raw water Loss of material/pitting, crevice, and Work Control AP-Q5§ ~ He 3-526 Steel microbiologically influenced Process corrosion

Serial No.09-777 Docket No. 50-305 Attachment 3/Page 10 of 16 Chanaes to LRA Table 3.x.2-v (Table 2)

Component Material Environment Aging Effect / Mechanism Aging NUREG-1801 Table 1 Item Notes LRAPage Type Management Vol. 2 Number Program Reference Valves Steel Raw water Loss of material/general, pitting, Work Control ~ ~ He 3-526 crevice, and microbiologically Process influenced corrosion, and foulinq Waste Stainless Raw water Loss of material/pitting, crevice, and Work Control AP-G&a ~ He 3-527 Condensate Steel microbiologically influenced Process Pumps corrosion Waste Stainless Raw water Loss of material/pitting, crevice, and Work Control AP-G&a ~ He 3-527 Condensate Steel microbiologically influenced Process Tanks corrosion Waste Stainless Air-moist Loss of material/pitting and crevice Work Control ~ ~ He;1 3-527 Evaporator Steel corrosion Process Concentrates Sample Cooler Shell Only Waste Stainless Raw water Loss of material/pitting, crevice, and Work Control AP-G&a ~ He 3-528 Evaporator Steel microbiologically influenced Process Feed Pump corrosion Waste Holdup Stainless Raw water Loss of material/pitting, crevice, and Work Control AP-Gaa ~ He 3-528 Tank Steel microbiologically influenced Process corrosion Table 3.3.2-23: Auxiliary Systems - Radiation Monitoring - Aging Management Evaluation Radiation Stainless Air-moist Loss of material/pitting and crevice Work Control ~ ~ He 3-530 Detectors Steel corrosion Process Radiation Stainless Raw water Loss of material/pitting, crevice, and Work Control AP-G&a ~ He 3-530 Detectors Steel microbiologically influenced Process corrosion Tubing Stainless Air-moist Loss of material/pitting and crevice Work Control ~ ~ He 3-531 Steel corrosion Process Valves Stainless Air-moist Loss of material/pitting and crevice Work Control ~ ~ He 3-531 Steel corrosion Process Table 3.3.2-25: Auxiliary Systems - Service Water Pretreatment - Aging Management Evaluation Filter Housings Steel Raw water Loss of material/general, pitting, Work Control ~ ~ He 3-537 crevice, and microbiologically Process influenced corrosion, and fouling Flow Elements Stainless Raw water Loss of material/pitting, crevice, and Work Control ~ ~ He 3-537 Steel microbiologically influenced Process corrosion Mixers Static Stainless Raw water Loss of material/pitting, crevice, and Work Control ~ ~ He 3-537 Steel microbiologically influenced Process corrosion

Serial No.09-777 Docket No. 50-305 Attachment 3/Page 11 of 16 Chanaes to LRA Table 3.x.2-y (Table 2)

Component Material Environment Aging Effect / Mechanism Aging NUREG-1801 Table 1 Item Notes LRA Page Type Management Vol. 2 Number Program Reference Pipe Stainless Raw water Loss of material/pitting, crevice, and Work Control AP-Gaa ~ He 3-538 Steel microbiologically influenced Process corrosion Pipe Steel Raw water Loss of material/general, pitting, Work Control ~ ~ He 3-538 crevice, and microbiologically Process influenced corrosion, and foulina Tubing Copper Raw water Loss of material/pitting, crevice, and Work Control A-Q44 ~ He 3-539 Alloys microbiologically influenced Process corrosion, and fouling Tubing Stainless Raw water Loss of material/pitting, crevice, and Work Control AP-Gaa ~ He 3-539 Steel microbiologically influenced Process corrosion Tubing Steel Raw water Loss of material/general, pitting, Work Control ~ ~ He 3-539 crevice, and microbiologically Process influenced corrosion, and fouling Valves Copper Raw water Loss of material/pitting, crevice, and Work Control A-Q44 ~ He 3-540 Alloys microbiologically influenced Process corrosion, and fouling Valves Steel Raw water Loss of material/general, pitting, Work Control ~ ~ He 3-540 crevice, and microbiologically Process influenced corrosion, and foulina Table 3.3.2-26: Auxiliary Systems - Miscellaneous Drains and Sumps - Aging Management Evaluation Annulus Sump Steel Raw water Loss of material/general, pitting, Work Control ~ ~ He 3-542 Pumps crevice, and microbiologically Process influenced corrosion, and fouling Deaerated Stainless Raw water Loss of material/pitting, crevice, and Work Control AP-Gaa ~ He 3-543 Drains Tank Steel microbiologically influenced Process Emergency corrosion Pumps Flow Elements Elastomers Raw water Hardening and loss of Work Control AF!--Q7§ ~ He 3-543 strenath/elastomer dearadation Process Flow Elements Elastomers Raw water Loss of material/erosion Work Control AP-G7e ~ He 3-543 Process Reactor Steel Raw water Loss of material/general, pitting, Work Control ~ ~ He 3-543 Containment crevice, and microbiologically Process Vessel Sump influenced corrosion, and fouling Pumps Includes 1A, 18, and Rx Cavity C

