ML100220082
| ML100220082 | |
| Person / Time | |
|---|---|
| Site: | Kewaunee  (DPR-043) |
| Issue date: | 01/21/2010 |
| From: | Hartz L Dominion, Dominion Energy Kewaunee |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| 10-008 | |
| Download: ML100220082 (25) | |
Text
Dominion Energy Kewaunee, Inc.
5000 Dominion Boulevard, Glen Allen, VA 23060 January 21, 2010 United States Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001 Serial No.:
10-008 LR/MWH RO 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 16, 2009 (Reference 1), the NRC provided a request for additional information regarding 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. to this letter provides the Dominion Energy Kewaunee Inc. (DEK) responses to each of the RAls submitted by the NRC staff in Reference 1.
In a telephone call, the NRC indicated that RAI 3.4.2.3-1 in Reference 1 should be re-numbered to 3.4.2.3-3 to avoid duplication of RAI numbers.
The correct numbering is reflected in Attachment 1.
Should you have any questions regarding this submittal, please contact Mr. Paul C.
Aitken at (804) 273-2818.
Very truly yours,
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Leslie N. Hartz Vice President - Nuclear Support Services COMMONWEALTH OF VIRGINIA COUNTY OF HENRICO The foregoing document was acknowledged before me, in and for the County and State aforesaid, today by Leslie N. Hartz, who is Vice President - Nuclear Support Services of Dominion Energy Kewaunee, Inc.
She has affirmed before me that she is duly authorized to execute and file the foregoing document in behalf of that Company, and that the statements in the document are true to the best of her knowledge and belief.
Acknowledged before me this (2 ~s+- day of :J0,Y\\'0QY'v\\
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No ary Public GINGER L. ALLIGOOD Notary Public Commonwealth of Virginia 310847 My Comnillion.ExpIrIl Apr 30. 2013
Serial No.10-008 Docket No. 50-305 Page 2 of 3
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 16, 2009.
[ADAMS Accession No.
ML093310443]
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]
3.
Letter from John Daily (NRC) to DEK, "Summary of Discussion on January 11, 2010, Between Dominion Energy Kewaunee, Inc. and the U.S. Nuclear Regulatory Commission to Discuss Duplicate RAI Number (TAC No. MD9408)," dated January 13,2010.
Attachments:
- 1. Response to Request for Additional Information Regarding the Kewaunee Power Station License Renewal Application Commitments made in this letter:
- 1. License Renewal Commitment 40 will be added to LRA Table A6.0-1 consistent with the response to RAI B2.1.8-3a. The new commitment is proposed to support approval of the renewed operating license, and may change during the NRC review period.
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.10-008 Docket No. 50-305 Page 3 of 3
Serial NO.1 0-008 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.10-008 Docket No. 50-305 /Page 1of 21 RAJ 3.1.2.3-1
Background
LRA Tables 3.1.2-1, 3.1.2-3 and 3.1.2-4 contain items which address the exterior surfaces of steel components exposed to uncontrolled indoor air.
The applicant proposes that there is no aging effect associated with this combination of material and environment and that no AMP is required.
The applicant proposes 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 these items, the staff noted that "air-indoor uncontrolled" is defined in the GALL Report as an environment where "condensation can occur, but only rarely".
The staff also notes that, contrary to Note 4 of the application, the components under consideration may routinely have temperatures above 212°F (during operation) and at much lower temperatures approaching ambient (during outages).
The staff further notes that in all cases the GALL Report recommends that the aging effect "Loss of Material" be considered when steel is exposed to uncontrolled indoor air.
Request Please select an AMP appropriate for the management of steel components exposed to uncontrolled indoor air as recommended by the GALL Report.
DEK Response The items referred to from LRA Tables 3.1.2-1, 3.1.2-3, and 3.1.2-4 are subcomponents that comprise the reactor vessel, pressurizer, and steam generator, respectively.
Chapter IV of NUREG-1801, Generic Aging Lessons Learned (GALL) Report, identifies aging effects for components of the reactor vessel, pressurizer, and steam generator, but does not identify any aging effects for steel exposed to an air-indoor uncontrolled environment.
