SBK-L-11173, First Annual Update to License Renewal Application and Changes to LRA Appendix a

First Annual Update to License Renewal Application and Changes to LRA Appendix a

ML11241A142
Person / Time
Site:	Seabrook
Issue date:	08/25/2011
From:	Freeman P NextEra Energy Seabrook
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
SBK-L-11173
Download: ML11241A142 (34)

Text

NEXTera ENERGY7M&

August 25, 2011 SBK-L-1 1173 Docket No. 50-443 U.S. Nuclear Regulatory Commission Attention: Document Control Desk One White Flint North 11555 Rockville Pike Rockville, MD 20852 Seabrook Station First Annual Update to the Seabrook Station License Renewal Application

References:

1. NextEra Energy Seabrook, LLC letter SBK-L-10077, "Seabrook Station Application for Renewed Operating License," May 25, 2010. (Accession Number ML101590099)

2. NextEra Energy Seabrook, LLC letter SBK-L-11133, "Seabrook Station Response to Request for Additional Information NextEra Energy Seabrook License Renewal Application - Set 14 RAI B.1.4-1," June 24, 2011. (Accession Number MLI 1 178A236)

In Reference 1, NextEra Energy Seabrook, LLC (NextEra) submitted an application for a renewed facility operating license for Seabrook Station Unit 1 in accordance with the Code of Federal Regulations, Title 10, Parts 50, 51, and 54.

The License Renewal-Rule, 10 CFR 54.21(b) requires that each year following submittal of a license renewal application (LRA), and at least 3 months before scheduled completion of the NRC review, an Update to the renewal application must be submitted that identifies any change to the current licensing basis (CLB) of the facility that materially affects the content of the LRA including the FSAR supplement.

NextEra Energy Seabrook, LLC, P.O. Box 300, Lafayette Road, Seabrook, NH 03874

United States Nuclear Regulatory Commission SBK-L-11173 / Page 2 In accordance with this requirement, NextEra Energy Seabrook, LLC performed a review of CLB changes since the submittal of Reference 1, to determine whether any sections of the LRA were affected by these changes. The results of the review are reported in Enclosure 1. This update also includes a review of plant specific and industry operating experience for the same time period. Alkali Silica Reaction (ASR) has been identified as a new aging effect. This new aging effect is currently under review by NextEra Energy Seabrook. Enclosure 1 contains changes to the License Renewal Application as a result of the Annual Update review.

In Reference 2, NextEra Energy Seabrook provided changes to the LRA regarding its continual review of both plant-specific and industry operating experience. Based on discussion with the NRC Staff, section A.1.6 has been added to the Updated Final Safety Analysis Report Supplement to describe the Operating Experience program. Enclosure 2 contains changes made to LRA Appendix A.

There are no new or revised regulatory commitments contained in this letter.

If there are any questions or additional information is needed, please contact Mr. Richard R.

Cliche, License Renewal Project Manager, at (603) 773-7003.

If you have any questions regarding this correspondence, please contact Mr. Michael O'Keefe, Licensing Manger, at (603) 773-7745.

Sincerely, NextEra Energy Seabrook, LLC.

Paul 0. Freeman Site Vice President

Enclosures:

First Annual Update to the Seabrook Station License Renewal Application -

Changes to LRA Appendix A Associated with NRC Staff Discussion cc:

W.M. Dean, NRC Region I Administrator G. E. Miller, NRC Project Manager, Project Directorate 1-2 W. J. Raymond, NRC Resident Inspector R. A. Plasse Jr.,

NRC Project Manager, License Renewal M. Wentzel, NRC Project Manager, License Renewal

United States Nuclear Regulatory Commission SBK-L-11173 / Page 3 Mr. Christopher M. Pope Director Homeland Security and Emergency Management New Hampshire Department of Safety Division of Homeland Security and Emergency Management Bureau of Emergency Management 33 Hazen Drive Concord, NH 03305 John Giarrusso, Jr., Nuclear Preparedness Manager The Commonwealth of Massachusetts Emergency Management Agency 400 Worcester Road Framingham, MA 01702-5399

United States Nuclear Regulatory Commission SBK-L-11173 / Page 4 NEXTera ENERGý-y&'

I, Paul 0. Freeman, Site Vice President of NextEra Energy Seabrook, LLC hereby affirm that the information and statements contained within are based on facts and circumstances which are true and accurate to the best of my knowledge and belief.

Sworn and Subscribed Before me this,? 57 day of August, 2011 Paul 0. Freeman Site Vice President lotary Public to SBK-L-11173 First Annual Update to the Seabrook Station License Renewal Application

United States Nuclear Regulatory Commission Page 2 of 35 SBK-L-l 1173 / Enclosure 1

1. In Table 2.3.3-5, on page 2.3-86, the 3rd row is revised as follows:

Damper Housing F~e Pressure Boundary In Table 2.3.3-5, on page 2.3-86, the 8th row is revised as follows:

FilterHousing IPre.-re BIundmy Structural Integrity (Attached) 2.

3. In Section 2.3.3-40, on page 2.3-253, under System Description new paragraphs are added after the 3rd paragraph as follows:

For the original switchyard equipment, each circuit breaker and each bus section of the 345-k V switching station forms a separate gas-insulated system that is individually monitored as a 3-phase system. Each 3-phase circuit breaker is supplied with its own self-contained SF6 gas system. There is no interconnection between the circuit breaker SF6 gas systems and the switching station gas systems. The bus section gas systems include the 3-phase bus connections between two circuit breakers, extending to the point of connection to a transformer or to an overhead line.

For replacement switchyard equipment, each circuit breaker and each bus section are comprised of individual gas zones that are monitored separately for each phase of the 3-phase system. There exist some locations where original and replacement equipment interface. Bypass valves that connect adjacent gas zones are only used with the replacement equipment where it is necessary to interface with original equipment that is already connected with bypass valves. Similar to the original equipment, there is no interconnection between the circuit breaker SF6 gas systems and the switching station gas systems.

