ML11126A016
| ML11126A016 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 04/29/2011 |
| From: | Byrd K FirstEnergy Nuclear Operating Co |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| L-11-131, TAC ME4640 | |
| Download: ML11126A016 (78) | |
Text
FENOC Davis-Besse Nuclear Power Station 15501 N. State Route 2 FirstEnergy Nuclear Operating Company Oak Harbor, Ohio 43449 April 29, 2011 L-11-131 10 CFR 54 ATTN: Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555-0001
SUBJECT:
Davis-Besse Nuclear Power Station, Unit No. 1 Docket No. 50-346, License Number NPF-3 Reply to Request for Additional Information for the Review of the Davis-Besse Nuclear Power Station, Unit No. 1, License Renewal Application, Section 2.1 (TAC No.
ME4640), License Renewal Application Amendment No. 5, and Revised License Renewal Application Boundary Drawings By letter dated August 27, 2010, (Agencywide Documents Access and Management System (ADAMS) Accession No. ML102450565), FirstEnergy Nuclear Operating Company (FENOC) submitted an application pursuant to Title 10 of the Code of Federal Regulations, Part 54 for renewal of Operating License NPF-3 for the Davis-Besse Nuclear Power Station (DBNPS), Unit Number 1. By letter dated March 30, 2011 (ADAMS Accession No. ML110820624), the Nuclear Regulatory Commission (NRC) requested additional information to complete its review of the License Renewal Application (LRA).
The Attachment provides the FENOC reply to the NRC request for additional information.
The NRC request is shown in bold text followed by the FENOC response. Enclosure A provides Amendment No. 5 to the DBNPS LRA. Enclosure B provides revised LRA boundary drawings.
There are no regulatory commitments contained in this letter. If there are any questions or if additional information is required, please contact Mr. Clifford I. Custer, Fleet License Renewal Project Manager, at 724-682-7139.
Davis-Besse Nuclear Power Station, Unit No. 1 L-11-131 Page 2 I declare under penalty of perjury that the foregoing is true and correct. Executed on April.
2011.
Sincerely, Kendall W.
Director, S erformance Improvement
Attachment:
Reply to Request for Additional Information for the Review of the Davis-Besse Nuclear Power Station, Unit No. 1, License Renewal Application, Section 2.1
Enclosures:
A.
Amendment No. 5 to the DBNPS License Renewal Application B.
Revised License Renewal Application Boundary Drawings cc:
NRC DLR Project Manager NRC Region III Administrator cc:
w/o Attachment or Enclosure NRC DLR Director NRR DORL Project Manager NRC Resident Inspector Utility Radiological Safety Board
Attachment L-11-131 Reply to Request for Additional information for the Review of the Davis-Besse Nuclear Power Station, Unit No. 1, License Renewal Application, Section 2.1 Page 1 of 31 Section 2.1 Question RAI 2.1-1 10 CFR 54.4(a)(2) states: (a) Plant systems, structures and components within the scope of this part are (2) All nonsafety-related systems, structures and components whose failure could prevent satisfactory accomplishment of any of the [safety-related] functions identified in (a)(1)(i), (ii), or (iii) of this section.
During the scoping and screening methodology audit, performed on-site January 24-28, 2011, the staff reviewed the License Renewal Application (LRA),
the 10 CFR 54.4(a)(2) implementing documents and license renewal drawings, and also performed plant walkdowns. The staff determined that the applicant had identified safety-related components located in the turbine building. The applicant also confirmed that there are nonsafety-related structures, systems, and components (SSCs) in the vicinity of the safety-related components. The applicant had concluded that the nonsafety-related SSCs were not required to be included within the scope of license renewal in accordance with 10 CFR 54.4(a)(2).
The staff requests that the applicant provide a description and the results of the evaluation that formed the basis for concluding that the nonsafety related SSCs, located within the vicinity of safety-related SSCs within the turbine building, do not meet the criteria for inclusion within the scope of license renewal in accordance with 10 CFR 54.4(a)(2) for spatial interaction. During the review of this issue, consider extent of condition, and indicate if the review concludes that use of the scoping methodology precluded the identification of SSCs which should have been included within the scope of license renewal in accordance with 10 CFR 54.4(a)(2). Describe any additional scoping evaluations performed to address the 10 CFR 54.4(a)(2) criteria. List any additional SSCs included within the scope as a result of your efforts, and list those structures and components for which aging management reviews were conducted or any additional information related to material and environment combinations. For each structure and component, describe the aging management programs, as applicable, to be credited for managing the identified aging effects.
Attachment L-11-131 Page 2 of 31 RESPONSE RAI 2.1-1 Safety-related components located in the turbine building were identified through review of plant drawings, review of the SAP database (Davis-Besse Configuration Database),
and plant walkdowns.
In accordance with NEI 95-10, Appendix F, Section 5.2.3.1, some safety-related components are fail-safe by design. Fail-safe components are components whose failure (through interaction with the failed nonsafety-related SSC) cannot prevent the accomplishment of the safety-related intended function. Fail-safe components may not be vulnerable to spatial interaction because their function may be accomplished as a result of their failure. As long as the nonsafety-related SSC failure causes the safety-related SSC to attain its fail-safe state, the nonsafety-related SSCs would not be considered in scope for 10 CFR 54.4(a)(2). This approach is applied to the following systems and components:
" The safety-related (Q) components of the Startup Feedwater Pump and Auxiliaries System that are located in the Turbine Building are the position controllers for control valves DB-FV6459 and DB-FV6460. As shown on license renewal drawing LR-MO06D, these control valves fail open and the valve position controller is energized to close the valve, so the associated control valve opens on a loss of signal from the controller. Therefore, because the controllers are considered to be fail-safe components, the surrounding nonsafety-related systems and components are not in scope for 10 CFR 54.4(a)(2).
- The safety-related (Q) components of the Anticipatory Reactor Trip System (ARTS) are the pressure switches. The pressure switches (1) monitor the hydraulic oil pressure at the fast acting solenoids for the turbine generator main stop valves, and (2) monitor the oil pressure of the feedwater pump turbine high pressure stop valve.
In either case, a low oil pressure (below setpoint) will result in a reactor trip.
The ARTS is a fail-safe, de-energize-to-trip system. Therefore, if the power supply is lost to a logic system, that logic system will trip. The ARTS actuating equipment is designed to allow single failure without preventing the system from performing the required operation.
Therefore, because these pressure switches are considered to be fail-safe components, the surrounding nonsafety-related systems and components are not in scope for 10 CFR 54.4(a)(2).
" The safety-related (Q) components of the Main Feedwater Pump Turbine Oil System are drain valves associated with the ARTS pressure switches. A failure of the pressure boundary for these drain valves will result in a decrease in oil header pressure, as sensed by the ARTS pressure switches; if the pressure decreases below the setpoint, then the ARTS will perform its intended function. Therefore, because these drain valves are considered to be fail-safe components, the
Attachment L-11-131 Page 3 of 31 surrounding nonsafety-related systems and components are not in scope for 10 CFR 54.4(a)(2).
The following components will be protected in such a way as to prevent spatial interaction:
The safety-related (Q) radiation monitoring components that are located in the Turbine Building are associated with station vent normal and accident range monitors DB-RE4598AA, AB, BA, and BB. They are located on the turbine operating floor near the north wall between column lines D and E.
FENOC has made a commitment for license renewal, item number 22 of Table A-1 of the license renewal application (LRA), to enclose, or otherwise provide protection for, the station vent radiation monitors such that leakage and spray from surrounding piping systems does not cause age-related degradation which would prevent them from performing their intended functions. Therefore, the surrounding nonsafety-related systems and components are not in scope for 10 CFR 54.4(a)(2).
A review for the extent of condition determined that the scoping methodology did not preclude the identification of any SSCs that should have been within the scope of license renewal in accordance with 10 CFR 54.4(a)(2). No additional scoping evaluations were required to address 10 CFR 54.4(a)(2) criteria, and no additional SSCs were included within the scope of license-renewal.
Question RAI 2.1-2 10 CFR 54.4(a)(2) states: (a) Plant systems, structures and components within the scope of this part are (2) All nonsafety-related systems, structures and components whose failure could prevent satisfactory accomplishment of any of the [safety-related] functions identified in (a)(1 )(i), (ii), or (iii) of this section.
During the scoping and screening methodology audit, performed on-site January 24-28, 2011, the staff reviewed the LRA, the 10 CFR 54.4(a)(2) implementing documents and license renewal drawings, and also performed plant walkdowns. The staff determined through a review of license renewal drawings and discussion with the applicant that for certain systems, nonsafety-related pipe attached to safety-related pipe, had not been included within the scope of license renewal.
The staff requests that the applicant provide details of the analysis performed and any conclusions related to nonsafety-related pipe, attached to safety-related pipe, for inclusion within the scope of license renewal up to and including a seismic anchor or equivalent, in accordance with 10 CFR 54.4(a)(2). During the review of this issue, consider extent of condition, and indicate if the review concludes that use of the scoping methodology precluded the identification of
Attachment L-11-131 Page 4 of 31 SSCs which should have included within the scope of license renewal in accordance with 10 CFR 54.4(a)(2). Describe any additional scoping evaluations performed to address the 10 CFR 54.4(a)(2) criteria. List any additional SSCs included within the scope as a result of your efforts, and list those structures and components for which aging management reviews were conducted or any additional information related to material and environment combinations. For each structure and component, describe the aging management programs, as applicable, to be credited for managing the identified aging effects.
RESPONSE RAI 2.1-2 In-scope nonsafety-related mechanical components that are directly connected to safety-related piping and piping components are highlighted on the license renewal boundary drawings beyond the safety-related (Q) boundary to the limits of the seismic class I analysis boundary, designated as "S/I" on the Piping and Instrument Diagrams (P&IDs). The S/I boundary is delineated on the hanger location isometric drawings at the first seismic restraint or equivalent seismic restraint, which corresponds to the S/I boundary identified on the P&ID drawing. This boundary is supported by the pipe stress analysis performed for the piping. The S/I boundary is generally a six-way physical anchor point, but may be a series of pipe restraints or equipment nozzles which provide an equivalent terminal restraint (i.e., an equivalent anchor) for the piping.
However, as identified during the scoping and screening methodology audit, the locations of the S/I boundaries were incomplete on plant P&IDs. Several Condition Reports (CRs) were written and entered into the FENOC Corrective Action Program to identify drawings where S/I boundaries were not properly identified on the P&IDs. As part of the corrective actions, an extent of condition review was performed to identify the scope of the issue. Calculations were performed as necessary to confirm seismic class I analysis boundaries, andthe P&IDs were updated to include the S/I boundaries.
As a result of the updated P&ID drawings, the affected license renewal boundary drawings are revised to include license renewal notes to identify the location of updated S/I boundaries. Based on the updated S/I boundaries, highlighting is added to or removed from the license renewal drawings to bring additional components within the scope of license renewal or remove components from the scope of license renewal.
The following license renewal boundary drawings are revised to update S/I boundaries:
LR-MO03A LR-MO06D LR-MO07A LR-M01OC LR-MO10D LR-MO15A LR-M015D LR-M015F LR-MO17B LR-MO19 LR-M022A LR-M029B LR-M029C LR-M029D LR-M030A LR-M031 B LR-M031C LR-M033B
Attachment L-11-131 Page 5 of 31 LR-M033C LR-M036B LR-M038B LR-M040A LR-M041 C LR-M035 LR-M036C LR-M038C LR-M040D LR-M046 LR-M036A LR-M037D LR-M039A LR-M041 B LR-M900A A number of the drawings from the above list had no highlighting changes when the S/I boundary updates were completed. The following table lists only those drawings where license renewal scoping boundary highlighting is added or removed due to the updated P&ID S/I boundaries. The table identifies the affected drawing number, plant system, location of new highlighting, component types in the new highlighting, whether the LRA is impacted, and a summary of the change.
Attachment L-11-131 Page 6 of 31 LR Location of Component Types Affects Drawing System New in the New LRA Text?
Discussion/Conclusion Highlighting Highlighting (Yes/No)
A/2, C/1, tubing, valve body No Control air supply components not subject to Main Steam D/3, E/3, AMR as described in LRA Section 2.3.4.4 LR-MO03A No component types, materials, or environments were removed from the Main Main Steam G/9 n/a No Steam System scoping results as a result of removing this highlighting.
LRA Table 3.3.2-24 rows 5, 8, 37, 41, 42, 86, 90-92, 96, and 97 Reactor Coolant Vent A/, A/14 bolting, piping, valve No address the internal and external a
rbenvironments of subject bolting and piping, and valve body.