NUREG-1801, page IX-14, defines the air-indoor uncontrolled environment as: Indoor air on systems with temperatures higher than the dew point, i.e.,
condensation can occur but only rarely, equipment surfaces are normally dry.
During the 18 month power operation cycle, Kewaunee normally operates at full power where the external surface temperature of the reactor vessel, pressurizer, and steam generator is greater than the dewpoint of the surrounding air environment. This high operating temperature precludes condensation from occurring on the component surfaces. During the short duration refueling outages (typically one month or less) scheduled each 18 months, the external surfaces of these components are cooled to ambient temperature and may be reduced below the dewpoint temperature of the local environment.
However, significant condensation is not expected to occur since the component external surfaces are insulated.
In addition, any moisture that may be
Serial No.10-008 Docket No. 50-305 /Page 2 of 21 present on the component surface is eliminated when the surface temperature increases upon plant startup.
Therefore, based on the short period of time that the external surfaces of these components are potentially exposed to moisture due to condensation, significant corrosion is not anticipated. The loss of material aging effect was determined not to be applicable and an aging management program is not required for these subcomponents.
Serial No.10-008 Docket No. 50-305 /Page 3 of 21 RAI 3.4.2.3-3
Background
LRA Table 3.4.2-1 contains items which address the interior surfaces of steel components exposed to hydraulic oil.
The applicant proposes that there is no aging effect associated with this combination of material and environment and that no AMP is required.
The applicant proposes 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 these items, the staff noted that for the material/environment combinations of steel and fuel oil as well as steel and lubricating oil, the GALL Report recommends the consideration of the aging effect "loss of material".
In each case the GALL Report recommends recommendations in the GALL Report, the staff must also consider that loss of material for steel components exposed to hydraulic oil may be possible.
Request Please select an AMP appropriate for the management of aging in steel components exposed to hydraulic oil or to justify why aging of steel components in hydraulic oil is not possible.
DEK Response As indicated in the definition of the lubricating oil environment in NUREG-1801, Generic Aging Lessons Learned (GALL) Report,Section IX.D, "Selected Definitions & Use of Terms for Describing and Standardizing - ENVIRONMENTS":
"...Piping, piping components, and piping elements, whether copper, stainless steel, or steel, when exposed to lubricating oil that does not have water pooling, will have limited susceptibility to aging degradation, due to general or localized corrosion."
Water pooling is not expected to occur in the electro-hydraulic control (EHC) system due to the high standards for fluid quality in this system.
However, as a conservative measure, in response to RAI 3.4.2.3.1-1 in DEK letter 09-587 dated September 28, 2009 [ADAMS Accession No. ML092720184], loss of material has been included as an applicable aging effect for the EHC reservoir, since this component would be the most likely location for water to separate from the hydraulic fluid and result in water pooling.
As further stated in the response to RAI 3.4.2.3.1-1, loss of material for the EHC reservoir will be managed with the Lubricating Oil Analysis program, which is confirmed to be effective by the One-Time Inspections program through the Work Control Process program. The Lubricating Oil Analysis program performs monthly sampling of the EHC
Serial No.10-008 Docket No. 50-305 /Page 4 of 21 fluid to ensure fluid chemistry parameters (e.g., water content, particulate count, chloride content, etc.) are maintained within required limits.
A review of plant-specific operating experience did not identify any evidence of corrosion occurring in components, including steel components, in the hydraulic oil (EHC fluid) environment. Also, a review of monthly EHC fluid sample results from 2001 through 2009 indicated that water content is typically within the limit of 0.10% by volume, with a limited number of samples as high as 0.14%.
Based on the lack of identified degradation in this environment and the low limit established for water content, no aging effects were identified for steel EHC system components in a hydraulic oil environment.
Serial No.10-008 Docket No. 50-305 /Page 5of 21 RAI 3.5.2.3-7
Background
LRA Table 3.5.2-9 contains items which address steel sheet pile exposed to soil.
