NG-09-0643, Response to Request for Additional Information Regarding Sections 2.2 and 2.3 of the Duane Arnold Energy Center License Renewal Application

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Response to Request for Additional Information Regarding Sections 2.2 and 2.3 of the Duane Arnold Energy Center License Renewal Application
ML092510454
Person / Time
Site: Duane Arnold NextEra Energy icon.png
Issue date: 09/03/2009
From: Costanzo C
NextEra Energy Duane Arnold
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
NG-09-0643, TAC MD9769
Download: ML092510454 (42)
v • d • e


Text

NExTera ENERGY DUANE ARNOLD September 3, 2009 NG-09-0643 10 CFR 54 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Duane Arnold Energy Center Docket 50-331 License No. DPR-49 Response to Request for Additional Information Regarding Sections 2.2 and 2.3 of the Duane Arnold Energy Center License Renewal Application

References:

1. Letter, Richard L. Anderson (FPL Energy Duane Arnold, LLC) to Document Control Desk (USNRC), "Duane Arnold Energy Center Application for Renewed Operating License (TSCR-109)," dated September 30, 2008, NG-08-0713 (ML082980481)
2. Letter, Richard L. Anderson (FPL Energy Duane Arnold, LLC) to Document Control Desk (USNRC), "License Renewal Application, Supplement 1: Changes Resulting from issues Raised in the Review Status of the License Renewal Application for the Duane Arnold Energy Center," dated January 23, 2009, NG-09-0059 (ML090280418)
3. Letter, Maurice L. Heath (USNRC) to Richard L. Anderson (FPL Energy Duane Arnold, LLC), "Request for Additional Information for the Review of the Duane Arnold Energy Center License Renewal Application - Section 2.2 and 2.3 (TAC No. MD9769)," dated August 7, 2009 (ML092080414)

By Reference 1, FPL Energy Duane Arnold, LLC submitted an application for a renewed Operating License (LRA) for the Duane Arnold Energy Center. Reference 2 provided Supplement 1 to the application. By Reference 3 the U.S. Nuclear Regulatory Commission (NRC) Staff requested additional information regarding Sections 2.2 and 2.3 of the LRA.

The enclosure to this letter contains the NextEra Energy Duane Arnold, LLC, (f/k/a FPL Energy Duane Arnold, LLC) responses to the Staff's requests for additional information.

This letter contains no new commitments or changes to existing commitments.

4Z5"7 NextEra Energy Duane Arnold, LLC, 3277 DAEC Road, Palo, IA 52324

Document Control Desk NG-09-0643 Page 2 If you have any questions or require additional information, please contact Mr. Kenneth Putnam at (319) 851-7238.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on September 3, 2009.

Christopher R. Costanzo Vice President, Duane Arnold Energy Center NextEra Energy Duane Arnold, LLC

Enclosure:

DAEC Response to NRC Requests for Additional Information Regarding LRA Sections 2.2 and 2.3 cc: Administrator, Region III, USNRC Project Manager, DAEC, USNRC Senior Resident Inspector, DAEC, USNRC License Renewal Project Manager, USNRC License Renewal Inspection Team Lead, Region Ill, USNRC M. Rasmusson (State of Iowa)

NextEra Energy Duane Arnold, LLC, 3277 DAEC Road, Palo, IA 52324

Enclosure DAEC Response to NRC Requests for Additional Information Regarding LRA Sections 2.2 and 2.3 RAI 2.2-01

Background:

License Renewal Application (LRA) Section 2.1 states in part "Each license renewal application must then provide an Integrated Plant Assessment that fulfills the requirements of §54.21, §54.3 Definitions," defines the Integrated Plant Assessment as:

Integrated Plant Assessment (IPA) is a licensee assessment that demonstrates that a nuclear power plant facility's structures and components requiring aging management review in accordance with [10 CFR] 54.21(a) for license renewal have been identified and Issue:

The following Updated Final Safety Analysis Report (UFSAR) systems could not be located in Table 2.2-1 or Table 2.2-2.

UFSAR Section System 1.3.2.1 1.2 General Service Water System Turbine Building Cooling Water System 12.3.3.3.3 Technical Support Center Technical Support Center Radiation Radiation Monitoring System Monitoring System 9.5.8 Diesel-Generator Combustion Air Diesel-Generator Combustion Air Intake Intake and Exhaust System and Exhaust System Request:

Provide the reasoning for not including the above systems in Table 2.2-1 or Table 2.2-2.

DAEC Response to RAI 2.2-01 The Turbine Building Cooling Water System is in scope as part of the General Service Water System listed in Table 2.2-1. The Turbine Building Cooling Water System is that portion of the General Service Water System that is in the Turbine Building.

The Technical Support Center Radiation Monitoring System is part of the Technical Support Center Heating, Ventilation and Air Conditioning System listed in Table 2.2-2.

The Diesel-Generator Combustion Air Intake and Exhaust System is in scope but under two different systems. The Standby Diesel Generator Rooms Heating, Ventilation, and Air Conditioning under Plant Ventilation contains the axial fans and ductwork described in UFSAR Section 9.5.8. The Standby Diesel Generator System contains the mufflers (exhaust silencer) and associated piping. Plant Ventilation and the Standby Diesel Generator Systems are listed in Table 2.2-1.

Page 1 of 40

Enclosure DAEC Response to NRC Requests for Additional Information Regarding LRA Sections 2.2 and 2.3 RAI 2.3-01

Background:

License renewal rule 10 CFR 54.21(a) requires applicants to list all component types subject to an Aging Management Review (AMR). The staff confirms inclusion of all component types subject to an AMR by reviewing components within the license renewal boundary.

Issue:

The following identifies drawings where the staff was unable to identify the license renewal boundary because: (1) continuations were not provided or are incorrect, or (2) the continuation drawing was not provided.

LRA Section/Drawing Issue Section 2.3.3.13 BECH-M146-LR Location B-4 shows a 4"-JBD-1 line as in scope for license renewal for 10 CFR 54.4 (a)(2). The line is continued to BECH-C140 but the continuation location and drawing are not provided.

Section 2.3.3.15 BECH-M173-LR Locations C-5 and E-5 show continuations of 10 CFR 54.

4(a)(1) 2"-KBF-1 piping sections from drawing M133 (E-6).

Review of drawings BECH-M133<1, 2, 3, 4, 5>-LR could not locate the continuations to drawing BECH-M173-LR.

Location A-5 shows a continuation of a 10 CFR 54.4(a)(1) pipe section (pneumatic signal) to drawing BECH-M158-LR (C-2) (to CV5837B). Review of drawing BECH-M1 58-LR could not locate the continuation at C-2 but a possible continuation was found at location A-5.

Section 2.3.3.22 BECH-M116-LR Location (A-5) shows a continuation of 10 CFR 54.4 (a)(2) pipe section (2"-HCC-1 33) to drawing BECH-M137-LR (C-7). Review of drawings BECH-M137<1>-LR and BECH-M137<2>-LR could not locate the continuation from BECH-M1 16-LR.

I

____________________________________________________________________________

Page 2 of 40

Enclosure DAEC Response to NRC Requests for Additional Information Regarding LRA Sections 2.2 and 2.3 Section 2.3.3.27 BECH-M158-LR Location A-6 shows a continuation of a 10 CFR 54.4 (a)(3) pipe section (3"-KBF-1 from Fire Protection System) from drawing BECH-M133<1 >-LR (D-5). Review of drawing BECH-M133<1>-LR could not locate the continuation to BECH-M158-LR.

BECH-M161-LR Location D-5 shows a continuation a pipe section (before valve V61-0116) from the same drawing, however, review of drawing BECH-M161-LR could not locate the continuation.

Location E-7 shows a continuation of a pipe section (1 1/2"-

HBD-163) from drawing BECH-M160<2>-LR. Drawing BECH-M160<2>-LR was not provided with the LRA.

Section 2.3.3.31 BECH-M106-LR Location B-5 shows continuation of the line downstream of valve V06-0194 to drawing BECH-M147 (H-6). Location H-6 does not exist on drawing BECH-M147-LR.

BECH-M147-LR Location E-1 shows continuation of the line downstream of valve V47-0117; however, no continuation location is provided.

Section 2.3.3.32 BECH-M161-LR Location B-6 shows a continuation with a notation to see Note #9. Note #9 refers to M527 which was not provided with the LRA.

Section 2.3.4.1 BECH-M136-LR Location D-4 shows line 1/2"-HCD-40 downstream of valve V36-0078 with a system boundary interface for systems 37.00 and 68.00. However, the location of the license renewal boundary cannot be determined.

Section 2.3.4.2 BECH-M103<3>-LR Location B-6 downstream of valve

  • Location B-6 downstream of valve V03-0158
  • Location B-6 downstream of valve V03-0151
  • Location B-6 downstream of valve V03-0153
  • Location B-6, downstream of valve V03-0155
  • Location A-6 downstream of valve V03-0150

" Location B-5 downstream of valve V03-0157

  • Location B-5 downstream of valve V03-0161
  • Location A-5 downstream of valve V03-0162
  • Location B-2 downstream of valve V03-0138 Page 3 of 40

Enclosure DAEC Response to NRC Requests for Additional Information Regarding LRA Sections 2.2 and 2.3 BECH-M104<2>-LR Location D-6 downstream of HP Heater 1E006A (to CV1158A)

BECH-M104<3>-LR Location D-6 downstream of valve V04-0050 BECH-M107-LR Location D-2 downstream of valve V07-0314 Location E-8 downstream of valve V07-0318 Section 2.3.4.4 BECH-M1 14-LR Location B-2 shows an in-scope line continuation TO MSIV drawing M184 (H-2). However, this continuation cannot be found on BECH-M184-LR.

