ML13158A016

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Requests for Additional Information for the Review of the Sequoyah Nuclear Plant, Units 1 and 2, License Renewal Application (TAC Nos. MF0481 and MF0482) Set 9
ML13158A016
Person / Time
Site: Sequoyah  Tennessee Valley Authority icon.png
Issue date: 06/25/2013
From: Plasse R
License Renewal Projects Branch 1
To: James Shea
Tennessee Valley Authority
Plasse R 415-1427
References
TAC MF0481, TAC MF0482
Download: ML13158A016 (28)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 June 25, 2013 Mr. Joe W. Shea Vice President, Nuclear Licensing Tennessee Valley Authority P.O. Box 2000 Soddy-Daisy, TN 37384

SUBJECT:

REQUESTS FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE SEQUOYAH NUCLEAR PLANT, UNITS 1 AND 2, LICENSE RENEWAL APPLICATION (TAC NOS. MF0481 AND MF0482) - SET 9.

Dear Mr. Shea:

By letter dated January 7, 2013, Tennessee Valley Authority submitted an application pursuant to Title 10 of the Code of Federal Regulations (CFR) Part 54, to renew the operating license DPR-77 and DPR-79 for Sequoyah Nuclear Plant, Units 1 and 2, for review by the U.S. Nuclear Regulatory Commission (NRC) staff. The staff is reviewing the information contained in the license renewal application and has identified, in the enclosure, areas where additional information is needed to complete the review.

These requests for additional information, outlined in Enclosure 1, were discussed with Henry Lee, and a mutually agreeable date for the response is within 30 days from the date of this letter. If you have any questions, please contact me at 301-415-1427 or e-mail Richard.Plasse@nrc.gov.

Sincerely, Richard A. Plasse, Project Manager Projects Branch 1 Division of License Renewal Office of Nuclear Reactor Regulation Docket Nos. 50-327 and 50-328

Enclosure:

Requests for Additional Information cc w/encl: Listserv

ML13158A016 *concurred via email OFFICE LA:DLR PM:RPB1 :DLR BC:RPB1 :DLR PM: RPB1 :DLR NAME YEdmonds E Sa oc Y Diaz-Sanabria R Plasse DATE 6/12/2013 6/17/2013 6/25/2013 6/25/2013

SEQUOYAH NUCLEAR PLANT, UNITS 1 AND 2 LICENSE RENEWAL APPLICATION REQUESTS FOR ADDITIONAL INFORMATION RAI 3.5.2.2.2.5-1

Background:

In license renewal application (LRA) Section 3.5.2.2.2.5, the applicant states that its time-limited aging analysis (TLAA) identification methodology did not identify any containment bolting, anchorage system, or weld analyses that conform to the definition of a TLAA in 10 CFR 54.3.

Based on this determination, the applicant states that the LRA does not need to include any TLAAs for these type of structural components. Design basis information and data for the containment anchorage systems are given in updated final safety analysis report (UFSAR)

Appendix 3.BC. Meridional loads for the anchorage systems are given in UFSAR Figure 3.BC-2.

Issue:

UFSAR Appendix 3.BC states that the meridional loads for the anchorage systems include non axisymetric pressure transient loads. It is not evident which pressure transients were assessed for the creation of the non-axisymetric loads or whether the assessment of non-axisymetric loads was based on the total number of cycles assumed for those pressure transients in the design basis over the life of the plant.

Request:

1. Identify all pressure transients that were assessed as inducing the non-axisymetric loads that are identified in UFSAR Figure 3.BC-2. Clarify whether the assessment of those pressure transients was based on an assessment of the total number cycles that were assumed for those transients in the design basis.
2. Based on your response to Part a., justify why the assessment of non-axisymetric loads for the containment anchorage systems would not need to be identified as a TLAA for the LRA, when compared to the six criteria for identifying an analysis as a TLAA in 10 CFR 54.3.

RAI B.1.29-1

Background:

The table on page B-10B of LRA Section B.1.29, "One-Time Inspection," describes how the effectiveness of the program will be verified, and states that external surfaces of residual heat remover (RHR) heat exchanger tubes will be included in the One-Time Inspection Program. It also states that the inspections conducted by the program will confirm that loss of material is not occurring or is so insignificant that an aging management program is not warranted. The table on page B-107 describes the parameters monitored and inspected for aging effects and aging mechanism, and states that for a loss of material due to wear, the wall thickness will be tested using the eddy current inspection method.

ENCLOSURE

-2 SQN-RPT-10-LRD03, "Aging Management Program Evaluation Report (AMPER) Non-Class 1 Mechanical," Attachment 1, "One-Time Inspection Activities," states the following:

  • Parameters Monitored or Inspected: visual inspections will be used if the surface condition of the component is the subject inspection or eddy current inspections will be used to measure wall thickness.
  • Detection of Aging: visual or eddy current will be used to inspect a representative sample of the external surfaces to manage loss of material.

Issue:

The LRA and AMPER are inconsistent in that the LRA states that eddy current will be used to detect loss of material due to wear for the RHR heat exchanger tubes, whereas the AMPER states that either visual inspections or wall thickness measurements will be used. The staff is unsure if the applicant will be using visual inspections or the eddy current inspections to detect loss of material due to wear. Additionally, it is unclear to the staff how visual inspection will be effective in detecting loss of material due to wear.

Request:

State whether visual inspection methods will be used to detect loss of material due wear for RHR heat exchanger tubes. If visual inspection methods will be used state the basis for how they will be capable of detecting loss of material due to wear for the RHR heat exchanger tubes.

RAI B.1.29-2

Background:

The table on page B-108 of LRA Section B.1.29, "One-Time Inspection," describes how the program will verify the effectiveness of several programs and verify that loss of material or cracking is not occurring or is, "so insignificant that an aging management program is not warranted."

Issue:

The staff lacks sufficient information to understand how it will be determined that cracking and loss of material will be so insignificant that an aging management program is not warranted.

Request:

What specific steps will be taken to demonstrate that cracking or loss of material found is so nsignificant that an aging management program is not warranted?

-3 RAI B.1.31-1

Background:

SRP-LR Section A.1.2.3.1, "Scope of Program," states that this program element should include the specific structures and components.

LRA Section B.1.31 discusses ultrasonic testing inspections to manage cracking in carbon steel piping exposed to stagnant treated water at greater than 130°F in the component cooling water system. SQN-RPT-1 O-LRD08, "Operating Experience Review Report - AERM" discusses two reports that address cracking of component cooling water piping near a reactor coolant pump.

