NLS2009049, Response to Request for Additional Information for License Renewal Application - Section B and C

Response to Request for Additional Information for License Renewal Application - Section B and C

ML091800024
Person / Time
Site:	Cooper
Issue date:	06/22/2009
From:	Minahan S Nebraska Public Power District (NPPD)
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NLS2009049, TAC MD9737, TAC MD9763
Download: ML091800024 (20)

Text

H Nebraska Public Power District "Always there when you need us" 54.17 NLS2009049 June 22, 2009 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001

Subject:

Response to Request for Additional Information for License Renewal Application

- Safety RAI and Revised RAI Cooper Nuclear Station, Docket No. 50-298, DPR-46

References:

1. Letter from Tam Tran, U.S. Nuclear Regulatory Commission, to Stewart B. Minahan, Nebraska Public Power District, dated June 8, 2009, "Request for Additional Information for the Review of the Cooper Nuclear Station License Renewal Application (TAC No. MD9763 and MD9737)."

2. Letter from Stewart B. Minahan, Nebraska Public Power District, to U.S.

Nuclear Regulatory Commission, dated September 24, 2008, "License Renewal Application" (NLS2008071).

Dear Sir or Madam:

The purpose of this letter is for the Nebraska Public Power District to respond to Sections B and C of the Nuclear Regulatory Commission Request for Additional Information (RAI) (Reference

1) related-to the Cooper Nuclear Station License Renewal Application (LRA) aging management review and aging management programs. These responses are provided in Attachment 1.

Certain changes to the LRA (Reference 2) have been made to reflect these RAI responses and to make other miscellaneous changes. These changes are provided in Attachment 2.

Should you have any questions regarding this submittal, please contact David Bremer, License Renewal Project Manager, at (402) 825-5673.

COOPER NUCLEAR STATION P.O. Box 98 / Bro wnville, NE 68327-0098 Telephone: (402) 825-3871 / Fax: (402) 825-5211 www.nppd.com

NLS2009049 Page 2 of 2 I declare under penalty of perjury that the foregoing is true and correct.

Executed on / 07 (Date)

Sincerely, wart B. Minahan Vice President - Nuclear and Chief Nuclear Officer

/WV Attachments cc: Regional Administrator w/ attachments USNRC - Region IV Cooper Project Manager w/ attachments USNRC - NRR Project Directorate IV- 1 Senior Resident Inspector w/ attachments USNRC - CNS Nebraska Health and Human Services w/ attachments Department of Regulation and Licensure NPG Distribution w/o attachments CNS Records w/ attachments

ATTACHMENT 3 LIST C)F REGULATORY COMMITMENTS© 4 I 4

ATTACHMENT 3 LIST OF REGULATORY COMMITMENTS© Correspondence Number: NLS2009049 The following table identifies those actions committed to by Nebraska Public Power District (NPPD) in this document. Any other actions discussed in the submittal represent intended or planned actions by NPPD. They are described for information only and are not regulatory commitments. Please notify the Licensing Manager at Cooper Nuclear Station of any questions regarding this document or any associated regulatory commitments.

COMMITMENT COMMITTED DATE COMMITMENT NUMBER OR OUTAGE None

4. 4

+ 4

+

+

+

I PROCEDURE 0.42 REVISION 23 PAGE 19 OF 26 1

NLS2009049 Page 1 of 7 Attachment 1 Response to Request for Additional Information for License Renewal Application - Safety RAI and Revised RAI Cooper Nuclear Station, Docket No. 50-298, DPR-46 The Nuclear Regulatory Commission (NRC) Request for Additional Information (RAI) regarding the License Renewal Application (LRA) aging management review and aging management programs are shown in italics. The Nebraska Public Power District's (NPPD) response to each question is shown in block font.