Request:

Provide additional information to locate the continuations described above.

DAEC Response to RAI 2.3-01 Section 2.3.3.13 BECH-M146-LR On BECH-M146-LR (B-4), BECH-C140 is a Grading, Drainage &

Detail drawing and not a license renewal drawing showing the scoping boundary. Drawing BECH-M146-LR shows the license renewal boundary. Line 4"-JBD-1 is the Service Water Automatic Strainer 1S024 backwash piping to storm drain (manhole). A license renewal drawing note should have been provided for this line to state, "LR Boundary ends as piping exits Pumphouse".

Section 2.3.3.15 BECH-M173-LR On BECH-M173-LR .(C05and E75) showing continuations of 2"-KBF-1 piping sections from drawing M133 (E-6), the continuations should list M133<3> (F-5). On BECH-M133<3>-LR (F-5), the continuations should list coordinates C-5 and E-5.

On BECH-M173-LR at location A-5 showing continuation of pipe section (pneumatic signal) to drawing M158 (C-2), the continuation should list coordinate A-5.

Section 2.3.3.22 BECH-M1 16-LR It should be noted that continuation of 2"-HCC-133 is actually %"-

HCC-133 on BECH-M116-LR (A-5). This drawing shows a continuation of pipe section 3/4"-HCC-133 to drawing M137-LR (C-7).

The continuation should list M137<1> coordinate C-8.

Section 2.3.3.27 BECH-M158-LR On BECH-M158-LR (A-6) the continuation of pipe section 3"-KBF-1 from drawing M1 33<1> is at coordinate C-2, downstream of valve V33-0088. BECH-M158 should show coordinate C-2.

Page 4 of 40

Enclosure DAEC Response to NRC Requests for Additional Information Regarding LRA Sections 2.2 and 2.3 BECH-M161-LR On BECH-M161-LR (D-5) the continuation upstream of valve V61-0116 is at coordinate A-8, downstream of V61-091.

On BECH-M161-LR the continuation of line 11/2"-HBD-163 at location E-7 from drawing M160-02 should show the continuation as M169<2>, coordinate E-4.

Section 2.3.3.31 BECH-M106-LR On BECH-M106-LR (B-5) for continuation of the line downstream of valve V06-0194 to drawing M147 (H-6), the continuation should list M147 coordinate F-6. On BECH-M147-LR (F-6) the continuation should read M106 (B-5)

BECH-M147-LR On BECH-M147-LR (E-1) downstream of V47-0117, no continuation exists. V47-0117 is the chiller drain valve with a connection for a temporary drain line.

Section 2.3.3.32 BECH-M161-LR On BECH-M161-LR, Note #9 is not a license renewal note. Note 9 on M161 refers to drawing M527 for the potable water supply connection.

A license renewal drawing note should have been provided to read, "Potable Water located in an area with safety-related equipment is in scope of LR".

Section 2.3.4.1 BECH-M136-LR BECH-M136-LR is for the Service Condensate System which is in scope for 10 CFR 54.4(a)(2). M139 is the drawing for the Floor Drain Radwaste System (Open) which is not in scope of license renewal for 10 CFR 54.4(a)(2), because it is not located near safety-related equipment. Downstream of V36-0078, a license renewal drawing note should have been provided to read, "Only the portion of piping located in the Reactor Building is in scope of LR".

Section 2.3.4.2 BECH-M103<3>-LR On BECH-M103<3>-LR, at locations downstream of valves V03-0158, V03-0151, V03-0153, V03-0155, V03-0150, V03-0157, V03-0161, V03-0162, and V03-0138, no continuations exist. These are vent/drain/test connections for instrumentation calibrations.

BECH-M104<2>-LR On BECH-M104<2>-LR (D-6) the continuation shown downstream of HP Heater 1E006Ato CV1158A does not exist. On BECH-M104<2>-

LR, the continuation should be deleted.

BECH-Ml 04<3>-LR On BECH-M104<3>-LR (D-6) the continuation downstream of V04-0050 should be labeled CRW.

Page 5 of 40

Enclosure DAEC Response to NRC Requests for Additional Information Regarding LRA Sections 2.2 and 2.3 BECH-M107-LR On BECH-M107-LR (D-2) downstream of V07-0313 (V07-0314), no continuations exist. V07-0313 and V07-0314 are RFP Lube Oil Reservoirs drain valves with a connection for a temporary drain line.

On BECH-M107-LR (E-8) downstream of V07-0318, no continuation exists. V07-0318 is the pressure transmitter (PT-1637) Sensing Line Vent with a connection for instrumentation calibration.

Section 2.3.4.4 BECH-M1 14-LR On BECH-M1 14-LR (B-2) the continuation to MSIV drawing M184 (H-

2) should list M184 coordinate (0-2). This line is appropriately highlighted green as being in scope for 10 CFR 54.4(a)(2).

Note that on BECH-M184-LR (C-2), Detail 1 is incorrect as drawn.

BECH-M103<1 >-LR (F-8), shows the configuration of this piping, and correctly shows that line 20"-EBD-2 and valves V03-0311 and V03-0318 are not abandoned in place and are in scope of license renewal.

RAI 2.3.3.4-01

Background:

License renewal rule 10 CFR 54.21(a)(1) requires applicants to list all components subject to an AMR. The staff confirms inclusion of all components subject to an AMR by reviewing component types within the license renewal boundary.

Issue:

License renewal drawing BECH-M142-LR (E-8) upstream of vent V42-0020, shows a component as in scope for license renewal for 10 CFR 54.4(a)(2), whereas a similar component at location E-7 upstream of vent V42-0019 is shown as not in scope for license renewal.

Request:

Provide additional information explaining why the component upstream of vent V42-0019 is not within the scope of license renewal.

DAEC Response to RAI 2.3.3.4-01 The component upstream of vent V42-0019 on drawing BECH-M142-LR (E-8) is a representation of pipe fittings associated with pipe section JBD023. It has been analyzed as being in the scope of license renewal for 10 CFR 54.4(a)(2) and is subject to aging management review. This component should have been colored green.

Page 6 of 40

Enclosure DAEC Response to NRC Requests for Additional Information Regarding LRA Sections 2.2 and 2.3 RAI 2.3.3.4-02

Background:

License renewal rule 10 CFR 54.21 (a)(1) requires applicants to list all components subject to an AMR. The staff confirms inclusion of all components subject to an AMR by reviewing component types within the license renewal boundary.

Issue:

License renewal drawing BECH-M142-LR (C-8) at component AT4254, shows flexible connections as in scope for license renewal for 10 CFR 54.4(a)(2). LRA Table 2.3.3-4 which lists components that require AMR, does not include these flexible connections.

Request:

Provide additional information explaining why flexible connectors are not included in LRA Table 2.3.3-4.

DAEC Response to RAI 2.3.3.4-02 The license renewal drawing BECH-M142-LR is incorrect in that the flexible inlet and outlet tubing for AT4254 should be colored black, indicating they are not subject to aging management review. A preventive maintenance input request has been initiated to have this tubing replaced on a 10 year frequency. This component was then screened out as not being subject to aging management review due to periodic replacement.

RAI 2.3.3.8-01

Background:

In LRA Section 2.3.3.8 portions of the Drywell Sumps are in scope based on criteria 10 CFR 54.4(a)(1) and 10 CFR 54.4(a)(2). License renewal rule 10 CFR 54.21(a) requires applicants to list all component types subject to an AMR.

Issue:

License renewal drawing BECH-M137 <1>-LR (C-6 and F-6) shows flow element venturi casings (FE3708 and FE3707) in-scope for 10 CFR 54.4(a)(2). Flow element venturi casings are not included in LRA Table 2.3.3-8 as a component type.

Page 7 of 40

Enclosure DAEC Response to NRC Requests for Additional Information Regarding LRA Sections 2.2 and 2.3 Request:

Provide additional information explaining why flow element venturi casings are not included as a component type subject to an AMR in LRA Table 2.3.3-8.

DAEC Response to RAI 2.3.3.8-01 The component type Instrumentation (Flow Element) included in LRA Table 2.3.3-8 includes the flow element casing.

RAI 2.3.3.13-01

Background:

License renewal rule 10 CFR 54.21(a)(1) requires applicants to list all components subject to an AMR. The staff confirms inclusion of all components subject to an AMR by reviewing component types within the license renewal boundary.

Issue:

License renewal drawing BECH-Mi 11-LR (E-8) upstream of radiation element RE-4767, shows a 10 CFR 54.4 (a)(2) 3" line as not in scope for license renewal. This line is directly connected to a 12"-JBD-1 1 line that is within the scope of license renewal.

Request:

Provide additional information explaining why the 3" line is not within the scope of license renewal.

DAEC Response to RAI 2.3.3.13-01 The 3" line is a mounting point for RW4767 and is not a pressure boundary. The 3" pipe is welded to the side of 12"-JBD-1 1 but does not penetrate the larger pipe. This is a standard configuration for applications of this type in the plant. Since the 3" pipe provides no pressure boundary or leakage boundary, it does not meet the requirements of 10 CFR 54.4(a)(2) and is not in scope for license renewal.