4. In Section 2.3.3.40, on page 2.3-253, the 1st paragraph of the In-Scope Boundary Description is revised as follows:

The first boundary begins at the three phase duct connections to the Generator Step-Up Transformer also shvwn as detail "L". The three duct boundaries continue (see detail "W and,,W), dividing and connecting to the three phases of breaker number 11 and to the three phases of breaker number 12shewn en detail,,

1,, -

eun ed a4 the Fee-ea1se, of breaker number 163 shown on detail "B 1". The boundary includes one voltage transformer connection per phase as depi.ted in detail "B 1" and "K".

5. In Section 2.3.3.40, on page 2.3-253, the 2 nd paragraph of the In-Scope Boundary Description is revised as follows:

The second boundary begins at the three duct connections on each of the reserve auxiliary transformers shovrn in detail "I". The individual phases jin to f..m. three phase-ducts boundary combine then that-continue and branch-to the three phases of two bfeakers

United States Nuclear Regulatory Commission Page 3 of 35 SBK-L-11173 / Enclosure 1 breaker 52 and breaker number 695. Each phase common duct boundary contains one voltage transformer connection.

6. In Section 2.3.3.40, on page 2.3-254, the 1st paragraph of the In-Scope Boundary Description is deleted as follows:

Eaeh breaker-contain*

a cotrol system connecting to the inter-eonncctcd pole tanks (low' pr-essur-e gas). The boundar~y leads, through a filter and dr-yer-to a comfpr-essor-, ei e1

fil,

-f i t dryera, and to the main high pr3essure resen.eir where the as gas ndnses reaylorth next beaker-eyele.

7. In Table 2.3.3-40, on page 2.3-255, the 3rd row is deleted as follows:

8.

Filter Housing Pressure Botinday In Table 2.3.4-8, on page 2.3-315, a new row is added after the 7th row as follows:

Piping Element Leakage Boundary (Spatial)

9. In Section 2.5.3, on page 2.5-5, the 3 d paragraph is revised as follows:

The first path includes all components required to restore offsite power from the 345 kV Switchyard Power Circuit Breakers through the Unit Auxiliary Transformers (UAT) to the diesel backed 4160 volt (V) emergency buses. This path includes the SF 6 bus from 345 kV Power Circuit Breakers 11 and 121-63. to the Generator Step Up (GSU) transformer, the Isolated phase bus from the GSU to the UAT's, and the non-segregated bus from the UATs to 4160 V Bus E5 (EDE-SWG-5) and E6 (EDE-SWG-6).

10. In Section 2.5, on page 2.5-8, Figure 2.5-1 is replaced with a new Figure as follows:

United States Nuclear Regulatory Commission SBK-L-11173 / Enclosure I Page 4 of 28 FUTURE ED-X-IA. ED-X-IB. ED-X-IC GENERATOR STEP-IP TRANS IGSUI LEGENM RECOVERY PATHS I TO UATS RECOVERY PATH Z TO RATS NOT PART OF RECOVERY PATHS I

DESCRIPTMl*1KION NEXTera ENERGYZ SEAMROO SEABROOK(

STATION SBO OFFSITE RECOVERY PATH LICENSE RENEWAL DRAWING Seabrook~ Statlan UniJt I Llcense Renewal APPIIcatIon FIGURE 2.5-1 P.og 2.5-8 a

04wa

United States Nuclear Regulatory Commission SBK-L-11173 / Enclosure I Page 5 of 28

11. In Table 3.2.1, on page 3.2-32, line item 3.2.1-53 is revised as follows:

3.2.1-53 Stainless steel, copper alloy, and nickel alloy piping, piping components, and piping elements exposed to air-indoor uncontrolled (external)

None None NA - No AEM or AMP Consistent with NUREG-1801.

Components in the Auxiliary Boiler, Chemical and Volume Control, Chlorination, Centainment Air Handling Containment Enclosure Air Handling, Control Building Air Handling, Demineri4ized Demineralized Water, Dewatering, Diesel Generator, Fire Protection, Fuel Handling, Fuel Storage Building Air Handling, Hot Water Heating, Instrument Air, Miscellaneous Equipment, Plant Floor Drain, Potable Water, Primary Component Cooling Water, Service Water, and Vent Gas systems have been aligned with this line item based on material, environment and aging effect.

Consistent with NUREG-1801.

Components having the same intemal/external environments have the same aging effects on both internal/external surfaces. As shown in NUREG-1801 Vol. 2 line item V.F-12 stainless steel in an indoor, uncontrolled air (external) environment exhibits no aging effect and that the component or structure will therefore, remain capable of performing its intended functions consistent with the CLB for the period of extended operation.

Stainless steel piping components exposed to air-indoor uncontrolled (external) are contained in the Combustible Gas Control, Containment Building Spray, Demineralized Water, Residual Heat Removal, Safety Injection, and Vent Gas systems and stainless steel piping components in air-indoor uncontrolled (internal) are contained in the Combustible Gas Control and Containment Building Spray systems.

Stainless steel heat exchanger components in air-indoor uncontrolled (external) are contained in the Combustible Gas Control, Containment Building Spray, Residual Heat Removal, and Safety Iniection systems

United States Nuclear Regulatory Commission Page 6 of 28 SBK-L-1 1173 / Enclosure 1 and stainless steel heat exchanger components exposed to air-indoor uncontrolled (internal) are contained in the Combustible Gas Control system.

Stainless steel hydrogen recombiners in air-indoor uncontrolled (internal/external) are contained in the Combustible Gas Control system.

Stainless steel screens exposed to air-indoor uncontrolled (external/intemal) are contained in the Containment Building Spray system.

Stainless steel tanks in air-indoor uncontrolled (external) are contained in the Combustible Gas Control and Containment Building Spray system and stainless steel tanks in air-indoor uncontrolled (internal) are contained in the Combustible Gas Control system.

Copper alloy piping components exposed to air indoor uncontrolled (external) are contained in the Auxiliary Boiler, Chemical and Volume Control, Chlorination, Containment Air Handling, Containment Enclosure Air Handling, Control Building Air Handling, Deminerilized Demineralized Water, Dewatering, Diesel Generator, Fire Protection, Fuel Handling, Fuel Storage Building Air Handling, Hot Water Heating, Instrument Air, Miscellaneous Equipment, Plant Floor Drain, Potable Water, Primary Component Cooling Water, and Safety Injection systems.