LRA Table 3.3.2-22 rows 6-8 and 15-17 address the internal and external Nitrogen Gas A/3, A12 bolting, piping, valve Yes environments of subject bolting and piping.
body LR-MO07A LRA Table 3.3.2-22 is revised to add rows for subject valve body LRA Table 3.4.2-4 rows 10, 13, 14, 62, 69, and 70 address the Main Steam A/5-7, A/8-10 bolting, piping No internal and external environments of subject bolting and piping.
LRA Table 3.4.2-4 rows 10, 13, 14, 62, 69, and 70 address the Main Steam C/7, C/9 bolting, piping No internal and external environments of subject bolting and piping.
Attachment L-11-131 Page 7 of 31 LR Location of Component Types Affects Drawing System New in the New LRA Text?
Discussion/Conclusion Highlighting Highlighting (Yes/No) position controller',
LRA Table 3.4.2-4 is revised to add rows LR-MO07A Main Steam C-D/6, C-D/9 pressure converter',
Yes for subject tubing tubing forsubjecttubing LRA Table 3.3.2-17 rows piping, pressure 19-23, 25, and 34-36 address the internal LR-MO15A Instrument Air F/3-4 indicator1, tubing, No and exera evrn ens ose
- ing, valvebodyand external environments of subject piping,
- valve body
___tubing, and valve body.
LRA Table 3.3.2-29 rows 4-6 and 13-15 address the internal and LR-M015D Station Air G/8-9 bolting, piping No 46ad1-5adesteitra n
Mexternal environments of subject bolting and piping.
LRA Table 3.3.2-29 rows 4-6 and 13-15 address the internal and bolting, piping, external environments of the subject bolting LR-MO15F Station Air D/2-6 pressure indicator ',
Yes and piping.
valve body LRA Table 3.3.2-29 is revised to add rows for subject valve body Highlighting removed due to new S/I boundary. However, no component types, LR-M017B Emergency Diesel C/5, E/5, G/5, n/a No materials, or environments were removed Generators J/5 from the Emergency Diesel Generator System scoping results as a result of removing this highlighting.
D-K/1-2, tubing Yes LRA Table 3.3.2-22 is revised to add rows LR-M019 Nitrogen Gas A-F/1 3-14 for subject tubing
Attachment L-11-131 Page 8 of 31 LR Location of Component Types Affects Drawing System New in the New LRA Text?
Discussion/Conclusion Highlighting Highlighting (Yes/No)
LRA Table 3.3.2-22 rows 6-8 and 15-17 address the internal and external environments of the subject bolting and Nitrogen Gas B/3 bolting, piping, valve Yes piping.
body LRA Table 3.3.2-22 is revised to add rows LR-M019g for subject valve body LRA Table 3.3.2-22 rows 6-8 and 15-17 address the internal and external valve environments of the subject bolting and Nitrogen Gas C-D/5-6 bolting, piping, Yes piping.
body LRA Table 3.3.2-22 is revised to add rows for subject valve body Process and Area bolting, piping, LRA Table 3.3.2-23 is revised to add rows Radiation Monitoring C/2, D/2 tubing Yes for subject bolting, piping, and tubing LRA Table 3.3.2-8 rows 13, 16, 73-75, and LR-M029B Containment C/3 bolting, piping, valve No 112-114 address the internal and external Hydrogen Control body environments of the subject bolting, piping, and valve body.
LRA Table 3.3.2-8 rows 13, 16, 73-75, and Containment E/4 bolting, piping, valve No 112-114 address the internal and external Hydrogen Control body environments of the subject bolting, piping, and valve body.
Attachment L-11-131 Page 9 of 31 LR Location of Component Types Affects Drawing System New in the New LRA Text?
Discussion/Conclusion Highlighting Highlighting (Yes/No)
Instrument Air A-B/1 -2, F-G/1 -2 tubing No LRA Table 3.3.2-17 rows 26-28 address the internal and external environments of the subject tubing LR-M029C LRA Table 3.3.2-17 rows Instrument Air H/5 tubing No 26-28 address the internal and external environments of the subject tubing LRA Table 3.3.2-8 rows 97, 99, 100, 102, 104, and 105 flow indicator1,
address the internal and external Containment A-C/12-'14 pump casing, t*Jbing, Yes environments of the subject tubing and valve Hydrogen Control valve body body.
LRA Table 3.3.2-8 is revised to add rows for pump casing Instrument Air D-F/1 3-14 tubing No LRA Table 3.3.2-17 rows 26-28 address the internal and external environments of the subject tubing J
£
.1.
L L
Attachment L-11-131 Page 10 of 31 LR Location of Component Types Affects Drawing System New in the New LRA Text?
Discussion/Conclusion Highlighting Highlighting (Yes/No)
LRA Table 3.3.2-8 rows Containment 17, 20, 21, and 76-78 address the internal Hydrogen Control K/3 bolting, piping No and external environments of the subject LR-M029D bolting and piping.
LRA Table 3.3.2-8 rows 17, 20, 21, and 76-Containment 78 address the internal and external Hydrogen Control D/11 bolting, piping No environments of the subject bolting and piping.
LRA Table 3.3.2-24 rows 5, 8, 37, 41, 42, Reactor Coolant Vent bolting, flow gage1, 72, 76, 77, 86, 90, 91, 92, 96, and 97 and Drain AM1-2 piping, tubing, valve No address the internal and external body environments of the subject bolting, piping, tubing, and valve body.
LRA Table 3.3.2-24 rows 5, 8, 37, 41, and Reactor Coolant Vent 42 address the internal and external and Drain A/3 bolting, piping No environments of the subject bolting and piping.
LR-M030A LRA Table 3.3.2-24 rows 5, 8, 37, 41, 42, Reactor Coolant Vent A-C/11-12, bolting, flow gage',
72, 76, 77, 86, 90, 91, 92, 96, and 97 and Drain D-F/1-2 piping, tubing, valve No address the internal and external body environments of the subject bolting, piping, tubing, and valve body.
LRA Table 3.3.2-22 rows 6-8 and 15-17 Nitrogen Gas E/3, E 11 bolting, piping No address the internal and external environments of the subject bolting and piping.
Attachment L-11-131 Page 11 of 31 LR Location of Component Types Affects Drawing System New in the New LRA Text?
Discussion/Conclusion Highlighting Highlighting (Yes/No)
LRA Table 3.3.2-18 rows 154 and 155 address the external environment of the Makeup and A/23 tubing, pressure subject tubing.
Purification indicator1 LRA Table 3.3.2-18 is revised to add rows for tubing in dried air (Internal)
LRA Table 3.3.2-18 rows 154, 155, 176, and 177 address the external environment of the LR-M031 B Makeup and F/8, G/8, J/8, tubing, pressure subject tubing and valve body.
Purification K/8 bodyctrvleY s.....
Pr obody LRA Table 3.3.2-18 is revised to add rows for tubing and valve body in dried air (Internal)
LRA Table 3.3.2-18 rows 154 and 155 address the external environment of the Makeup and F/7, G/7, J/7, tubing, pressure Yes subject tubing.
Purification K/7 indicator1 LRA Table 3.3.2-18 is revised to add rows for tubing in dried air (Internal)
Decay Heat Removal Control air supply components not subject to and Low Pressure E/10, G/12 tubing No AMR as described in LRA Section 2.3.2.4 Injection LR-M033B LRA Table 3.2.2-4 rows 6, 7, 82, 89, and 90 Decay Heat Removaladrsthinealndxenl and Low Pressure H/5 bolting, piping No address the internal and external Injection environments of the subject bolting and Injection__piping.
Attachment L-11-131 Page 12 of 31 LR Location of Component Types Affects Drawing System New in the New LRA Text?
Discussion/Conclusion Highlighting Highlighting (Yes/No)
E1/7 -
Decay Heat Removal highlighting tubing, pressure LRA Table 3.2.2-4 rows and Low Pressure changed from indicatore No 135-140 address the internal and external LR-M033C Injection green to environments of the subject tubing.
magenta Decay Heat Removal Control air supply components not subject to and Low Pressure C/10, E/1 1 tubing:.
No AMR as described in LRA Section 2.3.2.4 Injection System LRA Table 3.3.2-7 rows 13, 16, 63, 68, and 69 address the external environments of the subject bolting and piping.
LR-M036A Component Cooling A/9, A/1 bolting, piping Yes Water System LRA Table 3.3.2-7 is revised to add rows for bolting/air-indoor uncontrolled (External)/loss of material and piping/gas (Internal)
Attachment L-11-131 Page 13 of 31 LR Location of Component Types Affects Drawing System New in the New LRA Text?
Discussion/Conclusion Highlighting Highlighting (Yes/No)
Gaseous Radwaste B/3 bolting, piping, valve body No LRA Table 3.3.2-16 rows 5, 8, 34, 36, 37, 60, 62, and 63 address the internal and external environments of the subject bolting, piping, and valve body.
LRA Table 3.3.2-16 rows 5, 8, 34, 36, and Gaseous Radwaste E/4, H/4 bolting, piping No 37 address the internal and external environments of the subject bolting and piping.
LRA Table 3.3.2-16 rows 5, 8, 34, 36, 37, 60, 62, and 63 Gaseous Radwaste C-D/9-13 bolting, piping, valve No address the internal and external body environments of the subject bolting, piping, and valve body.
LRA Table 3.3.2-16 rows 5, 8, 27-29, 34, 36, 37, 60, 62, and 63 Gaseous Radwaste E/9 - E/14 bolting, piping, No address the internal and external orifice, valve body environments of the subject bolting, piping, orifice, and valve body.
LR-M038B C-K/4-8 Gaseous Radwaste bolting, moisture separator body, trap body, piping, valve body Yes LRA Table 3.3.2-16 rows 5, 8, 34-37, and 60-63 address the internal and external environments of the subject bolting, piping, and valve body.
LRA Table 3.3.2-16 is revised to add rows for subject moisture separator body and trap body
Attachment L-11-131 Page 14 of 31 LR Location of Component Types Affects Drawing System New in the New LRA Text?
Discussion/Conclusion Highlighting Highlighting (Yes/No)
LRA Table 3.3.2-16 rows 5, 8, 28, 29, 34-37, and 60-63 address the internal and external environments of the bolting, level subject bolting, piping, orifice, and valve LR-M038B Gaseous Radwaste H-K/8-14 indicator', piping, Yes body.
orifice, valve body body.
LRA Table 3.3.2-16 is revised to add rows for orifice/condensation (Internal)
LRA Table 3.3.2-16 rows 5, 8, 34, 36, and 37 LR-M038C Gaseous Radwaste G/2, G/4, G/6 bolting, piping No address the internal and external environments of the subject bolting and piping.
LRA Table 3.3.2-24 rows Reactor Coolant Vent 5, 8, 37, 41, and 42 and Drain E/3 bolting, piping No address the internal and external environments of the subject bolting and piping.
LRA Table 3.3.2-24 rows 5, 8, Reactor Coolant Vent 36, 41, and 42 LR-M040A and Drain C/11 bolting, piping No address the internal and external environments of the subject bolting and piping.
LRA Table 3.3.2-24 rows 5, 8, 36, 37, 41, 42, 86, 90-92, 96, and 97 Reactor Coolant Vent G-K/1-7 bolting, piping, valve No address the internal and external and Drain body environments of the subject bolting, piping, and valve body.
Attachment L-11-131 Page 15 of 31 LR Location of Component Types Affects Drawing System New in the New LRA Text?
Discussion/Conclusion Highlighting Highlighting (Yes/No)
LRA Table 3.3.2-24 rows LR-M040D Reactor Coolant Vent 5, 8, 37, 41, and 42 address the internal and and Drain H/8 bolting, piping No external environments of the subject bolting and piping.
LR-M041C Service Water B-C/3-4, C/7-8, E/H converter1, Yes LRA Table 3.3.2-26 is revised to add rows C/10-12 tubing, valve body for tubing and valve body LRA Table 3.3.2-17 rows LR-M900A Instrument Air C-G/1-6
- piping, No 19-21 and 34-36 address the internal and valve body external environments of the subject piping
_____and valve body.
1 - Flow gage, level indicator, pressure indicator, position controller, E/H converter, and pressure indicator are in a line that serves a structural integrity function and are within the scope of license renewal as indicated by the highlighting. These instruments and instruments in general are exempt from aging management review (AMR) because 10 CFR 54.21 (a)(1)(i) specifically excludes, but is not limited to, pressure and water level indicators, which are similar to those instruments and indicators identified in the table.
See Enclosure A to this letter for the revision to the DBNPS LRA.
See Enclosure B to this letter for the revision to the LRA Boundary Drawings.
Attachment L-11-131 Page 16 of 31 Question RAI 2.1-3 10 CFR 54.4(a)(2) states: (a) Plant systems, structures and components within the scope of this part are (2) All nonsafety-related systems, structures and components whose failure could prevent satisfactory accomplishment of any of the [safety-related] functions identified in (a)(1 )(i), (ii), or (iii) of this section.