Page 8 of 40

Enclosure DAEC Response to NRC Requests for Additional Information Regarding LRA Sections 2.2 and 2.3 RAI 2.3.3.13-02

Background:

License renewal rule 10 CFR 54.21(a)(1) requires applicants to list all components subject to an AMR. The staff confirms inclusion of all components subject to an AMR by reviewing component types within the license renewal boundary.

Issue:

License renewal drawing BECH-M146-LR (A-2, A-3 and A-4) shows three service water pump casings as in scope for license renewal for 10 CFR 54.4(a)(2). The components XJ4937A, XJ4937B and XJ4937C attached to the pump casings are shown as not in scope for license renewal.

Request:

" Provide additional information explaining the function and component type for XJ4937A, XJ4937B and XJ4937C.

  • Provide additional information explaining why these components are not within the scope of license renewal.

DAEC Response to RAI 2.3.3.13-02 XJ4937A, XJ4937B, and XJ4937C are expansion joints on the discharge of the General Service Water pumps, constructed of an elastomer material and having the function of leakage boundary. XJ4937A, XJ4937B, and XJ4937C are in scope for license renewal; however, they screen out as not being subject to aging management review (AMR) since they are periodically replaced. Components which are periodically replaced are not subject to AMR per 10 CFR 54.21 (a)(1)(ii). Therefore, the license renewal drawing appropriately has these components colored black, indicating the components are not subject to aging management review.

RAI 2.3.3.14-01

Background:

LRA Section 2.3.3-14, Hydrogen Water Chemistry System, states that components are within the scope of license renewal for 10 CFR 54.4(a)(2) because the system includes nonsafety-related structures, systems and components (SSC) whose failure could prevent satisfactory accomplishment of a safety-related function due to spatial proximity. Portions of the system are also within scope of license renewal for 10 CFR 54.4(a)(3) because the system contains components credited in the current licensing basis for Fire Protection (10 CFR 50.48).

Page 9 of 40

Enclosure DAEC Response to NRC Requests for Additional Information Regarding LRA Sections 2.2 and 2.3 Issue:

License renewal drawing BECH- M189<2>-LR (A-3), shows a line from a compressed oxygen bottle penetrating the oxygenated water tank. The water tank is shown within the scope of license renewal per 10 CFR 54.4(a)(2); however, the line from the oxygen bottle is not.

Request:

Provide additional information explaining why the oxygen line and associated penetration are not within the scope of license renewal for 10 CFR 54.4(a)(2).

DAEC Response to RAI 2.3.3.14-01 The oxygen line and oxygenated water tank are part of 10C502 which is a test panel constructed for hydrogen water chemistry. The oxygen bottle is isolated by an instrument valve which is not shown on the drawing. This stainless steel tubing from the oxygenated water tank up to and including the valve at the oxygen bottle is in scope and subject to an AMR and should be colored green.

RAI 2.3.3.14-02

Background:

LRA Section 2.3.3-14, Hydrogen Water Chemistry System, states that components are within the scope of license renewal for 10 CFR 54.4(a)(2) because the system includes nonsafety-related SSCs whose failure could prevent satisfactory accomplishment of a safety related function due to spatial proximity. Portions of the system are also within scope of license renewal for 10 CFR 54.4(a)(3) because the system contains components credited in the current licensing basis for Fire Protection (10 CFR 50.48).

Issue:

License renewal drawing BECH-M189<1>ILR (E-2 and F-2) shows 1/2" lines, CCD-2, and the associated check valves V89-0052 and V89-0049 within the scope of license renewal for 10 CFR 54.4(a)(2). The license renewal boundary is shown to be at the check valves. The continuation of the CCD-2 lines upstream of the check valves are shown as not within the scope of license renewal.

Request:

Provide additional information explaining why the continuations of the 11/2"-CCD-2 lines upstream of check valves V89-0052 and V89-0049 are not within the scope of license Page 10 of 40

Enclosure DAEC Response to NRC Requests for Additional Information Regarding LRA Sections 2.2 and 2.3 renewal.

DAEC Response to RAI 2.3.3.14-02 Check valves V89-0049 and V89-0052 provide the boundary between feedwater pressure at the suction of the feedwater pumps and hydrogen gas pressure from the Hydrogen Water Chemistry System. The 1/2"-CCD-2 piping upstream of these check valves is gas filled and not in scope for License Renewal, because it is not safety related, nor does it support a regulated event and it has no potential to leak or spray and affect safety related components.

RAI 2.3.3.15-01

Background:

LRA Section 2.3.3.15, Instrument Air System, states that components are within the scope of license renewal for 10 CFR 54.4(a)(1) and 10 CFR 54.4(a)(2) and have intended functions of providing a pressure and leakage boundary.

Issue:

License renewal drawing BECH-M173-LR (B-7) shows valve SV7334B as not in-scope.

A similar valve SV7333B is in scope.

Request:

Provide additional information explaining why valve SV7334B is not scope or confirm the staff located continuation is correct.

DAEC Response to RAI 2.3.3.15-01 On BECH-M173-LR (B-7), valve SV7334B is in the scope of license renewal and subject to an AMR and should be colored red on the drawing.

RAI 2.3.3.16-01

Background:

In LRA Section 2.3.3.8 portions of the Intake and Traveling Screens are in-scope based on criteria 10 CFR 54.4(a)(1), 10 CFR 54.4(a)(2) and 10 CFR 54.4(a)(3). License renewal rule 10 CFR 54.21(a) requires applicants to list all component types subject to an AMR.

Page 11 of 40

Enclosure DAEC Response to NRC Requests for Additional Information Regarding LRA Sections 2.2 and 2.3 Issue:

License renewal drawing BECH-M129-LR (D-2 and D-8) shows strainers (1S-1 85A & B) in-scope for 10 CFR 54.4(a)(2). Strainers are not included in the list of component types in LRA Table 2.3.3-16.

Request:

Provide additional information explaining why strainers are not included as a component type subject to an AMR in LRA Table 2.3.3-16.

DAEC Response to RAI 2.3.3.16-01 The filter numbers 1S-1 85A & B in the issue description should be 1S-85A and 1S-85B.

The DAEC component database uses a component category "filter" for all strainers contained within the database. This database terminology was carried through to the license renewal scoping and screening reports, aging management reports, and the LRA tables. The component type "filter" in LRA Table 2.3.3-16 includes the intake traveling screen wash pump suction strainers shown on BECH-M129-LR as 1S-85A and 1S-85B.

RAI 2.3.3.17-01

Background:

The OE System is within the scope of license renewal based on the criteria of 10 CFR 54.4(a)(1). Portions are in scope as nonsafety-related affecting safety-related components for spatial interaction based on the criteria of 10 CFR 54.4(a)(2).

Issue:

License renewal drawing BECH-M105<1>-LR (F-6) shows a section of piping (3"-EBD-

5) continued to drawing BECH-149-LR (C-8). LR note 2 states that "a portion of this pipe runs through a room(s) that contains safety-related components and would be in scope for license renewal". However, review of drawing BECH-149-LR (C-8) found that the continuation (3"-EBD5) is not included in scope of license renewal.

Request:

Provide additional information explaining why the continuation on BECH-149-LR (C-8) is not within the scope of license renewal.

Page 12 of 40

Enclosure DAEC Response to NRC Requests for Additional Information Regarding LRA Sections 2.2 and 2.3 DAEC Response to RAI 2.3.3.17-01 BECH-M149-LR should have a portion of line 3"-EBD-5 shown green with a note similar to LR Note 2 on BECH-M105-<1>-LR. That portion of 3"-EBD-5 which passes through the room containing safety related components is in scope for License Renewal.

RAI 2.3.3.21-01

Background:

LRA Section 2.3.3-6, Reactor Building and Radwaste Building Sampling System, states that components are within the scope of license renewal per 10 CFR 54.4(a)(2). The system includes nonsafety-related SSCs whose failure could prevent satisfactory accomplishment of a safety-related function due to spatial proximity.

Issue:

License renewal drawing BECH-M138<1>-LR (D-7), shows the discharge line from waste collector pump IP065 to valve V38-0021 as within the scope of license renewal per 10 CFR 54.4(a)(2); however, the 3/4 inch line, HBC-30 to sample station SC 3805, attached to the discharge line is not in-scope for license renewal.

Request:

Provide additional information explaining why the %"-HBC-30 line is not within the scope of license renewal for 10 CFR 54.4(a)(2).

DAEC Response to RAI B2.3.3.21-01 Line %"-HBC-30 provides sample flow to the sample station in the Radwaste Building.

The portion of %"-HBC-30 on BECH-M138<1>-LR on the Reactor Building side of the system boundary should have been colored green with a note stating the portion of the pipe in the Reactor Building is in the scope of license renewal and subject to aging management review for 10 CFR 54.4(a)(2). The portion below the system boundary in the Radwaste Building is appropriately colored black.

RAI 2.3.3.22-01

Background:

License renewal rule 10 CFR 54.21(a) requires applicants to list all component types subject to an AMR. The staff confirms inclusion of all component types subject to an AMR by reviewing components within the license renewal boundary.

Page 13 of 40

Enclosure DAEC Response to NRC Requests for Additional Information Regarding LRA Sections 2.2 and 2.3 Issue:

License renewal drawing BECH-M147-LR (B-2) shows a continuation of a 10 CFR 54.4 (a)(2) pipe section (to CRW) to drawing BECH-M137<1>-LR (B-3). The continuation on drawing BECH-M137<1>-LR (B-3) is not included in the scope of license renewal.