The applicant proposes that there is no aging effect associated with this combination of material and environment and that no AMP is required.
The applicant proposes 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 these
- items, the staff noted that for the material/environment combinations of steel and soil, the GALL Report recommends the consideration of the aging effect "loss of material." Based on the information provided, it is not clear to the staff why steel sheet pile exposed to soil as part of the plant's discharge structure would not experience loss ofmaterial due to corrosion.
Request Please select an AMP appropriate for the management of aging in steel sheet pile exposed to soil.
DEK Response LRA Table 3.5.2-9, Structures and Component Supports - Discharge Structure - Aging Management Evaluation, includes the aging management review results for steel sheet pile in the structural member "Structural Steel (sheet piling)." As indicated in the table, the steel sheet pile was evaluated in air-outdoor, raw water, and soil environments.
The Loss of Material aging effect was identified as requiring management for the sheet pile in air-outdoor and raw water environments, and is managed by the Structures Monitoring Program.
These environments are applicable to the portion of the steel sheet pile at the air-soil interface on the shore side of the sheet piling, and at the air-water interface and the soil-water interface on the lake side, where there is the greatest potential for corrosion of the steel sheet pile.
The soil environment is applicable to the portion of the steel sheet pile that is driven into undisturbed soil. In this environment, the steel sheet pile is not significantly affected by corrosion based on the conclusions documented in NUREG-1557, Summary of Technical Information and Agreements from Nuclear Management and Resources Council Industry Reports Addressing License Renewal, and EPRI TR-103842, Revision 1, Class I Structures License Renewal Industry Report. Based on test results evaluated in EPRI TR-103842, for an exposure time varying from 7 to 50 years, the type and amount of corrosion observed on steel piles is not sufficient to significantly affect the strength of the steel piles as load bearing structures, regardless of the soil
Serial No.10-008 Docket No. 50-305 /Page 6 of 21 characteristics and properties, due to the oxygen-deficient environment associated with the undisturbed soil.
Therefore, loss of material is not an applicable aging effect for the steel sheet piling exposed to a soil environment, and no aging management program is required.
Inspections performed as part of the Structures Monitoring Program for the portion of the sheet pile exposed to raw water and air-outdoor environments provide a leading indication of corrosion at these more aggressive locations.
If loss of material is identified at these locations, the condition is documented in the Corrective Action Program for evaluation and implementation of necessary corrective actions. As part of the extent of condition evaluation, the need for inspection of steel sheet pile below the soil surface would be evaluated.
Serial No.10-008 Docket No. 50-305 /Page 7 of 21 RAI 3.3.2.3-4
Background
LRA Table 3.3.2-8 contains items which address loss of strength/hydrolysis from the exterior surfaces of non metallic filters and regulators exposed to dry air.
The applicant proposes to manage this aging through the use of its Work Control Process (LRA AMP B2.1.32).
The applicant proposes 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 these items, the staff noted that the aging effect identified by the applicant is applicable for this combination of component, material, and environment.
The staff also noted that the LRA AMP specifically addresses paper filter elements used in the compressed air system.
The staff concurs with the applicant's assertion that visual inspection, as included in the Work Control Process AMP, is sufficient to manage aging of these filters.
The staff also notes, however, that the entry in Table 3.3.2-8 includes both filters and regulators and that the material is listed as "Non Metallic" rather than paper.
While the staff suspects that this item refers only to paper filters, it could also refer to some unidentified non metallic material contained in either a filter or a regulator. Additionally, the staff noted that, with the exception of elastomeric materials, the scope of the Work Control Process is limited to the internal surfaces of components.
This appears to be in conflict with the component under consideration as the environment is specified to be external.
The staff assumes, but cannot confirm that the applicant is referring to the external surface of the filter but that the filter is contained in another, larger, enclosure which actually makes the external surface of the filter an internal surface of the filter assembly.
Request Please a) confirm that this item refers to only paper filters; b) if necessary, define the other materials and components included in this item; c) if necessary, justify the use of the Work Control Process AMP for these materials and components; d) confirm that the.
