NL-12-190, Amendment 12 to License Renewal Application (LRA)

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Amendment 12 to License Renewal Application (LRA)
ML13003A178
Person / Time
Site: Indian Point  Entergy icon.png
Issue date: 12/27/2012
From: Dacimo F
Entergy Nuclear Northeast
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-12-190
Download: ML13003A178 (26)
v • d • e


Text

Entergy Nuclear Northeast Indian Point Energy Center

'P Entergy 450 Broadway, GSB P.O. Box 249 Buchanan, NY 10511-0249 Tel (914) 254-2055 Fred Dacimno Vice President Operations License Renewal NL-12-190 December 27, 2012 Document Control Desk U. S. Nuclear Regulatory Commission Mail Stop O-P1-17 Washington, D.C. 20555-0001

SUBJECT:

Amendment 12 to License Renewal Application (LRA)

Indian Point Nuclear Generating Unit Nos. 2 and 3 Docket Nos. 50-247 and 50-286 License Nos. DPR-26 and DPR-64 REFERENCES 1 Entergy Letter dated April 23, 2007, F. R. Dacimo to Document Control Desk, "License Renewal Application" (NL-07-039) 2 Entergy Letter dated April 23, 2007, F. R. Dacimo to Document Control Desk, "License Renewal Application Boundary Drawings" (NL-07-040) 3 Entergy Letter dated April 23, 2007, F. R. Dacimo to Document Control Desk, "License Renewal Application Environmental Report References" (NL-07-041) 4 Entergy Letter dated October 11, 2007, F. R. Dacimo to Document Control Desk, "License Renewal Application (LRA)" (NL-07-124) 5 Entergy Letter dated November 14, 2007, F. R. Dacimo to Document Control Desk, "Supplement to License Renewal Application (LRA)

Environmental Report References" (NL-07-133)

Dear Sir or Madam:

In the referenced letters, Entergy Nuclear Operations, Inc. applied for renewal of the Indian Point Energy Center operating license. This letter contains Amendment 12 of the License Renewal Application (LRA).

Should you have any questions concerning this report, please contact Mr. Robert W. Walpole, Licensing Manager, at (914) 254-6710.

NL-12-190 Dockets 50-247 and 50-286 Page 2 of 2 I declare under penalty of perjury that the foregoing is true and correct. Executed on Sincerely, FRD/mb Attachment 1. Annual Update Amendment cc: Mr. William Dean, Regional Administrator, NRC Region 1 Mr. Sherwin E. Turk, NRC Office of General Counsel, Special Counsel Mr. Dave Wrona, NRC Branch Chief, Engineering Review Branch I Mr. Douglas Pickett, Senior Project Manager, NRC NRR DORL NRC Resident Inspector's Office Ms. Bridget Frymire, NYS Dept. of Public Service Mr. Francis J. Murray, Jr., President and CEO NYSERDA

ATTACHMENT 1 TO NL-12-190 Annual Update Amendment ENTERGY NUCLEAR OPERATIONS, INC INDIAN POINT NUCLEAR GENERATING UNITS 2 AND 3 DOCKET NOS. 50-247 & 50-286

INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3 LICENSE RENEWAL APPLICATION ANNUAL UPDATE AMENDMENT In accordance with 10 CFR 54.21(b), each year following submittal of the license renewal application and at least 3 months before scheduled completion of the NRC review, an amendment to the renewal application must be submitted that identifies any change to the CLB of the facility that materially affects the contents of the license renewal application (LRA), including the FSAR supplement. This attachment is the required annual update amendment to the Indian Point Energy Center (IPEC) LRA.

This amendment is based on a review of documents potentially affecting the CLB during the period of September 1, 2011 through August 31, 2012. The last annual.

update of the LRA included a review of documents through August 31, 2011 The review concluded that certain sections of the LRA are affected by changes to the CLB that occurred during the period of review. The table below summarizes the changes listing the affected system (if applicable), an explanation of the change (including effect on the LRA), and the affected LRA section.