Copper alloy heat exchanger components exposed to air-indoor uncontrolled (external) are contained in the Chemical and Volume Control System, Control Building Air Handling, and Diesel Generator systems Copper alloy tanks exposed to air indoor uncontrolled (external) are contained in the Instrument Air system.

Copper alloy heating coils exposed to air indoor uncontrolled (external) are contained in the Hot Water Heating

United States Nuclear Regulatory Commission SBK-L-11173 / Enclosure 1 Page 7 of 28 system.

Copper alloy ducting components exposed to air-indoor uncontrolled (external) are contained in the Auxiliary Boiler system.

Copper alloy piping components exposed to air-indoor uncontrolled (internal) are contained in the Chemical and Volume Control, CGntai.mcnt Air HandlingContainment Enclosure Air Handling, Control Building Air Handling, Dewatering, Diesel Generator, Fire Protection, Fuel Storage Building Air Handling, and Service Water systems.

12. In Section 3.3.2.1.20, on page 3.3-34, the following new bullet is added after steel as follows:

9 Zinc

13.

In section 3.3.2.1.35, on page 3.3-52, the following new bullet is added after the 1 st bullet under Materials as follows:

• Elastomer

14.

In section 3.3.2.1.35, on page 3.3-53, the following new bullet is added after the 1st bullet under Aging Effects Requiring Management as follows:

0 Hardening and Loss of Strength

15.

In section 3.3.2.1.35, on page 3.3-53, the following new bullet is added after the 4th bullet under Aging Management Programs as follows:

• Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program (B.2.1.25)

16.

In Section 3.3.2.1.40, on page 3.3-60, the 3rd bullet under Environments is deleted as follows:

0 Lubr-icating Oil

17.

In Section 3.3.2.1.40, on page 3.3-60, the 3 rd and 4 th bullets under Aging Management Programs are deleted as follows:

T 4

. 4 A 4

0 I iihricn;tingz Oil Annlvqi-q prnorn~m lK 7 I 7ý14

United States Nuclear Regulatory Commission Page 8 of 28 SBK-L-I 1173 / Enclosure 1 0

One Time.i.p. tien Pro.gram (B.2. 1.20)

18.

In 3.3.2.2.5.1, on page 3.3-71, the 1st paragraph is revised as follows:

Seabrook Station will implement the External Surfaces Monitoring Programs, B.2.1.24, to manage hardening and loss of strength due to elastomer degradation of the elastomer components exposed to air-indoor uncontrolled (external) in the Containment Building Spray, Chemical and Volume Control, Containment Air Handling, Containment Air Purge, Containment Enclosure Air Handling, Containment On-Line Purge, Control Building Air Handling, Dewatering, Diesel Generator, Diesel Generator Air Handling, Emergency Feed Water Pump House Air Handling, Fire Protection System, Fuel Handling, Fuel Storage Building Air Handling, Instrument Air, Miscellaneous Equipment, Primary Auxiliary Building Air Handling, Sampling, Service Water Pump House Air Handling, and Spent Fuel Pool Cooling systems. The External Surfaces Monitoring Program is discussed in Appendix B.

19.

In Section 3.3.2.2.10.4, on page 3.3-79, the 2 nd paragraph is revised as follows:

Seabrook Station will implement the One-Time Inspection Program, B.2.1.20, to verify the effectiveness of the Lubricating Oil Analysis Program, B.2.1.26, to manage loss of material due to pitting and crevice corrosion of the copper alloy piping components exposed to lubricating oil in the Chemical and Volume Control, Diesel Generator, Instrument Air, Miscellaneous Equipment, and Service Water, and Sw.ehyard systems, and copper alloy heat exchanger components exposed to lubricating oil in the Chemical and Volume Control and Diesel Generator systems. The Lubricating Oil Analysis and One-Time Inspection Programs are described in Appendix B.

20.

In Section 3.3.2.2.12.2, on page 3.3-83, the 3 rd paragraph is revised as follows:

Seabrook Station will implement the One-Time Inspection Program, B.2.1.20, to verify the effectiveness of the Lubricating Oil Analysis Program, B.2.1.26, to manage loss of material due to pitting, crevice, and microbiologically influenced corrosion of the stainless steel piping components exposed to lubricating oil in the Chemical and Volume Control, Diesel Generator, Fire Protection, Instrument Air, Miscellaneous Equipment, and Oil Collection for Reactor Coolant Pumps,-and Switehya,*-

systems, stainless steel drip pan, stainless steel flame arrestor, and stainless steel tank are exposed to lubricating oil in the Oil Collection for RC Pumps system, and stainless steel heat exchanger components are exposed to lubricating oil in the Chemical and Volume Control System. The Lubricating Oil Analysis and One-Time Inspection Programs are described in Appendix B.

United States Nuclear Regulatory Commission Page 9 of 28 SBK-L-1 1173 / Enclosure 1

21.

In Table 3.3.1, on page 3.3-88, line item 3.3.1-11 is revised as follows:

3.3.1-11 Elastomer seals Hardening A plant Yes, plant Consistent with NUREG-1801 with and components and loss of specific aging specific exceptions. Components in the exposed to air-strength due management Containment Building Spray system have indoor uncontrolled to elastomer program is to been aligned to this line item due to (internal/external) degradation be evaluated, material, environment, and aging effect.

The Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program (with exceptions),

B.2.1.25, will be used to manage loss of material due to hardening and loss of strength of the elastomer components exposed to air-indoor uncontrolled (internal) in the Containment Building Spray, Containment Air Handling, Containment Air Purge, Containment Enclosure Air Handling, Containment On-Line Purge, Control Building Air Handling, Diesel Generator, Diesel Generator Air Handling, Emergency Feed Water Pump House Air Handling, Fuel Storage Building Air Handling, Primary Auxiliary Building Air Handling, Service Water Pump House Air Handling, and Spent Fuel Pool Cooling systems.