NRC Request: RAI3.3.2.2.3.3-1 Background.:

Section 3.3.2.2.3.3 "Cracking due to Stress CorrosionCracking (SCC)" of the StandardReview Plan-License Renewal (SRP-LR) identifies SCC as an aging effect requiringmanagementfor stainless steel diesel engine exhaustpiping,piping components, andpiping elements exposed to diesel exhaust. The generic aging lessons learned (GALL) report identifies this MEAP combination in Item VII.H2-1. Aging management review (AMR) Item AP-33 in Table IIA of NUREG-1833, "Technical Basesfor Revision to the License Renewal Guidance Documents, "

provides a basisfor why it is importantto identify SCC as an aging effect requiringmanagement (AERM)for the internal surfaces of stainless steel emergency diesel generatorexhaustpiping that are exposed to diesel exhaust. Specifically, NUREG-1833 states that hot diesel engine exhaust may contain moisture andparticulateswhich lead to SCC in stainlesssteel diesel exhaust components.

Issue:

Contraryto the License Renewal Guidance identified above, the applicantstates that stainless steel exhaust components are not subject to significant moisture accumulation that would allow cracking to occur. The staff disagreeswith this approach,and takes the position that this must be identified as an AERM similar to the GALL Item VII.H2-1.

Request:

Pleaseprovide an aging managementprogram (AMP) andAMR line item to manage the aging effect recommended by GALL VII.H2-1 NPPD Response:

NPPD concurs that cracking is an aging effect requiring management for the diesel generator exhaust stainless steel expansion joint. Associated changes to LRA are provided in Attachment 2, Changes 1, 2, 5, and 9.

NLS2009049 Page 2 of 7 NRC Request: RAI3.3.2.2. 7.3-1 Background."

Section 3.3.2.2. 7.3, "Loss of Materialdue to General, Pitting,and Crevice Corrosion" of the SRP-LR identifies loss of materialas an AERMfor steel and stainlesssteel diesel exhaust piping, piping components, andpiping elements exposed to diesel exhaust. The applicanthas credited the plant specific AMP B. 1.31, PeriodicSurveillance and Preventive Maintenance (PSPM)

Program with managingthis aging effect for emergency diesel generatorexhaustpiping,piping components, andpiping elements.

Issue:

The PSPMProgram identifies the use of visual inspectionsperformed on a "representative sample" of diesel generatorexhaust gas components to manage the loss of materialaging effect.

The AMP indicates that sample size is determined using guidancefrom EPRI TR-107514, Age-Related DegradationInspection Method and Demonstration,for a 90% confidence level that 90% of the population does not experience degradation. However, it is not clear what the population and sample size will be for the diesel generatorsystem exhaust components.

Additionally, the AMP indicates that "components with the same material-environment combinations at otherfacilities may be included in the sample." The inspection of components at other facilitieswould not necessarily offer an accuraterepresentationof the aging effects at the currentfacility, and thus brings into question the extent of which this method will be used and the effect of its inclusion on the overall population and sample size.

Request:

a) Pleaseprovide the total actualpopulation andsample size of diesel generatorexhaust gas components to manage the loss of material aging effect at CNS.

b) Please clarify the use of "inspection of components at otherfacilities" as part of the representativesample for diesel generatorexhaust gas components to manage the loss of materialaging effect at CNS, and identify the specific impact this will have on the overallpopulation and sample size.

NPPD Response:

a) The total population of diesel generator exhaust gas components is eight. Using the 90/90 confidence level as defined in EPRI Report TR- 107514, the sample size will be seven.

b) The use of "inspection of components at other facilities" was intended to allow the inspection results for components with identical material and environment combinations as those at Cooper Nuclear Station (CNS) to be used in the sample population for CNS.

However, NPPD plans to perform the required number of inspections to attain a 90/90 confidence level using only CNS components. Therefore, LRA Section B. 1.31 is revised

NLS2009049 Page 3 of 7 to remove reference to crediting components with the same material-environment combinations at other facilities (see Attachment 2, Change 8).

NRC Request: RAI3.3.2.2. 7.3-2 Backzround."

Section 3.3.2.2. 7.3, "Loss of Material due to General,Pitting,and Crevice Corrosion" of the SRP-LR identifies loss of material as an AERMfor steel and stainless steel diesel exhaustpiping, piping components, andpiping elements exposed to diesel exhaust. The applicanthas credited the plant specific AMP B. 1.16, Fire ProtectionProgramwith managingthis aging effect for the dieselfire pump engine exhaust piping,piping components, andpiping elements.