Request:

Provide additional information to clarify the scoping classification for this pipe section.

DAEC Response to RAI 2.3.3.22-01 On drawing BECH-M147-LR, Coordinate B-2, the continuation arrow labeled BECH-M1 37<1> (B-3) CRW should be black. The piping represented by this continuation arrow is not in scope of license renewal for 10 CFR 54.4(a)(2) because it is located in a room that contains no safety-related equipment. A note should have been placed on BECH-M147-LR explaining that the piping colored green up to the continuation arrow is in the turbine building and in scope, and that the arrow depicts piping that is located in a different room that contains no safety-related equipment and is not in scope and does not require an AMR.

RAI 2.3.3.25-01

Background:

License renewal rule 10 CFR 54.21(a)(1) requires applicants to list all components subject to an AMR. The staff confirms inclusion of all components subject to an AMR by reviewing component types within the license renewal boundary.

Issue:

License renewal drawing BECH-M119-LR (B-3 and B-4) and drawing BECH-M120-LR (B-6) show the 12"-GBB-6, 12"-GBB-8, 12"-GBB-7, and 12"-GBB-9 lines as in-scope for license renewal for 10 CFR 54.4 (a)(1) whereas the continuations of these lines on license renewal drawing BECH-M 113-LR (E-6 and E-7), are shown as out of scope.

Request:

Provide additional information explaining the difference in-scope classification between drawings BECH-M119-LR, BECH-M120-LR and the continuations on BECH-M113-LR.

Page 14 of 40

Enclosure DAEC Response to NRC Requests for Additional Information Regarding LRA Sections 2.2 and 2.3 DAEC Response to RAI 2.3.3.25-01 The 12"-GBB-6, 12"-GBB-8, 12"-GBB-7 and 12"-GBB-9 line depictions on drawing BECH-M113-LR are shown in a dotted line configuration to show their relationship to the RHR Service Water Heat Exchangers. The continuations of the actual lines are shown on the Residual Heat Removal drawings BECH-M119-LR and BECH-M120-LR.

However, it had been the convention of the DAEC license renewal drawings to color code these dotted "relational" piping depictions with the same color as the actual piping lines that are shown on other license renewal drawings. The 12"-GBB-6, 12"-GBB-8, 12"-GBB-7 and 12"-GBB-9 lines depicted on drawing BECH-M113-LR should have been colored red to indicate they are in scope and subject to license renewal aging management review for 10 CFR 54.4(a)(1).

RAI 2.3.3.25-02

Background:

LRA Section 2.3.3.25, Residual Heat Removal (RHR) Service Water System, states that components are within the scope of license renewal for 10 CFR 54.4(a)(1), 10 CFR 54.4(a)(2) and 10 CFR 54.4(a)(3) and have intended functions of providing a pressure boundary, leakage boundary, pressure relief and structural integrity.

Issue:

License renewal drawing BECH-M 13-LR (B-5 and B-6), shows a change of scope classification from 10 CFR 54.4 (a)(1) to 10 CFR 54.4 (a)(2) at valves V13-0074 and V1 3-0076 whereas the corresponding seismic class I break is shown at valves V13-0073 and V1 3-0075, respectively.

Request:

Provide additional information explaining why seismic class I pipe is in-scope for 10 CFR 54.4(a)(2) versus 10 CFR 54.4(a)(1).

DAEC Response to RAI 2.3.3.25-02 V1 3-0073 and V1 3-0075 are non safety related outboard drain valves located downstream of normally closed safety related valves V1 3-0074 and V1 3-0076. These outboard drain valves are shown with seismic breaks because they are included in the seismic analysis. Bechtel constructed the plant drain valves with double isolation valves. Per the applicable piping specifications, double valving is required on nuclear systems with 600 psig ratings and above. RHR Service Water pressure at these valve locations is well below 600 psig; therefore only one isolation valve for these drain lines is necessary. Conservatively, the seismic analysis is carried out to the second isolation Page 15 of 40

Enclosure DAEC Response to NRC Requests for Additional Information Regarding LRA Sections 2.2 and 2.3 valve. Therefore, the piping downstream of V1 3-0074 and V1 3-0076 is not safety related; however, it is attached to safety related components and is colored green to indicate that it is in scope and subject to aging management review for 10 CFR 54.4 (a)(2).

RAI 2.3.3.25-03

Background:

LRA Section 2.3.3.25, RHR Service Water System, states that components are within the scope of license renewal for 10 CFR 54.4(a)(1), 10 CFR 54.4(a)(2) and 10 CFR 54.4(a)(3) and have intended functions of providing a pressure boundary, leakage boundary, pressure relief and structural integrity.

Issue:

License renewal drawing BECH-Mi 13-LR (C-5 and C-6) shows lines 16"-GBC-3 and 16"-GBC-4 as in-scope for 10 CFR 54.4 (a)(1). Two thermal elements TE1945F and TE1 945B are connected to 16"-GBC-3 and 16"-GBC-4 respectively and the connecting lines are shown as out of scope.

Request:

Provide additional information explaining why the lines to the thermal elements are not in-scope.

DAEC Response to RAI 2.3.3.25-03 Thermal elements TE1945F and TE1945B are installed in thermowells that are part of the 16"-GBC-3 and 16"-GBC-4 pipes. There is no actual pipe from 16"-GBC-3 and 16"-

GBC-4 and their respective temperature elements. The lines on drawing BECH-M1 16-LR that extend from TE1 945F and TE1 945B do not represent piping and therefore the lines were not colored. The thermowells for TE1 945F and TE1 945B are not explicitly depicted on BECH-M1 13-LR, but are addressed in LRA Table 2.3.2-5 as Piping.

RAI 2.3.3.26-01

Background:

LRA Section 2.3.3.26, River Water System, states that components are within the scope of license renewal for 10 CFR 54.4(a)(1), 10 CFR 54.4(a)(2) and 10 CFR 54.4(a)(3) and have intended functions of providing a pressure boundary, leakage boundary, throttle, and structural integrity.

Page 16 of 40

Enclosure DAEC Response to NRC Requests for Additional Information Regarding LRA Sections 2.2 and 2.3 Issue:

LRA drawing BECH- M146-LR (E-6), upstream of valves V46-0045 and V46-0046 depict two functional seismic class I breaks. These functional seismic class I breaks are located on the 10 CFR 54.4(a)(2) portion of the air vents.

Request:

Provide additional information to explain not including the portions of the air vent and piping downstream of the functional seismic class I break as in-scope for 10 CFR 54.4(a)(1).

DAEC Response to RAI 2.3.3.26-01 AV4916 and AV4917 are non safety related vents located downstream of normally closed safety related valves V46-0045 and V46-0046. These vents are shown with seismic class 1 breaks because they are included in the seismic analysis. There is no piping downstream of these vents.

RAI 2.3.3.26-02

Background:

LRA Section 2.1.2.2.2b., Nonsafety-Related SSCs Directly Connected to Safety-Related SSCs, states in part "For nonsafety-related SSCs directly connected to safety-related SSCs, the in-scope boundary for license renewal extends into the nonsafety-related portion of the piping and supports up to and including the first equivalent anchor beyond the safety/non-safety interface."

Issue:

LRA drawing BECH-M146-LR (F-4), upstream of valve V46-0086 shows a portion of 10 CFR 54.4(a)(2) piping (2"-HBD-79) continued from the floor drain radwaste system (M-139 (D-2)) that connects to 10 CFR 54.4(a)(1) piping at valve CV4909. LR Note 2 indicates that only 2"-HBD-79 is in-scope for that portion within the pump house.

Request:

Provide confirmation that an anchor exists at the pump house boundary or provide the location of the anchor.

Page 17 of 40

Enclosure DAEC Response to NRC Requests for Additional Information Regarding LRA Sections 2.2 and 2.3 DAEC Response to RAI 2.3.3.26-02 An anchor is present on line 2"-HBD-79 just after the line enters the Pump House from below grade.

RAI 2.3.3.28-01

Background:

LRA Section 2.3.3-28, Solid Radwaste System, states that components are within the scope of license renewal per 10 CFR 54.4(a)(2). The system includes nonsafety-related SSCs whose failure could prevent satisfactory accomplishment of a safety related function due to spatial proximity.

Issue:

License renewal drawing BECH-M182-LR (A-5) shows continuation of 11/2"-HBD-60 downstream of valves V82-0113 and V82-01 11 as within the scope of license renewal per 10 CFR 54.4(a)(2). The continuation of the line from license renewal drawing BECH-M160<1> (F-2) is shown as not in scope for license renewal.

Request:

Provide additional information explaining the difference in-scope classification for the continuation of the line upstream of valves V82-0113 and V82-01 11.

DAEC Response to RAI 2.3.3.28-01 The system boundary flag on drawing BECH-M160<1>-LR (F-2) should have been placed at the underground transition marker, and the above ground sections of these lines should have been colored green. In addition, the continuation arrows for the 11/2A"-HBD-60 lines upstream of V82-0113 and V82-0111 on BECH-M182-LR (A-5) should have been green. The above ground portions of the 11/2"-HBD-60 lines located in the turbine building are in scope and subject to aging management review for 10 CFR 54.4(a)(2).