The External Surfaces Monitoring Program (with exceptions), B.2.1.24, will be used to manage loss of material due to hardening and loss of strength of the elastomer components exposed to air-indoor uncontrolled (external) in the Containment Building Spray, Chemical and Volume Control, Containment Air Handling, Containment Air Purge, Containment Enclosure Air Handling, Containment On Line Purge, Control Building Air Handling, Dewatering, Diesel Generator Air Handling, Diesel Generator, Emergency Feed Water Pump House Air Handling, Fire Protection, Fuel Handling, Fuel Storage Building Air Handling, Instrument Air, Miscellaneous Equipment, Primary Auxiliary Building Air Handling, Sampling, Service Water Pump House Air Handling, and Spent Fuel Pool Cooling systems.

See subsection 3.3.2.2.5.1.

United States Nuclear Regulatory Commission SBK-L-11173 / Enclosure 1 Page 10 of 28

22.

In Table 3.3.1, on page 3.3-94, line item 3.3.1-26 is revised as follows:

3.3.1-26 Copper alloy piping, piping components, and piping elements exposed to lubricating oil Loss of material due to pitting and crevice corrosion Lubricating Oil Analysis and One-Time Inspection

Yes, detection of aging effects is to be evaluated Copper alloy heat exchanger components in the Chemical and Volume Control and Diesel Generator systems have been aligned to this line item based on material, environment, and aging effect.

Consistent with NUREG-1801 with exceptions. The One-Time Inspection Program, B.2.1.20, will be used to verify the effectiveness of the Lubricating Oil Analysis Program (with exceptions),

B.2.1.26, to manage loss of material due to pitting and crevice corrosion of the copper alloy piping components, and copper alloy heat exchanger components exposed to lubricating oil.

a) Copper alloy piping components in the Chemical and Volume Control, Diesel Generator, Instrument Air, Miscellaneous Equipment, and Service Water,--afd Switchya.4 systems.

b) Copper alloy heat exchanger components in the Chemical and Volume Control System and Diesel Generator Systems.

See subsection 3.3.2.2.10.4.

United States Nuclear Regulatory Commission SBK-L-11173 / Enclosure 1 Page 11 of 28

23.

In Table 3.3.1, on page 3.3-97, line item 3.3.1-33 is revised as follows:

3.3.1-33 Stainless steel piping, piping components, and piping elements exposed to lubricating oil Loss of material due to pitting, crevice, and microbiologi cally influenced corrosion Lubricating Oil Analysis and One-Time Inspection

Yes, detection of aging effects is to be evaluated Components in the Chemical and Volume Control and Oil Collection for Reactor Coolant Pumps systems have been aligned to this line item based on material, environment, and aging effect.

Consistent with NUREG-1801 with exceptions. The One-Time Inspection Program, B.2.1.20, will be used to verify the effectiveness of the Lubricating Oil Analysis Program (with exceptions), B.2.1.26, to manage loss of material due to pitting, crevice, and microbiologically influenced corrosion of the following stainless steel components exposed to lubricating oil:

a) Stainless steel piping components exposed to lubricating oil in the Chemical and Volume Control, Diesel Generator, Fire Protection, Instrument Air, Miscellaneous Equipment, and Oil Collection for Reactor Coolant Pumps, and-witehyard systems.

b) Stainless steel drip pans, stainless steel flame arrestors, and stainless steel tanks exposed to lubricating oil in the Oil Collection for Reactor Coolant Pumps system.

c) Stainless steel heat exchanger components exposed to lubricating oil are contained in the Chemical and Volume Control system.

See subsection 3.3.2.2.12.2.

United States Nuclear Regulatory Commission SBK-L-11173 / Enclosure 1 Page 12 of 28

24.

In Table 3.3.1, on page 3.3-108, line item 3.3.1-60 is revised as follows:

3.3.1-60 Steel piping, piping components, and piping elements exposed to air-outdoor (external)

Loss of material due to general, pitting, and crevice corrosion External Surfaces Monitoring No Consistent with NUREG-1801 with exceptions. The External Surfaces Monitoring Program (with exceptions),

B.2.1.24, will be used to manage loss of material due to general, pitting, and crevice corrosion of the following steel components exposed to air-outdoor a) Steel piping components exposed to air-outdoor in the Auxiliary Boiler, Control Building Air Handling, Diesel Generator, Fire Protection, Fuel Oil, and Service Water, and Switchyard systems.

In addition, galvanic corrosion is an additional aging mechanism in the Fuel Oil and Service Water systems and, b) Galvanized steel piping components exposed to air-outdoor in the Fire Protection and Service Water systems. In addition galvanic corrosion is an additional aging mechanism in the Service Water System.

United States Nuclear Regulatory Commission SBK-L-11173 / Enclosure 1 Page 13 of 28

25.

In Table 3.3.1, on page 3.3-127, line item 3.3.1-97 is revised as follows:

3.3.1-97 Steel, stainless steel, aluminum, and copper alloy piping, piping components, and piping elements exposed to gas None None NA - No AEM or AMP Consistent with NUREG-1801. The following steel, stainless steel, aluminum, and copper alloy piping, piping components, and piping elements exposed to gas have been aligned to this item number based on material, environment and aging effect::

a) Steel piping components exposed to gas are contained in the Fire Protection, Nitrogen Gas, Switehyard, and Waste Gas systems b) Steel heat exchanger components are exposed to gas in the Chemical and Volume Control system.

c) Steel compressor housing exposed to gas are contained in the Control Building Air Handling system.

d) Stainless steel piping components exposed to gas are contained in the Chemical and Volume Control, Fire Protection, Nitrogen Gas, Switchyard, Vent Gas, and Waste Gas systems.

e) Stainless steel heat exchanger components exposed to gas are contained in the Chemical and Volume Control system.

f) Aluminum piping components exposed to gas are contained in the Switchyard system.

g) Copper alloy piping components exposed to gas are contained in the Control Building Air Handling, Fire Protection, and Switchyard systems.

h) Copper alloy heat exchanger components are exposed to gas in the Control Building Air Handling system.