Issue:

It is not clear to the staff whether the specific components (carbon steel piping exposed to stagnant treated water at greater than 130°F) included in this item are only near the reactor coolant pumps or whether there are locations in other parts of the component cooling water system that are included in this item.

Request:

Provide details regarding the specific components that are included in the activities associated with the carbon steel piping exposed to stagnant treated water at greater than 130°F in the component cooling water system.

RAI B.1.31-2

Background:

For conditioning monitoring programs, SRP-LR Section A.1.2.3.4, "Detection of Aging Effects,"

states that the discussion should provide justification that the technique is adequate to detect aging before a loss of an intended function(s) occurs.

LRA Section B.1.31 states that the plant-specific AMP, "Periodic Surveillance and Preventive Maintenance Program" will manage the standby diesel generator lube oiler cooler heat exchanger tubes for loss of material due to wear through an enhanced visual inspection (EVT-1) of the surface condition of a representative sample. LRA Table 3.3.2-15, Standby Diesel Generator System, indicates that this aging effect occurs in an external lube oil environment.

Issue:

It is not clear to the staff that an EVT-1 visual inspection will be able to detect loss of material due to wear on the outside of the lube oil cooler heat exchanger tubes. In that respect, the program basis documents did not provide any discussion regarding the cause of this aging effect. In addition, the staff notes that eddy current testing is typically used to detect wall thinning of heat exchanger tubes, and if the heat exchanger tubes have any intermediate supports, the ability to detect loss of material due to wear using visual techniques may not be sufficient.

-4 Request:

Provide information demonstrating that an EVT-1 visual inspection will be able to detect loss of material due to wear before a loss of intended function(s) occurs. Consider describing the cause of wear (Le., tube-to-tube interaction, or tUbe-to-support interaction), and including details of the heat exchanger to show that an EVT-1 will be effective.

RAI 8.1.31-3

Background:

SRP-LR Section A.1.2.3.5, "Monitoring and Trending" states that the related activities should be described and should provide for a prediction of the extent of degradation. This section also states that this program element includes an evaluation of the results and a prediction regarding the rate of degradation in order to confirm that the timing of the next scheduled inspection will occur before there is a loss of intended function.

For the associated program element, LRA Section 8.1.31 states that preventive maintenance activities provide for monitoring and trending. The staff notes that SQN-RPT-10-LRD03, "Aging Management Program Evaluation Report Non-Class I Mechanical," Section 4.11, "Periodic Surveillance and Preventive Maintenance," cites NEDP-12, "Equipment Failure Trending" as the implementing procedure for this program element. The stated purpose of NEDP-12 is to establish the requirements and processes for evaluation of equipment failures.

It is not clear to the staff what "preventive maintenance activities provide for monitoring and trending," as stated in LRA Section B.1.31. Although SQN-RPT-1 O-LRD03 refers to a trending procedure, this procedure appears to only be applicable to equipment failures and would not provide a prediction regarding the rate of degradation in order to confirm that the timing of the next inspection will occur before there is a loss of function.

Request:

Discuss the specific preventive maintenance activities that provide for monitoring and trending, and provide information regarding whether these activities are prescribed in an implementing procedure or how these activities are controlled.

RAI8.1.31-4

Background:

SRP-LR Section A.1.2.3.6, "Acceptance Criteria," states that this program element should describe qualitative or quantitative acceptance criteria and that those criteria should ensure that the structure and component intended functions are maintained consistent with all current licensing basis (CLB) design conditions during the period of extended operation. This section notes that acceptance criteria could be specific numerical values or could consist of a discussion of the process for calculating specific numerical values of conditional acceptance

-5 then it is not necessary to discuss CLB loads, but if the acceptance criteria does permit degradation, then these criteria are based on maintaining the intended function under all CLB design loads.

LRA Section B.1.31 states that acceptance criteria are defined in specific inspection procedures and that those procedures verify the absence of aging effects or compare applicable parameters to limits established by plant design basis. In addition, Section B.1.31 states that the acceptance criteria for metallic components include "no unacceptable loss of material such that component wall thickness remains above the required minimum."

SQN-RPT-10-LRD03, "Aging Management Program Evaluation Report, Non-Class I Mechanical," Section 4.11, "Periodic Surveillance and Preventive Maintenance," states, that a list of activities and their specific acceptance criteria is contained in Attachment 2, "Periodic Surveillance and Preventive Maintenance Activities." The staff notes that the enhancement included in Section 4.11 states, to revise the procedures as necessary to incorporate the activities in Attachment 2. The staff also notes that Attachment 2 contains acceptance criteria for each activity that does not reflect the same information as the information in the LRA. For example, for activities which manage cracking, the acceptance criteria listed in Attachment 2 states "no unacceptable cracking," "no significant cracking," or "no cracks that exceed minimum wall thickness requirements." For activities that manage loss of material, the acceptance criteria listed in Attachment 2 states "no unacceptable loss of material," "no significant corrosion that would impede performance," and "no unacceptable loss of material such that pipe wall thickness remains above the required minimum."

Issue:

It is not clear to the staff whether the acceptance criteria for each activity will be as stated in the LRA (Le., verifying the absence of an aging effect) or as stated in SQN-RPT-10-LRD03, . If the acceptance criteria are something other than verifying the absence of an aging effect, then the staff considers the use of the terms "unacceptable loss of material" or "unacceptable cracking" in the acceptance criteria to be too vague.

Request:

1. Clarify whether the acceptance criteria for loss of material will not permit degradation by verifying the "absence of the aging effect," or whether the acceptance criteria will permit degradation by including "no unacceptable loss of material."
2. If "unacceptable loss of material" is to be used, then for each applicable activity provide the bases for quantifying "unacceptable" with respect to ensuring that intended function(s) of the component will be maintained under all CLB design loads. If the acceptance criteria will include "remaining above required minimum," confirm that the specific numerical value will be included in the implementing procedures or that a discussion of the process for calculating specific numerical values of conditional acceptance criteria will be included for each activity.
3. For activities that involve monitoring for cracking, confirm that the acceptance criteria will be the absence of cracking or confirm that a specific numerical value for acceptable

- 6 cracking will be included in the implementing procedure and provide the bases to demonstrate that the intended functions of components with acceptable cracking will be maintained under all CLB design loads.

RAI B.1.31-5

Background:

SRP-LR Section A.1.2.3.4, "Detection of Aging Effects," states that this program element should describe the "when," "where," and "how" program data are collected. In addition, SRP-LR Section A.1.2.3.6, "Acceptance Criteria," states that the acceptance criteria, against which the need for corrective actions is evaluated, should ensure that the structure- and component intended function(s) are maintained consistent with all CLB design conditions during the period of extended operation.