Work Control Process is used for this component because the external surface of the filter is an internal surface or a larger assembly; and, e) if necessary, justify the use of the Work Control Process for external surfaces.
DEK Response The entry in LRA Table 3.3.2-8 for non-metallic material refers only to the paper (cellulose) filter element of the Filter/Regulators component type.
The filter element is
Serial No.10-008 Docket No. 50-305 /Page 8 of 21 located internally to the filterlregulator assembly.
The Internal Surfaces Monitoring inspections of the Work Control Process program, described in DEK letter 09-597 dated September 25, 2009 [ADAMS ML092710045], is used to manage aging effects for the filter element because filterlregulator assembly must be disassembled to inspect the paper filter element.
Serial No.10-008 Docket No. 50-305 /Page 9 of 21 RAI 3.3.2.3-5
Background
LRA Tables 3.3.2-6 and 3.3.2-20 contaii? items which address loss of material due to MIC from the internal surfaces of stainless steel piping, piping components, and piping elements exposed to raw water.
The applicant proposes to manage this aging through the use of its Work Control Process (LRA AMP B2.1.32) or its Open Cycle Cooling Water System (LRA B2.1.23) AMPs.
The applicant proposes 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 these items, the staff noted that in the majority, but not all instances, the applicant states that the AMP "Open Cycle Cooling Water" is used for safety-related systems and the AMP "Work Control Process" is used for nonsafety-related systems.
The staff also noted that MIC is only one of the appropriate corrosion mechanisms which could lead to loss of material in stainless steel piping exposed to raw water.
Irrespective of the corrosion mechanism leading to the loss of material, the staff has no objection to the use of the Open Cycle Cooling Water AMP for systems to which Generic Letter 89-13 applies (safety systems) because this is the AMP recommended by the GALL Report. Also, irrespective of the corrosion mechanism leading to the loss of material, the staff has no objection to the use of the Work Control Process AMP for nonsafety systems because this AMP contains procedures for visual inspection of the interiors of pipes which are appropriate for the detection of loss of material due to exposure to raw water.
However, it is not clear to the staff that this distinction will be met in all cases.
It is also not clear to the staff whether the applicant is inferring that MIC is the only corrosion mechanism which is possible in this case or whether the applicant is using these items in conjunctions with other AMR items such as 3.3-1 10 78 and/or 79.
Request Please confirm that the Open Cycle Cooling Water AMP will be used for all safety-related systems and that the Work Control Process AMP will be used only for nonsafety-related systems.
DEK Response The Open Cycle Cooling Water program manages applicable aging effects for safety-related component types in LRA Tables 3.3.2-6 and 3.3.2-20.
The Work Control Process program manages applicable aging effects only for non-safety-related component types in LRA Tables 3.3.2-6 and 3.3.2-20.
Serial No.10-008 Docket No. 50-305 /Page 10 of 21 RAI 3.3.2.3-8
Background
LRA Table 3.3.2-8 contains items which address loss of material due to general and pitting corrosion from the internal surfaces of steel piping, piping components, and piping elements exposed to moist air.
The applicant proposes to manage this aging through the use of its Work Control Process (LRA AMP B2.1.32).
The applicant proposes 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 these items, the staff noted that the aging effect identified by the applicant is applicable for this combination of component, material, and environment.
The staff also noted that in its original application, the applicant included these components in LRA Table 3.3.1, item 3.3.1-53 using Generic Note E.
The staff further noted that, for SRP Table 3.3-1 ID 53, the GALL Report recommends the use of the Compressed Air Monitoring AMP.
The staff finally noted that the components under consideration are included in the station and instrument air system.
The staff acknowledges that both the Compressed Air Monitoring AMP recommended by the GALL Report and the Work Control Process AMP as proposed by the applicant contain inspection procedures appropriate for the detection of loss of material due to corrosion on the internal surfaces of piping.
The staff notes, however, that the Compressed Air Monitoring program contains many aspects in addition to piping inspections to manage aging.
Given the additional aging management controls contained in the Compressed Air Monitoring program, it is not clear to the staff that the aging of these compressed air components can be adequately managed solely through the visual inspections contained in the Work Control Process program.