United States Nuclear Regulatory Commission Page 14 of 28 SBK-L-1 1173 / Enclosure 1

26.

In Table 3.3.1, on page 3.3-127, line item 3.3.1-99 is revised as follows:

3.3.1-99 Stainless steel and None None NA - No Consistent with NUREG-1801.

copper alloy <15%

AEM or Components in the Auxiliary Steam, Zn piping, piping AMP Auxiliary Steam Condensate, Auxiliary components, and Steam Heating, Feedwater, Main Steam, piping elements and Steam Generator Blowdown systems exposed to air with have been aligned to this line item based borated water on material, environment, and aging leakage effect.

The following stainless steel and copper alloy <15% Zn components exposed to air with borated water leakage have been aligned to this item number based on material, environment and aging effect::

a) Stainless steel piping components exposed to air with borated water leakage in the Auxiliary Steam, Auxiliary Steam Condensate, Recovery, Chemical and Volume Control, Containment Air Handling, Containment Enclosure Air Handling, Containment On-Line Purge, Demineralized Water, Dewatering, Diesel Generator, Feedwater, Fire Protection, Fuel Handling, Fuel Storage Building Air Handling, Hot Water Heating, Instrument Air, Leak Detection, Main Steam, Mechanical Seal Supply, Miscellaneous Equipment, Nitrogen Gas, Oil Collection for Reactor Coolant Pumps, Primary Component Cooling Water, Radiation Monitoring, Reactor Make-Up Water, Release Recovery, Resin Sluicing, Sample, Service Water, Spent Fuel Pool Cooling, Steam Generator Blowdown, Valve Stem Leak-Off, Vent Gas, Waste Gas, Waste Processing Liquid, and Waste Processing Liquid Drains systems.

b) Stainless steel drip pans and stainless steel flame arrestors exposed to air with borated water leakage in the Oil Collection for Reactor Coolant Pump system.

c) Stainless steel heat exchanger components exposed to air with borated water leakage in the Auxiliary Steam Heating, Chemical and Volume Control, Mechanical Seal Supply, Radiation Monitoring, Sample, Spent Fuel Pool Cooling, Waste Processing Liquid Drains, and Steam Generator Blowdown systems.

d) Stainless steel tanks exposed to air with borated water leakage in the Boron

United States Nuclear Regulatory Commission Page 15 of 28 SBK-L-1 1173 / Enclosure I Recovery, Chemical and Volume Control, Dewatering, Mechanical Seal Supply, Oil Collection for Reactor Coolant Pumps, Reactor Make-Up Water, Sample, Steam Generator Blowdown, Spent Fuel Pool Cooling, Vent Gas, Waste Processing Liquid, and Waste Processing Liquid Drains systems e) Stainless steel ducting closure bolting and stainless steel filter housings exposed to air with borated water leakage in the Fuel Storage Building Air Handling

system, J) Stainless steel damper housing and stainless steel filter housing exposed to air with borated water leakage in the Containment Air Handling system.

g) Copper alloy piping components exposed to air with borated water leakage in the Auxiliary Steam Condensate,,

Chemical and Volume Control, Containment Air Handling, Containment Enclosure Air Handling, Dewatering, Fire Protection,, Fuel Storage Building Air Handling, Instrument Air, Primary Component Cooling Water, and Service Water systems.

h) Copper alloy heater coil exposed to air with borated water leakage in the Hot Water Heating system.

i) Copper alloy heat exchanger components exposed to air with borated water leakage in the Diesel Generator system.

27.

In Table 3.3.2-5, on page 3.3-195, the 4 h row is revised as follows:

Fire Damper Baffe Galvanized Air-Indoor VIIJ-6 3.3.1-Uncontrolled None None (AP-13)

Housing Pressure Steel (External)

Boundary

United States Nuclear Regulatory Commission SBK-L-11173 / Enclosure 1 Page 16 of 28

28.

In Table 3.3.2-5, on page 3.3-195, the 6th row is revised as follows:

Fire Damper Baf-iei Galvanized Air-Indoor VII.J-6 3.3.1-Housing Steel Uncontrolled None None (AP-13) 92 C

Pressure (Internal)

Boundary

29.

In Table 3.3.2-5, on page 3.3-197, the 4 th, 5th, and 6 th rows are deleted as follows:

Fifter PreSSre Stainless Air Ide VHJ is 3.3.1 i

BI-n-y-ntelle None None G

(External)

Aif-With Berated Filter Piessure stainless Water None None G

44ousin Beundaiy Steel (AP8)99 (External)

Filter Pressure Stainless Ai-

.V.J 3

H4ousin Bounda teel Uneentelled None None

&4 (linternal)

(P1) 9

30.

In Table 3.3.2-5, on page 3.3-197, the 7th and 8th rows are revised as follows:

P-r-essure Filereu A

nExternal Filter A

o Loss of Surfaces VII.F3-2 3.3.1-Structural Steel Uncontrolled B

Housing Sttural (Extroll)

Material Monitoring (A-10) 56 Integrity (External)

Program (Attached)

Pressure Air With Filter Beundary Borated Loss of Boric Acid VII.I-10 3.3.1-Housing Structural Steel Water Material Corrosion (A-79) 89 A

Integrity Leakage Program (Attached)

(External)

31.

In Table 3.3.2-5, on page 3.3-198, the 1st row is revised as follows:

Inspection of Pressure Internal r Boundary Air-Indoor Surfaces in Filter Structural Steel Uncontrolled Loss of Miscellaneous V.A-19 3.2.1-D Housing Integrity (Internal)

Material Piping and (E-29) 32 (Attaghety (Ducting (Attached)

Components Program

United States Nuclear Regulatory Commission SBK-L-1 1173 / Enclosure 1 Page 17 of 28

32.

In Table 3.3.2-5, on page 3.3-200, the 6th, 7th, and 8 th rows are deleted as follows:

PiigadPressure Ceppe Ar indee1e NeNne Y.F 3 3.2.1 A

Fiaings B nd Alley U

(EP1 )

Bor-atem Neo V4--..-A Pipin*g and Pr-essure Copper Beut VH 5

A..