IPEC LRA Sections Affected LRA Section CLB Change Affected Engineering Change 29952 replaced valve bodies (backflow preventer) in the City Water portion of the Components to Support the AFW Pump Room Fire Event. Table 3.4.2-5-4-1P2 Change added cast iron valve material type to AFW PRFE.

Engineering Change 30847 - Implement permanent configuration change to the work done under Temporary Modification EC 11487 to allow an alternate method of removing fuel oil Table 2.3.3-13-1P3 from GT Fuel Oil Tank (GT 2/3-FOT) to mobile tanker truck (Black start diesel added to support pump operation). Table 3.3.2-13-1P3 Change added new component type/ material/

environment to Fuel Oil System.

CLB Change LRA Section jAffected Engineering Change 34530 identified flex hose found during plant walkdown that was not previously shown on drawings. Table 2.3.3-19-30-1P2 Change added new component type "flex hose" Table 3.3.2-19-30-1P2 to IP2 nonsafety-related affecting safety-related tables for RCS.

Engineering Change EC-33660 added existing flex connections to EDG show Jacket Water piping not prviouly.Table 2.3.3-14-1P3 shown previously.

Change added component type 'flex connector' Table 3.3.2-14-IP3 to 1P3 Emergency Diesel Generators.

Engineering Change-27644 adds demineralizer system (tanks, piping and valves) to IACC system head tank. Component type "flow element and tubing" to be added to City Water Table 2.3.3-19-13-1P3 System.

Table 3.3.2-19-13-1P3 Change added component types to IP3 nonsafety-related affecting safety-related for IACC.

During review of AMM12, Rev. 2, Service Water Systems it was noted that the main service water Section 3.3.2.1.2 pumps had been inadvertently shown as (IP3) stainless steel.

Change pump casing material to aluminum Table 3.3.2-2-1P3 bronze (deleted stainless steel).

CR-IP2-2012-6346 was issued to correct NL 060 which deleted copper alloy > 15% Zn material and selective leaching as a program from section 3.3.2.1.15, Security Generators Section 3.3.2.1.15 (Heat exchanger) for both 1P2 and IP3. (IP32)

Change added back material and program applicable to 1P2 even though the copper alloy >

15% Zn was replaced with fiberglass in 1P3.

LRA Section CLB Change Affected LRA Sections 2.3.4.5, IP2 AFW Pump Room Fire Event and 3.4.2, Results (IP2 AFW Pump Room Fire Event) were revised to clarify that the aging management review of structures and components that maintain the intended functions Section 2.3.4.5 for the AFW PRFE are included in the LRA.

Section 3.4.2 Change clarified that these systems/components are conservatively included in the IPEC LRA after further discussions with the NRC in letter NL-12-123.

During the review of Engineering Change 30847, no new component type, material or environments were identified for this plant system as a result of a field walkdown. During the same walkdown it was noted that the material for fuel oil pumps GT2-ACP and GT2- Table 3.3.2-13-1P2 DCP is cast iron and carbon steel. Previous to this walkdown these fuel oil pumps were shown as carbon steel.

Add cast iron as a material for pump casing

IPEC LRA changes are shown below.

(Changes are shown as strikethroughs for deletigns and underlines for additions) 3.4.2-5-4-1P2 City Water System Components Required to Support AFW Pump Room Fire Event Summary of Aging Management Review Component Intended Aging Effect Aging NUREG- Table 1 Notes Material Environment Requiring Management 1801 Vol. 2 Item Type Function Management Programs Item Pressure Gray cast Air-indoor (ext) Loss of External Surfaces VIt.l-8 Valve body boundary iron A Material Monitoring (A-77 3.3.1-58 A Periodic Pressure Gray cast Treated water(int) Loss of Surveillance and Valve body boundar iron Material Preventive

___Maintenance Pressure Gray cast Treated wa Loss of Selective VII.G-14 Valve body boundary iron Trete nt) Material Leaching J6-511 3.3.1-85 C.303

Table 2.3.3-13-1P3 Fuel Oil Components Subject to Aging Management Review Component Type Intended Function Filter housing Pressure boundary Flexible bellows Pressure boundary Heat exchanger (bonnet) Pressure boundary Heat exchanger (tubes) Heat transfer Heat exchanger (tubes) Pressure boundary Silencer Pressure boundary Turbocharger Pressure boundary 3.3.2.1.13 Fuel Oil Materials Fuel oil system components are constructed of the following materials.