LRA Section B.1.31 states that the plant-specific AMP, "Periodic Surveillance and Preventive Maintenance," will manage the divider barrier seal (seal between the upper and lower compartments of the containment) for cracks, loss of material, and significant change in material properties through pressure testing of the divider barrier seal test coupons, and manually flexing and visually monitoring the surface condition of elastomeric components.

The staff noted that UFSAR Section 3.8.3.4.5 states that the design life of the seal material is eight years in the expected radiation environment and at a temperature of 120°F, but that the replacement will be determined by the results of testing specimen coupons hung throughout the reactor building. The staff also noted that Sequoyah Technical Specification 4.6.5.9, Surveillance Requirements states that the divider barrier seal shall be determined operable at least once every 18 months by: (a) removing and pressure testing the divider barrier seal test coupons, and (b) visually inspecting at least 95 percent of the seal's entire length and verifying that the seal and seal mounting bolts are properly installed, and that the seal material shows no visual evidence of deterioration due to holes, ruptures, chemical attack, abrasion, radiation damage, or changes in physical appearances.

Issue:

The "Detection of Aging Effects" program element in LRA Section B.1.31 does not provide any details (e.g., pressure, sample size) related to the pressure testing of the divider barrier seal coupons that is being credited by this program. In addition, the "Acceptance Criteria" program element in LRA Section B.1.31 does not provide the acceptance criteria for the pressure testing of the divider barrier seal coupons that is being credited by this program. Also, the "Operating Experience" program element did not discuss any results for the every 18 month surveillance requirements given in the technical specification.

Request:

For the pressure testing that is being credited by this program of the divider barrier seal test coupons:

-7 For the pressure testing that is being credited by this program of the divider barrier seal test coupons:

1. Provide additional details for the detection of aging effects, such as the number of coupons to be tested, the pressure at which the test will be performed, and the frequency of the test.
2. Provide additional details for the acceptance criteria against which the results of the pressure tests of the seal coupons are evaluated.
3. Provide a discussion of operating experience for any age-related degradation that has been identified on past divider barrier seal tests and inspections, including any repairs, replacements, and/or additional inspections being performed to ensure that the divider barrier seal will maintain its intended function during the period of extended operation.

RAI B.1.31-6

Background:

As required by 10 CFR 54.21 (d), the FSAR supplement for the facility must contain a summary description of the program and the activities for managing the effects of aging. SRP-LR Section 3.3.2.5, "FSAR Supplement," states that the summary description of the programs and activities for managing the effects of aging for the period of extended operation should be sufficiently comprehensive such that later changes can be controlled by 10 CFR 50.59. The SRP-LR also states that the description should contain information associated with the bases for determining that aging effects will be managed during the period of extended operation (PEO).

LRA Section B.1.31 states that each inspection occurs at least once every five years, and that for activities that refer to a representative sample, this is 20 percent of the population with a maximum number of 25 components.

LRA Appendix A, UFSAR Supplement, Section A.1.31 "Periodic Surveillance and Preventive Maintenance," does not include the frequency of inspections and does not discuss the sample size for the inspections involving a representative sample. The staff believes that this information is associated with the bases for determining that the aging will be effectively managed during the PEO. The staff also believes that this information should be explicitly stated in the UFSAR supplement to ensure that the licensing basis for the PEO is clear.

Request:

Either revise LRA Section A.1.31 to include the frequency of inspections to be conducted and the sample size for inspections involving a representative sample during the period of extended operation, or provide the bases to demonstrate that these aspects cannot be changed without being controlled by 10 CFR 50.59.

-8 RAI 3.3.1.42-1

Background:

The GALL Report AMP XI.M20, "Open-Cycle Cooling Water System," addresses several aging effects, including reduction of heat transfer for heat exchanger tubes of various materials exposed to raw water. In LRA Table 3.3.2-2, "High Pressure Fire Protection - Water System,"

the copper alloy heat exchanger tubes exposed to raw water cite item 3.3.1-42, with a Generic Note E and credit the Fire Water System Program to manage reduction of heat transfer. The GALL Report AMP XLM27, "Fire Water System," addresses loss of material due to corrosion, microbiologically-influenced corrosion, and biofouling; however, the AMP does not address reduction of heat transfer due to fouling.

It is not clear to the staff how SaN's Fire Water System Program will manage reduction of heat transfer due to fouling, since this aging effect is not addressed by this AMP in the LRA.

Request:

Provide information regarding how the Fire Water System Program will manage reduction of heat transfer due to fouling for the copper alloy heat exchanger tubes in the High Pressure Fire Protection - Water System, and as appropriate, provide any updates to the LRA RAI2.5-1

Background:

In accordance with 10 CFR 54.4(a)(3) and Standard Review Plan (SRP)-License Renewal (LR) section 2.5.2.1.1, the station blackout (SBO) recovery path in scope of license renewal includes switchyard circuit breakers that connect to the offsite system power transformers (startup transformers), the transformers themselves, the intervening overhead or underground circuits between circuit breaker and transformer and onsite electrical distribution system, and the associated control circuits and structures.

Sequoyah Nuclear Plant (SON) UFSAR Section 8.2.1.1 indicated that there are overhead conductors between the common station service transformers (CSSTs) and the 6.9 kilovolts (kV) shutdown boards. It is unclear whether the overhead conductors between the CSSTs and the 6.9kV shutdown boards are within the scope of license renewal.

Request:

Confirm whether the overhead conductors between the CSSTs and the 6.9kV shutdown boards are within the scope of license renewal.

-9 RAI2.5-2

Background:

Table 2.5-1 of the LRA shows that the intended function of the insulation materials for non environmental qualification (EQ) electrical cables and connections (includes non-EQ electrical and instrumentation and control penetration conductors and connections), non-EQ electrical cables and connections used in instruments circuits, and fuse holders is to conduct electricity.

The intended function of "conducts electricity" as defined in Table 2.0-1 of the LRA is to "provide electrical connections to specified sections of an electrical circuit to deliver voltage, current or signals.

The intended function of the above insulation materials is unclear.

Request:

Clarify the intended functions of the above insulation materials.

RAI2.5-3

Background:

In section 2.1.2.3.1 of the LRA, "Passive Screening," the licensee stated that electrical components are supported by structural commodities such as cable trays, electrical penetrations, conduit, or cable trenches that are included in the structural aging management.