RAI 2.3.3.28-02

Background:

LRA Section 2.3.3-28, Solid Radwaste System, states that components are within the scope of license renewal per 10 CFR 54.4(a)(2). The system includes nonsafety-related Page 18 of 40

Enclosure DAEC Response to NRC Requests for Additional Information Regarding LRA Sections 2.2 and 2.3 SSCs whose failure could prevent satisfactory accomplishment of a safety related function due to spatial proximity.

Issue:

License renewal drawing BECH-M139-LR (C-3), shows 1/2"-HCD-54 as within scope of license renewal per 10 CFR 54.4(a)(2). The license renewal boundary is shown at valve V39-0053 and the continuation of the line is shown as not in scope for license renewal.

Request:

Provide additional information to explain why the 1/2"-HCD-54 line is not in scope to the Floor Drain Sample Tank.

DAEC Response to RAI 2.3.3.28-02 The line 1/2"-HCD-54 on license renewal drawing BECH-M139-LR (C-3) was incorrectly colored green; it should have been left black indicating it is not subject to aging management review. The continuation of 1/2"-HCD-54 on license renewal drawing BECH-M109-LR (E-6) is also black and not subject to license renewal aging management review. It should be noted that the continuation arrow on BECH-M109 (E-

6) is incorrectly identified as M138<1> (C-2) and should be M139 (C-3). As explained in LR note 3 on drawing BECH-M109-LR, this line originates as HCD035 and is located in the Radwaste Building in areas that do not contain safety related equipment. The boundary flag on BECH-M139-LR (C-3) at V39-0153 designates the boundary between the Solid Radwaste System and the Condensate and Demineralized Water Systems and- is not a boundary indicating components in scope and subject to aging management review.

RAI 2.3.3.28-03

Background:

LRA Section 2.3.3-28, Solid Radwaste System, states that components are within the scope of license renewal per 10 CFR 54.4(a)(2). The system includes nonsafety-related SSCs whose failure could prevent satisfactory accomplishment of a safety-related function due to spatial proximity.

Issue:

License renewal drawing BECH-M139-LR (C-2), shows 11/2"-HCD-36 as within the scope of license renewal per 10 CFR 54.4(a)(2). The license renewal boundary is shown at valve V390075 and the continuation of the line is shown as not in scope per license renewal.

Page 19 of 40

Enclosure DAEC Response to NRC Requests for Additional Information Regarding LRA Sections 2.2 and 2.3 Request:

Provide additional information to clarify the location of the license renewal boundary.

DAEC Response to RAI 2.3.3.28-03 The 11/2A"-HCD-36 service condensate continuation line on license renewal drawing BECH-M139-LR (C-2) was incorrectly colored green; it should have been left black indicating that it is not subject to aging management review. This line is.a continuation of line 11/2"-HCD-36 on license renewal drawing BECH-M136-LR that is also colored black. The 111/2"-HCD-036 line is located in areas of the Radwaste Building that do not contain any safety related equipment as explained by LR note 6 on BECH-M136-LR.

The boundary flag at V39-0075 designates the system boundary between the Solid Radwaste System and the Condensate and Demineralized Water System, and does not signify a boundary indicating components in scope and subject to aging management review.

RAI 2.3.3.29-01

Background:

In LRA Section 2.3.3.29 portions of the Standby Diesel Generator System are in-scope based on criteria 10 CFR 54.4(a)(1) and 10 CFR 54.4(a)(2). License renewal rule 10 CFR 54.21(a) requires applicants to list all component types subject to an AMR. The

-staff confirms inclusion of all component types subject to an AMR by reviewing components within the license renewal boundary.

Issue:

License renewal drawing BECH-M132<1>-LR shows the following components that are in-scope for license renewal based on 10 CFR 54.4(a)(1) or (a)(2) and are not included in the list of AMR components in LRA Table 2.3.3-29:

  • exhaust silencers at locations C-7 and E-7
  • vent and flame arrestors at locations C-4, E-4, and A-3
  • combustion air filter-silencer at locations B-5 and E-5 Request:

Provide additional information explaining why the exhaust silencers, vent and flame arrestors, combustion air filter-silencers, and fuel injector housings are not included as component types in LRA Table 2.3.3-29.

Page 20 of 40

Enclosure DAEC Response to NRC Requests for Additional Information Regarding LRA Sections 2.2 and 2.3 DAEC Response to RAI 2.3.3.29-01 Exhaust silencers 1S003A and 1S003B are in scope and subject to aging management review, and are included in the component type Piping in LRA Table 2.3.3-29.

Vent and flame arrestors for 1T-35, 1T-37A (1S005A), and 1T-37B (1S005B) are in scope and subject to aging management review, and are included in the component type Piping in LRA Table 2.3.3-29.

Combustion air filter-silencers 1F031A and 1F031 B are in scope and subject to aging management review, and are included in the component type Filter in LRA Table 2.3.3-29.

RAI 2.3.3.29-02

Background:

In LRA Section 2.3.3.29 major portions of the Standby Diesel Generator System are in scope based on criteria 10 CFR 54.4(a)(1). The diesel generator equipment boundary is normally shown in red because it is in scope for 10 CFR 54.4(a)(1).

Issue:

License renewal drawing BECH-M132<1>-LR (C-6 and E-6) shows a black boundary (not in scope for license renewal)for the standby diesel generators in lieu of red (in scope for license-renewal based on criteria 10 CFR 54.4(a)(1)). Drawing-LR legend note for 10 CFR 54.4(a)(1) or (a)(3) components states "Components in scope per 10 CFR 54.4(a)(1) and/or (a)(3) and subject to AMR per 54.21 ." The drawing does not provide indication that the diesel generators are in scope for 10 CFR 54.4(a)(1).

Request:

Provide additional information to confirm that the standby diesel generators are in scope for 10 CFR 54.4(a)(1).

DAEC Response to RAI 2.3.3.29-02 The Standby Diesel Generators are in scope for License Renewal but screen out as active per 10 CFR 54.21 and NEI 95-10, Appendix B. Therefore, they are not subject to aging management review and are appropriately colored black.

Page 21 of 40

Enclosure DAEC Response to NRC Requests for Additional Information Regarding LRA Sections 2.2 and 2.3 RAI 2.3.3.29-03

Background:

In LRA Section 2.3.3.29 portions of the Standby Diesel Generator System are in-scope based on criteria 10 CFR 54.4(a)(1) and 10 CFR 54.4(a)(2). License renewal rule 10 CFR 54.21(a) requires applicants to list all component types subject to an AMR. The staff confirms inclusion of all component types subject to an AMR by reviewing components within the license renewal boundary.

Issue:

The staff typically finds the fuel injector housing and the turbo-charger housing identified in license renewal drawings and included in the table listing component types subject to AMR. The staff finds no reference to either the fuel injector housing or the turbo-charger housing in either the license renewal drawings or the table listing component types subject to AMR.

Request:

Provide additional information explaining why the fuel injector housing and the turbo-charger housing are not included in either the license renewal drawings or the table listing component types subject to AMR.

DAEC Response to RAI 2.3.3.29-03 The fuel injector housings and turbo-charger housings areconsidered part of the active diesel engines and are not subject to aging management review per 10 CFR 54.21 and NEI 95-10, Appendix B.

RAI 2.3.3.32-01

Background:

LRA Section 2.3.3.32, Well Water System, states that components are within the scope of license renewal for 10 CFR 54.4(a)(2) and have an intended function of leakage boundary.

Issue:

License renewal drawing BECH-M142-LR (B-3) shows a 2"-JBD-59 pipe line as out of-scope for license renewal. However, the continuation of this 2" line to M146 (E-3) is in-scope for 10 CFR 54.4(a)(2). Also the continuation from BECH M-144<01> (D-2) is in scope for 10 CFR 54.4(a)(2).

Page 22 of 40

Enclosure DAEC Response to NRC Requests for Additional Information Regarding LRA Sections 2.2 and 2.3 Request:

Provide additional information to clarify why this pipe section is not in scope.

DAEC Response to RAI 2.3.3.32-01 The 2"-JBD-59 pipe section on BECH-M142-LR should be colored green as it is in scope and subject to aging management review for 10 CFR 54.4(a)(2). In addition, valves V42-0098 and V42-01 00 are in scope and subject to aging management review for 10 CFR 54.4(a)(2), and should have been colored green on BECH-M142-LR.

RAI 2.3.3.32-02

Background:

LRA Section 2.1.2.2.2b., Nonsafety-Related SSCs Directly Connected to Safety-Related SSCs, states in part "For nonsafety-related SSCs directly connected to safety-related SSCs, the in-scope boundary for license renewal extends into the nonsafety-related portion of the piping and supports up to and including the first equivalent anchor beyond the safety/non-safety interface."

Issue:

License renewal drawing BECH-M113-LR (A8) shows a 10 CFR 54.4(a)(2) line (8"-JBD-

34) connected to a 10CFR 54.4(a)(1) line,(8"-HBD-32) at valve V13-0014. Thelocation of the anchor for the nonsafety-related SSCs directly connected to safety-related SSCs could not be located.

Request:

Provide additional information to locate the anchor.