Fittings Boumdavs Aley N(AP-11) 99 Ppnan rsue Coppet Air ndoof Y.F 3 3.2.1-Fiig Bendf A41ey Uneentfelled None None(E

)

-53 A4 (internal)

33.

In Table 3.3.2-5, on page 3.3-202, the 3 rd, 4 th, and 5th rows are deleted as follows:

Air indoo3 Valv'e*Body e

f Al 4Utnentrel4ed None Ne0 A

folows:i Aly

(~

~O AiF With Prstf ep erated NLH4 5 34.3.

1. 1 A-Bd I P.- -F4YBudl, 4e Watei None Nonefi

ýp1) 9 A

Pressure Cepper Air-Ind V.F-3 3.2.1-ValveAodyy Uneontrelled None None A4 ThemowilBoundary

>1%A n(ElrnoyE-O)5 Oil Analysis

34.

In Table 3.3.2-12, on page 3.3-285, two new rows are added after the 61h row as follows:

Thermoweil Pressure Copper Air-i 3..1-TemwlBonayAlloy Uncontrolled None None (EP-10) 53 A

Bounary>15% Zn (External,)

Lubricating OilAnalysis B

Prsue Copper Lbiang Loss of Program VII.H2-331 Thermowell BonayAlloy oil Materil 0

26 Boundary

>15% Zn (Internal) aeria One-Time (AP-47)

A Inspection Program

United States Nuclear Regulatory Commission SBK-L-l 1173 / Enclosure I Page 18 of 28

35.

In Table 3.3.2-12, on page 3.3-286, new row is added after the 1 st row as follows:

Lubricating Oil Analysis B

Pressure Stainless Lubricating Loss of Program VII.H2-3.3.1-Thermowell Oil Material 17

(

5 Boundary Steel (Internal)

One-Tine (AP-59)

A Inspection Program

36.

In Table 3.3.2-20, on page 3.3-351, a new row is added after the 6th row as follows:

Inspection of Internal g Hardening Surfaces in Flexible Pressure Lubricating ardening Miscellaneous None None G

Hs BonayElastomer Oil atid Loss of Piping~ antd Noe on G

Hose Boundary (Internal)

Strength Piping Ducting Components nProgram

37.

In Table 3.3.2-20, on page 3.3-365, the following new rows are added after the 1 st row as follows:

Valve Pressure Air-Indoor Zinc Uncontrolled None None None None F, 7 Body Boundary (External)

Air With Borated Boric Acid Valve Pressure Loss of Corio Nen F

Body Boundary Zinc Water Material Corrosion None None F, 8 Leakage Program (External)

Valve Pressure Dried Air None None None None F, 7 Body Boundary (Internal)

United States Nuclear Regulatory Commission SBK-L-11173 / Enclosure 1 Page 19 of 28

38.

In Table 3.3.2-20, on page 3.3-367, new notes 7 and 8 are added as follows (Note 6 was added in Letter SBK-L-10192, dated November 15, 2010, as item 23 on page 16 of Enclosure 2):

7 NUREG-1801 does not include zinc components in air-indoor uncontrolled or dried air environments. Similar to zinc coating in galvanized steel, which protects the underlying steel, zinc by itself is not subject to aging effects in air-indoor uncontrolled or dried air environments (reference line item VII.J-6 for galvanized steel in air-indoor uncontrolled environment).

8 NUREG-1801 does not include zinc components in air with borated water leakage environments. Similar to zinc coating in galvanized steel, zinc is subject to aging effect/mechanism of loss of material due boric acid corrosion.

39.

In Table 3.3.2-35, on page 3.3-445, the following three new rows are added after the 7th row as follows:

External Flexible Leakage Air-Indoor Hardening Surfaces VII.F2-7 Hose Boundary Elastomer Uncontrolled and Loss of Monitoring (A-I 7) 3.3.1-11 E, 3 s (Spatial)

(External)

Strength Program Air Withi External Flexible Leakage Borated Hardening Surfaces Hose Boundary Elastomer Water and Loss of Monitoring None None G

(Spatial)

Leakage Strength (External)

Program Inspection of Internal Surfaces in Flexible Leakage Treated Hardening Miscellane Hose Boundary Elastomer Water and Loss of ous Piping None None G

(Spatial)

(Internal)

Strength and Ducting Componen ts Program

40.

In Table 3.3.2-35, on page 3.3-456, plant specific note 3 is added as follows:

3 NUREG-1801 specifies a plant-specificprogramfor this line item. The External Surfaces Monitoring Program is used to manage the aging effect(s) applicable to this component type, material, and environment combination.

United States Nuclear Regulatory Commission SBK-L-11173 / Enclosure 1 Page 20 of 28

41.

In Table 3.3.2-37, on page 3.3-474, two new rows are added after the 2nd row as follows:

External VII.FJ-Valve Pressure Stainless Condensation Loss of Surfaces 1

3.3.1-E, 5 Body Boundary Steel (External)

Material Monitoring (A-09) 27 Program Open-Cycle VII. C1 -

Valve Pressure Stainless Raw Water Loss of Cooling Water 15 3.3.1-B Body Boundary Steel (Internal)

Material System (A-54) 79 Program

42.

In Table 3.3.2-40, on page 3.3-492, the 9 th row is deleted as follows:

eExtemal Fike Pressufe Aope Air-Outdeer Less-f e

Sufraees Housin Boundar-iy atefial N4e....

ing n

_PRram

43.

In Table 3.3.2-40, on page 3.3-493, the 1st, 2 nd, 3rd, and 4th rows are deleted as follows:

,ub*iMating Oil-Analysis Filte Pressure bess Lubricating Lesse0 YII.H2 3.3.-a Housing Boundary)

Alloy Oil{4 (Inefn 4

N~e-a

-26 "Zf A

One Time

(

A finspection Filte Pressue Sgtainless Airs O-dee.