Serial No.09-777 Docket No. 50-305 Attachment 3/Page 12 of16 Changes to LRA Table 3.x.2-y (Table 2)

Component Material Environment Aging Effect / Mechanism Aging NUREG-1801 Table 1 Item Notes LRA Page Type Management Vol. 2 Number Program Reference Orifices Stainless Raw water Loss of materiaVpitting, crevice, and Work Control ~ ~ He 3-544 Steel microbiologically influenced Process corrosion Pipe Stainless Air-moist Loss of material/pitting and crevice Work Control AP--GS ~ He 3-545 Steel corrosion Process Pipe Stainless Raw water Loss of material/pitting, crevice, and Work Control ~ ~ He 3-545 Steel microbiologically influenced Process corrosion Pipe Steel Raw water Loss of material/general, pitting, Work Control ~ ~ He 3-545 crevice, and microbiologically Process influenced corrosion, and foulina RHR Pump Pit Stainless Raw water Loss of material/pitting, crevice, and Work Control AP--Q§§ ~ He 3-546 Sump Pumps Steel microbiologically influenced Process corrosion Safeguards Steel Raw water Loss of material/general, pitting, Work Control ~ ~ He 3-546 Alley Sump crevice, and microbiologically Process Pumps influenced corrosion, and fouling Screen House Steel Raw water Loss of material/general, pitting, Work Control ~ ~ He 3-546 Sump Pumps crevice, and microbiologically Process influenced corrosion, and fouling Valves Stainless Air-moist Loss of material/pitting and crevice Work Control AP--GS ~ He 3-547 Steel corrosion Process Valves Stainless Raw water Loss of material/pitting, crevice, and Work Control ~ ~ He 3-547 Steel microbiologically influenced Process corrosion Valves Steel Raw water Loss of material/general, pitting, Work Control ~ ~ He 3-547 crevice, and microbiologically Process influenced corrosion, and foulina Table 3.3.2-27: Auxiliary Systems - Miscellaneous Gas - Aging Management Evaluation Hoses Stainless Air-moist Loss of material/pitting and crevice Work Control AP--GS ~ He 3-551 Steel corrosion Process Table 3.3.2-28: Auxiliary Systems - Potable Water - Aging Management Evaluation Nozzles Steel Air-fndoor Loss of material/general corrosion Work Control ¥I-k-l-OO ~ He 3-557 uncontrolled Process Pipe Copper Raw water Loss of material/pitting, crevice, and Work Control A-G44 ~ He 3-558 Alloys microbiologically influenced Process corrosion, and fouling Pipe Steel Raw water Loss of material/general, pitting, Work Control ~ ~ He 3-558 crevice, and microbiologically Process influenced corrosion, and fouling

Serial No.09-777 Docket No. 50-305 Attachment 3/Page 13 of 16 Changes to LRA Table 3.x.2-v (Table 2)