Issue.

License renewal application (LRA) AMP B.]. 16, FireProtectionProgramstates as an enhancement that the dieselfire pump engine carbon steel exhaust components are inspectedfor evidence of corrosion or cracking. However, the LRA is not clear whether the inspection will be an internal inspection or external only. An internal inspection is necessary to inspectfor the aging effects caused by exhaust gas.

Request:

Please clarify whether the inspection conducted by the FireProtectionProgram includes the internalsurface of the components.

NPPD Response:

The environment that credits the Fire Protection Program discussed in LRA Section 3.3.2.2.7 item 3 is exhaust gas (internal) for the component types of expansion joint, muffler and piping shown in Table 3.3.2-6. Therefore the inspection documented in the enhancement is an internal inspection. External inspections of these components are performed under the External Surfaces Monitoring Program as shown in Table 3.3.2-6.

NRC Request: RAI B. 1.15-9 Based on the conference call between the staff and the applicanton May 20, 2009, this RAI was updatedasfollow:

Background:

ProgramElement 4 of NUREG-1801 Section XM1 is concerningdetection of aging effects.

Under the CNS Fatigue MonitoringProgram,B. 1.15 (CNS-RPT-LRD02, Revision 1), program Element 4 Subsection B states: "No actions are taken as part of this program to detect aging effects ... If a design cycle assumption is approached,corrective action is taken which will include update offatigue usage calculation, if necessary."

NLS2009049 Page 4 of 7 In addition, ProgramElement 5 of NUREG-1801 Section XM] is concerningmonitoring and trending. Under the CNS FatigueMonitoringProgram,B.]. 15 (CNS-RPT-LRD02, Revision 1),

ProgramElement 5, Subsection B, it states: "The FatigueMonitoringProgram,monitors the number ofpressure and temperature transientcycles andperiodicallycompares this cycle count with the design cycle count to ensure thatfatigue sensitive components remain within their allowable design...

Issue Clarificationis deemed necessary,as describedbelow. Additionally, Element 5 indicates that only the feedwater nozzle will be monitored.

Request (a) Pleaseprovide basis why taking "no action" will achieve the goal of detecting aging effects.

(b) Please explain why "design cycle" can be used as basisfor detecting aging effects when the design transients do not include all thermal events actually experienced by the reactorcoolantpressure boundary components, as discussed in RAI B.]. 15-2.

(c) The LRA states that the environmentalfatigue analyses were performed based on the 60-yearprojected cycles and LRA Table 4.3-1 shows that the 60-year projectedcycles for most of the transientsare less than the design cycles. With these conditions in mind, components could have failed before the design cycles are approached.Provide justification that the design cycles can be used as criteriato detect aging effects.

(d) GALL requiresall high fatigue locations are monitored, notjust at the most limiting location within the applicable NUREG/CR-6260 locations, as minimum. Pleaseprovide justification that CNS will monitor the feedwater nozzle only.

NPPD Response:

(a) The goals of the program do not include detecting aging effects. With respect to detection of aging effects, Element 4 ofNUREG-1801 Section X.M1 states only, "The program provides for periodic update of the fatigue usage calculations." As indicated under the heading of Preventive Actions in NUREG-1801,Section X.M1, the program entails actions to prevent fatigue cracking of reactor coolant system components. The program ensures the numbers of cycles assumed in design basis fatigue analyses that include consideration of the effect of the reactor water environment remain valid, thereby preventing the effects of aging due to fatigue. The CNS program provides for periodic update of the number of cycles incurred by the plant. The CNS program also provides update of the fatigue analyses if the incurred number of cycles is approaching the

NLS2009049 Page 5 of 7 analyzed number. As indicated in LRA Section B. 1.15, the CNS program will be consistent with the guidance provided in NUREG- 1801 Section X.M 1.