Less-e....faees

-No-G Housing B.undary Stee (External)

.aterian Monkening Program bubr-kating Oil AnalysisB Filter Pressure Stainlssi urien Less Pr-egram VHbC4-3.3.1 Housing Boundayj Steel Oil (internal)

Mater-ial44--

Filter Prsue Stils Gas Nene None XLW~l- !9 33 A

Housing Boundary Steel (Internal)

(AP 22) 9-7

United States Nuclear Regulatory Commission SBK-L-11173 / Enclosure 1 Page 21 of 28

44.

In Letter SBK-L-1 1054, dated March 22, 2011, Enclosure 1, item 15 on page 10(associated with Table 3.3.2-40), the row is deleted as follows:

p res i S&ahtl s A kr-O WOOf

__Ke wa W f

ý o

o Giaeing

~-Atoew

-N'oie G

45.

In Table 3.3.2-40, on page 3.3-493, the 9 th row is deleted as follows:

bubrieatin Oil Analysis Piping P-r-essufe Copper Less e P-r-egr-am V1.-4-2 3.3.

Fittigs Beundar-y Alley Oil-(Internal)

Material 4-0-2 One Te (AP-47)

A

46.

In Table 3.3.2-40, on page 3.3-494, the 2nd and 3rd rows are deleted as follows:

E-temral V141 "v"*,

8re l e8 Piin adv Pressur-e Sel Air Outdoor Los e u-ae 833 Fiting a,

(-Etr...a Material Menitering (A 2)

__Pre rgram

~_

P Gas Nene None 3fI2

.i A

Steel A

Fitns Boundairyitenl (AP 6) 97

47.

In Table 3.3.2-40, on page 3.3-495, the 1s" and 2 nd rows are deleted as follows:

External VII.14I Soyteela-j (Exerna)

Matereai Monitering (A2)_

Valve'.'sre Steel Gas None None Vl~ 33.3.1 A

Body Boundaryj (internal)

(AP 6) 9-7

United States Nuclear Regulatory Commission Page 22 of 28 SBK-L-l 1173 / Enclosure 1

48.

In Section 3.4.2.1.6, on page 3.4-8, the following new bullet is added in Environments after the 2 "d bullet as follows:

Concrete

49.

In section 3.4.2.1.8, on page 3.4-10, new bullet is added in Materials after the Is' bullet as follows:

0 Glass

50.

In section 3.4.2.2.7.1, on page 3.4-17, the 2 nd paragraph is revised as follows:

Seabrook Station will implement the One-Time Inspection Program, B.2.1.20, to verify the effectiveness of the Water Chemistry Program, B.2.1.2, to manage loss of material due to pitting and crevice corrosion in the stainless steel piping components exposed to treated water in the Auxiliary Steam, Auxiliary Steam Condensate, Chemical and Volume Control System, Condensate, Demineralized Water, Feedwater, Fuel Handling, Hot Water Heating, Main Steam, Mechanical Seal Supply, Radiation Monitoring, Reactor Coolant, Reactor Makeup Water, Release Recovery, Sample, and Steam Generator Blowdown systems, and stainless steel heat exchanger components exposed to treated water in the Condensate, Feedwater, Mechanical Seal Supply, Radiation Monitoring, Sample, and Steam Generator Blowdown systems, and stainless steel tanks exposed to treated water in the Chemical and Volume Control, Condensate, Containment Building Spray, Mechanical Seal Supply, Reactor Coolant, Reactor Makeup Water, and Sample, and Steam Generator Blowdown systems. The One-Time Inspection and Water Chemistry Programs are described in Appendix B.

United States Nuclear Regulatory Commission SBK-L-11173 / Enclosure 1 Page 23 of 28

51.

In Table 3.4.1, on page 3.4-23, line item 3.4.1-6 is revised as follows:

3.4.1-6 Steel and stainless steel tanks exposed to treated water Loss of material due to general (steel only) pitting and crevice corrosion Water Chemistry and One-Time Inspection

Yes, detection of aging effects is to be evaluated Components in the Chemical and Volume Control, Containment Building Spray, Fuel Handling, Hot Water Heating, Mechanical Seal Supply, Reactor Coolant, Reactor Make-Up Water, Release Recovery, and Sample systems have been aligned to this line item based on material, environment, and aging effect.

Consistent with NUREG-1801. The One-Time Inspection Program, B.2.1.20, will be used to verify the effectiveness of the Water Chemistry Program, B.2.1.2, to manage loss of material due to general, pitting, and crevice corrosion in steel tanks exposed to treated water in the Auxiliary Steam Condensate, Fuel Handling, Hot Water Heating, Release Recovery, and Steam Generator Blowdown systems, and to manage pitting and crevice corrosion in the stainless steel tanks exposed to treated water in the Chemical and Volume Control, Containment Building Spray, Condensate, Mechanical Seal Supply, Reactor Coolant, Reactor Make-Up Water, and-Sample, and Steam Generator Blowdown systems.

See Subsection 3.4.2.2.2.1 for steel tanks and Subsection 3.4.2.2.7.1 for stainless steel tanks.

United States Nuclear Regulatory Commission SBK-L-1 1173 / Enclosure 1 Page 24 of 28

52.

In Table 3.4.1, on page 3.4-36, line item 3.4.1-40 is revised as follows:

3.4.1-40 Glass piping elements exposed to air, lubricating oil, raw water, and treated water None None NA - No AEM or AMP Consistent with NUREG-1801. Glass piping elements exposed to Air-Indoor Uncontrolled are contained in the Auxiliary Steam Condensate, Auxiliary Steam Heating, Condensate, Feedwater, and-Main Steam, and Steam Generator Blowdown systems.

Glass piping components exposed to lubricating oil are contained in the Feedwater and Main Steam systems.

Glass piping components exposed to raw water are contained in the Auxiliary Steam Condensate system.

Glass piping components exposed to treated water are contained in the Auxiliary Steam Condensate, Auxiliary Steam Heating, and-Condensate, and Steam Generator Blowdown systems.

United States Nuclear Regulatory Commission SBK-L-1 1173 / Enclosure 1 Page 25 of 28

53.