The structural aging management of cable tie wraps needs clarification.

Request:

Clarify whether cable tie wraps are included in the structural aging management since cable tie-wraps, which are intended to support cables and maintain spacing for power cable ampacity, would be considered long-lived passive components depending on whether they have a credited design function.

RAI2.2-1

Background:

The applicant's scoping criteria is described in Section 2.1 of the Callaway License Renewal Application (LRA). In LRA Section 2.2, "Plant Level Scoping Results," provides the results of applying the license renewal scoping criteria to Systems, Structures, and Components (SSCs).

- 10 The following systems, as described in the UFSAR, could not be located in LRA Tables 2.2-1 and 2.2-2.

UFSAR Section System

!

9.2.S Ultimate Heat Sink 9.3.S Auxiliary Charging System 9.S.8 Hydrogen System 9.S.9 Nitrogen System Request:

The staff requests the applicant to identify where the above systems are in the LRA. If the above systems are not included in the LRA, the staff also requests the applicant to provide its basis for the exclusion of the above systems from LRA Tables 2.2-1 and 2.2-2.

RAI2.3.3-1

Background:

LRA Section 2.1 describes the applicant's scoping methodology, which specifies how systems or components were determined to be included in scope of license renewal. The staff confirms the inclusion of all component types subject to Aging Management Review (AMR) by reviewing the results of the screening of components within the license renewal boundary.

For the drawing locations identified in the table below, the continuation of piping in scope for license renewal could not be located.

License Renewal Drawing I Continuation Issue Number & Location Section 2.3.3.7 Compressed Air LRA-1 ,2-47W848-12, coordinates C-S, 0-4, G-3, H-3, 0-11, and E-10 I Lines highlighted green continued from "Detail B" Section 2.3.3.8 Station Drainage LRA-1,2-47W81S-2, coordinate H-1 11" line to Aux Bldg. Drains

- 11 4" line continuation to drawing 47W479-7, with Note: Not a

! LRA-1,2-47W852-3, coordinate C-8 LRA Drawing: Piping enters the yard 4" line continuation to drawing 47W479-7, with Note: Not a LRA-1,2-47W852-4, coordinate C-7 LRA Drawing: Piping enters the yard Line continuation from sink drain to drawing 47W560-2, LRA-1 ,2-47W853-1, coordinate E-2 with Note: Not a LRA Drawing LRA-1 ,2-47W855-1, coordinate E 2" plant drain line within the scope of 10 CFR 54.4 (a)(3),

11 with continuation after valves 0-40-532 and 0-40-533 Section 2.3.3.9 Sampling and Water Quality System Line within the scope of 10 CFR 54.4(a)(2) continues from LRA-1,2-57523, coordinate F-12 valve 1V34 LRA-1,2-57523, coordinates F-1 Line within the scope of 10 CFR 54.4(a)(2) continues through F-12 downward to "GS" Lines within the scope of 10 CFR 54.4(a)(2) continues LRA-1 ,2-47W881-8, coordinates A-from valves 1-VLV-43-382, 1-VLV-43-389, 1-VLV-43-384, 6, D-2, D-7, and H-2 and 2-FSV-43-201 1 %" line within the scope of 10 CFR 54.4(a)(2) continues LRA-1,2-47W881-9, coordinate F-4 from sample sink No. 87 samples system 77 Section 2.3.3.11 Essential Raw Cooling Water System LRA-1-47W845-3, coordinates D- Line continuations to Drawing 47W600-171, with Note:

8,F-8,and G-8 Not a LRA Drawing Line continuation to 1-47E600-286, with Note: Not a LRA LRA-1,2-47W845-5, coordinate K-9 Drawing LRA-1,2-47W845-5, coordinate K- Line continuation to 1-47E600-179, with Note: Not a LRA 10 Drawing I Section 2.3.3.12 Component Cooling System

  • Line continuations to deionization unit on drawing 1,2 LRA-1,2-47W856-1, coordinate E-4 47W625-60, with Note: Not a LRA Drawing Line continuations to sample panels on drawing 47W625 LRA-1 ,2-47W856-1, coordinate F-4 1, with Note: Not a LRA Drawing I ~~-1 ,2-57521, coordinate F-1, and Lines within the scope of license renewal end without any continuation information I Section 2.3.3.16 Flood Mode Boration Makeup System Line within the scope of 10 CFR 54.4(a)(1) continuing LRA-1,2-47W809-7, coordinate C-6 from valve 0-84-524 I Section 2.3.3.17, Miscellaneous Auxiliary Systems in Scope for 10 CFR 54.4(a)(2)
  • Sampling and Water Quality System Line continuation from drawing 1-47W625-13, coordinate LRA-1 ,2-57521 , coordinate G-6 E-3, with Note: Not a LRA Drawing Four line continuations to drawing 30137 -A 1 and two line LRA-1 ,2-47W881-2, coordinates A continuations to drawing 57749, with Notes: Not a LRA 6, A-7, D-6/7 Drawing

- 12 LRA-1,2-47W881-5-1, coordinate F Five continuations to drawing 1,2-47W625-60 6

Section 2.3.3.17, Miscellaneous Auxiliary Systems in Scope for 10 CFR 54.4(a)(2)

Station Drainage and Sewage System 3" drain line continuation to drawing 17W300, with Note:

LRA-1 ,2-47W851-1, coordinate A-4 Not a LRA Drawing LRA-1 ,2-47W851-1, coordinates Nine (9) drain line continuations to drawing 47W915 and B/C-2 through B/C-11 one to drawing 47W600, with Notes: Not a LRA Drawing LRA-1 ,2-47W853-11, coordinate E Line continuations after valves 683 and 684 to the deck 3 drainage sump and the traveling screen well, respectively Section 2.3.3.17, Miscellaneous Auxiliary Systems in Scope for 10 CFR 54.4(a)(2)

Raw Cooling Water System Line continuations within the scope of license renewal to LRA-1,2-47W844-2, coordinate H-1 and from unidentified continuations could not be found Section 2.3.3.17, Miscellaneous Auxiliary Systems in Scope for 10 CFR 54.4(a)(2)

Waste Disposal System LRA-1-4 7W830-2, coordinates H-8 Line continuations within the scope of license renewal to and G-8 drawing 47W61 0-90-2, with Note: Not a LRA Drawing Section 2.3.3.17, Miscellaneous Auxiliary Systems in Scope for 10 CFR 54.4(a)(2)

Water Treatment System and Makeup Water Treatment Plant System Line continuation to drawing 47E871-6, coordinate G-5, LRA-1-47W834-1, coordinate H-8 with Note: Not a LRA Drawing Request:

The staff requests the applicant to provide sufficient information to locate the license renewal boundary. If the continuation cannot be shown on license renewal drawings, then provide additional information describing the extent of the scoping boundary and verify whether or not there are additional component types subject to AMR between the continuation and the termination of the scoping boundary. If the scoping classification of a section of the piping changes over the continuation, provide additional information to explain the change in scoping classification.