DAEC Response to RAI 2.3.3.32-02 The seismic analysis break symbols are shown on drawing BECH-M144<1>-LR for pipe 8"-JBD-34 before this pipe continues on drawing BECH-M1 13-LR. A seismic anchor is located on 8"-JBD-34 just upstream of its connection with 4"-JBD-28. Additional equivalent seismic anchors are provided by 8"-JBD-34 connections to the Offgas Closed Cooling Heat Exchangers, 1E070A and 1E070B, which are substantial equipment. These heat exchangers are shown on BECH-M149-LR. Therefore, because they provide seismic anchorage, the shells of heat exchangers 1E070A and 1E070B, as well as valves V49-0060, M04159B, and M04160B and interconnecting piping on BECH-M149-LR; and valves V44-0074, V44-0093, and V44-0114 and Page 23 of 40

Enclosure DAEC Response to NRC Requests for Additional Information Regarding LRA Sections 2.2 and 2.3 interconnecting piping on BECH-M144<1>-LR, should have been colored green to indicate they were in scope for License Renewal and subject to aging management review.

To reflect the addition of these components and piping to the scope of license renewal, the following changes are made to the LRA:

In LRA Table 2.3.3-17, Offgas Exhaust System, on page 2.3-94, an additional component type is added as follows:

Component Types Intended Function Heat Exchanger Structural integrity (Attached)

In LRA Table 3.3.2-17, Summary of Aging Management Review Results, Offgas Exhaust System, on page 3.3-166, additional line items are added as follows:

Component Intended Material Environment Aging Effect Aging NUREG- Table Notes Type Function Requiring Management 1801 3.X.1 Management Program Volume 2 item line Item Heat Structural Carbon Air - indoor Loss of External VII.I-8 3.3.1- A Exchanger, integrity steel uncontrolled material Surfaces (A-77) 58 condenser, (attached) (external) Monitoring cooler, fan Program coil Heat Structural Carbon Raw water Loss of Inspection of VII.C1-5 3.3.1- E, Exchanger, integrity steel (internal) material Internal (A-64) 77 220 condenser, (attached) - -. . -. .. . Surfaces-:of......

cooler, fan Miscellaneous coil Piping and Ducting Components Program RAI 2.3.3.32-03

Background:

LRA Section 2.3.3.32, Well Water System, states that components are within the scope of license renewal for 10 CFR 54.4(a)(2) and have an intended function of leakage boundary.

Page 24 of 40

Enclosure DAEC Response to NRC Requests for Additional Information Regarding LRA Sections 2.2 and 2.3 Issue:

License renewal drawing BECH-M144<1>-LR (F-8) shows a continuation from M-44<2>

(D-4) as not in scope for 10 CFR 54.4(a)(2). However, the continuation of this line from a dot-dash-dot line is in-scope for 10 CFR 54.4(a)(2).

Request:

Provide additional information to clarify the license renewal boundary.

DAEC Response to RAI 22.3.3.32-03 The dot-dash-dot line represents the exterior wall of the Reactor Building where the well water system enters the building from underground. This well water piping outside the Reactor Building is not in scope for License Renewal because it is not safety related and has no potential to affect safety related components.

RAI 2.3.3.32-04

Background:

LRA Section 2.3.3.32, Well Water System, states that components are within the scope of license renewal for 10 CFR 54.4(a)(2) and have an intended function of leakage boundary.

-Issue:

License renewal drawing BECH-M144<1>-LR (A-3) shows the following:

" The connected line to valve V44-0487 is not in scope.

" The continuation to "To Radwaste Lavatory Facilities" was not provided.

Request:

Provide additional information to:

  • Clarify the significance of the braces ([])for locating a license renewal boundary.

" Clarify why the connected line to valve V44-0487 is not in scope.

  • Locate the continuation to "To Radwaste Lavatory Facilities."

Page 25 of 40

Enclosure DAEC Response to NRC Requests for Additional Information Regarding LRA Sections 2.2 and 2.3 DAEC Response to RAI 2.3.3.32-04 The braces, green color of the pipe, and the green "RB" delineate that portion of the domestic water system which is in the Reactor Building and, therefore, in scope for license renewal and subject to aging management review for 10 CFR 54.4(a)(2).

V44-0487 is in a short section of domestic water pipe contained in the north Reactor Building stairwell. The stairwell is an enclosed space with no openings except for doors. This short section of pipe and V44-0487 are not in scope because there is no potential for these components to affect a safety related component.

No drawing could be located which shows a continuation to lavatory facilities. This pipe leaves the Reactor Building and enters the Radwaste Building Heating and Ventilation (H&V) room. Within this H&V room is an isolation damper classified as safety related.

As a result, this pipe is in scope for License Renewal for 10 CFR 54.4(a)(2).

RAI 2.3.3.32-05

Background:

LRA Section 2.3.3.32, Well Water System, states that components are within the scope of license renewal for 10 CFR 54.4(a)(2) and have an intended function of leakage boundary.

Issue:

License renewal drawing BECH-M144<1>-LR (E-7)) shows 11/2"-JBD-29 from the Evaporator Room Cooling Unit as not in-scope for 10 CFR 54.4(a)(2). However the connected 11/2"-JBD-29 pipe section is in-scope for 10 CFR 54.4(a)(2).

Request:

Provide additional information to clarify the scoping classification for this section of pipe.

DAEC Response to RAI 2.3.3.32-05 Within the Radwaste Building, the piping in scope for license renewal and subject to aging management review for 10 CFR 54.4(a)(2) is located in the Radwaste Building HVAC room. This room contains an isolation damper which is classified as safety related. LR Note 2 on BECH-M144(1)-LR states, "Non-green lines are outside the RW

[Radwaste] Building HVAC Room." Line 11/2"-JBD-29 on the return from 1VAC042 is outside the Radwaste Building HVAC room, is not in scope, and is appropriately colored black.

Page 26 of 40

Enclosure DAEC Response to NRC Requests for Additional Information Regarding LRA Sections 2.2 and 2.3 RAI 2.3.4.1-01

Background:

LRA Section 2.2, Plant Level Scoping Results, states that components required to support system level LRA functions were included in-scope for license renewal. The Condensate and Demineralized Water System is identified as in-scope for 10 CFR 54.4 (a)(2).

Issue:

License renewal drawing BECH-M106-LR (F-6) does not show lines connecting with instruments P11475 and PP1472.

Request:

Provide additional information to establish the scope classification for these lines.

DAEC Response to RAI 2.3.4.1-01 On drawing BECH-M106-LR (F-6), the drawing should show green lines connecting P11475 and PP1472 to the 3/4" instrument line.

RAI 2.3.4.1-02

Background:

LRA Section 2.2, Plant Level Scoping Results, states that components required to support system level LRA functions were included in-scope for license renewal. The Condensate and Demineralized Water System is identified as in-scope for 10 CFR 54.4(a)(2).

Issue:

License renewal drawing BECH-M106-LR (E-6) shows an instrumentation line between instruments CIT 1516A and CRS 1415 as not in-scope, in-scope for 10 CFR 54.4 (a)(2) and then not in-scope.

Request:

Provide additional information to establish the scope classification for this line.

Page 27 of 40

Enclosure DAEC Response to NRC Requests for Additional Information Regarding LRA Sections 2.2 and 2.3 DAEC Response to RAI 2.3.4.1-02 CIT 1516A is a conductivity indicating transmitter and the dashed line to CRS 1514 (conductivity recording switch) is a depiction of an electrical connection between them, not piping. Some of the dashes between the instruments were inadvertently colored green and should have been black.

RAI 2.3.4.1-03

Background:

LRA Section 2.2, Plant Level Scoping Results, states that components required to support system level LRA functions were included in-scope for license renewal. The Condensate and Demineralized Water System is identified as in-scope for 10 CFR 54.4(a)(2).

Issue:

License renewal drawing BECH-M109-LR (D-1 and F-7) shows lines in and out of the Demineralized Water Storage Tank Heaters 1E014 & 1E015 as in-scope for license renewal for 10 CFR 54.4(a)(2). However, the continuation of these lines on drawing BECH-M163-LR (E-2) shows these lines as not in-scope for 10 CFR 54.4(a)(2).

Request:

Provide additional information explaining why there is a difference in scope classification between drawing BECH-M109-LR and the continuation on BECH-M163-LR.

DAEC Response to RAI 2.3.4.1-03 On drawing BECH-M163-LR (E-2), the Auxiliary Heating System lines are in scope and subject to aging management review for 10CFR54.4 (a)(2), and should be colored green.

RAI 2.3.4.1-04

Background:

LRA Section 2.2, Plant Level Scoping Results, states that components required to support system level LRA functions were included in-scope for license renewal. The Condensate and Demineralized Water System is identified as in-scope for 10 CFR 54.4(a)(2).

Page 28 of 40

Enclosure DAEC Response to NRC Requests for Additional Information Regarding LRA Sections 2.2 and 2.3 Issue:

License renewal drawing BECH-M109-LR (D-4) shows the line downstream of valve V09-0206 as in-scope for license renewal for 10 CFR 54.4(a)(2). However, the continuation of this line on drawing BECH-M131-LR (C-4) shows this line as not in-scope for 10 CFR 54.4(a)(2).

Request:

Provide additional information explaining why there is a difference in scope classification between drawing BECH-M109-LR and the continuation on BECH-M131-LR.

DAEC Response to RAI 2.3.4.1-04 On drawing BECH-M109-LR (D-4) the line downstream of closed valve V09-0206 is not in scope due to being isolated and abandoned in place (cut & capped). The line is appropriately colored black.