During the scoping and screening methodology audit, performed on-site January 24-28, 2011, the staff reviewed the LRA, the 10 CFR 54.4(a)(2) implementing documents and license renewal drawings, and also performed plant walkdowns. The staff determined through a review of license renewal drawings and discussion with the applicant that equipment that was no longer required had been placed in an abandoned state.
The staff requests that the applicant provide details on the activities performed to confirm that all abandoned equipment that at any time contained fluids, and is in the proximity of safety-related SSCs, has been verified to be drained. If abandoned equipment has not been verified to be drained or is not included within the scope of license renewal, provide details of the analysis performed and any conclusions, related to the inclusion of abandoned equipment within the scope of license renewal in accordance with 10 CFR 54.4(a)(2). During the review of this issue, consider extent of condition, and indicate if the review concludes that use of the scoping methodology precluded the identification of SSCs which should have included within the scope of license renewal in accordance with 10 CFR 54.4(a)(2).
Describe any additional scoping evaluations performed to address the 10 CFR 54.4(a)(2) criteria. List;any additional SSCs included within the scope as a result of your efforts, and list those structures and components for which aging management reviews were conducted or any additional information related to material and environment combinations. For each structure and component, describe the aging management programs, as applicable, to be credited for managing the identified aging effects.
RESPONSE RAI 2.1-3 FENOC provides the following new license renewal future commitment regarding abandoned equipment, which will be included in LRA Appendix A, "Updated Safety Analysis Report Supplement," Table A-i, "Davis-Besse License Renewal Commitments:"
Prior to the period of extended operation, FENOC will review all License Renewal scoping drawings and Aging Management Review reports to ensure identification of components that would have been in scope under 10 CFR 54.4(a)(2), but were excluded from aging management because they are abandoned. For each such component or set of components,
Attachment L-11-131 Page 17 of 31 FENOC will ensure administrative controls are in place to maintain the components isolated from fluid sources and drained.
If any additional components are determined to be within the scope of License Renewal as a result of this review, they will be addressed in an amendment to the LRA (if identified during the LRA review process),'or during the periodic UFSAR update required by 10 CFR 50.71(e), as specified in 10 CFR 54.37(b).
See Enclosure A to this letter for,the revision to the DBNPS LRA.
Question RAI 2.1-4 10 CFR 54.4(a)(2) states: (a) Plant systems, structures and components within the scope of this part are (2) All nonsafety-related systems, structures and components whose failure could prevent satisfactory accomplishment of any of the [safety-related] functions identified in (a)(1 )(i), (ii), or (iii) of this section.
During the scoping and screening methodology audit, performed on-site January 24-28, 2011, the staff reviewed the LRA, the 10 CFR 54.4(a)(2) implementing documents and license renewal drawings, and also performed plant walkdowns. The staff determined that the applicant did not include nonsafety-related relief valve drain lines, within the vicinity of safety-related SSCs, within the scope of license renewal. The staffs reviewdetermined that the function of a drain line is to pass fluid when required and therefore the pipe should be included within the scope of license renewal and subject to aging management review in accordance with 10 CFR 54.4 (a)(2) for spatial interaction. The staff further determined that following inclusion of the drain lines within the scope of license renewal, the applicant's aging management review will allow for the evaluation of material and environment combinations to identify aging effects and the suitability of aging management programs.
The staff requests that the applicant provide details of the analysis performed and any conclusions, related to the review of the potentially 'fluid filled, nonsafety-related relief valve drain lines, located within the vicinity of safety-related SSCs, for inclusion within the scope of license renewal in accordance with 10 CFR 54.4(a)(2) for spatial interaction. During the review of this issue, consider extent of condition, and indicate if the review concludes that use of the scoping methodology precluded the identification of SSCs which should have included within the scope of license renewal in accordance with 10 CFR 54.4(a)(2). Describe any additional scoping evaluations performed to address the 10 CFR 54.4(a)(2) criteria. List any additional SSCs included within the scope as a result of your efforts, and list those structures and components for which aging management reviews were conducted or any additional information related to material and environment combinations. For each structure and component, describe the aging
Attachment L-11-131 Page 18 of 31 management programs, as applicable, to be credited for managing the identified aging effects.
RESPONSE RAI 2.1-4 FENOC has performed a review of potentially fluid filled, nonsafety-related relief valve drain lines, located within the vicinity of safety-related SSCs, for inclusion within the scope of license renewal in accordance with 10 CFR 54.4(a)(2) for spatial interaction.
The review resulted in identifying additional components for inclusion within the scope of license renewal. License renewal drawings were revised to highlight the additional components. A listing of the subject drawings and tables containing the AMR results along with any required additional rows are presented in the table below. The AMR tables (existing and revised) contain the component type, material/environment combinations, aging effects requiring management and credited aging management programs.
Attachment L-11-131 Page 19 of 31 LR Drawing System Location of Component Types in Affected LRA Discussion/Conclusion New the New Highlighting text?
Highlighting (Yes/No)
A-B/5-8; Table 3.4.2-4 rows 10, 13, 14, 62, 69, 70 LR-MO07A Main Steam A-B/8-1 1; Bolting, Piping No address the internal and external C/7; C/8 environments of subject bolting and piping.
G/5-6, Table 3.3.2-18 rows 12-15, 89, 97, 98, 169, Makeup and Bolting, Piping, Valve 176, 177 address the internal and external Purification C-G/5; body, Flow gage1 No environments of subject bolting, piping and n
C/5-9; valve body.
B-C/9-1O0; Table 3.3.2-24 rows 5-8, 24, 27, 28, 38, 41, 42 address the internal and external LR-M031A F/7-1 1; Bolting, Orifice, Piping No environments of subject bolting, orifice and Reactor piping.
Coolant Vent and Drain Table 3.3.2-24 rows 5-8, 39-42 address the internal ýnd external environments of subject bolting and piping.
Reactor Table 3.3.2-24 rows 5-8, 24, 27, 28, 38, 41, 42 address the internal and external LR-M031 B Coolant Vent A/9-1 0 Bolting, Piping No 4
drs h
nenladetra B ant Vint Benvironments of subject bolting and piping.
and Drain Decay Heat Table 3.2.2-4 rows 6, 7, 82, 89, 90 address Removal and the internal and external environments of LR-M033B Low Pressure D-E/l-2; H/5 Bolting, Piping No subject bolting and piping.
Injection Table 3.2.2-3 rows 1, 4, 23, 30, 31 address the internal and external environments of LR-M034 Core Flooding G/3; G/8 Bolting, Piping No sbe boting and piping.
subject bolting and piping.
Attachment L-11-131 Page 20 of 31 LR Drawing System Location of Component Types in Affected LRA Discussion/Conclusion New the New Highlighting text?
Highlighting (Yes/No)
Table 3.3.2-24 rows 5-8, 24, 27, 28, 38, 41, Reactor 42 address the internal and external LR-M035 Coolant Vent H-J/4-5 Bolting, Orifice, Piping No environments of subject bolting, orifice and and Drain piping Table 3.3.2-7 rows 13, 16, 63, 68, 69 LR-M036C Component No address the internal and external Comonenti Wae environments of subject bolting and piping.
Table 3.3.2-24 rows 5-8, 24, 27, 28, 38, 41, LR-M037C 42 address the internal and external (included in Reactor environments of subject bolting, orifice and FENOC Letter Coolant Vent G/2-1 1; Bolting, Orifice, Piping No piping.
L-11-114 dated and Drain April 15, 2011)
Table 3.3.2-24 rows 5-8, 24, 27, 28, 38, 41, Reactor 42 address the internal and external LR-M037E Coolant Vent A-B/2-7 Bolting, Orifice, Piping No environments of subject bolting, orifice and and Drain piping.
Attachment L-11-131 Page 21 of 31 LR Drawing System Location of Component Types in Affected LRA Discussion/Conclusion New the New Highlighting text?
Highlighting (Yes/No)
Table 3.3.2-21 rows 3, 4, 24, 25 address the external environments of subject bolting and Miscellaneous piping.
LR-M039B Liquid E/2-3; Bolting, Piping Yes LRA Table 3.3.2-21 is revised to add rows (included in Radwaste for piping/air-indoor uncontrolled FENOC Letter (internal)
L-1 1-114 dated Apr'il 15, 2011 )
-*Table 3.3.2-24 rows 5-8, 24, 27, 28, 38, 41, Reactor 42 address the internal and external Coolant Vent E/7-8; Bolting, Orifice, Piping No environments of subject bolting, orifice and and Drain piping..*..
Table 3.3.2-24 rows 5-8, 36, 38, 41, 42, 87, Reactor*
C/10-11; 90, 91, 93, 96, 97 address the internal and LR-M040A Coolant Vent D/7-8; Bolting, Piping, Valve No external environments of subject bolting, and Drain E-F/8-9 body piping and valve body.
Table 3.3.2-2 rows 1, 2, 3, 35 address the external environments of subject bolting and piping.
Auxiliary LR-M043 Building B/5 Bolting, Piping Yes LRA Table 3.3.2-2 is revised to add rows Chilled Water for piping/air-indoor uncontrolled (internal) and piping/air-indoor uncontrolled (External)
Attachment L-11-131 Page 22 of 31 LR Drawing System Location of Component Types in Affected LRA Discussion/Conclusion New the New Highlighting text?
Highlighting (Yes/No)
Table 3.3.2-21 rows 3, 4, 24, 25 address the Right external environments of subject bolting and Miscellaneous drawing piping.
LR-M281N 13 Liquid border Bolting, Piping Yes LRA Table 3.3.2-21 is revised to add rows Radwaste downstream for piping/air-indoor uncontrolled of WM2252 (internal) 1 -
Flow gage or flow indicator is in a line that serves a structural integrity function and within the scope of license renewal as indicated by the highlighting. These instruments and instruments in general are exempt from aging management review (AMR) because 10 CFR 54.21(a)(1)(i) specifically excludes, but is not limited to, water level indicators, which are similar to sight glasses and flow gages.
See Enclosure A to this letter for the revision to the DBNPS LRA.
See Enclosure B to this letter for the revision to the LRA Boundary Drawings.
Attachment L-11-131 Page 23 of 31 Question RAI 2.1-5 10 CFR 54.4(a)(2) states: (a) Plant systems, structures and components within the scope of this part are (2) All nonsafety-related systems, structures and components whose failure could prevent satisfactory accomplishment of any of the [safety-related] functions identified in (a)(1)(i), (ii), or (iii) of this section.
During the scoping and screening methodology audit, performed on-site January 24-28, 2011, the staff reviewed the LRA, the 10 CFR 54.4(a)(2) implementing documents and license renewal drawings, and also performed plant walkdowns. The staff determined that the applicant did not include nonsafety-related drip pans and retention area drain lines, within the vicinity of safety-related SSCs, within the scope of license renewal. The staffs review determined that the function of the drip pans and retention area drain lines is to contain or pass fluid when required and therefore should be included within the scope of license renewal and subject to aging management review in accordance with 10 CFR 54.4 (a)(2) for spatial interaction and 10 CFR 54.21. The staff further determined that following inclusion of the drain lines within the scope of license renewal, the applicant's aging management review will allow for the evaluation of material and environment combinations to identify aging effects and the suitability of aging management programs.
The staff requests that the applicant provide details of the analysis performed and any conclusions, related to the review of the potentially fluid filled, non safety-related drip pan and retention area drain lines, located within the vicinity of safety-related SSCs, for inclusion within the scope of license renewal in accordance with 10 CFR 54.4(a)(2) for spatial interaction. During the review of this issue, consider extent of condition, and indicate if the review concludes that use of the scoping methodology precluded the identification of SSCs which should have included within the scope of license renewal in accordance with 10 CFR 54.4(a)(2). Describe any additional scoping evaluations performed to address the 10 CFR 54.4(a)(2) criteria. List any additional SSCs included within the scope as a result of your efforts, and list those structures and components for which aging management reviews were conducted or any additional information related to material and environment combinations. For each structure and component, describe the aging management programs, as applicable, to be credited for managing the identified aging effects.
RESPONSE RAI 2.1-5 FirstEnergy Nuclear Operating Company (FENOC) has performed a review of potentially fluid filled, nonsafety-related drip pan and retention area drain lines, located within the vicinity of safety-related SSCs, for inclusion within the scope of license renewal in accordance with 10 CFR 54.4(a)(2) for spatial interaction. The review has
Attachment L-11-131 Page 24 of 31 considered extent of condition and identified additional SSCs for inclusion into the LRA.