RAI2.3.3.7-1

Background:

License renewal drawing LRA-1 ,2-47W848-1, coordinates C-4, depicts a line from the Auxiliary Building on drawing 47W848-9 (not provided with the LRA) not highlighted as being within the scope of license renewal. However, the line is attached to valve 32-251, which is depicted as being within the scope of license renewal for 10 CFR 54.4(a)(1).

A similar line from the Auxiliary Building on the same license renewal drawing, coordinate F-4, is highlighted as being within the scope of license renewal for 10 CFR 54.4(a)(2) attached to valve

-13 32-310. The staff would have expected that the line attached to valve 32-251 should have been highlighted for 10 CFR 54.4(a)(2).

Request:

The staff requests the applicant to provide the basis for excluding the line attached to valve 32 251 from the scope of license renewal for 10 CFR 54.4(a)(2).

RAI 2.3.3.8-1

Background:

License renewal drawing LRA-1,2-47W853-10, coordinates G-5 through H-5, depict 6" lines within the scope of license renewal for 10 CFR 54.4(a)(1) from the Diesel Generator Building.

However, these 6" lines are not highlighted within the scope of license renewal after valves 0 40-840 and 0-40-584 through 0-40-587.

The staff would have expected that the 6" lines should have been highlighted for 10 CFR 54.4(a)(2) after valves 0-40-840 and 0-40-584 through 0-40-587.

Request:

The staff requests the applicant to provide the basis for excluding the 6" lines from the scope of license renewal for 10 CFR 54.4(a)(2) after valves 0-40-840 and 0-40-584 through 0-40-587 RAI 2.3.3.11-01

Background:

License renewal drawing LRA-1,2-47W8545-1 coordinate E-6, depicts a 14" overflow line that is not highlighted within the scope of the license renewal. This 14" overflow line is attached to a 36" line that is highlighted within the scope of license renewal for 10 CFR 54.4 (a)(1).

The staff would have expected that the 14" overflow line should have been highlighted for 10 CFR 54.4(a)(2) past the safety/nonsafety-related interface on the 36" line.

Request:

The staff requests the applicant to provide the basis for excluding the 14": overflow line from scope of license renewal for 10 CFR 54.4(a)(2).

- 14 RAI 2.3.3.11-02

Background:

In LRA Section 2.1.1.2.2. the applicant indicates that nonsafety-related SSCs attached to safety-related SSCs are in scope of license renewal for 10 CFR 54.4(a)(2) up to the first seismic anchor past the safety/non-safety interface.

On license renewal drawing LRA-1,2-47WS45-5, coordinates C-3, E-3, H-3, and K-3, the staff could not locate seismic or equivalent anchors on the 10 CFR 54.4(a)(2) nonsafety-related continuation lines to the gutter drains.

Request:

The staff requests the applicant to provide the locations of the seismic or equivalent anchors on the nonsafety-related continuation lines past the safety/non-safety interface and the end of the 10 CFR 54.4(a)(2) scoping boundary.

RAI2.3.3.11-03

Background:

License renewal drawing LRA-1,2-47WS545-1 coordinate D-1, depicts a 4S" overflow line that is not highlighted within the scope of the license renewal. This 4S" overflow line is attached to a 36" line that is highlighted within the scope of license renewal for 10 CFR 54.4(a)(1).

The staff would have expected that the 4S" overflow line should have been highlighted for 10 CFR 54.4(a)(2) past the safety/nonsafety-related interface on the 36" line.

Request:

The staff requests the applicant to provide the basis for excluding the 4S": overflow line from scope of license renewal for 10 CFR 54.4(a)(2).

RAI 2.3.3.13-1

Background:

On license renewal drawing LRA-1,2-47WS30-6, coordinates B/C-S, the staff could not locate seismic or equivalent anchors on the Accum TK-1, 2, 3, and 4.

- 15 The staff could not also locate seismic or equivalent anchors on four 10 CFR 54.4(a)(2) nonsafety-related lines, which continue and are attached to safety-related lines as depicted on license renewal drawing LRA-1,2-47W811-1, coordinates A-1, A-2, A-3, and A-5.

Request:

The staff requests the applicant to provide the locations of the seismic or equivalent anchors on the Accum TK-1, 2, 3, and 4, and the four 10 CFR 54.4(a)(2) lines that continue onto license renewal drawing LRA-1,2-47W811-1.

RAI 2.3.3.13-2

Background:

License renewal drawing LRA-1,2-47W830-6, coordinates NB/C/D-8, depicts the Accum tanks and Steam Generator loops within the scope of license renewal for 10 CFR 54.4(a)(2).

However, the lines and components in between the Accum tanks and Steam Generator loops are not highlighted within the scope of license renewal for 10 CFR 54.4(a)(2).

Request:

The staff requests the applicant to provide the basis for excluding the lines and components in between the Accum tanks and Steam Generator loops from the scope of license renewal.

RAI 2.3.3.15-1

Background:

License renewal drawing LRA-1,2-47W839-1, depicts various lines in scope for license renewal for 10 CFR 54.4(a)(1).

However, the license renewal boundary of these lines, at coordinates H-5 and H-6, is shown to end at the hydraulic unloader of the air compressors 1 and 2, respectively. Furthermore, the compressor housings are depicted on the license renewal drawing LRA-1,2-47W839-1 as not being highlighted within the scope of license renewal and are excluded from LRA Table 2.3.3-15 as a component type subject to an AMR.

- 16 Request:

The staff requests the applicant to indicate the appropriate license renewal boundary near the hydraulic unloader and justification for the exclusion of the compressor housing component type from LRA Table 2.3.3-15.

RAI 2.3.3.15*2

Background:

License renewal drawing LRA*1 ,2-A950F04001, at coordinates A-5 and A-B, depicts 1" overflow lines attached to the water expansion tanks as being within the scope of license renewal for 10 CFR 54.4(a)(2). However, the scoping boundaries for these lines are depicted to abruptly end at these locations.

The staff could not locate scoping boundary termination indicators for these lines.