(b) The term "design cycle" is not limited to the cycles in USAR Table 111-3-1, but includes the analyzed cycles in the fatigue analyses of record. The response to RAI B. 1.15-2' explains that CNS has added analyzed transients to the Fatigue Monitoring Program (FMP) as they have been identified. Where appropriate, the fatigue analyses of record have been revised accordingly. Thus the "projected transients" in LRA Table 4.3-1 includes the transients identified to date that would contribute to fatigue usage at CNS.

The actuation of a safety/relief valve was recently identified as a transient to be recorded as input to the FMP, as documented in the second enhancement for this AMP. The FMP includes identified transients used as the basis for fatigue analyses to assure that the fatigue analyses remain valid.

(c) LRA Table 4.3-3 provides the results of analyses that project the CUFs for the locations identified in NUREG/CR-6260 for 60 years of operation including consideration of environmental effects. As discussed in LRA Section 4.3.3, there is no analysis of environmentally assisted fatigue under the current licensing basis. Rather, the effect on fatigue life of the reactor water environment is a new consideration for license renewal.

Applying the Fen identified in Table 4.3-3 is not required during the initial 40 years of operation, consistent with the closure of Generic Safety Issue 190. Upon receipt of a renewed license, these analyses become the analyses of record. At that time, CNS will revise the FMP to include the numbers of analyzed cycles (projected cycles) in the environmentally assisted fatigue analyses as acceptance criteria, to assure that those analyses remain valid throughout the period of extended operation.

(d) The program is not limited to tracking only the cycles that affect the feedwater nozzle.

The FMP at CNS counts the occurrence of design transients and compares the actual cycles incurred to the analyzed cycles for the applicable reactor coolant system components at CNS. As a cycle-based program it is not limited to specific components, but covers all applicable reactor coolant system components. Components that have a required fatigue analysis are covered by the cycles monitored under the FMP.

Letter from Stewart B. Minahan (NPPD) to U.S. NRC, "Response to Request for Additional Information for License Renewal Application - Aging Management Programs" (NLS2009040), dated June 15, 2009.

NLS2009049 Page 6 of 7 NRC Request: RAIB.I.15-10 Based on the conference call between the staff and the applicanton May 20, 2009, this RAI was updated asfollow:

Background:

ProgramElement 6 of NUREG-1801 Section XM1 is concerningacceptance criteria. Under the CNS Fatigue MonitoringProgram,B. 1. 15 (CNS-RPT-LRD02, Revision 1), Program Element 6 Subsection B states: "The FatigueMonitoringProgram acceptance criteriaare that none of the transients exceeded the allowable numbers in USAR Table 111-3-1 ... "

Issue.

Clarificationis deemed necessary, as describedbelow.

Request:

(a) Questions (b) and (c) of RAI B. 1. 15-32 apply here. Please explain accordingly.

(b) GALL Section XM1 Element 6 requires maintainingfatigue usage below the design code limit consideringenvironmentalfatigue effects. CNS Fatigue MonitoringProgram Element 6 does not mention environmentalfatigue effects. Please explain why.

NPPD Response:

(a) The following is Question (b) of RAI B.1.15-9:

"Please explain why 'design cycle' can be used as basisfor detecting aging effects when the design transientsdo not include all thermal events actually experienced by the reactor coolantpressure boundary components, as discussedin RAI B. 1.15-2."

NPPD Response to RAI B. 1.15-9 (b) As Applied to the Acceptance Criteria Element NUREG-1801 Section X.M1 The term "design cycle" is not limited to the cycles in USAR Table 111-3-1, but includes the analyzed cycles in the fatigue analyses of record. The response to RAI B. 1.15-2 explained that NPPD has added analyzed transients to the FMP as they have been identified. Where appropriate, the fatigue analyses of record have been revised accordingly. Thus the "projected transients" in LRA Table 4.3-1 includes the transients identified to date that would contribute to fatigue usage at CNS. The actuation of a safety/relief valve was recently identified as a transient to be recorded as input to the FMP, as documented in the second enhancement for this AMP. The FMP includes 2 In an e-mail dated June 18, 2009, from Tam Tran (U.S. NRC) to Bill Victor (NPPD) it was clarified that this RAI should have referred to RAI B. 1.15-9, which superseded RAI B. 1.15-3.