  • glass
  • stainless steel
  • aluminum Environment Fuel oil system components are exposed to the following environments.
  • air - indoor
  • air -outdoor

concrete fuel oil soil exhaust gas treated water Aging Effects Requiring Management The following aging effects associated with the fuel oil system require management.

" fouling

  • loss of material

" Aboveground Steel Tanks

" Bolting Integrity 9 Buried Piping and Tanks Inspection

" Diesel Fuel Monitoring

" External Surfaces Monitoring

  • Fire Protection
  • Periodic Surveillance and.Preventive Maintenance
  • Water chemistry control - Closed Cooling Water
  • Selective Leaching

NL-12-190 Page 7 of 23 Dockets 50-247 and 50-286 Attachment I Table 3.3.2-13-1P3 Fuel Oil Systems Summary of Aging Management Review Table 3.3.2-13-1P3: Fuel Oil Systems Component Intended Effect Aging Management NUREG- Table I Environment Requiring Programs 1801 Vol. 2 Notes Type Function Material Management Item Item Pressure. Carbon steel Air- indoor (ext) Loss of material External Surfaces VII.l-8 Filter housing Monitoring (A-77)A Pressure Diesel Fuel VII.H1-10 B, F boundary Carbon steel Fuel oil (int) Loss of material Monitoring (A-30) 316 FilterFitr osig housing boundary Pressure -Monitoring Carbon steel Air - indoor (int) Loss of material External Surfaces V.3-1 LE-2M 3.2.1-32 E None VII.J-15 (AP-17) 3.3.1-94 A Flexible Pressure Stainless Air - indoor (ext) None bellows boundary steel Flexible Pressure Stainless Periodic surveillance , -- H bellows boundary steele Exhaust gas (int) Cracking-fatigue and preventive bmaintenance Flexible Pressure Stainless Periodic surveillance VII.H2-2 3.3.1-18 E bellows boundary steel Exhaust gas (int) Loss of material and preventive (A-27) maintenance

NL-12-190 Page 8 of 23 Dockets60-247 and 50-286 Attachment 1 Table 3.3.2-13-IP3: Fuel Oil Systems Component Intended Aging Effect Aging Management UREG- Table I Notes Type Function Material Environment Requiring Programs 1801 Vol. 2 Item Management Item Heat Pressure External Surfaces VII.1-8 3.3.1-58 A exchanger boundary Carbon steel Air - indoor (ext) Loss of material Monitorinaq (A-77)

(bonnet)

Heat Water chemistry VII.C2-1 3.3.1-48 D exchange Pressure Treated water Loss of material control - closed (A63)

(bonnet) boundary Cnt)

  • cooling water Heat Periodic surveillance G exchane Heat transferCoer alloy Air - indoor (ext) Fouling and preventive (tubes) >15% zn maintenance Heat Water chemistry VII.C2-2 3.3.1-52 D exchanger Heat transfer Copper alloy Treated water Fouling control - closed (AP80)

(tubes) >15% zn (int) cooling water Heat V.F-3 3.2.1-53 C exchange Pressure Copper alloy Air - indoor (ext) None None (EP10)

(tubes) boundary >15% zn Heat Pressure Copper

>5%zn alloy Treated fiDLoss water of material Selective leachingq VII.H1-4 A-3 3.3.1-84 C exhage bond~

exchanger boundary >15% zn nA (tubes)