License renewal drawings were revised to highlight the additional components. For each affected drawing, the additional components including revised aging management review results are addressed below:
Drawing LR-M006D (H/2; C/14)
The drain pans and retention area drain lines associated with the Motor Driven Start-up Feed Pump P15 (H-2) and Aux Feed Pumps P14-1 and P14-2 (C-14) are in scope for (a)(2) considerations.
o Note: Changes to the LRA for the addition of the subject drip pans and retention area drain lines have been previously provided in the response to RAI 2.3.4.3-01 submitted by FENOC Letter dated 04/15/2011.
Drawing LR-M007A (J-K/4-7)
The drain pans and retention area drain lines associated with the main steam relief valves are in scope for (a)(2) considerations. LR-MO07A was revised to highlight these components.
o This change affects LRA Tables 2.3.4-4 and 3.4.2-4. The component types within the added highlighting are included in the Main Steam System, and consist of "Drain Pan" and "Piping". Piping component types and materials are addressed in License Renewal Application Table 3.4.2-4 rows 62, 69 and
- 70. However, LRA Tables 2.3.4-4 and 3.4.2-4 were changed to include drain pans.
Drawing LR-M017C (J/10)
The drain line and valve associated with the Fire Pump Diesel Day Tank T47 is in scope for (a)(2) considerations. LR-MO1 7C was revised to highlight these components. The curbs for oil spill confinement are structural components and are included with Bulk Commodities as concrete component type "Flood Curbs" in LRA Tables 2.4-13 and 3.5.2-13 as indicated in FENOC response to RAI 2.3.3.14-3 in Letter L-11-078 dated March 18, 2011.
o This change affects LRA Section 2.3.3.15 and Tables 2.3.3-15 and 3.3.2-15.
The component types within the added highlighting are included in the System, and consist of "Bolting", "Piping" and "Valve body". LRA Section
Attachment L-11-131 Page 25 of 31 2.3.3.15 and Tables 2.3.3-15 and 3.3,2 15 were changed or confirmed to include associated "Bolting", "Piping" and "Valve body".
Drawing LR-M033B (H/9)
The drain pans and retention area drain lines associated with the Decay Heat Pump P42-1 are inspcope for (a)(2) considerations. LR-M033B was revised to-highlight these components.
o This change affects LRA Tables 2.3.2-4 and 3.2.2-4. The component types within the added highlighting are included in the System, and consist of "Drain Pan" and "Piping". LRA Tables 2.3.2-4 and 3.2.2-4 were changed or confirmed to include drain pan and associated piping.
Drawing LR-M033C (F/8)
The drainpans and retention area drain lines associated with the Decay Heat Pump P42-2 are in scope for (a)(2) considerations. LR-M033C was revised to highlight these components.
o This change affects LRA Tables 2.3.2-4 and 3.2.2-4. The component types within the added highlighting are included in the System, and consist of "Drain Pan" and "Piping". LRA Tables 2.3.2-4 and 3.2.2-4 were changed or confirmed to include drain pan and associated piping.
Drawing LR-M034 (C/10; D/10)
The drain pans and retention area drain lines associated with the Containment Spray Pumps P5,6-1 and P56-2 are in scope for (a)(2) considerations. LR-M034 was revised to highlight these components.
o This change affects LRA Tables 2.3.2-2 and 3.2.2-2. The component types within the added highlighting are included in the System, and consist of "Drain Pan" and "Piping". Piping component types and materials are addressed in License Renewal Application Table 3.2.2-2 rows 36 and 37. However, LRA Tables 2.3.2-2 and 3.2.2-2 were changed or confirmed to include drain pans and associated piping.
Drawing LR-M035 (A/3; A/10)
The drain pans and retention area drain lines associated with the Refueling Canal Skimmer Pump P45 and Spent Fuel Pool Skimmer Pump
Attachment L-11-131 Page 26 of 31 P134 are in scope for (a)(2) considerations. LR-M035 was revised to highlight these components.
o This change affects LRA Tables 2.3.3-27 and 3.3.2-27. The component types within the added highlighting are included in the System, and consist of "Drain Pan" and "Piping". LRA Tables 2.3.3-27 and 3.3.2-27 were changed or confirmed to include drain pans and associated piping.
Drawing LR-M036C (G/11; G/14)
The drain pans and retention area drain lines associated with the Control Rod Drive Cooling (CRDC) Booster Pumps P170-1 and P170-2 are in scope for (a)(2) considerations. LR-M036C was revised to.-highlight these components.
o This change affects LRA Tables 2.3.3-7 and 3.3.2-7, and Appendix B.2.9.
The component types within the added highlighting are included in the System, and consist of "Drain Pan" and "Piping". Piping component types and materials are addressed in License Renewal Application Table 3.3.2-7 rows 63, 68 and 69. However, LRA Tables 2.3.3-7, 3.3.2-7, and Appendix B.2.9 were changed or confirmed to include drain pans and associated piping.
See Enclosure A to this letter for the revision to the DBNPS LRA.
See Enclosure B to this letter for the revision to the LRA Boundary Drawings.
Question RAI 2.1-6 10 CFR 54.4(a)(2) states: (a) Plant systems, structures and components within the scope of this part are (2) All nonsafety-related systems, structures and components whose failure could prevent satisfactory accomplishment of any of the [safety-related] functions identified in (a)(1)(i), (ii), or (iii) of this section.
During the scoping and screening methodology audit, performed on-site January 24-28, 2011, the staff reviewed the LRA, the 10 CFR 54.4(a)(2) implementing documents and license renewal drawings, and also performed plant walkdowns. During a plant walkdown,.the staff observed a nonsafety-related domestic water valve and other nonsafety-related fluid filled SSCs located in the service water tunnel and in the vicinity of safety-related SSCs.
The staff requests that the applicant provide a basis for not including the non-safety related components, within the vicinity of safety-related SSCs within the scope of license renewal in accordance with 10 CFR 54.4(a)(2) for spatial interaction. During the review of this-issue, consider extent of condition, and
Attachment L-11-131 Page 27 of 31 indicate if the review concludes that use of the scoping methodology precluded the identification of SSCs which should have included within the scope of license renewal in accordance with 10 CFR 54.4(a)(2). Describe any additional scoping evaluations performed to address the 10 CFR 54.4(a)(2) criteria. List any additional SSCs included within the scope as a result of your efforts, and list those structures and components for which aging management reviews were conducted or any additional information related to material and environment combinations. For each structure and component, describe the aging management programs, as applicable, to be credited for managing the identified aging effects.
RESPONSE RAI 2.1-6 Following the scoping and screening methodology audit walkdown, the license renewal boundary drawings were reviewed and walkdowns performed to identify nonsafety-related fluid filled SSCs located in the vicinity of safety-related systems, structures and components (SSCs) in areas of the station where the drawings did not clearly identify building boundaries. This extent-of-condition review identified additional piping and components located in the safety-related Service Water Tunnel that should have been included within the scope of license renewal. The piping and components identified are associated with the Demineralized Water Storage (DWS) System, the Fire Protection (FP) System, the Fuel Oil System (specifically, fire pump diesel fuel oil piping), and the Makeup Water Treatment (MWT) System. License renewal boundary drawings LR-MO06E, LR-MO10A, LR-MO10D, LR-MO12E, LR-MO16A, and LR-M017C are revised to highlight the added components. Based on the revised highlighting, no new component types are introduced to the scope of license renewal. However, additional material-environment combinations were evaluated as a result of the revised highlighting.
The component types within the added highlighting for the DWS System are already included in the LRA. For the DWS System, the component types consist of "Bolting,"
"Piping," and "Valve Body." These component types are addressed in LRA Table 3.3.2-11, "Aging Management Review Results - Demineralized Water Storage System,"
rows 5-8, 13-17, and 41-44. LRA Section'2.3.3.11 is revised to add license renewal boundary drawing LR-MO06E to the list of license renewal boundary drawings that depict the evaluation boundaries of the DWS System.
The component types within the added highlighting for the FP System are already included in the LRA. For the FP System, the component types consist of "Bolting,"
"Piping," "Tubing," and "Valve Body." These components are addressed in LRA Table 3.3.2-14 "Aging Management Review Results - Fire Protection System," rows 15-18, 57, 58,116,117,121,122,148,149, and151-153.
The component type within the added highlighting for the Fuel Oil System is "Piping",
which is already addressed in the LRA. However, LRA Section 2.3.3.15, "Fuel Oil
Attachment L-11-131 Page 28 of 31 System," is revised to identify that the system now contains components that meet the scoping criterion of 10 CFR 54.4(a)(2), for nonsafety-related components located near safety-related components. LRA Table 2.3.3.15, "Fuel Oil System Components Subject to Aging Management Review," is revised to include a new intended function for piping, "structural integrity". LRA Table 3.3.2-15 "Aging Management Review Results - Fuel Oil System," is revised to address aging management of the newly-identified (a)(2) piping.
For the MWT System, LRA Section 2.3.3.19, "Makeup Water Treatment System," is revised to add license renewal boundary drawinrg LR-MO12E to the list of license renewal boundary drawings that depict the evaluation boundaries of the MWT System.
The existing component types consist of "Bolting" and "Piping," which are addressed in LRA Table 3.3.2-19, "Aging Management Review Results - Makeup Water Treatment System," rows 1-4 and 8-10. The newly identified valve bodies are carbon steel (steel),
with a raw water internal environment. LRA Table 3.3.2-19 is revised to add the new material-environment combination for the component type "Valve Body" to the MWT System.
See Enclosure A to this letter for the revision to the DBNPS LRA.
See Enclosure B to this letter for the revision to the LRA Boundary Drawings.
Question RAI 2.1-7 10 CFR 54.4(a)(2) states: (a) Plant systems, structures and components within the scope of this part are (2) All nonsafety-related systems, structures and components whose failure could prevent satisfactory accomplishment of any of the [safety-related] functions identified in (a)(11)(i), (ii), or (iii) of this section.
During the scoping and screening methodology audit, performed on-site January 24-28, 2011, the staff reviewed the LRA, the 10 CFR 54.4(a)(2) implementing documents and license renewal drawings, and also performed plant walkdowns. During a plant walkdown, the staff observed the nonsafety-related condensate line located in the turbine building that exited through the deck to the space below that contained the auxiliary feedwater pumps. The applicant indicated that the condensate line nonsafety-related to safety-related interface was located at a point below the turbine building deck.
The staff requests that the applicant identify the specific location of the nonsafety to safetyrelated interface and all mitigative features installed to protect the integrity of the nonsafety to safety-related interface. The staff requests that the applicant provide the evaluation of all components and structures relied upon to protect the safety/nonsafety interface for inclusion within the scope of license renewal in accordance with 10 CFR 54.4(a)(2). During the review of this issue, consider extent of condition, and indicate if the review concludes that use of the
Attachment L-11-131 Page 29 of 31 scoping methodology precluded the identification of SSCs which should.
have included within the scope of license renewal in accordance with 10 CFR 54.4(a)(2). Describe any additional scoping evaluations performed to address the 10 CFR 54.4(a)(2) criteria. List any additional SSCs included within the scope as a result of your efforts, and list those structures and components for which aging management reviews were conducted or any additional information related to material and environment combinations. For each structure and component, describe the aging management programs, as applicable, to be credited for managing the identified aging effects.
RESPONSE RAI 2.1-7 The specific location of the nonsafety-related (NSR)-to-safety-related interface (i.e.,
Q boundary) for the auxiliary feedwater pump suction from the Condensate System is at a pipe anchor encased in grout located six inches below the Turbine Building floor surface in the safety-related Auxiliary Building ceiling. Mitigative features were recently installed to protect the integrity of the Q boundary. The mitigative features are a missile shield, pipe supports and a stainless steel pipe segment. Missile shields and pipe supports are within the scope of license renewal and evaluated as Structural Bulk Commodities in LRA Table 3.5.2-13, "Aging Management Review Results - Bulk Commodities," rows 85 and 93. The supported piping is within the scope of license renewal as part of the in-scope suction piping for the Auxiliary Feedwater (AFW)
Pumps. License renewal boundary drawing LR-MO06D (grid E-F/5-6) is revised to highlight the added piping. No additional systems, structures and components (SSCs) were added to scope as a result of the extent of condition review of this issue.
During preparation of this response, however, it was identified that a newly installed portion of the AFW suction line at this location is fabricated of stainless steel, which is a new material and environment combination for the AFW System piping. Therefore, stainless steel piping with an "Air-indoor uncontrolled" external environment and a "Treated water" internal environment are added as material and environment combinations. FENOC conducted an aging management review for the added stainless steel piping material and environment combinations.
As a result of the aging management review, two aging management programs are credited to manage the "Loss of Material" aging effect. The aging management programs credited for the stainless steel piping are the PWR Water Chemistry Program supplemented by the One-Time Inspection for the internal aging effect of "Loss of Material." LRA Table 3.4.2-1, "Aging Management Review Results - Auxiliary Feedwater System," is revised to include the new material-environment combination.
See Enclosure A to this letter for the revision to the DBNPS LRA.