NLS2009049 Page 7 of 7 identified transients used as the basis for fatigue analyses to assure that the fatigue analyses remain valid.

The following is Question (c) of RAI B. 1.15-9:

"The LRA states that the environmentalfatigue analyses were performed based on the 60-year projected cycles and LRA Table 4.3-1 shows that the 60-yearprojected cycles for most of the transientsare less than the design cycles. With these conditions in mind, components could have failed before the design cycles are approached Provide justification that the design cycles can be used as criteria to detect aging effects."

NPPD Response to RAI B. 1.15-9 (c) As Applied to the Acceptance Criteria Element of NUREG-1801 Section X.M1 LRA Table 4.3-3 provides the results of analyses that project the CUFs for the locations identified in NUREG/CR-6260 for 60 years of operation including consideration of environmental effects. As discussed in LRA Section 4.3.3, there is no analysis of environmentally assisted fatigue under the current licensing basis. Rather, the effect on fatigue life of the reactor water environment is a new consideration for license renewal.

Applying the Fen values identified in Table 4.3-3 is not required during the initial 40 years of operation, consistent with the closure of Generic Safety Issue 190. Upon receipt of a renewed license, these analyses become the analyses of record. At that time, NPPD will revise the FMP to include the numbers of analyzed cycles (projected cycles) in the environmentally assisted fatigue analyses as acceptance criteria, to assure that those analyses remain valid throughout the period of extended operation.

(b) As stated in LRA Section B.1.15, the FMP will be enhanced to consider the effect of the reactor water environment. This enhancement applies to element 6 acceptance criteria as shown in LRA Section B. 1.15 and in the associated CNS program basis document.

NLS2009049 Page 1 of 10 Attachment 2 Changes to the License Renewal Application Related to Aging Management Review and Aging Management Program RAI Responses and Miscellaneous Items Cooper Nuclear Station, Docket No. 50-298, DPR-46 This attachment provides changes to the LRA based on the responses to the RAI provided in . Certain additional changes are made to the LRA based on dialogue with the NRC Staff. The revisions are shown in underline/strikeout format.

I1. Section 3.3.2.2.3 item 3 states the following:

"Cracking due to SCC can occur in stainless steel diesel engine exhaust piping exposed to diesel exhaust when moisture can collect inside the component when the diesel is not in operation. At CNS, the stainless steel exhaust components are not subject to significant moisture accumulation that would allow cracking to occur. Therefore, cracking due to SCC is not an aging effect requiring management for the stainless steel diesel engine exhaust piping. This item was not used."

This is revised to read:

"Cracking due to SCC ean-eeeur in stainless steel diesel engine exhaust pipingcomponents exposed to diesel exhaust when moisture can collect inside the comnponent when the diesel is net in eper-ation. At CNS, the stainless steel exhaust components are not subjeet to significant moistufe accumulation that would allow cr-acking to occuf. Ther-efor-e, cr-acking due to SCC is net an aging effect requrin tsed.is an aging effect requiring management at CNS. Cracking of stainless steel exhaust components in the emergency diesel generator system is managed by the Periodic Surveillance and Preventive Maintenance Program. This program uses visual and other NDE techniques to manage cracking of the components. These inspections will manage the aging effect of cracking such that the intended function of the component will not be affected."

Reference:

Response to RAI 3.3.2.2.3.3-1

NLS2009049 Attachment 2 Page 2 of 10

2. Table 3.3.1 Item Number 3.3.1-6 on Page 3.3-28 states:

3.3.1-6 Stainless steel Cracking due Plant Yes, plant This item was not used. The diesel engine to stress specific specific stainless steel diesel exhaust exhaust piping, corrosion components are not subject to piping cracking significant moisture components, accumulation, which precludes and piping cracking due to stress elements corrosion cracking.

exposed to diesel exhaust See Section 3.3.2.2.3 item 3.