NL-12-190 Page 9 of 23 Dockets 50-247 and 50-286 Attachment I' Table 3.3.2-13-1P3: Fuel Oil Systems Component Intended Aging Effect Aging Management NUREG- Table I Notes Material Environment Requiring Programs 1801 Vol. 2 Item Type Function Management Item Heat Pressure Copper alloy Treated water Water chemistry VII.E1-2 exchaner Loss of material control - closed 3.3.1-51 Q (tubes) boundary >15% Zn int) cooling water (AP34-Waterchemistr VII.H2-23 3.3.1-47 D piing Pressue CTreated water Loss of material control - closed (A25) e boundaryr Carbon steel int) cooling water Periodic surveillance VI.H2-2 3.3.1-18 E Pinin Pressure Carbon steel Exhaust ,qas(int) Loss of material and preventive (A-27z) boundary maintenance V.A-19 3.2.1-32 E PiigPressureboundary Carbon steel Air - indoor (int) Loss of material Extrnl2Srfce MoniExternal Surfaces V.F-2 3.2.1-50 C

~boundaryPnPressure Aluminum Air - indoor (ext) None None (EP-3)

V.F-2 3.2.1-50 C Pressure Aluminum Air - indoor (int) None None (EP-3).

boundary

Table 3.3.2-13-1P3: Fuel Oil Systems Component Intended Aging Effect NUREG-Aging Management Table 1 Function Material Environment Requiring Programs Item Type Management Item Pressure External surfaces VII.1-8 3.3.1-58 A Silencer boundary Carbon steel Air- indoor (ext) Loss of material monitoring Periodic surveillance -- -- H Silencer boundary Carbon steel Exhaust gas (int) Cracking-fatigue and Preventive maintenance Pressure Periodic surveillance VII.H2-2 3.3.1-18 E Silencer boundary Carbon steel Exhaust gas (int) Loss of material and Preventive maintenance Pressure Gray cast A *d (t) Loss of material External surfaces VII.1-8 3.3.1-58 A Turbocharger boundary iron -monitoringq Pressure Gray cas External surfaces V.A-19 3.2.1-32 E LTurbcha,. boundary Pe iron Air-- indoor (int) Loss of material monitoring rPressurV.F-2 None 3.2F1-50 C bressure boundary Aluminum Air - indoor (int) None (EP-3)

Pressure Periodic surveillance .... G Turbocharger boundary Aluminum Exhaust gas (int) Loss of material and Preventive

. maintenance

Table 2.3.3-19-30-1P2 Reactor Coolant System Nonsafety-Related Components Potentially Affecting Safety Functions Subject to Aging Management Review Component Type Intended Function 1 Bolting Pressure boundary Flex hose Pressure boundary Piping Pressure boundary Tubing Pressure boundary Valve body Pressure boundary

Table 3.3.2-19-30-1P2 Reactor Coolant System Nonsafety-Related Components Potentially Affecting Safety Functions Summary of Aging Management Review Table 3.3.2-19-30-IP2: Reactor Coolant System Aging Effect AigManagement NU01REG.- Notes Component Intended Aging Efc gn aaeet NRG Table I Function Material Environment Requiring Programs Vol. 2 Item Type Management Item Flex hose Pressure Stainless Air- indoor (ext) None V.F-12 boundary steel None -1 3.2.153 C Flex hose Pressure Stainless Treated borated Water Chemistry boundary steel water >140°F (int) Loss of material Control - Primary V.A-27 3.2.1-49 C and Secondary (EPA1)

Flex hose Pressure Stainless Treated borated Water Chemistry .A-28 boundary steel water >140°F (int) Crackinq Control - Primary 3.2.1-48 C and Secondary E-12) 3