See Enclosure B to this letter for the revision to the LRA Boundary Drawings.
Attachment L-11-131 Page 30 of 31 Question RAI 2.1-8 10 CFR 54.21, "Contents of application-L-technical information," states, in part:
(1) For those systems, structures, and components within the scope of this part, as delineated in 10 CFR 54.4, identify and list those structures and components subject to an aging management review. Structures and components subject to an aging management review shall encompass those structures and components:
(i)
That perform an intended function, as described in 10 CFR 54.4, without moving parts or without a change in configuration or properties.
(ii) That are not subject to replacement based on a qualified life or specified time period.
During the scoping and screening methodology audit, performed on-site January 24-28, 2011, the staff reviewed the LRA, selected aging management review documents and license renewal drawings, and also performed plant walkdowns. The staff determined through a review of the service water aging management review documentation that the service water pump bolts were excluded from the scope of license renewal based on periodic replacement.
However, the aging management review documentation indicated that a visual inspection was also used to determine whether bolt replacement would be required. The staff determined that the use of inspection activities to determine the need to replace a component did not meet the requirements of 10 CFR 54.21 (a)(1)(ii), replacement based on a qualified life or specified time period.
The staff requests that the applicant provide details of the analysis performed and any conclusions, related to the review of service water pump bolts, for inclusion within the scope of license renewal in accordance with 10 CFR 54.4(a)(2). The staff requests that the applicant perform a review of the issue, consider extent of condition, and indicate if the review concludes that use of the scoping methodology precluded the identification of SSCs which should have been included within the scope of license renewal in accordance with 10 CFR 54.4(a). Describe any additional scoping evaluations performed to address the 10 CFR 54.4(a) criteria. List any additional SSCs included within the scope as a result of your efforts, and list those structures and components for which aging management reviews were conducted or any additional information related to material and environment combinations. For each structure and component, describe the aging management programs, as applicable, to be credited for managing the identified aging effects.
Attachment L-1 1-131 Page 31 of 31 RESPONSE RAI 2.1-8 Analysis and conclusions related to inclusion of the service water pump bolts with the scope of license renewal:
LRA Section 2.3.3.26, page 2.3-129, provided the following:
"The bolting in the service water pumps and dilution pump (DB-P3-1 through 3 and DB-P180) is within the scope of license renewal. However, in the process of rebuilding the pumps, the bolting is inspected and repaired or~replaced as necessary. As such the pump bolting is evaluated as short-lived, subject to replacement based on a qualified life or specified time period, and is not subject to AMR."
The bolts associated with the service water pumps and dilution pump (DB-P3-1 through 3 and DB-P180) are replaced as necessary but not on a qualified life basis or a specified time period. Therefore, the subject bolts are within the scope of license renewal in accordance with 10 CFR 54.4(a) and are subject to aging management review (AMR) in accordance with 10 CFR 54.21(a) on the basis that they perform a license renewal intended function and are not replaced on a qualified life basis or a specified time period.
The aging management review (AMR) for the bolts associated with the service water pumps (DB-P3-1, 2, and 3) and dilution pump (DB-P1 80) has been revised and the steel bolting was evaluated for a raw water external environment since the pumps are submerged in water supplied by Lake Erie. The AMR results are provided in revised LRA Table 3.3.2-26.
Extent of condition:
An extent of condition was conducted relative to components within the scope of license renewal and determined as "not subject to an AMR" based upon replacement. AMR reports were reviewed to identify components that were "not subject to AMR" based upon replacement. There were no other components that were determined as "not subject to AMR" due to replacement, where the-replacement was based upon an inspection versus a specified time period.
In addition, the license renewal AMR project instruction provides that components subject to refurbishment or replacement solely on the basis of condition (e.g., the component is replaced only if significant degradation is observed during a periodic inspection), are still considered long-lived and require an AMR.
No additional scoping evaluations were required to address the 10 CFR 54.4(a) or 10 CFR 54.21(a) criteria. Also, no changes were required to the Davis-Besse license renewal scoping and screening methodology.
See Enclosure A to this letter for the revision to the DBNPS LRA.
Enclosure A Davis-Besse Nuclear Power Station (DBNPS), Unit No. 1 Letter L-11-131 Amendment No. 5 to the DBNPS License Renewal Application Page 1 of 41 License Renewal Application Sections Affected Table 2.3.2-2 Table 2.3.2-4 Table 2.3.3-7 Table 2.3.3-8 Section 2.3.3.11 Section 2.3.3.15 Table 2.3.3-15 Table 2.3.3-16 Section 2.3.3.17 Section 2.3.3.19 Section 2.3.3.22 Table 2.3.3-22 Table 2.3.3-23 Section 2.3.3.24.
Section 2.3.3.26 Table 2.3.3-27 Section 2.3.3.29 Table 2.3.4-4 Table A-1 Section 3.3.2.1.8 Table 3.2.2-2 Table 3.2.2-4 Table 3.3.1 Table 3.3.2-2 Table 3.3.2-7 Table 3.3.2-8 Table 3.3.2-15 Table 3.3.2-16 Table 3.3.2-18 Table 3.3.2-19 Table 3.3.2-21 Table 3.3.2-22 Table 3.3.2-23 Table 3.3.2-26 Table 3.3.2-27 Table 3.4.2-1 Table 3.4.2-4 Section B.2.9
Enclosure A L-11-131 Page 2 of 41 The Enclosure identifies the change to the License Renewal Application (LRA) by Affected LRA Section, LRA Page No., and Affected Paragraph and Sentence. The count for the affected paragraph, sentence, bullet, etc. starts at the beginning of the affected Section or at the top of the affected page, as appropriate. Below each section the reason for the change is identified, and the sentence affected is printed in italics with deleted text JiRed-ou and added text underlined.
Enclosure A L-11-131 Page 3 of 41 Affected LRA Section LRA Page No.
Page 2.3-29 Affected Paragraph and Sentence Table 2.3.2-2 New row New intended function added due to changes from the response to RAI 2.1-5.
LRA Table 2.3.2-2, "Containment Spray System Components Subject to Aging Management Review," is revised to read:
Component Type Intended Function Co___nent
________~,_
(as defined in Table 2.0-1)
Drain Pan Structural integrity Affected LRA Section LRA Page No.
Page 2.3-36 Affected Paragraph and Sentence Table 2.3.2-4 New row New intended function added due to changes from the response to RAI 2.1-5.
LRA Table 2.3.2-4, "Decay Heat Removal and Low Pressure Injection System Components Subject to Aging Management Review," is revised to read:
Intended Function Component Type (as defined in Table 2.0-1)
Drain Pan Structural integrity Affected LRA Section LRA Page No.
Page 2.3-70 Affected Paraqraph and Sentence Table 2.3.3-7 New row New intended function added due to changes from the response to RAI 2.1-5.
LRA Table 2.3.3-7, "Component Cooling Water System Components Subject to Aging Management Review," is revised to read:
Component Type
]Intended Function ComponentType_____
(as defined in Table 2.0-1)
Drain Pan Structural integrity
Enclosure A L-11-131 Page 4 of 41 Affected LRA Section LRA Page No.
Page 2.3-73 Affected Paragraph and Sentence Table 2.3.3-8 New row New row added due to changes from the response to RAI 2.1-2. LRA Table 2.3.3-8, "Containment Hydrogen Control System Components Subject to Aging Management Review," is revised to read:
Component Type 1Intended Function Component__Type_
(as defined in Table 2.0-1)
Pump Casing - Post accident gas sample pump 1 (DB-P218)
Structural integrity Affected LRA Section LRA Page No.
Page 2.3-79 Affected Paragraph and Sentence Section 2.3.3.11 New drawing number New drawing number added due to changes from the response to RAI 2.1-6.
LRA Section 2.3.3.11, "Demineralized Water Storage System," is revised to read:
License Renewal Drawinas The following license renewal drawings depict the evaluation boundaries for the system components within the scope of license renewal:
LR-MOO6E. LR-MO10C, LR-MO10D, LR-M020B, LR-M021, LR-M031A, LR-M035, LR-M036A, LR-M037C, LR-M037D, LR-M037E, LR-M039A, LR-M040A, LR-M045
Enclosure A L-11-131 Page 5 of 41 Affected LRA Section LRA Page No.
Affected Paragraph and Sentence Section 2.3.3.15 Page 2.3-97 4 th paragraph Revised text due to changes from the response to RAI 2.1-5 and plant walkdowns in response to RAI 2.1-6. LRA Section 2.3.3.15, "Fuel Oil System," is revised to read:
Reason for Scope Determination The Fuel Oil System does not perform any safety-related system intended functions that satisfy the scoping criteria of 10 CFR 54.4(a)(1).
The Fuel Oil System does not contain any NSR components that are identified in the CLB as having the potential to prevent the satisfactory accomplishment of a function identified in 10 CFR 54.4(a)(1). The Fue,,il SYtm does not cOntain NSR components that are attached or-located near-safety related SSs C, whe -~
failure cr-eateis a potential for spatial inter-action that could prevent the satisfactor-y acco.mplshment of a function identifi*ed*in 10
.FR 54.;(a)(1). Therefor9e, the Fuel Oil System does not satisfy the scoping criteria of 10 CFR 54. 4(a)(2). The Fuel Oil System does, however, contain NSR components that are attached to or located near safety-related SSCs, whose failure creates a potential for spatial interaction that could prevent the satisfactory accomplishment of a function identified in 10 CFR 54.4(a)(1). Therefore, the Fuel Oil System satisfies the scoping criteria of 10 CFR 54.4(a)(2) and performs the following system intended function:
Maintain structural integrity The Fuel Oil System is relied upon to demonstrate compliance with, and satisfies the 10 CFR 54.4(a)(3) scoping criteria for, the Fire Protection (10 CFR 50.48) regulated event.
Enclosure A L-11-131 Page 6 of 41 Affected LRA Section LRA Page No.
Page 2.3-98
'Affected Paraaraoh and Sentence Table 2.3.3-15 New intended functions New intended functions added due to changes from the response to RAI 2.1-5.
LRA Table 2.3.3-15, "Fuel Oil System Components Subject to Aging Management Review," is revised-to read:
Component Type
.Intended Function (as defined in Table 2.0-1)
Pressure boundary Bolting Structural integrity Pressure boundary Piping Structural integrity Pressure boundary Valve Body Structural integrity Affected LRA Section LRA Page No.
Page 2.3-101
-Affected Paragraph and Sentence Table 2.3.3-16 New rows New rows added due to changes from the response to RAI 2.1-2. LRA Table 2.3.3-16, "Gaseous Radwaste System Components Subject to Aging Management Review," is revised to read:
Component Type Intended Function ComponentType_....__(as defined in Table 2.0-1)
Moisture separator body Structural integrity Trap body Structural integrity
Enclosure A L-11-131 Page 7 of 41 Affected LRA Section LRA Page No.
Page 2.3-102 Affected Paraqraph and Sentence Section 2.3.3.17 New drawing number New drawing number added due to changes from the response to RAI 2.1-2.
LRA Section 2.3.3.17, "Instrument Air System," is revised to read:
License Renewal Drawinqs The following license renewal drawings depict the evaluation boundaries for the system components within the scope of license renewal:
LR-MO15A, LR-M029C, LR-M900A Affected LRA Section LRA Page No.
Page 2.3-108 Affected Paragraph and Sentence Section 2.3.3.19 New drawing number New drawing number added due to changes from the response to RAI 2.1-6.
LRA Section 2.3.3.19, "Makeup Water Treatment System," is revised to read:
License Renewal Drawinqs The following license renewal drawings depict the evaluation boundaries for the system components within the scope of license renewal:
LR-MO11, LR-MO12E
Enclosure A L-11-131 Page 8 of 41 Affected LRA Section LRA Page No.
Page 2.3-115 Affected Paragraph and Sentence Section 2.3.3.22
-New drawing number New drawing number added due to changes from the response to RAI 2.1-2.
LRA Section 2.3.3.22, "Nitrogen Gas System," is revised to read:
License Renewal Drawings The following license renewal drawings depict the evaluation boundaries for the system components within the scope of license renewal:
LR-M019, LR-M030A, LR-MOO7A Affected LRA Section LRA Page No.
Page 2.3-116 Affected Paragraph and Sentence Table 2.3.3-22 New intended function New intended function added due to changes from the response to RAI 2.1-2.
LRA Table 2.3.3-22, "Nitrogen Gas System Components Subject to Aging Management Review," is revised to read:
Component Type Intended Function (as defined in Table 2.0-1)
TPressure boundary Tubing
[Structural integrity
Enclosure A L-11-131 Page 9 of 41 Affected LRA Section LRA Page No.
Page 2.3-119 Affected Paraqraph and Sentence Table 2.3.3-23 New intended functions New intended functions added due to changes from the response to RAI 2.1-2.