Request:

The staff requests the applicant to provide the appropriate scoping boundary termination indicators for these 1" overflow lines attached to the water expansion tanks.

RAI 2.3.3.16-1

Background:

In license renewal drawing LRA-1,2-47WB09-7, coordinate E-6, and continuing to license renewal drawing LRA-1 ,2-47WB56-1, coordinate E-5, the staff could not locate seismic or equivalent anchors on the 10 CFR 54.4(a)(2) nonsafety-related lines attached to the Unit 1 and Unit 2 Primary Water Storage Tanks, Cask Decon Storage Tank, or the Demin Water Storage Tank.

Request:

The staff requests the applicant to provide the locations of the seismic or equivalent anchors locations on the 10 CFR 54.4(a)(2) lines attached to the Unit 1 and Unit 2 Primary Water Storage Tanks, Cask Decon Storage Tank, or the Demin Water Storage Tank.

RAI 2.3.3.17-01

Background:

License renewal drawing LRA-1 ,2-47WB15-1, coordinates B/C-10/11 and B/C-7, depicts several lines in and out of the auxiliary boilers "A" and "B" as being within the scope of license renewal for 10 CFR 54.4(a)(2).

- 17 However, the auxiliary boilers "A" and "B" are not depicted as being within the scope of license renewal. The auxiliary boilers are also not included in LRA Table 2.3.3-17-1.

Request:

The staff requests the applicant to provide the basis for excluding the auxiliary boilers from the scope of license renewal as indicated on license renewal drawing LRA-1,2-47W815-1 and LRA Table 2.3.3-17.1.

RAI 2.3.3.17-02

Background:

On the following license renewal drawings, the staff could not locate seismic or equivalent anchors on the 10 CFR 54.4(a)(2) nonsafety- related lines attached to safety-related lines:

License Renewal Drawing Number 10 CFR 54.4(a)(2) Pipe Line(s) or Identifier

& Coordinate 3" line downstream and upstream of loop seal LRA-1,2-47W815-2, coordinate C-1 2-VLV-40-536 LRA-1,2-47W815-2, coordinate C-2 8" line downstream of 16" sleeve Request:

The staff requests the applicant to provide the locations of the seismic or equivalent anchors on the 10 CFR 54.4(a)(2) nonsafety-related lines between the safety/non-safety interface and the end of the 10 CFR 54.4(a)(2) scoping boundary.

RAI 2.3.3.17-03

Background:

On license renewal drawing LRA-1,2-47W856-1, coordinates E-3 and C-3, the staff could not locate seismic and equivalent anchors on the 10 CFR 54.4(a)(2) nonsafety-related lines downstream of valves 2-59-633 and 1-59-633 and upstream of valves 2-59-522 and 1-59-522 to the Unit 1 and Unit 2 Primary Water Storage Tanks, Cask Decon Storage Tank and the Demin Water Storage Tank.

Request:

The staff requests the applicant to provide the locations of the seismic or equivalent anchors on the 10 CFR 54.4(a)(2) nonsafety-related lines downstream of valves 2-59-633 and 1-59-633 and upstream of valves 2-59-522 and 1-59-522 to the Unit 1 and Unit 2 Primary Water Storage Tanks, Cask Decon Storage Tank and the Demin Water Storage Tank.

- 18 RAI2.3.3.17-04

Background:

On license renewal drawing LRA-1 ,2-47W860-1, coordinates G/H-7/9, the staff could not locate seismic or equivalent anchors on eight 10 CFR 54.4(a)(2) nonsafety-related lines attached to ERCW valves 1-50-513,1-50-514,.1-50-517,1-50-518, 2-50-515, 2-50-516, 2-50-519, and 2 50-520.

Request:

The staff requests the applicant to provide the locations of the seismic or equivalent anchors on eight 10 CFR 54.4(a)(2) nonsafety-related lines attached to ERCW valves 1-50-513, 1-50 514,.1-50-517,1-50-518,2-50-515,2-50-516,2-50-519, and 2-50-520.

RAI2.3.3.17-05

Background:

License renewal drawing LRA-1 ,2-47W860-1, coordinate E-1 ,depicts a 1 ~" line between component 0-LG-50-1100 and the Bulk Chemical Storage Tank (0-TNK-50-1100) being within the scope of license renewal for 10 CFR 54.4(a)(2).

However, a 1 W' vent line directly attached above the 10 CFR 54.4(a)(2) 1 ~" line is not highlighted within the scope of license renewal. The staff would expect that the 1 W' vent line should have been included within scope of license renewal for 10 CFR 54.4(a)(2).

Request:

The staff requests the applicant to provide the basis for excluding the 1 W' vent line from scope of license renewal.

RAI 2.3.3.17-06

Background:

License renewal drawing LRA-1,2-47W862-2, coordinates B-3, E-3, B-9, and E-9, depicts several lines as being within the scope of license renewal for 10 CFR 54.4(a)(2).

However, these lines are attached to additional lines and components, which were not highlighted as being within the scope of license renewal. The staff could not identify the scoping boundary termination indicators on the 10 CFR 54.4(a)(2) lines at above locations.

-19 Request:

The staff requests the applicant to provide the scoping boundary termination indicators at the above locations for the 10 CFR 54.4(a)(2) lines.

RAI 2.3.3.17-07

Background:

On the following license renewal drawings, the staff could not locate seismic or equivalent anchors on the 10 CFR 54.4(a)(2) non-safety related lines attached to safety-related lines:

License Renewal Drawing Number 10 CFR 54.4(a)(2) Pipe Line(s) or Identifier

& Coordinate 3" lines upstream of Unit 1 and Unit 2 valves LRA-1 ,2-47WB19-1, coordinates C-4 FCV-B1-12 to the Primary Water Storage and F-4 Tanks LRA-1 ,2-47WB19-1, coordinates C-5 1" lines upstream of valves 2-B1-512 and 1 and 0-5 B1-512 to the Primary Water Storage Tanks Reguest:

The staff requests the applicant to provide the locations of the seismic or equivalent anchors on the 10 CFR 54.4(a)(2) nonsafety-related lines between the safety/non-safety interface and the end of the 10 CFR 54.4(a)(2) scoping boundary.

RAI2.3.4-1

Background:

LRA Section 2.1 describes the applicant's scoping methodology, which specifies how systems or components were determined to be included in scope of license renewal. The staff confirms the inclusion of all components subject to AMR by reviewing the results of the screening of components within the license renewal boundary.

For the drawing locations identified in the table below, the continuation of piping in scope for license renewal could not be located.