NL-12-190 Dockets 50-247 and 50-286 Page 13 of 23 Attachment I Table 2.3.3-14-1P3 Emergency Diesel Generator System Components Subject to Aging Management Review Component Type Intended Function Flex connector Pressure boundary Table 3.3.2-14-1P3: Emergency Diesel Generators Component Intended Aging Effect Aging Management' NUREG- Table I Type Function Material Environment Requiring Programs 1801 Vol. 2 Item Notes Management Item Presure tainessVII.J-15 FlexPressure Stainless Air - indoor (ext) None None 3.3.1-94 A boundary steel (AP-1 7)

Pressure Stainless Treated water Water Chemistry VII.C2-10 Flex connector boury s ted wate Loss of material Control - Closed 3.3.1-50 Q boundary steel > 140°F (int) Coolinq Water

Table 3.3.2-14-1P3: Emergency Diesel Generators Aging Effect Aging Management NUREG- Table N Component Intended Material Environment Requiring Programs 1801 Vol. 2 Item Notes Type Function Management Item Pressure Stainless Treated water Water Chemistry VII.C2-11 3.3.1-46 Q Flex connector Pressundary steeless Flexconnerboundary steel >

> 1r 140°F (int) Cracking Cooling -Water Control Closed Table 2.3.3-19-13-1P3 City Water Makeup System Nonsafety-Related Components Potentially Affecting Safety Functions Subject to Aging Management Review Component Type Intended Function Flow element Pressure boundary Tubing Pressure boundary

NL-1 2-190 Dockets 50-247 and 50-286 Page 16 of 23 Attachment I Table 3.3.2-19-13-IP3: City Water Makeup System Component Intended Aging Effect Aging Management NUREG- Table I Material Environment Requiring Programs 1801 Vol. 2 Item Notes Type Function Item Management Pressure V.F-3 Flow element boundary Copper alloy Air - indoor (ext) None None (EP-100 3.2.1-53 C Treated waterPeidcSrilae Periodic Surveillance Pressure Flow element boundr Copper alloy Tt Loss of material and Preventive -- G,305 ba Maintenance Pressure V. F-3 Tubing boundary Copper alloy Air- indoor (ext) None None (EP-10) 3.2.1-53 C Periodic Surveillance boundare Copper alloy (int) Maintenance

Related to table 3.3.2.1.2 and Table 3.3.2-2-1P3, during the review of AMM12, Revision 2, Service Water Systems it was noted that the material for the IP3 main service water pumps had inadvertently been shown as stainless steel. This has been revised to aluminum bronze.

3.3.2.1.2 Service Water Materials Service water system components are constructed of the following materials.

" aluminum bronze

" carbon steel

Table 3.3.2-2-1P3 Service Water System Summary of Aging Management Review Table 3.3.2-2-1P3: Service Water System Component Intended Aging Effect Table 1 Agn fet Aging Management 1801REl.- Notes Material Environment Requiring Programs 1801 Vol. 2 Item Type Function Management Item Pressure Aluminum Condensation External surfaces VII.F1-16 3.3.1-25 E 319 Pump casing boundary bronze (ext) Loss of material monitoring (A-46)

Prssr AuinmVII.Cl-9 1.3.1-81 A. 319 casure bn Raw water (ext) Loss of material Service water integrity (A-44)

Pump cain Pressure Aluminum Raw water (ext) Loss of material Selective Leaching VII.C1-1O 3.3.1-84 A,319 sin-q boundary bronze (A-47)

Pump___

casnbundry brnze Rawte (ext)Lossofmaeria Slc integracityq (A-47)

Pressure Aluminum Raw waterI.nt Loss of material Service water* VIIC1-9 3.3.1-81 A. 319 Pump casing boundare bronze Rawwar 3 PumpPressure Aluminum Raw water (int) Loss of material Selective Leaching VIIC1-10 3.3.1-84 A,31 boundary bronze (A-47)

E xernal fa e N1 a3 3.27 -E-Pes uLose of mtrial P .M P Gai

b. u.da. y steel (e MG,,i÷te,

,) (A-

Add plant specific note:

Notes for Tables 3.3.2-1-1P2 through 3.3.2-62-1P3 Plant Specific Notes 319. Aluminum bronze material evaluated as copper alloy with greater than 15% zinc or > 8% aluminum.