LRA Table 2.3.3-23, "Process and Area Radiation Monitoring System Components Subject to Aging Management Review," is revised to read:
Component Type Intended Function (as defined in Table 2.0-1)
Pressure boundary Bolting Structural integrity Pressure boundary Piping Structural integrity Pressure boundary Tubing Structural integrity Affected LRA Section LRA Page No.
Page 2.3-121 Affected Paragraph and Sentence Section 2.3.3.24 New drawing numbers New drawing numbers added due to changes from the response to RAI 2.1-2.
LRA Section 2.3.3.24, "Reactor Coolant Vent and Drain System," is revised to read:
License Renewal Drawincs The following license renewal drawings depict the evaluation boundaries for the system components within the scope of license renewal:
LR-MO10C, LR-M030A, LR-M031C, LR-M033A, LR-M033B, LR-M033C, LR-M037D, LR-M040A, LR-M040D, LR-MOO7A, LR-MO31B
Enclosure A L-1 1-131 Page 10 of 41 Affected LRA Section LRA Page No.
Page 2.3-129 Affected Paragraph and Sentence Section 2.3.3.26 2 nd bullet Deleted text due to changes from the response to RAI 2.1-8. LRA Section 2.3.3.26, "Service Water System," is revised to read:
Components Subiect to AMR In addition to those components specifically excluded in 10 CFR 54.21(a)(1)(i),
such as instruments, the following components are within the scope of license renewal, but not subject to AMR:
The radiation element (DB-RE8432), as a radiation monitor, does not meet the requirements of 10 CFR 54.21 (a)(1 )(i).
=
1.,.i i;-.
k.-
!i, a
n
.f n
aun.e r
il
~n
,,n tD 0
U 1
411-5~E U~U 1"
(;,
Itt-
~'4 U
1 4~ 1411 1#;-
fl 0
So n
0 I-Ia.
/.L-..;.
i;-
i in the proc"SS Of rebuilding the PUmPS, the bolting i; ir-npeted a"r rired or replaced as necessary."
As such the pumtp boltg is evlated as shod4 lived-, subjfecttoreplacement based on a qualified life or specified tUMA Perod, Rnd isf not sbiect to AMR-.
Affected LRA Section LRA Page No.
Page 2.3-133 Affected Paragraph and Sentence Table 2.3.3-27 New row New intended function added due to changes from the response to RAI 2.1-5.
LRA Table 2.3.3-27, "Spent Fuel Pool Cooling and Cleanup System Components Subject to Aging Management Review," is revised to read:
o T
Intended Function Component Type I(as defined in Table 2.0-1)
Drain Pan j Structural inteqrity
Enclosure A L-11-131 Page 11 of 41 Affected LRA Section LRA Page No.
Page 2.3-136 Affected Paragraph and Sentence Section 2.3.3.29 New drawing number New drawing number added due to changes from the response to RAI 2.1-2.
LRA Section 2.3.3.29, "Station Air System," is revised to read:
License Renewal Drawings The following license renewal drawings depict the evaluation boundaries for the system components within the scope of license renewal:
LR-MO15D, LR-MO15F Affected LRA Section LRA Page No.
Page 2.3-162 Affected Paragraph and Sentence Table 2.3.4-4 New row New intended function added due to changes from the response to RAI 2.1-5.
LRA Table 2.3.4-4, "Main Steam System.Components Subject to Aging Management Review," is revised to read:
[Intended Function Component Type (as defined in Table 2.0-11 Drain Pan Structural integrity
Enclosure A L-11-131 Page 12 of 41 Affected LRA Section LRA Page No.
Page 3.3-12
-Affected Paragraph and Sentence Section 3.3.2.1.8 New material New material added due to changes from the response to RAI 2.1-2. LRA Section 3.3.2.1.8, "Containment Hydrogen Control System," is revised to read:
Materials The materials of construction for subject mechanical components of the Containment Hydrogen Control System are:
- Stainless steel 0 Steel
Enclosure A L-11-131 Page 13 of 41 Affected LRA Section LRA Page No.
Page 3.2-51 Affected Paragraph and Sentence Table 3.2.2-2 5 New Rows New rows added due to changes from the response to RAI 2.1-5. LRA Table 3.2.2-2, "Aging Management Review Results - Containment Spray System," is revised to read:
Table 3.2.2-2 Aging Management Review Results - Containment Spray System NUREG-,
Component*
Intended Aging Effect
- Aging NUREG-Cmponent Fntendd Material Environment Requiring Management
- 1801, Table I Notes Type Function(s)
Maaeet Porm Volume 2 Item Management Program Item Air with Structural borated water Loss of Boric Acid.
C Pintegrit leakage material Corrosion 0201
_ (Internal)
Structural Air-indoor Loss of External Drain Pan Strut Steel uncontrolled LossroflSurfaces V.E-7 3.2.1-31 integrity (Internal) material Monitoring 0201 Air with Drain Pan Structural Steel borated water Loss of Boric Acid V.A-4 3.2.1-45 A
integrit leakage material Corrosion (External)
Structural Air-indoor Loss of External Drain Pan integrit Steel uncontrolled material Surfaces V.A-1 3.2.1-31 A
External)
Monitoring Structural Air-indoor Loss of External n
Steel uncontrolled Surfaces V.E-7 3.4.1-28 -0 integrit(Internal) material
_Monitorin 0201
Enclosure A L-11-131 Page 14 of 41 Affected LRA Section LRA Page No.
Page 3.2-68 Affected ParagraDh and Sentence Table 3.2.2-4 7 New Rows New rows added due to changes from the response to RAI 2.1-5. LRA Table 3.2.2-4, "Aging Management Review Results - Decay Heat Removal and Low Pressure Injection System," is revised to read:
Table 3.2.2-4 Aging Management Review Results - Decay Heat Removal and Low Pressure Injection System NUREG-Maea EAging Effect Aging Component Intended Agn fet
- Aig1801, Table 1 Compoen Functionded Material Environment Requiring Management 10, Tbe1 Notes Type Function(s)
Management Program Volume 2 Item Item Structural Air-indoor Loss of External Drain Pan S
Steel uncontrolled materialSurfaces V.E-7 3.2.1-31 nrit (Internal) material Monitoring 0201 Air with Drain Pan Structural Steel borated water Loss of Boric Acid V.DI-1 3.2.1-45 C integrit leakage material Corrosion (Internal)
Air with Drain Pan Structural Steel borated water Loss of Boric Acid V.DI-1 3.2.1-45 A
integrity leakage material Corrosion (External)
Structural Air-indoor Loss of External Drain Pan integrit Steel uncontrolled material Surfaces V.E-7 3.2.1-31 A (External)
Monitori Mongtoring Structural Air-indoor Loss of External C
Pipig Steel uncontrolled Surfaces V.E-7 3.2.1-31 0-201 (Internal) material Monitoring Air with Pipin Structural Steel borated water Loss of Boric Acid V.01-I 3.2.1-45 A i
Se leakage material Corrosion V
(External)
Enclosure A L-11-131 Page 15 of 41 Table 3.2.2-4 Aging Management Review Results - Decay Heat Removal and Low Pressure Injection System Component Intended Aging Effect Aging NUREG-Type Intended Material Environment Requiring Management
- 1801, Table I Notes Management Program Volume 2 Item Item tructural Air-indoor Loss of External Pipin integrity Steel uncontrolled Material Surfaces V.E-7 3.2.1-31 A
S _(External)
____lMonitoring I
I
Enclosure A L-11-131 Page 16 of 41 Affected LRA Section LRA Page No.
Page 3.3-99 Affected Paragraph and Sentence Table 3.3.1 Row 3.3.1-76 Text in Discussion column revised based on the response to RAI 2.1-8. LRA Table 3.3.1, "Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of NUREG-1 801," is revised to read:
Table 3.3.1 Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of NUREG-1801 I
Further Item Co tiCo dit Aging Aging Management Evaluation Discussion Number omponenommoiy Effect/Mechanism Programs Recommended 3.3.1-76 Steel piping, piping Loss of material Open-Cycle Cooling No Consistent with NUREG-1 801, components, and piping due to general, Water System with exceptions.
elements (without lining/coating pitting, crevice, and Except as noted below, loss of or with degraded lining/coating) microbiologically material in steel (including gray exposed to raw water influenced cast iron) piping, piping corrosion, fouling, components, and piping and lining/coating elements, and bolting that are degradation exposed to raw water is managed by the Open-Cycle Cooling Water Program.
For steel (including gray cast iron) piping, piping components, piping elements, and bolting that are exposed to raw water that is not from an open-cycle cooling water system, loss of material will be detected and characterized by the Collection, Drainage, and Treatment Components Inspection Program.
Enclosure A L-11-131 Page 17 of 41 Affected LRA Section LRA Page No.
Page 3.3-145 Affected Paragraph and Sentence Table 3.3.2-2 2 New Rows New rows added due to changes from the response to RAI 2.1-4. LRA Table 3.3.2-2, "Aging Aging Management Review Results - Auxiliary Building Chilled Water System," is revised to read:
Table 3.3.2-2 Aging Management Review Results - Auxiliary Building Chilled Water System NUREG-Component Int ended M
Aging Effect Aging:-
- 1801, Table 1 Type Function(s)
Material Environment Requiring Management Volume 2 Item Notes Management Program Item Structural Copper Alloy Air-indoor None None V.F-3 3.2.1-53 A'-
integrit uncontrolled 0307 (Internal)
Structural Copoer Alloy Air-indoor None None V.F-3 3.2.1-53: A integrit uncontrolled (External)
Enclosure A L-11-131 Page 18 of 41 Affected LRA Section LRA Pane No.
Page 3.3-233 Affected Paragraph and Sentence Table 3.3.2-7 2 New Rows New rows added due to changes from the response to RAI 2.1-2. LRA Table 3.3.2-7, "Aging Management Review Results - Component Cooling Water System," is revised to read:
Table 3.3.2-7 Aging Management Review Results - Component Cooling Water System NUREG-Component Intended MtraAging Effect Aging
- 1801, Table I N
Type Function(s)
Material Environment Requiring Management Vlm2 Itm Notes Management Program Item Structural Air-indoor Loss of Bolting Souin integritel uncontrolled material Integrity VII.1-4 3.3.1-43 B
_(External) material Pipin Structural Steel Gas (Internal) None None VII.J-23 3.3.1-97 A
Enclosure A L-11-131 Page 19 of 41 Affected LRA Section LRA Page No.
Page 3.3-233 Affected Paragraph and Sentence Table 3.3.2-7 5 New Rows New rows added due to changes from the response to RAI 2.1-5. LRA Table 3.3.2-7, "Aging Management Review Results - Component Cooling Water System," is revised to read:
Table 3.3.2-7 Aging Management Review Results - Component Cooling Water System Intended Aging Effect
- Aging NUREG-Component Intend Material Environment Requiring Management
- 1801, Table 1 Notes Management Program Item Air with Drain Pan Structural Steel borated water Loss of Boric Acid Vill-O 3.3.1-89 C
inte__ri_
leakage material Corrosion 0307 (Internal)
Collection, Structural Raw water Loss of Drainage, and E
Drain Pan Strut Steel Rwnter materialTreatment VII.C1-19 3.3.1-76 E (Internal) material
...Components 0328 Inspection Air with Drain Pan Structural Steel borated water Loss of Boric Acid VI0II0 3.3.1-89 A
integrit leakage material Corrosion (External)
Structural Air-indoor Loss of External Drain Pan integrit Steel uncontrolled Material Surfaces VII.I-8 3.3.1-58 A
_________(External)
Monitoring Collection, Structural Raw water Loss of Drainage, and E
Sptr ctu Steel (internal) material Treatment VII.C1-19 3.3.1-76 Components 0328 Inspection
Enclosure A L-11-131 Page 20 of 41 Affected LRA Section LRA Page No.