License Renewal Drawing Continuation Issue Number & Location Section 2.3.4.1 Main Steam LRA-1 ,2-47WB01-1, coordinate H-7 Line continuation to seat drains on drawing 47WB07-1, coordinate F-2

, -47WB01-1, coordinate H- Line continuation to drawing 47WB07-1, coordinate A-3

- 20 LRA-1 ,2-47W802-1, coordinates C- Lines within the scope of 10 CFR 54.4(a)(2) with 8 and 0-10 continuation from valves 15-113A, 15-114A, 1-887, and 15-120A to and from RE 90-120 on drawing 47W61 0-90 2, with Notes: Not a LRA drawing Section 2.3.4.2 Main and Auxiliary Feedwater Y2" line within the scope of 10 CFR 54.4(a){2) with LRA-2-47W804-1, coordinate 0-8 continuation to drawing 47W600-47-1, with Note: Not a LRA drawing.

LRA-1.2-47W803-1, coordinates K 4" and 6" lines within the scope of 10 CFR 54.4(a)(2) with 3 and H-3 continuation to the atmospheric condensate drain sump.

Y2" line within the scope of 10 CFR 54.4(a)(2) with LRA-2-47W804-1. coordinate 0-8 continuation to drawing 47W600-47-1, with Note: Not a LRA drawing LRA-1,2-47W803-1. coordinates K 4" and 6" lines within the scope of 10 CFR 54.4(a)(2) with 3 and H-3 continuation to the atmospheric condensate drain sump Section 2.3.4.3, Miscellaneous Auxiliary Systems in Scope for 10 CFR 54.4(a)(2)

Condensate Demineralizer System 1" line to Unit 2 and a %" line to Unit 1 within the scope of LRA-1,2-47W804-2. coordinates G 10 CFR 54.4(a)(2) with continuations to drawing 47W600 6 and F-6 130, with Note: Not a LRA drawing Section 2.3.4.3, Miscellaneous Auxiliary Systems in Scope for 10 CFR 54.4(a)(2)

Condensate Circulating Water System 3" lines within the scope of 10 CFR 54.4(a)(2) from the LRA-1 ,2-47W834-1, coordinate H-8 treatment plant sump pumps, with continuation to drawing 47E871-6. with Note: Not a LRA drawing Section 2.3.4.3, Miscellaneous Auxiliary Systems in Scope for 10 CFR 54.4(a)(2)

Heater Drains and Vents System LRA-1,2-47W805-1, coordinates H 2" line to waste drain pans located at coordinates H-3, H

1. F-1, and E-1 5. F-3, F-S, E-3 and E-S 8" line drain pans located at coordinates 8-3, 8-6, 8-9, C LRA-1,2-47W80S-2, coordinate A-3 2, C-4, C-7, E-2, E-4, E-7, F-2, F-4, and F-7 Section 2.3.4.3, Miscellaneous Auxiliary Systems in Scope for 10 CFR 54.4(a)(2)

Steam Generator Blowdown System 1" lines (from SG drain down flash tank and to condenser)

LRA-1.2-47W801-2, coordinates C- that are within the scope of 10 CFR S4.4(a)(2) and are 7 and 0-10 continued on drawing 47W61 0-90-2, with Note: Not a LRA

  • drawing Request:

The staff requests the applicant to provide sufficient information to locate the license renewal boundary. If the continuation cannot be shown on license renewal drawings, then provide additional information describing the extent of the scoping boundary and verify whether or not there are additional component types subject to AMR between the continuation and the termination of the scoping boundary. If the scoping classification of a section of the piping

- 21 changes over the continuation, provide additional information to explain the change in scoping classification.

RAI 2.3.4.1-01

Background:

On license renewal drawing LRA-1 ,2-47W801-2, coordinate A-6, the staff could not locate seismic or equivalent anchors on the 10 CFR 54.4(a)(2) nonsafety-related 4" line to the station sump.

Request:

The staff requests the applicant to provide the locations of the seismic or equivalent anchors on the 4" line, which is attached to the station sump.

RAI 2.3.4.2-01

Background:

On the following license renewal drawings, the staff could not locate seismic or equivalent anchors on the 10 CFR 54.4(a)(2) nonsafety-related lines attached to safety-related lines:

License Renewal Drawing Number 10 CFR 54.4(a)(2) Pipe Line(s) or Identifier

& Coordinate 18" line upstream of valve TW 3-104 and 8" LRA-1 ,2-47W803-1, coordinate B-3 line downstream of valve FCV 3-194 8" line upstream of valve TW 3-36 and 6" line LRA-1,2-47W803-1, coordinate C-3 wnstream of valve FCV 3-191 8" line upstream of valve TW 3-49 and 8" line LRA-1 ,2-47W803-1, coordinate E-3 ownstream of valve FCV 3-192 18" line upstream of valve TW 3-91 and 8" line LRA-1 ,2-47W803-1, coordinate F-3 downstream of valve FCV 3-193 Request:

The staff requests the applicant to provide the locations of the seismic or equivalent anchors on the 10 CFR 54.4(a)(2) nonsafety-related lines between the safety/non-safety interface and the end of the 10 CFR 54.4(a)(2) scoping boundary.

RAI 2.3.4.2-02

Background:

License renewal drawing LRA-2-47W804-1 depicts several lines in and out of the condensers, pumps and feed water heaters as being within the scope of license renewal for 10 CFR 54.4(a)(2).

- 22 However, the 10" line between valves TW 2-329A and 2-742. at coordinates A-5/6. is depicted as not being within the scope of license renewal. The staff would expect that the 10" line would also be included within the scope of license renewal for 10 CFR 54.4(a)(2).

Request:

The staff requests the applicant to provide the basis for excluding the 10" line between valves TW 2-329A and 2-742 from scope of license renewal.

RAI 2.3.4.3-01

Background:

License renewal drawing LRA-1.2-47W804-2, coordinates G-2. G-3 and G-4, depicts W' lines attached to the condensate demineralizer pumps labeled "A", "B", and "C" as being within the scope of license reneWal for 10 CFR 54.4(a)(2).

However, the associated tank components (also labeled "A", "B", and "C") attached to these W' lines were not highlighted within the scope of license renewal. The staff would expect that the attached tank components should have also been included within the scope of license renewal for 10 CFR 54.4(a)(2).

Reguest:

The staff requests the applicant to provide the basis for excluding the tank components attached to the W' lines from the scope of license renewal.