In Table 3.4.1, on page 3.4-36, line item 3.4.1-41 is revised as follows:

3.4.1-41 Stainless steel, copper alloy, and nickel alloy piping, piping components, and piping elements exposed to air-indoor uncontrolled (external)

None None NA - No AEM or AMP Consistent with NUREG-1801. Copper alloy piping components exposed to Air-Indoor Uncontrolled (external) are contained in the Auxiliary Steam, Auxiliary Steam Condensate, Auxiliary Steam Heating, Condensate, and Feedwater systems.

Stainless steel piping components exposed to Air-Indoor Uncontrolled (external) are contained in the Auxiliary Steam, Auxiliary Steam Condensate, Auxiliary Steam Heating, Condensate, Feedwater, Main Steam, and Steam Generator Blowdown systems.

Stainless steel heat exchanger components exposed to Air-Indoor Uncontrolled (external) are contained in the Auxiliary Steam Heating, Feedwater, and Steam Generator Blowdown systems.

Stainless steel tank exposed to Air-Indoor Uncontrolled (external) is contained in the Main Steam, and Steam Generator Blowdown systems.

Copper alloy heat exchanger components exposed to Air-Indoor Uncontrolled (external) are contained in the Feedwater system.

54.

In table 3.4.1, on page 3.4-37, line item 3.4.1-43 is revised as follows:

3.4.1-43 Steel and None None NA - No Consistent with NUREG-1801.

stainless steel AEM or Stainless steel piping components in piping, piping AMP concrete are contained in the components, Condensate system. Steelpiping and piping components in concrete are contained elements in in the Feedwater system.

concrete

United States Nuclear Regulatory Commission SBK-L-11173 / Enclosure 1 Page 26 of 28

55.

In Table 3.4.2-6, on page 3.4-84, a new row is added after the 3 rd row as follows:

56.

In Table 3.4.2-7, on page 3.4-92, three new rows are added after the 5 th row as follows:

Inspection of Internal Surfaces in Piping Pressure Stainless Air-Outdoor Miscellaneous and Boundary Steel (Internal)

Cracking Piping anid None None G

Fillings Ducting Components Program Inspection of Internal Surfaces in Piping Pressure Stainless Air-Outdoor Loss of Miscellaneous and Boundary Steel (Internal)

Material Piping atd None None G

Fittings Ducting Components Program Inspection of Internal Surfaces in Piping Leakage Stainless Condensation Loss of Miscellaneous VILD-4 and Boundary Steel (Internal)

Material Piping and (AP-81) 3.3.1-54 E,1 Fittings (Spatial)

Ducting Components Program

United States Nuclear Regulatory Commission SBK-L-11173 / Enclosure I Page 27 of 28

57.

In Table 3.4.2-8, on page 3.4-104, the following 3 new rows are added after the 5 th row as follows:

piping Leakage Air-Indoor V

5I.I-5 pg Boundary Glass Uncontrolled None None (SP-9) 3.4-1-40 A

Element (Spatial)

(External)

Air With Piping Leakage Borated piping Boundary Glass Water None None None None G, 1 Element (Spatial)

Leakage (External)

Piping Leakage Treated VIII.-8 Pipmng Boundary Glass Water None None (SP-35) 3.4.1-40 A

Element (Spatial)

(Internal)

58.

In Table 3.4.2-8, on page 3.4-105, the following 3 new rows are added after the 2nd row as follows:

Leakage Stainless Air-Indoor VIILI-10 Tank Boundary Uncontrolled None None VI.-10 3..4.1-41 C

(Spatial) Steel (External)

(SP-12)

Air With Leakage Stainless Borated VII.J-16 Tank Boundary Water None None (AP-18) 3.3.1-99 C

(Spatial)

Leakage (External)

Water Chemistry A

Leakage Stainless Treated Loss of Program VIII. G-41 Tank Boundary Steel Water (S-13) 3.4.1-6 (Spatial)

(Internal)

Material One-Time S

Inspection A

I Program

59.

In Table 3.4.2-8, on page 3.4-109, plant specific note is added as follows:

Plant Specific Notes:

1 This environment is not in NUREG-1801for this component and material.

There are no aging effects for glass in Air With Borated Water Leakage, Air Outdoor, Closed-Cycle Cooling Water, Condensation or Gas environments based on other NUREG-1801 items for glass, such as VII.J-11 in Raw Water environment and VII.J-12 for glass in treated borated water environment.

United States Nuclear Regulatory Commission SBK-L-11173 / Enclosure 1 Page 28 of 28

60.

In Appendix A, on page A-40, revised commitment 29 as follows:

Enhance the program to sample the oil

1. Lubricating Oil for the S,.itehyard SF eempr.essef.-as Analysis the-Reactor Coolant pump oil collection tanks.

Prior to the period of extended operation.

61.

In Appendix B, Section B.2.1.26 in Enhancements, on page B-148, the 2 nd paragraph is revised as follows:

2. The Seabrook Station Lubricating Oil Analysis Program will be enhanced to sample the oil for the S-witehyarrd SF-eenmpresse1r-and the Reactor Coolant pump oil collection tanks.

62.

In Ap pendix B, Section B.2.2.1, in Element 1-Scope of Program, on page B-193, the 3' paragraph is revised as follows:

The first path includes the SF 6 bus from 345 kV Power Circuit Breakers 11 and 12-4-63 to the Generator Step Up transformer. This path continues from the Generator Step Up transformer to Unit Auxiliary Transformers via the Isolated Phase Bus.

to SBK-L-11173 Changes to the License Renewal Application, Appendix A Associated with NRC Staff Discussions

United States Nuclear Regulatory Commission Page 2 of 2 SBK-L-1 1173 / Enclosure 2 Changes to Section A.lof the LRA Based on discussion with the Staff regarding operating experience, the following section is being added to supplement the original response to RAI B. 1.4-1 (Reference 2). Section A. 1.6 has been added to the LRA Appendix A, page A-6.

A.1.6 Operating Experience The existing Corrective Action Program and the Operating Experience Program ensure, through the continual review of both plant-specific and industry operating experience, that the license renewal aging management programs are effective to manage the aging effects for which they are credited. The programs are either enhanced or new programs are developed when the review of operating experience indicates that the programs may not be effective. For each aging management program, operating experience is reviewed on a continuing basis.