This is revised to read:

3.3.1-6 Stainless steel Cracking due Plant Yes, plant This item was not used. The diesel engine to stress specific specific stainless steel diesel exhau.

exhaust piping, corrosion components are not subject to piping cracking sigificant moistur components, accum uatien, w.hich precludes and piping cr.acking due to stress elements .o..osion

r.acking.

exposed to Cracking of stainless steel diesel exhaust diesel exhaust components will be managed by the Periodic Surveillance and Preventive Maintenance Program.

See Section 3.3.2.2.3 item 3.

Reference:

Response to RAI 3.3.2.2.3.3-1

NLS2009049 Attachment 2 Page 3 of 10

3. Table 3.3.1 Item Number 3.3.1-68 on Page 3.3-55 states:

3.3.1-68 Steel piping, Loss of Fire No Consistent with NUREG- 1801 for fire piping material due Water protection system components. The components, to general, System loss of material in steel components and piping pitting, exposed to raw water is managed by elements crevice, and the Fire Water System Program. For exposed to microbiologic steel components of the potable water raw water ally system, also exposed to treated but influenced unmonitored (raw) water, the Periodic corrosion, and Surveillance and Preventive fouling Maintenance Program manages loss of material by mean of periodic visual inspections.

This is revised to read:

3.3.1-68 Steel piping, Loss of Fire No Consistent with NUREG- 1801--f-fi-re piping material due Water protection system

.. mponents. The components, to general, System loss of material in steel components and piping pitting, exposed to raw water is managed by elements crevice, and the Fire Water System Program. Fef exposed to microbiolog steel componenits of the potable wate raw water ically system, also exposed to treated but.

influenced ... nitred (raw) water-, the Periodic-corrosion, Surveillaace and Pr-evente and fouling Maintenance Program manages losso mater-ial by mean of per-iodic visual inspeefiefts7

Reference:

This change is a clarification to remove credit for the PSPM Program in the aging management of potable water system steel components, consistent with the Program Description discussion in LRA Section B. 1.31.

NLS2009049 Attachment 2 Page 4 of 10

4. Table 3.3.1 Item Number 3.3.1-70 on Page 3.3-56 states:

3.3.1-70 Copper alloy Loss of material Fire Water No Consistent with NUREG-piping, piping due to pitting, System 1801. The loss of material components, crevice, and in copper alloy components and piping microbiologicall exposed to raw water is elements y influenced managed by the Fire Water exposed to raw corrosion, and System Program.

water fouling This is revised to read:

3.3.1-70 Copper alloy Loss of material Fire Water No Consistent with NUREG-piping, piping due to pitting, System 1801 for fire protection components, crevice, and system components. The and piping microbiologically loss of material in copper elements influenced alloy components exposed exposed to raw corrosion, and to raw water is managed by water fouling the Fire Water System Program. For copper alloy components of the potable water system, also exposed to treated, but unmonitored (raw) water, the Periodic Surveillance and Preventive Maintenance Program manages loss of material by means of periodic visual inspections.

Reference:

This change is a clarification which adds information on the aging management of potable water system copper alloy components, consistent with the Program Description discussion in LRA Section B. 1.31.

NLS2009049 Attachment 2 Page 5 of10

5. Table 3.3.2-4 provides the following summary on Page 3.3-82 of the aging management evaluation for the diesel generator system:

Expansion Pressure Stainless Air - None None VII.J-15 3.3.1-94 A joint boundary steel indoor (AP-17)

(ext)

Expansion Pressure Stainless Air - Loss of External G joint boundary steel outdoor material surfaces (ext) monitoring Expansion Pressure Stainless Exhaust Loss of Periodic VII.H2-2 3.3.1-18 E joint boundary steel gas material surveillance (A-27)

(int) and preventive maintenance Filter Pressure Carbon Air - Loss of External VII.I-8 3.3.1-58 A housing boundary steel indoor material surfaces (A-77)

(ext) monitoring Filter Pressure Carbon Air - Loss of External V.D2-16 3.2.1-32 E housing boundary steel indoor material surfaces (E-29)

I (int) monitoring Filter Pressure Carbon Lube Loss of Oil analysis VII.H2-20 3.3.1-14 A, 302 housing boundary steel oil (int) material (AP-30)

Heat Pressure Carbon Air - Loss of External VII.H2-3 3.3.1-59 A exchanger boundary steel indoor material surfaces (AP-41)