Request Please justify the use of the Work Control Process AMP for compressed air system components or adopt an AMP containing all aspects of the Compressed Air Monitoring AMP recommended by the GALL Report.
DEK Response The component type "Traps" in LRA Table 3.3.2-8 are the Station and Instrument Air System steel components exposed to a moist air environment with aging effects managed by the Work Control Process program. As shown on license renewal drawing LRM-213-1 (at coordinates B-2, E-2, and H-2 indicated by "T"), the traps allow water from the instrument air compressor moisture separators and air receivers to drain to the floor drains. The traps provide a drain path for condensed moisture and do not provide a compressed air flowpath to system components.
Maintaining compressed air quality
Serial No.10-008 Docket No. 50-305 /Page 11 of 21 is not required for this portion of the system. Therefore, additional aging management controls and inspections contained in the Compressed Air Monitoring program are not applicable and the visual internal inspections performed by the Work Control Process program are adequate to manage loss of material for the traps.
Serial NO.1 0-008 Docket No. 50-305 /Page 12 of 21 RAI 82.1.8-3a
Background
In its review, the staff noted that the applicant's program did not specify a monitoring frequency for nitrate levels in the component cooling water system, which utilizes a nitrite/molybdate corrosion control program.
Energy Power Research Institute (EPRI)
Report 1007820, Revision 1 specifies that nitrate levels for such systems be monitored on a monthly basis for both Tier 1 and Tier 2 systems.
Consequently, the staff requested in RAI B2. 1.8-3 dated July 13, 2009, that the applicant provide a justification for not performing monthly monitoring of the nitrate levels in the closed cooling water system.
In its response dated August 17, 2009, the applicant stated that, as an alternative to monthly monitoring of nitrate levels, nitrite levels are monitored on a monthly basis and ammonia levels on a quarterly basis.
The applicant also stated that these monitoring activities verify chemistry stability and verify that unacceptable levels of nitrates, which would be produced by nitrifying bacteria, are not present in the closed-cycle cooling water system.
Issue The staff notes that, in nitrite-treated systems, nitrates are produced by nitrifying bacteria while ammonia is produced by denitrifying bacteria.
Either or both of these bacteria types may be present in a closed water system, and the absence of one type does not necessarily indicate the absence of the other.
Thus the periodic sampling for ammonia may be used to verify the absence or control of denitrifying bacteria, but it provides no assurance that nitrifying bacteria are not present.
For this reason, EPRI 1007820 recommends monitoring for both nitrates and ammonia on a monthly basis for Tier 1 and 2 systems.
Request Indicate how current monitoring procedures provide assurance that excessive levels of nitrifying bacteria are not present in the closed water system.
DEK Response EPRI TR-1007820, Closed Cooling Water Chemistry Guideline, Revision 1 has been reviewed and it has been determined that monitoring for nitrates through the Closed-Cycle Cooling Water System program would provide improved ability to identify the presence of nitrifying bacteria in the Component Cooling System.
As a result, nitrate monitoring will be implemented on a frequency consistent with the existing monitoring for ammonia.
Serial No.10-008 Docket No. 50-305 /Page 13 of 21 The following commitment will be added to LRA Appendix A, USAR Supplement, Table A6.0-1 :
Item Commitment Source Schedule 40 Implement nitrate monitoring for the Letter 10-008 Prior to the Component Cooling System on a Response to Period of frequency consistent with the existing RAI 82.1.8-3a Extended monitorinQ for ammonia.
Operation
Serial No.10-008 Docket No. 50-305 /Page 14 of 21 RAI 3.5.2.3-6a
Background
By letter dated Oct 13, 2009, the staff issued RAI 3.5.2.3-6 requesting that the applicant identify the specific material under consideration and justify why this material is not subject to aging under the conditions being considered.
The applicant responded by letter dated Nov 13, 2009.
In that response the applicant addressed potential aging effects on both the internal and external surfaces of each of the non-metallic materials under consideration.