(See section 3.0 page 3.3-81)

Added back copper alloy > 15% zinc material and the selective leaching program to LRA section 3.3.2.1.15 as it was inadvertently removed from this table by NL-09-060.

This material and program remained applicable to IP2, although this same material was replaced with fiberglass in' the bonnet of the jacket water heat exchanger in IP3.

(Tables 3.3.2-15-1P2 and 3.3.2-15-1P3 are not affected) 3.3.2.1.15 Security Generator Materials Security generator system components are constructed of the following materials.

  • aluminum
  • fiberglass
  • stainless steel
  • copper alloy > 15% zinc Environment Security generator system components are exposed to the following environments.
  • air - indoor
  • exhaust gas
  • gas
  • soil
  • treated water Aging Effects Requiring Management The following aging effects associated with the security generator system require management.
  • cracking - fatigue
  • fouling
  • Bolting Integrity
  • Buried Piping and Tanks Inspection
  • External Surfaces Monitoring
  • Periodic Surveillance and Preventive Maintenance
  • Water Chemistry Control - Closed Cooling Water
  • Selective Leaching

LRA Sections 2.3.4.5, IP2 AFW Pump Room Fire Event and 3.4.2, Results (IP2 AFW Pump Room Fire Event) were revised to clarify that, although systems/components subject to this event were not subject to aging management (Integrity of the systems and components required to perform post-fire intended functions for at least one hour is continuously confirmed by normal plant operation), these system/components were aging management reviewed. These systems/components were, conservatively, included in the IPEC LRA after further discussions with the NRC in letter NL-1 2-123.

2.3.4.5 Components Subiect to Aaina Manaaement Review Auxiliary steam system components supporting the RWST pressure boundary are evaluated with the safety injection systems (Section 2.3.2.4). River water system components forming part of the service water system pressure boundary are evaluated with service water systems (Section 2.3.3.2). Containment penetrations are reviewed in Section 2.3.2.5. Nonsafety-related components not evaluated with other systems whose failure could prevent satisfactory accomplishment of safety functions are evaluated with miscellaneous systems in scope for (a)(2) (Section 2.3.3.19).

For license renewal, the primary intended function of components associated with the AFW pump room fire event is to maintain system pressure boundary integrity. The heat exchangers have the function of heat transfer. The filters and strainers have the function of filtration. Nozzles have the function of flow control.

Aging management of the systems required to supply feedwater to the steam generators during a fire in the AFW pump room is not based on an analysis of materials, environments and aging effects. The components in the systems required to supply feedwater to the steam generators during the short duration of the fire event are in service at the time the event occurs or their availability is checked daily. Required components are adequately separated from the AFW pump room. Therefore, integrity of the systems and components required to perform post-fire intended functions for at least one hour is continuously confirmed by normal plant operation.

During the event these systems and components must continue to perform their intended functions to supply feedwater to the steam generators for a minimum of one hour. Significant degradation that could threaten the performance of the intended functions will be apparent in the period immediately preceding the event and corrective action will be required to sustain continued operation. For the minimal one-hour period that these systems would be required to provide make-up to the steam generators, further aging degradation that would not have been apparent prior to the event is negligible. Therefore, no aging effects are identified.

The IP1 condensate storage tanks are only subject to intermittent service. Therefore, a daily check of tank level and intermittent usage of piping and valves from the IPN CSTs to the IP2 condenser confirm availability. Significant degradation that could threaten the performance of the intended functions will be apparent in the period

immediately preceding the event and corrective action will be required to sustain continued operation.

Since normal plant operation assures adequate pressure boundary integrity, the post-fire intended function to provide feedwater to the steam generators is assured.

Therefore, no specific aging management program is required.

Nevertheless, as a conservative measure aging effects and aging management, programs have been identified for components required to support the AFW Pump Room Fire Event.