(bonnet) (ext) monitoring Heat Pressure Carbon Raw Loss of Service VII.C1-5 3.3.1-77 C exchanger boundary steel water material water (A-64)

(bonnet) (int) integrity

NLS2009049 Attachment 2 Page 6 of 10 This is revised to read:

Expansion Pressure Stainless Air - None None VII.J- 15 3.3.1-94 A joint boundary steel indoor (AP-17)

(ext)

Expansion Pressure Stainless Air - Loss of External G joint boundary steel outdoor material surfaces I (ext) monitoring Expansion Pressure Stainless Exhaust Loss of Periodic VII.H2-2 3.3.1-18 E joint boundary steel gas material surveillance (A-27)

(int) and preventive maintenance Periodic Exhaust Surveillance Expansion Pressure Stainless Gas3..- Crackin and VII.H2-1 E Joint boundary Steel g Preventive (AP-33) -

Maintenanc e

Filter Pressure Carbon Air - Loss of External VII.I-8 3.3.1-58 A housing boundary steel indoor material surfaces (A-77)

(ext) monitoring Filter Pressure Carbon Air - Loss of External V.D2-16 3.2.1-32 E housing boundary steel indoor material surfaces (E-29)

I (int) monitoring Filter Pressure Carbon Lube Loss of Oil analysis VII.H2-20 3.3.1-14 A, 302 housing boundary steel oil (int) material (AP-30)

Heat Pressure Carbon Air - Loss of External VII.H2-3 3.3.1-59 A exchanger boundary steel indoor material surfaces (AP-41)

(bonnet) (ext) monitoring Heat Pressure Carbon Raw Loss of Service VII.C1-5 3.3.1-77 C exchanger boundary steel water material water (A-64)

(bonnet) (int) integrity I I _ I

Reference:

Response to RAI 3.3.2.2.3.3-1

NLS2009049 Attachment 2 Page 7 of 10

6. LRA Table 3.3.2-14-17 on Pages 3.3-216 and 3.3-217 states the following:

Bolting Pressure Carbon Air - Loss of Bolting integrity VII.I-4 3.3.1-43 A boundary steel indoor material (AP-27)

(ext)

Bolting Pressure Carbon Air - Loss of Bolting integrity VII.I-5 3.3.1-45 A boundary steel indoor preload (AP-26)

(ext)

Piping Pressure Copper Air- None None V.F-3 3.2.1-53 C boundary alloy indoor (EP-10)

(ext)

Piping Pressure Copper Treated Loss of Periodic VII.G-24 3.3.1-68 E, 304 boundary alloy water material surveillance and (A-33)

(int) preventive maintenance Tubing Pressure Copper Air - None None V.F-3 3.2.1-53 C boundary alloy indoor (EP-10)

(ext)

Tubing Pressure Copper Treated Loss of Periodic VII.G-24 3.3.1-68 E, 304 boundary alloy water material surveillance and (A-33)

(int) preventive maintenance Valve Pressure Copper Air- None None V.F-3 3.2.1-53 C body boundary alloy indoor (EP-10)

(ext)

Valve Pressure Copper Treated Loss of Periodic VII.G-24 3.3.1-68 E, 304 body boundary alloy water material surveillance and (A-33)

(int) preventive maintenance

NLS2009049 Attachment 2 Page 8 of 10 This is revised to read:

Bolting Pressure Carbon Air - Loss of Bolting integrity VII.I-4 3.3.1-43 A boundary steel indoor material (AP-27)

(ext)

Bolting Pressure Carbon Air- Loss of Bolting integrity VII.I-5 3.3.1-45 A boundary steel indoor preload (AP-26)

(ext)

Piping Pressure Copper Air - None None V.F-3 3.2.1-53 C boundary alloy indoor (EP-10)

(ext)

Piping Pressure Copper Treated Loss of Periodic VII.G 24 3.3.1 68 E, 304 boundary alloy water material surveillance and (A 33) 3.3.1-70 (int) preventive VII.G-12 maintenance (A-45)