Component Material Environment Aging Effect / Mechanism Aging NUREG-1801 Table 1 Item Notes LRA Page Type Management Vol. 2 Number Program Reference Valves Copper Raw water Loss of material/pitting, crevice, and Work Control A-Q44 ~ He 3-559 Alloys microbiologically influenced Process corrosion, and foulinQ Valves Steel Raw water Loss of material/general, pitting, Work Control ~ ~ He 3-559 crevice, and microbiologically Process influenced corrosion, and foulina Table 3.4.2-1: Steam and Power Conversion System - Turbine - Aging Management Evaluation Electro Steel Raw water Loss of material/general, pitting, Work Control s-Q24 ~ He 3-611 Hydraulic crevice, galvanic, and Process Control System microbiologically influenced Oil Coolers corrosion, and fouling Bonnets Turbine Oil Steel Raw water Loss of material/general, pitting, Work Control s-Q24 ~ He 3-615 Coolers crevice, galvanic, and Process Channel heads microbiologically influenced corrosion, and fouling Table 3.4.2-4: Steam and Power Conversion Svstem - Feedwater - Aaina Manaaement Evaluation Feedwater Steel Raw water Loss of material/general, pitting, Work Control s-Q24 ~ He 3-633 Pumps Oil crevice, galvanic, and Process Coolers microbiologically influenced Channel Heads corrosion, and foulinQ Table 3.4.2-9: Steam and Power Conversion System - Heater and Moisture Separator Drains - Aging Management Evaluation Heater Drain Steel Raw water Loss of material/general, pitting, Work Control s-Q24 ~ He 3-675 Pumps crevice, galvanic, and Process microbiologically influenced corrosion, and foulinQ Table 3.4.2-10: Steam and Power Conversion System - Heating Steam - Aging Management Evaluation Boric Acid Steel Raw water Loss of material/general, pitting, Work Control s-Q24 ~ He 3-683 Evaporator crevice, galvanic, and Process Cond Return microbiologically influenced Unit Heat corrosion, and fOUling Exchanger Bonnet Control Room Steel Raw water Loss of material/general, pitting, Work Control ~ ~ He 3-685 NC HWPump crevice, and microbiologically Process influenced corrosion, and foulinQ

Serial No.09-777 Docket No. 50-305 Attachment 3/Page 14 of 16 Chan~es to LRA Table 3.x.2-v (Table 2)

Component Material Environment Aging Effect I Mechanism Aging NUREG-1801 Table 1 Item Notes LRAPage Type Management Vol. 2 Number Program Reference Heating Coils Copper Raw water Loss of material/pitting, crevice, and Work Control ~ ~ He 3-686 Alloys microbiologically influenced Process corrosion Table 3.4.2-11: Steam and Power Conversion System - Main Generator (Mechanical) and Auxiliaries - Aging Management Evaluation Air Side Seal Steel Raw water Loss of material/general, pitting, Work Control ~ ~ He 3-694 Oil Cooler crevice, galvanic, and Process Channel Heads microbiologically influenced corrosion, and fouling Generator Copper Raw water Loss of material/pitting, crevice, and Work Control ~ ~ He 3-696 Hydrogen Alloys microbiologically influenced Process Coolers Coils corrosion Hydrogen Side Steel Raw water Loss of material/general, pitting, Work Control ~ ~ He 3-696 Seal Oil Cooler crevice, galvanic, and Process Channel Heads microbiologically influenced corrosion, and fouling Table 3.4.2-12: Steam and Power Conversion System - Secondary Sampling - Aging Management Evaluation Cooler Units Steel Raw water Loss of material/general, pitting, Work Control ~ ~ He 3-702 Channel head crevice, galvanic, and Process of first stage microbiologically influenced cooler units corrosion, and foulino Cooler Units Steel Treated water- Loss of material/general, pitting, Work Control ~ ~ He 3-702 Shell of first closed cycle crevice, and galvanic corrosion Process stage cooler cooling units Coolers Shell of Stainless Treated water- Loss of material/pitting and crevice Work Control ~ ~ He 3-703 sample coolers Steel closed cycle corrosion Process coolino Coolers Shell of Steel Treated water- Loss of material/general, pitting, Work Control ~ ~ He 3-703 sample coolers closed cycle crevice, and galvanic corrosion Process cooling FW Sample Stainless Treated water- Loss of material/pitting and crevice Work Control SP--W9 ~ He 3-704 Line Chiller Steel closed cycle corrosion Process Evaporator tank cooling FW Sample Stainless Treated water- Loss of material/pitting and crevice Work Control SP--W9 ~ He 3-704 Line Chiller Steel closed cycle corrosion Process Recirculating cooling pump Pipe Stainless Treated water- Loss of material/pitting and crevice Work Control SP--W9 ~ He 3-705 Steel closed cycle corrosion Process cooling