RAI 2.3.4.1-05

Background:

LRA Section 2.2, Plant Level Scoping Results, states that components required to support system level LRA functions were included in-scope for license renewal. The Condensate and Demineralized Water System is identified as in-scope for 10 CFR 54.4(a)(2).

Issue:

License renewal drawing BECH-M110-LR (B-2) shows the line downstream of valve V1 0-0098 as in-scope for license renewal for 10 CFR 54.4(a)(2). However, the continuation of this line on drawing BECH-M137<1>-LR (F-5) shows.this line as not in-scope for 10 CFR 54.4(a)(2).

Request:

Provide additional information explaining why there is a difference in scope classification between drawing BECH-M11O-LR and the continuation on BECH-M137<1>-LR.

Page 29 of 40

Enclosure DAEC Response to NRC Requests for Additional Information Regarding LRA Sections 2.2 and 2.3 DAEC Response to RAI 2.3.4.1-05 On drawing BECH-M137<1>-LR (F-5), the continuation line to the Turbine Building Floor Drain Sump from M110, TB Aux Sump 1P100A & B, is in scope for 10 CFR 54.4(a)(2). The continuation line depiction on BECH-M137<1>-LR from BECH-M1 10 is located in the Turbine Building Floor Drain Sump room that contains no safety-related equipment. Therefore the piping is not in scope of 10 CFR 54.4(a)(2) and is appropriately shown as black.

RAI 2.3.4.1-06

Background:

LRA Section 2.2, Plant Level Scoping Results, states that components required to support system level LRA functions were included in-scope for license renewal. The Condensate and Demineralized Water System is identified as in-scope for 10 CFR 54.4(a)(2).

Issue:

License renewal drawing BECH-M11O-LR (C-3) shows line 1/2"-HBD-142 upstream of the Neutralizing Tank 1T022 as in-scope for 10 CFR 54.4(a)(2), not in-scope, and then in-scope for 10 CFR 54.4(a)(2).

Request:

Provide additional information to establish the scope classification for this line.

DAEC Response to RAI 2.3.4.1-06 On drawing BECH-M11O-LR (C-3), the black portion of the line 1/2"HBD-142 is in scope and subject to aging management review due to 10CFR54.4(a)(2), and should be colored green.

RAI 2.3.4.1-07

Background:

LRA Section 2.2, Plant Level Scoping Results, states that components required to support system level LRA functions were included in-scope for license renewal. The Condensate and Demineralized Water System is identified as in-scope for 10 CFR 54.4(a)(2).

Page 30 of 40

Enclosure DAEC Response to NRC Requests for Additional Information Regarding LRA Sections 2.2 and 2.3 Issue:

License renewal drawing BECH-Mi110-LR shows equipment as abandoned in place, however significant piping is identified as in-scope for 10 CFR 54.4(a)(2).

Request:

Provide additional information to clarify the mixing of in-scope versus abandoned in place on license renewal drawing BECH-M11O-LR.

DAEC Response to RAI 2.3.4.1-07 On drawing BECH-Mi 10-LR the Make-up Demineralizer has been abandoned.

However, the Demineralizer piping is not cut & capped, and lines are pressurized to the first isolation. Therefore the piping is in scope for 10 CFR 54.4(a)(2) and subject to aging management review.

RAI 2.3.4.1-08

Background:

LRA Section 2.2, Plant Level Scoping Results, states that components required to support system level LRA functions were included in-scope for license renewal. The Condensate and Demineralized Water System is identified as in-scope for 10 CFR 54.4(a)(2).

Issue:

License renewal drawing BECH-M136-LR (F-i) shows line 11/2"-HCD-36 downstream of valve V36-0045 as not in-scope for license renewal. The continuation of this line on drawing BECHM139-LR (D-2) shows this line as in-scope for 10 CFR 54.4 (a)(2).

Request:

Provide additional information explaining why there is a difference in scope classification between drawing BECH-M136-LR and the continuation on BECH-M139-LR.

DAEC Response to RAI 2.3.4.1-08 On drawing BECH-M139-LR (D-2), line 11/2"-HCD-36 is not in scope because it is located in the Radwaste Building and not in an area containing safety-related equipment. This line should be black.

Page 31 of 40

Enclosure DAEC Response to NRC Requests for Additional Information Regarding LRA Sections 2.2 and 2.3 RAI 2.3.4.1-9

Background:

LRA Section 2.3.3.4.1, Condensate and Demineralized Water System, states that components are within the scope of license renewal per 10 CFR 54.4(a)(2) because the system includes nonsafety-related SSCs whose failure could prevent satisfactory accomplishment of a safety-related function due to spatial proximity. Portions of the system are also within scope of license renewal per 10 CFR 54.4(a)(3) because the system contains components credited in the current licensing basis for Fire Protection (10 CFR 50.48).

Issue:

License renewal drawing BECH-M189<1>-LR (A-7) shows two 1/2" lines, HCD-182, and the associated check valves V89-0072 and V89-0074 within the scope of license renewal per 10 CFR 54.4(a)(2). The license renewal boundary is shown to be at the check valves. The continuations of the lines HCD-1 82, upstream of the check valves, are shown as not within the scope of license renewal.

Request:

Provide additional information explaining why the 1/2" lines HCD-182 continuations upstream of check valves V89-0072 and V89-0074 are not within the scope of license renewal.

DAEC Response to RAI 2.3.4.1-9 On BECH-M189<1>-LR (A-7), the lines downstream of check valves V89-0072 and V89-0074 are Feedwater System pressure boundary components; they are in scope of license renewal and subject to aging management review due to 10 CFR 54.4(a)(2).

The lines upstream of check valves V89-0072 and V89-0074 contain gas (02) and are not in scope since they do not have a license renewal intended function.

RAI 2.3.4.2-01

Background:

LRA Section 2.2, Plant Level Scoping Results, states that components required to support system level LRA functions were included in-scope for license renewal. The Condensate and Feedwater System is identified as in-scope for 10 CFR 54.4 (a)(2).

Page 32 of 40

Enclosure DAEC Response to NRC Requests for Additional Information Regarding LRA Sections 2.2 and 2.3 Issue:

License renewal drawing BECH-M 111 -LR (C-6 and D-6) shows Reactor Feed Pump Motor Coolers #1 E039A and #1 E039B as out of scope for license renewal, however these coolers are attached to General Service Water System piping which is identified as in-scope for 10 CFR 54.4(a)(2).

Request:

Provide additional information to clarify the scope status of the Reactor Feed Pump Motor Coolers on license renewal drawing BECH-M 111 -LR.

DAEC Response to RAI 2.3.4.2-01 The Reactor Feed Pump Motor Coolers 1E039A and 1E039B are an integral part of the Reactor Feed Pump Motors. These motors are in scope but were determined to be active components as determined by Appendix B of NEI 95-10, Industry Guideline for Implementing the Requirements of 10 CFR 54 -The License Renewal Rule. Therefore, they are not subject to aging management review.

RAI 2.3.4.3-01

Background:

License renewal rule 10 CFR 54.21 (a) requires applicants to list all component types subject to an AMR. The staff confirms inclusion of all component types subject to an AMR by reviewing components within the license renewal boundary.

Issue:

License renewal drawing BECH-M103<1>-LR (A-2) shows line 1"-EBD-3 in-scope for license renewal for 10 CFR 54.4(a)(2). However, the continuation of this 1," line on drawing BECH-M137<1>-LR (C3) shows this line is not in-scope.

Request:

Provide additional information explaining why there is a difference in scope classification between drawing BECH-M103<1>-LR and the continuation on BECH-M1 37<1 >-LR.

DAEC Response to RAI 2.3.4.3-01 Line 1"-EBD-3 originates in the condenser bay, becomes HBD pipe, and enters the Turbine Building sump room. Components in the Turbine Building sump room are not in Page 33 of 40

Enclosure DAEC Response to NRC Requests for Additional Information Regarding LRA Sections 2.2 and 2.3 scope for License Renewal because this room is a closed room containing no 10 CFR 54.4(a)(1) components. BECH-M103<1>-LR should have contained a wall illustration with a License Renewal Note explaining that the pipe leaves the condenser bay and enters the Turbine Building sump room.

RAI 2.3.4.3-02

Background:

LRA Section 2.2, Plant Level Scoping Results, states that components required to support system level LRA functions were included in-scope for license renewal. The Condenser and Condenser Air Removal System is identified as in-scope for 10 CFR 54.4(a)(2).

Issue:

License renewal drawing BECH-M103<1>-LR (A-4) shows line 11/2"-EBD-3 in-scope for license renewal for 10 CFR 54.4(a)(2). However, the continuation of this 11/2'"line on drawing BECH-M105-LR (1) (E6) shows this line is not in-scope for 10CFR54.4 (a)(2).

Request:

Provide additional information explaining why there is a difference in scope classification between drawing BECH-M103<1>-LR and the continuation on BECH-M105<1>-LR.

DAEC Response to RAI 2.3.4.3-02 Line 11/2"-EBD-3 originates in the Steam Jet Air Ejector (SJAE) room and enters the condenser bay. Components in the SJAE room are not in scope for License Renewal because it is a closed room with no 10 CFR 54.4(a)(1) components. BECH-M103<1>-

LR should have contained a wall illustration with a License Renewal Note explaining that the pipe leaves the SJAE room and enters the condenser bay.