The applicant stated that the non-metallic material in LRA Table 3.5.2-12 which has no aging effect is fiberglass.
The external surfaces of this material are exposed to uncontrolled indoor air. The internal surfaces of this material are exposed to raw water.
The applicant also stated that this material is not exposed to ultraviolet radiation, ozone, or high voltage current which could result in loss of strength.
The applicant conducted an operating experience search for this combination of material and environments and failed to find any instances of aging for either the internal or external environment.
The results of this search are consistent with the staff's knowledge of this material and the external environment.
Issue The staff's assessment of the interaction between raw water and fiberglass differs from that proposed by the applicant.
The staff is aware that fiberglass may undergo significant blistering as a result of exposure to water.
This is particularly true in fiberglass boats.
Blistering can become sufficiently severe to result in structural degradation of the material. Given the fact that fiberglass boats blister, the staff finds it difficult to accept the concept that, for the component under consideration, no aging exists.
Request Please propose an AMP for fiberglass exposed to water or to justify why the fiberglass component under consideration should be considered to have no aging effect.
DEK Response LRA Table 3.5.2-12, Structures and Component Supports - Screenhouse - Aging Management Evaluation, includes the non-metallic (fiberglass) structural member "Traveling water screen covers." As indicated in the table, the external surface of the cover is exposed to an air-uncontrolled indoor environment and the internal surface is exposed to a raw water environment.
The internal surface of the fiberglass covers is not submerged in raw water, but rather is exposed intermittently to raw water spray from
Serial No.10-008 Docket No. 50-305 /Page 15 of 21 the operation of the traveling water screens. Therefore, the internal environment for the traveling water screen covers is not similar to that for fiberglass boat hulls that are constantly immersed in water and subjected to hydraulic pressures, which can result in blistering from water that penetrates the gelcoat into the underlying laminate. As such, there is no potential for blistering of the traveling water screen covers and no aging management program is required.
Serial No.10-008 Docket No. 50-305 /Page 16 of 21 RAI 3.3.2.1-4
Background
LRA Tables 3.2.2-2, 3.3.2-9, 3.3.2-11, and 3.3.2-19 list combinations of components, materials environments and aging effects among otherparameters for items which are in scope for license renewal.
Issue In its review of these tables the staff noted that the applicant claims consistency for the items described below, by placing Note A on them. A review of these items against the GALL Report showed that the referenced items in the GALL Report do not correspond with the AMP proposed by the applicant.
The staff does not understand the applicant's description of consistency with the GALL Report.
Table Subcomponent Material Environment Aging Effect AMP GALL Table Notes Vol 2 1 Item 3.2.2-2 Valves Enclosures Steel (I) Air-moist Loss of Material/general, pitting, Work Control EP-043 3.2.1-46 A;4 crevice and Boric acid corrosion Process Loss ofmaterial/general, pitting, 3.3.2-11 Damper Housings Steel (I) Air-moist crevice, and (for drip pans and drain Work Control VII.F2-03 3.3.1-72 A;1 lines) microbiologically influenced Process corrosion Loss ofmaterial/general; pitting, 3.3.2-11 Ductwork Steel (I) Air-moist crevice, and (for drip pans and drain Work Control VII.F2-03 3.3.1-72 A;1 lines) microbiologically influenced Process corrosion Loss ofmaterial/general, pitting, 3.3.2-11 Fan/Blower Steel
(/) Air-moist crevice, and (for drip pans and drain Work Control VII.F2-03 3.3.1-72 A;1 Housings lines) microbiologically influenced Process corrosion Request Please, specify if the correct footnote for the referenced items is Note A, andjustify how that conclusion was reached.
Serial No.10-008 Docket No. 50-305 /Page 17 of 21 DEK Response DEK letter 09-597, dated September 25, 2009 [ADAMS ML092710045], amended the Work Control Process program to be consistent with NUREG-1801, Generic Aging Lessons Learned (GALL) Report,Section XI.M38, "Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components." Based on this change, the use of Note A is correct for the items identified in the RAI.