Page 3.3-251 Affected Paragraph and Sentence Table 3.3.2-8 6 New Rows New rows added due to changes from the response to RAI 2.1-2. LRA Table 3.3.2-8, "Aging Management Review Results - Containment Hydrogen Control System," is revised to read:
Table 3.3.2-8 Aging Management Review Results - Containment Hydrogen Control System Component Intended M
Aging Effect Aging NUREG-mponent Fnctiond Material Environment Requiring Management
- 1801, Table I Notes Management Program Volume 2 Item Item Pump Casing -
Post accident Structural Air-indoor Aluminum uncontrolled None None V.F-2 3.2.1-50 A gas sample inert (Internal)_
pump (DB-P218)
(Ineral Pump Casing-Air-indoor Post accident Structural Arido Aluminum uncontrolled None None V.F-2 3.2.1-50 A
-gas sample inte-grit (External) pump (DB-P218)
Pump Casing -
Air with Post accident Structural Aluminum borated water Loss of Boric Acid VII.A3-4 3.3.1-88 A
gas sample integrity leakage material Corrosion pump (DB-P218)
(External)
Pump Casing -
Air-indoor Post accident Structural Stainless uncontrolled None None VII.J-15 3.3.1-94 A gas sample integrity Steel (Internal) 0307 pump (DB-P218)
Pump Casing -
Air with Post accident Structural Stainless borated water None None VIIJ-16 3.3.1-99 A
gas sample inte-grit Steel leakage pump (DB-P218)
(External)
Enclosure A L-11-131 Page 21 of 41 Table 3.3.2-8 Aging Management Review Results - Containment Hydrogen Control System Component Intended Aging Effect Aging NUREG-Type Intended Material Environment Requiring Management
- 1801, Table I Notes Management Program Volume 2 Item Item Pump Casing-Air-indoor Post accident Structural Stainless Arido uncontrolled None None VII.J-15 3.3.1-94 A gas sample integrity Steel (Exteral) pump (DB-P218)
(ExternaI_
Enclosure A L-11-131 Page 22 of 41 Affected LRA Section LRA Page No.
Page 3.3-343 Affected Paragraph and Sentence Table 3.3.2-15 6 New Rows New rows added due to changes from the response to RAI 2.1-5. LRA Table 3.3.2-15, "Aging Review Results - Fuel Oil System," is revised to read:
Management Table 3.3.2-15 Aging Management Review Results - Fuel Oil System
-Aging NUREG-Component Intended Aging Effect Aging
- 1801, Table 1 Type Function(s)
Material Environment Requiring Management Volume 2 Item Notes Management Program Item Structural Air-indoor Loss of Boltin Boltin integrit Steel uncontrolled material Integrit VII.1-4 3.3.1-43 B (External)
Structural Air-indoor BlnV,5 315 Stutua Steel uncontrolled Loss of preload IVn.i-5 3.3.1-45 tB Bintegrity (External)
Structural Air-indoor Loss of External PiLn integrity Steel uncontrolled material Surfaces VII.l-8 3.3.1-58 0301 Internal)
Monitoring Structural Air-indoor Loss of External Pinin integrity Steel uncontrolled material Surfaces VII.1-8 3.3.1-58 A (External)
Monitoring Structural Air-indoor Loss of External Valve Bod integrit Steel uncontrolled material Surfaces VII.1-8 3.3.1-58 0_
ValveBody__
(Internal)
Monitoring 0301 Structural Air-indoor Loss of External Valve Body integrity Steel uncontrolled material Surfaces VI.L1-8 3.3.1-58 A S(External)
MIon Monitoring
Enclosure A L-11-131 Page 23 of 41 Affected LRA Section LRA Page No.
Page 3.3-343 Affected Paraqraph and Sentence Table 3.3.2-15 4 New Rows New rows added due to changes from the response to RAI 2.1-6. LRA Table 3.3.2-15, "Aging Review Results - Fuel Oil System," is revised to read:
Management Table 3.3.2-15 Aging Management Review Results - Fuel Oil System NUREG-Component Intended Aging Effect Aging
- 1801, Table 1 Type Function(s)
Material Environment Requiring Management Volume 2 Item Notes Management Program Item Src l Air-indoor External Structural Loss of C
Steel uncontrolled Surfaces VII.1-8 3.3.1-58 1
Internal material Monitoring 1701 Structural Fuel oil Loss of Fuel Oil inin inte-grity Steel (Internal) material Chemistry VII.HI-IO 3.3.1-20 B Structural Fuel oil Loss of One-Time Pinin integrity Steel (Internal) material Inspection VII.HI-IO 3.3.1-20 A Structural Air-indoor Loss of External Pintegrity Steel uncontrolled material Surfaces VII.1-8 3.3.1-58 A I
I (External) materia Monitoring I
Enclosure A L-11-131 Page 24 of 41 Affected LRA Section LRA Page No.
Page 3.3-350 Affected Paragraph and Sentence Table 3.3.2-16 7 New Rows New rows added due to changes from the response to RAI 2.1-2. LRA Table 3.3.2-16, "Aging Management Review Results - Gaseous Radwaste System," is revised to read:
Table 3.3.2-16 Aging Management Review Results - Gaseous Radwaste System NUREG-Component Intended Aging Effect Aging
- 1801, Table I Type Function(s)
Material Environment Requiring Management Volume 2 Item Notes Management Program Item Moisture Separator Body Structural Stainless Air-indoor
- Waste Gas uncontrolled None None VII.J-15 3.3.1-94 C
Compressor (External)
(DB-CIO-1 & 2)
Moisture Air with Separator Body Structural Stainless borated water
-Waste Gas None None VII.J-16 3.3.1-99 C
Comnpressor n
Steel leakage (DB-CIO-1 & 2)
(External)
Moisture Collection, Separator Body Structural Stainless Condensation Loss of Drainage, and
- Waste Gas i
Treatment VII.D-4 3.3.1-54 E Compressor integrity Steel (Internal) material Components (DB-CIO-1 & 2)
Inspection Collection, Structural Stainless Condensation Loss of Drainage, and Orifice Treatment VII.D-4 3.3.1-54 E
integrity Steel (Internal) material Comnonen I_
Inspection
Enclosure A L-11-131 Page 25 of 41 Table 3.3.2-16 Aging Management Review Results - Gaseous Radwaste System Component Intended IAging Effect Aging NUREG-T Copnet Itedd Material Environment Reurn Mage nt
- 1801, iTable I Notes Type Function(s) i equiring anagement Volume 2 Item Management Program Item Collection, Structural Stainless Condensation Loss of Drainage, and Trap Body i
Steel (Internal) material Treatment VII.D-4 3.3.1-54 E Components Inspection Air with Trap Body Structural Stainless borated water None None VII.J-16 3.3.1-99 A inte~grity Steel leakage (External)
Structural Stainless Air-indoor Trap Body Strutu Steel uncontrolled None None VII.J-15 3.3.1-94 A i
tSteel (External)
Enclosure A L-11-131 Page 26 of 41 Affected LRA Section LRA Page No.
Page 3.3-365 Affected Paragraph and Sentence Table 3.3.2-18 2 New Rows New rows added due to changes from the response to RAI 2.1-2. LRA Table 3.3.2-18, "Aging Management Review Results - Makeup and Purification System," is revised to read:
Table 3.3.2-18 Aging Management Review Results - Makeup and Purification System NUREG-Component Intended Material Aging Effect Aging
- 1801, Table 1 Note Type Function(s)
Environment Requiring Management Volume 2 Item Management Program Item Structural Stainless Dried air None None V.-18 3.3.1-98 A
Tubin interit Steel (Internal)
Structural Stainless Dried air Valve Body
- integrit Steel (Internal)
None None VII.J-18 3.3.1-98 A
Enclosure A L-11-131 Page 27 of 41 Affected LRA Section LRA Page No.
Page 3.3-398 Affected Paragraph and Sentence Table 3.3.2-19 2 New Rows New rows added due to changes from the response to RAI 2.1-6. LRA Table 3.3.2-19, "Aging Management Review Results - Makeup Water Treatment System," is revised to read:
Table 3.3.2-19 Aging Management Review Results - Makeup Water Treatment System NUREG-Component..
Intended Aging Effect-Aging
- 1801, Table 1 Cmpnen Fnctiondd Material Environment Requiring Management 1801m 2 I
Notes Type Function(s)
Maaeet Porm Volume 2 Item Management Program Item Collection, Structural Raw water Loss of Drainage, and Valve Body Steel Treatment VII.CI-19 3.3.1-76 E integrit (Internal).
material Components Inspection Structural Air-indoor Loss of External Valve Body Steel uncontrolled material Surfaces VII.1-8 3.3.1-58 A
_(External) material
_Monitoring
Enclosure A L-11-131 Page 28 of 41 Affected LRA Section LRA Page No.
Page 3.3-403 Affected Paragraph and Sentence Table 3.3.2-21 1 New Row New row added due to changes from the response to RAI 2.1-4. LRA Table 3.3.2-21, "Aging Management Review Results - Miscellaneous Liquid Radwaste System," is revised to read:
Table 3.3.2-21 Aging Management Review Results - Miscellaneous Liquid Radwaste System Component Intended Aging Effect
-Aging NUREG-fT/
Type Function(s)
Material Environment Requiring Management volume 2 Item Notes Management Program Item S
Air-indoor A
Structural i Stainless uncontrolled None None VIIJ-15 3.3.1-94 A inte*riV Steel (Internal) 0307
Enclosure A L-11-131 Page 29 of 41 Affected LRA Section LRA Page No.
Page 3.3-418 Affected Paragraph and Sentence Table 3.3.2-22 6 New Rows New rows added due to changes from the response to RAI 2.1-2. LRA Table 3.3.2-22, "Aging Management Review Results - Nitrogen Gas System," is revised to read:
Table 3.3.2-22 Aging Management Review Results - Nitrogen Gas System NUREG-Component Intended I
Aging Effect Aging 1801; I
Mateial Envronmnt M
t
- 1801, Table1I Nt Type Function(s)
Material Environment Requiring Management Volume 2 Item Notes Management Program Item Tubin Structural Stainless Gas (Internal) None None VII.J-:19 3.3.1-97 A int gi Steel Air with Tubing Structural Stainless borated water None None VIIJ-16 3.3.1-99 A
integrit Steel leakaege (External)
SStructural Stainless Air-indoor Tubtirnt Stele uncontrolled None None VII.J-15 3.3.1-94 A integrity Steel (External)
Valve Body Structural Steel Gas (Internal) None None VII.J-23 3.3.1-97 A Inte~grity Air with Valve Bod Structural Steel borated water Loss of Boric Acid VI0-10 3.3.1-89 A
Inteority leakage material Corrosion (External)
Structural Air-indoor Loss of External Valve Body Steel uncontrolled Surfaces VII.D-3 3.3.1-57 A Interity(External) material Monitoring
Enclosure A L-11-131 Page 30 of 41 Affected LRA Section LRA Page No.
Page 3.3-423 Affected Paragraph and Sentence Table 3.3.2-23 8 New Rows New rows added due to changes from the response to RAI 2.1-2. LRA Table 3.3.2-23, "Aging Management Review Results - Process and Area Radiation Monitoring System," is revised to read:
Table 3.3.2-23 Aging Management Review Results -. Process and Area Radiation Monitoring System NUREG-Aging Effect Aging Component Intended Aging Effect
- 1801, Table I Notes Type Function(s)
Material Environment Requiring Management Volume 2 Item hManagement Program Item Air with Bolting Structural Stainless borated water None None VIIJ-16 3.3.1-99 C
integrit Steel leakage (External)
Structural Stainless Air-indoor Boltin Boltin integrit Steel uncontrolled Loss of preload Integrit N/A N/A F
____Steel (External)
Structural Stainless Air-indoor Pipingtrut Steel uncontrolled None None VII.J-15 3.3.1-94 A integry Steel (Internal) 0307 Air with Piping Structural Stainless borated water None None VIIJ-16 3.3.1-99 A
integrity Steel leakage (External)
Structural Stainless Air-indoor PSingtrutu Steel uncontrolled None None VII.J-15 3.3.1-94 A in y
Steel (External)
Air-indoor TubinStructural Stainless uncontrolled None None VII.J-15 3.3.1-94 A
_q tegrit Steel (Introlle 0307 (nternalI
Enclosure A L-11-131 Page 31 of 41 Table 3.3.2-23 Aging Management Review Results - Process and Area Radiation Monitoring System Component Intended Aging Effect Aging NUREG-Type Intended Material Environment Requiring Management
- 1801, Table 1 Notes Management Program Volume 2 Item Item Air with Tubing Structural Stainless borated water None None VIIJ-16 3.3.1-99 A
inteTirit Steel leakage (External)
Structural Stainless Air-indoor TubinS uncontrolled None None VII.J-15 3.3.1-94 A inteTgrit Steel (External)
Enclosure A L-11-131 Page 32 of 41 Affected LRA Section LRA Page No.