Serial No.09-777 Docket No. 50-305 Attachment 3/Page 15 of 16 Changes to LRA Table 3.x.2-y (Table 2)

Component Material Environment Aging Effect / Mechanism Aging NUREG-1801 Table 1 Item Notes LRAPage Type Management Vol. 2 Number Program Reference Pipe Steel Treated water- Loss of material/general, pitting, Work Control ~ ~ He 3-706 closed cycle crevice, and galvanic corrosion Process coolinQ Recirculation Steel Treated water- Loss of materiaVgeneral, pitting, Work Control ~ ~ He 3-706 Pumps closed cycle crevice, and galvanic corrosion Process coolinq Refrigeration Steel Raw water Loss of material/general, pitting, Work Control s-424 ~ He 3-707 Unit Chiller crevice, galvanic, and Process Condenser microbiologically influenced Channel head corrosion, and foulinq Refrigeration Steel Treated water- Loss of material/general, pitting, Work Control ~ ~ He 3-707 Unit Chiller closed cycle crevice, and galvanic corrosion Process Condenser cooling Shell Refrigeration Steel Treated water- Loss of material/general, pitting, Work Control ~ ~ He 3-707 Unit Chiller closed cycle crevice, and galvanic corrosion Process Evaporator cooling Shell Storage Tank Steel Treated water- Loss of material/general, pitting, Work Control ~ ~ He 3-708 closed cycle crevice, and galvanic corrosion Process cooling Tubing Copper Treated water- Loss of material/pitting, crevice, and Work Control SP-008 ~ He 3-709 Alloys closed cycle galvanic corrosion Process cooling Tubing Stainless Treated water- Loss of material/pitting and crevice Work Control ~ ~ He 3-709 Steel closed cycle corrosion Process coolinq Tubing Steel Treated water- Loss of material/general, pitting, Work Control ~ ~ He 3-710 closed cycle crevice, and galvanic corrosion Process cooling Valves , Copper Treated water- Loss of material/pitting, crevice, and Work Control SP-008 ~ He 3-711 Alloys closed cycle galvanic corrosion Process cooling Valves Stainless Treated water- Loss of material/pitting and crevice Work Control ~ ~ He 3-711 Steel closed cycle corrosion Process cooling Valves Steel Treated water- Loss of material/general, pitting, Work Control ~ ~ He 3-712 closed cycle crevice, and galvanic corrosion Process cooling Table 3.5.2-1: Structures and Component Supports - Reactor Containment Vessel - Aging Management Evaluation

Serial No.09-777 Docket No. 50-305 Attachment 3/Page 16 of 16 Changes to LRA Table 3.x.2-v (Table 2)

Component Material Environment Aging Effect / Mechanism Aging NUREG-1801 Table 1 Item Notes LRA Page Type Management Vol. 2 Number Program Reference Reactor cavity Elastomers Air-indoor Loss of sealing/deterioration of Work Control +P-007 ~ H e;;4 3-793 seal ring uncontrolled seals, gaskets, and moisture Process barriers (caulking, flashing, and other sealants)

Table 3.5.2-4: Structures and Component Supports - Auxiliary Building - Aging Management Evaluation Spent fuel pool Elastomers Air-indoor Loss of sealing/deterioration of Work Control +P-007 ~ He; 3-819 gate seal uncontrolled seals, gaskets, and moisture Process barriers (caulking, flashing, and other sealants)

Table 3.5.2-14: Structures and Component Supports - Miscellaneous Structural Commodities - Aging Management Evaluation Gaskets/seals Elastomers Air-outdoor Loss of sealing/deterioration of Work Control +P-007 ~ He; 3-872 in junction, seals, gaskets, and moisture Process terminal, and barriers (caulking, flashing, and pull boxes other sealants)