Serial No,10-008 Docket No. 50-305 /Page 18 of 21 RAI 3.3.2.1-5
Background
LRA Table 3.3.2-19 lists combinations of components, materials environments and aging effects among other parameters for items which are in scope for license renewal.
Issue In its review of these tables, the staff noted that the applicant claims consistency for the items described below, by placing Note A on them. A review of these items against the GALL Report showed that the referenced items in the GALL Report do not correspond with the AMPs proposed by the applicant.
The staff does not understand the applicant's description of consistency with the GALL Report.
Table Subcomponent Material Environment Aging Effect AMP GALL Table Notes Vol 2 1 Item 3.3.2-19 Compressor Steel (I) Air-moist Loss of material/general, Compressed VII.H2-3.3.1-71 A;2 Casings pitting, and crevice Air Monitoring 21 corrosion 3.3.2-19 Expansion Tanks Steel (E) Air-Outdoor Loss of material/general, External VII.H1-3.3.1-40 A;1 pitting, and crevice Surfaces 11 corrosion Monitoring Request Please, specify if the correct footnote for the referenced items is Note A, andjustify how that conclusion was reached.
DEK Response Note A was listed in error for the LRA Table 3.3.2-19 items identified in this RAI. Note E should have been listed for both of these items.
Serial No.10-008 Docket No. 50-305 /Page 19 of 21 RAI 3.3.2.1-6
Background
LRA Tables 3.3.2-9, 3.3.2-13 and 3.3.2-14 list combinations of components, materials environments and aging effects among other parameters for items which are in scope for license renewal.
Issue In its review of these tables the staff noted that the applicant claims consistency for the items described below, by placing Note A on them. A review of these items against the GALL Report showed that for the referenced items the GALL Report proposes a plant-specific review and do not recommends a particular AMP. The staff does not understand the applicant's description of consistency with the GALL Report.
Table Subcomponent Material Environment Aging Effect AMP GALL Table 1 Notes Vol 2 Copper (E)Air-indoor Loss of material/pitting External 3.3.2-13 Heating Coils Surfaces VII.F2-14 3.3.1-25 A;1 Alloys uncontrolled and crevice corrosion Monitoring Copper (E)Air-indoor Loss of material/pitting External 3.3.2-14 Tubing Surfaces VII.F3-16 3.3.1-25 A
Alloys uncontrolled and crevice corrosion Monitoring Request Please, specify if the correct footnotes for the referenced items are Note A, andjustify how that conclusion was reached.
DEK Response Note A was listed in error for the LRA Table 3.3.2-13 and 3.3.2-14 items identified in this RAI. Note E should have been listed for both of these items.
Serial No.10-008 Docket No. 50-305 /Page 20 of 21 RAI 3.3.2.1-2
Background
LRA Tables 3.3.2-6 and 3.3.2-20 list combinations of components, materials environments and aging effects among other parameters for items which are in scope for license renewal.
Issue In its review of these tables the staff noted that the applicant claims consistency for the items described below, by assigning Notes Band E.
The staff is unable to verify the consistency of these items with the GALL Report because the applicant did not include references to Table 1 or to the GALL Report.
The staff does not understand the applicant's description of consistency with the GALL Report.
Table Subcomponent Material Environment Aging Effect AMP GALL Table 1 Notes Vol 2 Filter Housing (SW Stainless Loss of material/
Work Control 3.3.2-6 to chlorination Steel (I) Raw Water microbiologically Process E
pumps) influenced corrosion Stainless Loss of material/
Open-Cycle 3.3.2-20 Valves Steel (I) Raw Water microbiologically Cooling Water 8;2 influenced corrosion System Stainless Loss of material/
Work Control 3.3.2-20 Valves Steel (I) Raw Water microbiologically Process E;2 influenced corrosion Request Please, provide the references to Table 1 or to the GALL Report, and specify if the footnotes for the referenced items are correct.
Serial No.10-008 Docket No. 50-305 /Page 21 of 21 DEK Response Notes B<and E were listed in error for the LRA Table 3.3.2-6 and 3.3.2-20 items identified in this RAI. Note H should have been listed for each of these items.