Page 3.3-465 Affected Paragraph and Sentence Table 3.3.2-26 9 New Rows New rows added due to changes from the response to RAI 2.1-2. LRA Table 3.3.2-26, "Aging Management Review Results - Service Water System," is revised to read:
Table 3.3.2-26 Aging Management Review Results - Service Water System NUREG-
- Component Intended Aging Effect Aging
- 1801, Table i Type Intended Material Environment Requiring Management Volum 2 I
Notes Management Program Volume 2 Item Item Tubin Structural Copper Alloy Dried air None None VIIJ-3 3.3.1-98 A
integrit (Internal)
Air with Tubing Structural C
Alloy borated water None None VII.J-5 3.3.1-99 A
integrit C
leakaege (External)
Structural Air-indoor Tubing interit Copper Alloy uncontrolled None None VIII.1-2 3.4.1-41 A (External)
Structural Copper Alloy Dried air Tubing
- integrit
> 15% Zn (Internal)
None None VII.J-3 3.3.1-98 A Air with Tubing Structural Copper Alloy borated water Loss of Boric Acid V11.1-12 3.3.1-88 A
inteTgrit
> 15% Zn leakage material Corrosion (External)
Structural Copper Alloy Air-indoor Tubing trut
> 15%
uncontrolled None None VIII.1-2 3.4.1-41 A (External)
Enclosure A L-11-131 Page 33 of 41 Table 3.3.2-26 Aging Management Review Results - Service Water System Aging Effect 1 Aging NUREG-Component Intended Material Environment Requiring Management
- 1801, Table I Notes Type Function(s)
Malagene in Manam Volume 2 Item Management Program Item Structural Copper Alloy Dried air Valve Body
- integrit
> 15% Zn (Internal)
None None VII.J-3 3.3.1-98 A Air with Valve Bod Structural Copper Alloy borated water Loss of Boric Acid VIl.I-12 3.3.1-88 A integrita
> 15% Zn leakage:
material Corrosion (External)
Structural Coiner Alloy Air-indoor Valve BodS inteuritu
> 15%Zn uncontrolled None None VIII.1-2
-3.4.1-41 A (External)
Enclosure A L-11-131 Page 34 of 41 Affected LRA Section LRA Page No.
Page 3.3-465 Affected Paragraph and Sentence Table 3.3.2-26 1 New Row New row added based on the response to RAI 2.1-8. LRA Table 3.3.2-26, "Aging Management Review Results -
Service Water System," is revised to read:
Table 3.3.2-26 Aging Management Review Results - Service Water System NUREG-Component
- Intended
- Aging Effect Aging NUREN-Componen Fntendd Material Environment Requiring Management
- 1801, Table I Notes Type Function(s)
Maaeet Porm Volume 2 Item Management Program Item B6ltinQ Pressure Steel Raw Water Loss of Open-Cycle VII.C1-19 3.3.1-7 boundary (External) material Cooling Water 0334 Also, a new plant-specific note is added to the Plant-Specific Notes Table on LRA page 3.3-547. LRA Section 3.3, "Plant-Specific Notes" Table is revised to read:
Plant-Specific Notes:
0334 The subject bolting is associated with the service water pumps (DB-P3-1, 2, and 3) and dilution pump (DB-P180) that are submerged in water supplied by Lake Erie.
Enclosure A L-11-131 Page 35 of 41 Affected LRA Section LRA Page No.
Page 3.3-483 Affected Paragraph and Sentence Table 3.3.2-27 7 New Rows New rows added due to changes from the response to RAI 2.1-5. LRA Table 3.3.2-27, "Aging Management Review Results - Spent Fuel Pool Cooling and Cleanup System," is revised to read:
Table 3.3.2-27 Aging Management Review Results - Spent Fuel Pool Cooling and Cleanup System Aging Effect Aging r NUREG-ComponentMaterial Environment Ring Management
- 1801, Table I Not' Type Function(s)
Maequiring Program Volume 2 Item AirnwitheManagement Item Air with Drain Pan Structural Steel borated water Loss of Boric Acid VIIEI-1 3.31-89C integrit leakage material Corrosion 0307 (Internal) c Collection, Structural Raw water Loss of Drainage, and E
Drain Pan Steel Treatment VII.C3-10 3.3.1-76 (Internal) material Components 0328
_Inspection Air with Drain Pan Structural Steel borated water Loss of Boric Acid V/I.E-1 3.3.1-89 A
intelgrit leakaqe material Corrosion (External)
Structural Air-indoor Loss of External Drain Pan integrity Steel uncontrolled material Surfaces VIIU-8 3.3.1-58 A
External)
Monitoin Structural Air-indoor Loss of External PiDin gan Steel uncontrolled Surfaces VII.I-8 3.3.1-58 A (Internal) material Monitoring
Enclosure A L-11-131 Page 36 of 41 Table 3.3.2-27 Aging Management Review Results - Spent Fuel Pool Cooling and Cleanup System Component Intended Aging Effect Aging NUREG-Cmpnen Fnctiondd Material Environment Requiring Management
- 1801, Table 1 Notes Type Function(s)
Maaeet Porm Volume 2 Item Management Program Item Air with Pinin Structural Steel borated water Loss of Boric Acid VII.E1-1 3.3.1-89 A
integrit leakage material Corrosion V
(External)
Structural Air-indoor Loss of External PStegritu
-Steel uncontrolled Surfaces VII.I-8 3.3.1-58 A integrity (External) material Monitoring
Enclosure A L-11-131 Page 37 of 41 Affected LRA Section LRA Page No.
Page 3.4-41 Affected Paragraph and Sentence Table 3,4.2-1 3 New Rows New rows added due to changes from the response to RAI 2.1-7. LRA Table 3.4.2-1, "Aging Management Review Results - Auxiliary Feedwater System," is revised to read:
Table 3.4.2-1 Aging Management Review Results - Auxiliary Feedwater System NUREG-C e nAging Effect Aging Component Intended Requiring Management
- 1801, Table I Notes Type Function(s)
Malagenent Manam Volume 2 Item Management Program Item Air-indoor Pressure Stainless uncontrolled None None VlII.I-10 3.3.1-41 A boundary Steel (External Treatednl Pressure Stainless Treated Loss of One-Time boundary Steel wnternal material lnspection Pressure Stainless Treated Loss of PWR Water water matea.lG-32
.3.1-16 Piin boundary Steel (Internal) material Chemistry
Enclosure A L-11-131 Page 38 of 41 Affected LRA Section LRA Page No.
Page 3.4-81 Affected Paraqraph and Sentence Table 3.4.2-4 6 New Rows New rows added due to changes from the response to RAI 2.1-2. LRA Table 3.4.2-4, "Aging Management Review Results - Main Steam System," is revised to read:
Table 3.4.2-4 Aging Management Review Results - Main Steam System NUREG-
- Component Intended IAging Effect Aging
- 1801, Table Type Function(s)
Material Environment Requiring Management Volume 2 Item 1 Notes Management Program Item Structural Dried air TubinQ Coper Alloy None None VII.J-3 3.3.1-98 0 Air with Tubin Structural Copper Alloy borated water None None VII.J-5 3.3.1-99 A integrity leakage (External)
Structural Air-indoor Tubing i
Copper Alloy uncontrolled None None VIII.1-2 3.4.1-41 A (External)
Structural Copper Alloy Dried air A
Tubing integrit
> 15% Zn (Internal)
None None V03J-3 3.3.1-98 18 Air with Tubin Structural Copper Alloy borated water Loss of Boric Acid V11.1-12 3.3.1-88 A inteirity
> 15% Zn leakaqge material Corrosion (External)
Structural Conner Alloy Air-indoor Tubing trut
> 15%
uncontrolled None None VIII.I-2 3.4.1-41 A (External)
Enclosure A L-11-131 Page 39 of 41 Affected LRA Section LRA Page No.
Page 3.4-81 Affected Paragraph and Sentence Table 3.4.2-4 2 New Rows New rows added due to changes from the response to RAI 2.1-5. LRA Table 3.4.2-4, "Aging Management Review Results - Main Steam System," is revised to read:
Table 3.4.2-4 Aging Management Review Results - Main Steam System Component Intended Aging Effect Aging aNURNEG-Cmponet Fnctiond Material Environment Requiring Management
- 1801, Table I Notes Type Function(s)
Maaeet Porm Volume 2 Item Management Program Item External Structural Air-indoor Loss of External C
Drain Pan intercrit Steel uncontrolled material Surfaces VIII.H-7 3.4.1-28 0405 (Internal) material
_Monitoring 0409 Air-indoor External Structural Steel uncontrolled materialSurfaces VIII.H-7 3.4.1-28 A SIt ruc u Eraxternall material o
Monitoring 0409
Enclosure A L-11-131 Page 40 of 41 Affected LRA Section LRA Page No.
Affected ParagraDh and Sentence Table A-1 Page A-55 New Row A new license renewal future commitment is added to the table based on the response to RAI 2.1-3.
LRA Table A-1, "Davis-Besse License Renewal Commitments," is revised to read:
Table A-1 Davis-Besse License Renewal Commitments 1
- Related LRA Item ImplementationRead A
Number Commitment Schedule Source Section No./
Comments 26 FENOC will review all License Renewal scoping drawings and Prior to FENOC Response to Aging Management Review reports to ensure identification of April 22, 2017 Letter NRC RAI 2.1-3 components that would have been in scope under L-11-131 in NRC Letter 10 CFR 54.4(a)(2), but were excluded from aging management dated because they are abandoned. For each such component or set March 30, of components, FENOC will ensure administrative controls are in 2011 place to maintain the components isolated from fluid sources and drained.
Enclosure A L-11-131 Page 41 of 41 Affected LRA Section LRA Page No.
Affected Paragraph and Sentence Appendix B, Page B-48 New "Aging Management Program Section B.2.9 Elements - Scope" Sub-bullet The Component Cooling Water System now includes the Collection, Drainage, and Treatment Components Inspection Program to manage aging effects due to changes from the response to RAI 2.1-5 The Component Cooling Water System, however, is not addressed in LRA Appendix B, Section B.2.9, "Collection, Drainage, and Treatment Components Inspection Program," and is added to the subheading "Aging Management Program Elements," under the subheading "Scope." LRA Section B.2.9 is revised to read:
The piping and components (filter bodies, flexible connections, heat exchanger shell and tubes, humidifier tubing, orifices, pump casings (including bolting),
rupture discs, strainer bodies, tanks, tubing, and valve bodies) in the scope of this program are in the following systems:
Auxiliary Building HVAC - Control Room Normal Ventilation System Component Coolinq Water System Fire Protection System (including Diesel Fire Pump)
- Gaseous Radwaste System
" Makeup and Purification System
" Makeup Water Treatment System Miscellaneous Liquid Radwaste System
- Reactor Coolant Vent and Drain System Sampling System
" Spent Fuel Cooling and Cleanup System Station Plumbing, Drains, and Sumps System
Enclosure B Davis-Besse Nuclear Power Station (DBNPS), Unit No. I Letter L-11-131 Revised License Renewal Application Boundary Drawinqs Page 1 of 3 The following License Renewal Application Boundary Drawings are revised and are enclosed (69 drawings):
LR-MO03A LR-MO03B LR-MO03C.
LR-MO06D LR-MO06E LR-MO07A LR-MO07B LR-MO09B LR-MO10AI LR-MOIOC LR-MO10D LR-MO12E LR-MO15A LR-MO15D LR-MO15F LR-MO16A LR-MO16B LR-MO17B LR-MO17C Revision 1 Revision 1 Revision 2 Revision 2 Revision 1 Revision I Revision 2 Revision 1 Revision 1 Revision 1 Revision 2 Revision I Revision 1 Revision 1 Revision 0 Revision 1 Revision I Revision 1 Revision 2
Enclosure B L-11-131 Page 2 of 3 LR-MO17D LR-M019 LR-M020A LR-M020B LR-M020D LR-M021 LR-M022A LR-M024G LR-M024H LR-M027A LR-M027B LR-M029B LR-M029C LR-M029D LR-M029E LR-M030A LR-M030B LR-M031A LR-M031B LR-M031C LR-M033A LR-M033B LR-M033C LR-M034 LR-M035 LR-M036A LR-M036B LR-M036C LR-M037D LR-M037E LR-M037F Revision 1 Revision 1 Revision I Revision 2 Revision 1 Revision 2 Revision 1 Revision 1 Revision 1 Revision 1 Revision 1 Revision 1 Revision 2 Revision 1 Revision 1 Revision I Revision 1 Revision 2 Revision 1 Revision 1 Revision 1 Revision I Revision 1 Revision 1 Revision 1 Revision 2 Revision 1 Revision 2 Revision 3 Revision 2 Revision 1
Enclosure B L-11-131 Page 3 of 3 LR-M037G LR-M037H LR-M038B LR-M038C LR-M039A LR-M040A LR-M040D LR-M041A LR-M041 B LR-M041 C LR-M043 LR-M046 LR-M047 LR-M090 LR-M281N13 LR-M900A LR-OS002 LR-OS041A1 LR-OS041A2 Revision 2 Revision 1 Revision 1 Revision 2 Revision 3 Revision 3 Revision 2 Revision 1 Revision 1 Revision 1 Revision 1 Revision 1 Revision I Revision 2 Revision 2 Revision 0 Revision 1 Revision I Revision 1
The 69 Drawings specifically referenced in Enclosure B have been processed into ADAMS.
These drawings can be accessed within the ADAMS package or by performing a search on the Document/Report Number.