License Renewal Drawinas No LRA drawings are provided based on the intended function of supporting safe shutdown in the event of a fire in the auxiliary-feed pump room. For those components evaluated with other systems, see the referenced sections for drawing information.

3.4.2 Results The following system tables summarize the results of aging management reviews and the NUREG-1 801 comparison for the condensate storage system.

Table 3.4.2-1-1P2 Main Steam System-Summary of Aging Management Review Table 3.4.2-1-1P3 Main Steam System-Summary of Aging Management Review Table 3.4.2-2-IP2. Main Feedwater System-Summary of Aging Management Review Table 3.4.2-2-1P3 Main Feedwater System-Summary of Aging Management Review Table 3.4.2-3-1P2 Auxiliary Feedwater System-Summary of Aging Management Review Table 3.4.2-3-IP3 Auxiliary Feedwater System-Summary of Aging Management Review Table 3.4.2-4-1P2 Steam Generator Blowdown System-Summary of Aging Management Review Table 3.4.2-4-IP3 Steam Generator Blowdown System-Summary of Aging Management Review

IP2 AFW Pump Room Fire Event Aging management of the systems required to supply feedwater to the steam generators during a fire in the AFW pump room is not based on an analysis of materials, environments and aging effects. The components in the systems required to supply feedwater to the steam generators during the short duration of the fire event are in service at the time the event occurs or their availability is checked daily. Therefore, integrity of the systems and components required to perform post-fire intended functions for at least one hour is continuously confirmed by normal plant operation. During the event these systems and components must continue to perform their intended functions to supply feedwater to the steam generators for a minimum of one hour. Significant degradation that could threaten the performance of the intended functions will be apparent in the period immediately preceding the event and corrective action will be required to sustain continued operation: For the minimal one hour period that these systems would be required to provide make up to the steam generators, further aging degradation that would not have been apparent prior to the event is negligible. Therefore, no aging effects are identified, and no Summary of Aging Management Review tables are is-net required.

The IP1 condensate storage tanks are only subject to intermittent service.

Therefore, a daily check of tank level and intermittent usage of piping and valves from the IP1 CSTs to the IP2 condenser confirm availability. Significant degradation that could threaten the performance of the intended functions will be apparent in the period immediately preceding the event and corrective action will be required to sustain continued operation. Therefore, identification of aging effects and Summary of Aging Management Review tables are not required.

The use of this approach for confirmation of the integrity of systems required to perform the post-fire intended function of supplying water to the steam generators is analogous to the approach used for confirmation of condenser integrity in the MSIV leakage pathway of boiling water reactors. In this MSIV leakage pathway scenario, the intended function of the condenser (holdup and plateout of MSIV leakage) is continuously confirmed by normal plant operation.

The use of this approach has been accepted by the staff (NUREG-1796, Dresden and Quad Cities SER, Section 3.4.2.4.4, and NUREG-1769, Peach Bottom SER, Section 3.4.2.3), where they concluded that main condenser integrity is continually verified during normal plant operation and no aging management program is required to assure thepost-accident intended function.

Nevertheless, as a conservative measure aqinq effects and aging managqement, programs have been identified for components required to support the AFW Pump Room Fire Event.

NL-12-190 Page 23 of 23 Dockets 50-247 and 50-286 Attachment I Table 3.3.2-13-1P2: Fuel Oil Systems Component Intended Aging Effect Aging Management NUREG- Table 1 Environment Requiring Programs 1801 Vol. 2 Item Type Function Material Management Item Surfaces VII.I-8 V1A.-87731-83.3.1-58 A ray castExternal Pressure Pump casing Pressure Gray cast Air - indoor (ext) Loss of material Src Monitoring

' boundary iro._n Mntrn VII.HI-10 3.3.1-20 B 316 Pump casing Pressure Gray cast Fuel oil (int) Loss of material Monitoring boundary ironnMo

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