RAI 2.3.4.3-02

Background:

License renewal drawing LRA-1 ,2-47W831-1, coordinates B-6, C-6, D-6, E-6, F-6 and G-6, depicts condenser circulating water pump casings "1A", "'IB", "1C", "2A", "2B", and "2C" as not being within the scope of license renewal for 10 CFR 54.4(a)(2).

However, LRA Table 2.3.4-3-9 lists pump casings as being subject to an AMR with the intended function for pressure boundary.

Request:

The staff requests the applicant to provide the basis for not including the pump casings within the scope of license renewal.

- 23 RAI 2.3.4.3-03

Background:

License renewal drawing LRA-1 ,2-47W831-1, depicts the lines in and out of the condenser circulating water pumps as being within the scope of license renewal for 10 CFR 54.4(a)(2).

The staff could not identify the scoping boundary termination indicators on the 10 CFR 54.4(a)(2) lines at the following locations:

License Renewal Drawing Number & 10 CFR 54.4(a)(2) Pipe Line(s) or Coordinate Identifier LRA-1,2-47W831-1, coordinates B to G All lines between condenser circulating 7/8 water pumps and intake channel All 84" lines from condenser circulating LRA-1,2-47W831-1, coordinates C to G water pumps to Unit 1 and Unit 2 3/4 condensers I Request:

The staff requests the applicant to provide the scoping boundary termination indicators at the above locations for the 10 CFR 54.4(a)(2) lines.

RAI 2.3.4.3-04

Background:

License renewal drawing LRA-1 ,2-47W831-1-1, depicts various lines within the scope of license renewal for 10 CFR 54.4(a)(2). However. the license renewal boundaries of these lines, at coordinates B-3, B-9, C-9, D-7. E-7. F-7 and G-7, are depicted to end at valves 676, FCV27-61, FCV27-50, FCV27-79, FCV27-70, FCV27-100. and FCV27-91. respectively.

The staff could not identify the scoping boundary termination indicators for the 10 CFR 54.4(a)(2) lines at the valve locations.

Request:

The staff requests the applicant to provide the scoping boundary termination indicators at the above valve locations for the 10 CFR 54.4(a)(2) lines.

- 24 RAI 2.3.4.3-5

Background:

License renewal drawings LRA-1-47W857-1 and LRA-2-47W857-1, coordinates G-1/2, G-3, G 5, G-6, G-8, G-10, B-1I2, B-3, B-5, B-6, B-8 and B-10, depict condenser circulating water strainer housings "1A3", "1A4", "1B3", "1B4", "1C3", "1C4", "1A1", "1A2", "1B1", "1B2", "1C1",

"1C2", "2A3", "2A4", "2B3", "2B4", "2C3", "2C4", "2A1", "2A2", "2B1", "2B2", "2C1" and "2C2" as not being within the scope of license renewal for 10 CFR 54.4(a)(2).

LRA Table 2.3.4-3-9 lists the strainer housings component types as being subject to an AMR with the intended function of pressure boundary.

Request:

The staff requests the applicant to provide the basis for not including the strainer housing within the scope of license renewal.

RAJ 2.3.4.3-6

Background:

License renewal drawings LRA-1 , 4 7W807 -1 and LRA-2, 47W807 -1, coordinates F/G-10, depict several lines out of the gland steam condenser as being within the scope of license renewal for 10 CFR 54.4(a)(2). However, the scoping boundaries of these lines are depicted to end at valves VLV-047-0209A and VLV-047-0209B. Additionally, the fans and vent lines attached to the valves are also not depicted as not being within the scope of license renewal.

The staff could not identify the scoping boundary termination indicators for the 10 CFR 54.4(a)(2) lines at the valves VLV-047-0209A and VLV-047-0209B.

Request:

The staff requests the applicant to provide the scoping boundary termination indicators at valves VLV-047 -0209A and VLV-047 -0209B and also indicate if the attached fans and vent lines are within the scope of license renewal.

RAJ 3.3.2.17-17-1

Background

In LRA Table 3.3.2-17-17, "Sampling and Water Quality System Nonsafety-Related Components Affecting Safety-Related Systems Summary of Aging Management Evaluation,"

there is an aging management review (AMR) entry for a nickel alloy heat exchanger shell

- 25 internally exposed to "treated water," for which the applicant proposes to manage loss of material using the Water Chemistry Control - Primary and Secondary program. The applicant has cited generic note G, indicating that the environment is not in the GALL Report for this component and material.

The heat exchangers, for which this AMR entry applies, are shown on LRA drawings 1-47W881 1 and 2-47W881-1. These drawings indicate that the shell side of the heat exchangers is internally exposed to water from the "raw cooling water system."

Based on the information in LRA Table 3.3.2-17-17 and LRA drawings 1-47W881-1 and 2 47W881-1, it appears that the AMR entry for the nickel alloy heat exchanger shell is incorrect since cooling water, which is on the shell side, is from the raw cooling water system (system 024). LRA Table 3.0-1, "Service Environments for Mechanical Aging Management Reviews,"

defines "treated water," as demineralized water and is the base water for all clean systems, and lists potable raw water as a corresponding environment in the GALL Report. However, Section 9.2.7 of the Sequoyah UFSAR states that the source of the raw cooling water is river water via the condenser circulating water intake conduits.

Request Verify that the internal environment of the nickel alloy heat exchanger shell is considered to be "treated water," that is chemically treated by the Water Chemistry Control- Primary and Secondary program. If this is not the case and the environment is different, provide a correct LRA table entry for the nickel alloy heat exchanger shell, identifying the appropriate aging management program.

SUBJECT:

REQUESTS FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE SEQUOYAH NUCLEAR PLANT, UNITS 1 AND 2, LICENSE RENEWAL APPLICATION (TAC NOS. MF0481 AND MF0482) - SET 9.

DISTRIBUTION:

HARDCOPY:

DLRRF E-MAIL:

PUBLIC RidsNrrDlr Resource RidsNrrDlrRpb1 Resource RidsNrrDlrRpb2 Resource RidsNrrDlrRerb Resource RidsNrrDlrRarb Resource RidsNrrDlrRasb Resource beth.mizuno@nrc.gov brian.harris@nrc.gov john. pelchat@nrc.gov gena.woodruff@nrc.gov siva.lingam@nrc.gov wesley.deschaine@nrc.gov galen.smith@nrc.gov scott.shaeffer@nrc.gov jeffrey. ham man@nrc.gov craig.kontz@nrc.gov caudle.julian@nrc.gov generette.lloyd@epa.gov gmadkins@tva.gov clwilson@tva.gov hleeO@tva.gov dllundy@tva.gov