RAI 2.3.4.3-03

Background:

LRA Section 2.2, Plant Level Scoping Results, states that components required to support system level LRA functions were included in-scope for license renewal. The Condenser and Condenser Air Removal System is identified as in-scope for 10 CFR 54.4(a)(2).

Page 34 of 40

Enclosure DAEC Response to NRC Requests for Additional Information Regarding LRA Sections 2.2 and 2.3 Issue:

License renewal drawing BECH-M103<1>-LR (D-8) shows the I"-EBD-8 line in-scope for license renewal for 10 CFR 54.4(a)(2). However, the continuation of this 1" line on drawing BECH-M137(1) (C3) shows this line is not in-scope.

Request:

Provide additional information explaining why there is a difference in scope classification between drawing BECH-M103<1>-LR and the continuation on BECH-M137<1>-LR.

DAEC Response to RAI 2.3.4.3-03 Line 1"-EBD-8 originates in the heater bay, becomes HBD pipe, and enters the Turbine Building sump room. Components in the Turbine Building sump room are not in scope for License Renewal because it is a closed room with no 10 CFR 54.4(a)(1) components. BECH-M103<1>-LR should have contained a wall illustration with a License Renewal Note explaining that the pipe leaves that heater bay and enters the Turbine Building sump room.

RAI 2.3.4.3-04

Background:

LRA Section 2.2, Plant Level Scoping Results, states that components required to support system level LRA functions were included in-scope for license renewal. The Condenser and Condenser Air Removal System is identified as in-scope for 10 CFR 54.4(a)(2).

Issue:

License renewal drawing BECH-M104<1>-LR (C-5) shows equipment as abandoned in place, however 3" piping is identified as in-scope for 10 CFR 54.4(a)(2).

Request:

Provide additional information to clarify the mix of in-scope versus abandoned in place on license renewal drawing BECH-M104<1>-LR.

DAEC Response to RAI 2.3.4.3-04 The remainder of the steam seal piping within the "Abandoned In Place" border on drawing BECH-M104<1>-LR is in scope for 10 CFR 54.4(a)(2) and subject to aging Page 35 of 40

Enclosure DAEC Response to NRC Requests for Additional Information Regarding LRA Sections 2.2 and 2.3 management review because it is exposed to steam seal pressure.

RAI 2.3.4.4-01

Background:

LRA Section 2.2, Plant Level Scoping Results, states that components required to support system level LRA functions were included in-scope for license renewal. The Main Steam Isolation and Automatic Depressurization System is identified as in-scope for 10 CFR 54.4(a)(1) and 10 CFR 54.4(a)(2).

Issue:

License renewal drawing BECH-M184-LR (F-4) shows MAIN STEAM LINE "A" as out of scope for license renewal. However, drawing BECH-M1 14-LR shows these four main steam lines as in-scope for 10 CFR 54.4(a)(1) and 10 CFR 54.4(a)(2).

Request:

Provide additional information explaining why there is a difference in scope classification between drawing BECH-M114-LR and the continuation on BECH-M184-LR.

DAEC Response to RAI 2.3.4.4-01 Main Steam Line "A" on license renewal drawing BECH-M184-LR (F-4) is depicted as a dotted line to show its relationship to the other components on this drawing. The actual Main Steam Line (MSL) "A" is shown on license renewal drawing BECH-M1 14-LR, which correctly indicates that it is in scope and subject to aging management review for license renewal. It had been the license renewal drawing convention to color these "relational" dotted lines the same color as the actual lines that appear on other drawings. In this case Main Steam Line "A" on license renewal drawing BECH-M184-LR should have been colored red for the components CV4413 and all components upstream on MSL "A" to indicate it is in scope and subject to aging management review for 10 CFR 54.4(a)(1). The portion of MSL "A" down stream of CV4413 should have been colored green to indicate this portion of the steam line is in scope and subject to aging management review for 10 CFR 54.4(a)(2).

Page 36 of 40

Enclosure DAEC Response to NRC Requests for Additional Information Regarding LRA Sections 2.2 and 2.3 RAI 2.3.4.5-01

Background:

LRA Section 2.2, Plant Level Scoping Results, states that components required to support system level LRA functions were included in-scope for license renewal. The Turbine System is identified as in-scope for 10 CFR 54.4 (a)(2).

Issue:

License renewal drawing BECH-M145<1>-LR (E-5) shows the line downstream of valve V45-0268 out of scope for license renewal. However, the continuation of this line on the same drawing at location F-7 shows this line is in-scope for 10 CFR 54.4(a)(2).

Request:

Provide additional information explaining why there is a difference in scope classification for the line on drawing BECH-M145<1>-LR.

DAEC Response to RAI 2.3.4.5-01 The line downstream of valve V45-0268 on license renewal drawing BECH-M145<1>-LR (E-5) should have been colored green to indicate that it is also in scope and subject to aging management review for 10 CFR 54.4(a)(2).

RAI 2.3.4.5-02

Background:

LRA Section 2.2, Plant Level Scoping Results, states that components required to support system level LRA functions were included in-scope for license renewal. The Turbine System is identified as in-scope for 10 CFR 54.4(a)(2).

Issue:

License renewal drawing BECH-M145<4>-LR (E-7) shows GBV VENT as out of scope for license renewal, however this vent is attached to the Air Detraining Section which is in-scope for 10 CFR 54.4(a)(2).

Request:

Provide additional information to clarify the status of the vent line on license renewal drawing BECH-M145<4>-LR (E-7).

Page 37 of 40

Enclosure DAEC Response to NRC Requests for Additional Information Regarding LRA Sections 2.2 and 2.3 DAEC Response to RAI 2.3.4.5-02 The Main Lube Oil Air Detraining Section vent labeled as GBV VENT on license renewal drawing BECH-M145<4>-LR (E-7) is physically attached to the Air Detraining Section. The line should have been colored green to indicate that it is also in scope and subject to aging management review for 10 CFR 54.4(a)(2).

RAI 2.3.4.5-03

Background:

LRA Section 2.2, Plant Level Scoping Results states that components required to support system level LRA functions were included in-scope for license renewal. The Turbine System is identified as in-scope for 10 CFR 54.4(a)(2).

Issue:

License renewal drawing BECH-Mi 11-LR (A-4) shows Exciter Air Cooler 1 E059 as out of scope for license renewal, however this cooler is attached to General Service Water System piping which is in-scope for 10 CFR 54.4(a)(2).

Request:

Provide additional information to clarify the scope status of the Exciter Air Cooler on license renewal drawing BECH-M111-LR.

DAEC Response to RAI 2.3.4.5-03 The Exciter Air Cooler 1E059 shown on BECH-M111-LR (A-4) is a tube heat exchanger that is entirely contained within the Main Generator Exciter housing. There is no safety related equipment contained within the exciter housing, and any leaks from the Exciter Air Cooler 1 E059 would be prevented from spatially affecting safety related equipment in the Turbine Building. The GSW supply and return piping to the Exciter Air Cooler that is outside the Main Generator Exciter Housing is in scope and subject to aging management review for 10 CFR 54.4(a)(2).

RAI 2.3.4.5-04

Background:

LRA Section 2.2, Plant Level Scoping Results states that components required to support system level LRA functions were included in-scope for license renewal. The

.Turbine System is identified as in-scope for 10 CFR 54.4(a)(2).

Page 38 of 40

Enclosure DAEC Response to NRC Requests for Additional Information Regarding LRA Sections 2.2 and 2.3 Issue:

License renewal drawing BECH-MI 11-LR, (C-4 & D-4) shows four Gen. Hydrogen coolers 1E063A, B, C & D as out of scope for license renewal, however these coolers are attached to the General Service Water System piping which is identified as in-scope for 10 CFR 54.4(a)(2).

Request:

Provide additional information to clarify the scope status of the Gen. Hydrogen Coolers on license renewal drawing BECH-M 111 -LR.

DAEC Response to RAI 2.3.4.5-04 The four Generator Hydrogen Coolers 1E063A, B, C & D shown on BECH-M 111 -LR (C-4 & D-4) are tube heat exchangers that are entirely contained within the Main Generator Shell. There is no safety related equipment contained within the Main Generator Shell, and any leaks from these heat exchangers would be prevented from spatially affecting safety related equipment in the Turbine Building. The General Service Water supply and return piping to the Main Generator Hydrogen Coolers external to the Main Generator are in scope and subject to aging management review for 10 CFR 54.4(a)(2).

RAI 2.3.4.5-05

Background:

LRA Section 2.2, Plant Level Scoping Results, states that components required to support system level LRA functions were included in-scope for license renewal. The Turbine System is identified as in-scope for 10 CFR 54.4(a)(2).

Issue:

License renewal drawing BECH-M145<2>-LR, (G-4) shows Generator Frame as out of scope for license renewal, however this cooler is attached to the Stator Winding Cooling Water System piping which is identified as in-scope for 10 CFR 54.4(a)(2).

Request:

Provide additional information to clarify the scope status of the Generator Frame on license renewal drawing BECH-M145<2>-LR.

Page 39 of 40

Enclosure DAEC Response to NRC Requests for Additional Information Regarding LRA Sections 2.2 and 2.3 DAEC Response to RAI 2.3.4.5-05 On BECH-M145<2>-LR (G-4), the Stator Winding Cooling Water components located inside the Generator are not in scope for 10 CFR 54.4(a)(2) because they are contained in the Generator Frame. Should the components inside the frame fail any spray will not affect safety-related equipment in the Turbine Building.

Page 40 of 40

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