Tubing Pressure Copper Air- None None V.F-3 3.2.1-53 C boundary alloy indoor (EP-10)

(ext)

Tubing Pressure Copper Treated Loss of Periodic VI.G 24 3.3.I 68 E, 304 boundary alloy water material surveillance and (A-33) 3.3.1-70 (int) preventive VII.G- 12 maintenance (A-45 Valve Pressure Copper Air - None None V.F-3 3.2.1-53 C body boundary alloy indoor (EP-10)

(ext)

Valve Pressure Copper Treated Loss of Periodic V-I.G 24 3.3.1 68 E, 304 body boundary alloy water material surveillance and (A 33) 3.3.1-70 (int) preventive VII.G- 12 maintenance (A-45)

Reference:

NPPD has identified a more appropriate NUREG- 1801 reference for two lines of LRA Table 3.3.2-14-17. Reference to item (A-33) is changed to (A-45).

7. Appendix A, Section A. 1.1.31 (Periodic Surveillance and Preventive Maintenance Program) and Appendix B, Section B. 1.31 (Periodic Surveillance and Preventive Maintenance) Program Description state in the first and second paragraphs respectively:

"The Periodic Surveillance and Preventive Maintenance Program is an existing program that includes periodic inspections and tests that manage aging effects not managed by other aging management programs. In addition to specific activities in the plant's preventive maintenance program and surveillance program, the Periodic Surveillance and Preventive Maintenance Program includes enhancements to add new activities. The

NLS2009049 Page 9 of 10 preventive maintenance and surveillance testing activities are generally implemented through repetitive tasks or routine monitoring of plant operations. The program is credited with managing loss of material from external surfaces for situations in which external and internal material and environment combinations are the same such that internal surface condition is representative of external surface condition."

This is revised to read:

"The Periodic Surveillance and Preventive Maintenance Program is an existing program that includes periodic inspections and tests that manage aging effects not managed by other aging management programs, including loss of material, cracking, change in material properties, loss of material due to wear, and fouling. In addition to specific activities in the plant's preventive maintenance program and surveillance program, the Periodic Surveillance and Preventive Maintenance Program includes enhancements to add new activities. The preventive maintenance and surveillance testing activities are generally implemented through repetitive tasks or routine monitoring of plant operations.

While primarily used for managing the effects of aging on internal surfaces,Tlthe program is also credited with managing loss of material from external surfaces for situations in which external and internal material and environment combinations are the same such that internal surface condition is representative of external surface condition."

Reference:

This clarification itemizes the aging effects included under the PSPM Program and underscores that the PSPM Program is primarily used for managing the effects of aging on internal component surfaces.

8. Appendix B, Section B. 1.31 (Periodic Surveillance and Preventive Maintenance) states under the Program

Description:

"In cases where a representative sample is inspected by this program, a representative sample will be selected from each unique material and environment combination covered under each of the program activities. Each sample size will be based on Chapter 4 of EPRI document 107514, Age-related Degradation Inspection Method and Demonstration, which outlines a method to determine the number of inspections required for 90%

confidence that 90% of the population does not experience degradation (90/90).

Components with the same material-environment combinations at other facilities may be included in the sample."

This is revised to read:

"In cases where a representative sample is inspected by this program, a representative sample will be selected from each unique material and environment combination covered under each of the program activities. Each sample size will be based on Chapter 4 of

I . . I NLS2009049 Attachment 2 Page 10 ofO10 EPRI document 107514, Age-related Degradation Inspection Method and Demonstration, which outlines a method to determine the number of inspections required for 90%

confidence that 90% of the population does not experience degradation (90/90).

included in the sample."

Reference:

Response to RAI 3.3.2.2.7.3-1

9. Appendix B, Section B. 1.31 (Periodic Surveillance and Preventive Maintenance) states under the Program Description table of activities for the Diesel generator (DG) system:

Diesel generator Perform internal visual inspection of a representative sample (DG) system of DG exhaust gas components to manage loss of material.

Perform intercooler operability testing to manage fouling for stainless steel tubes and aluminum fins.

Perform visual inspection of a representative sample of DG service air component internal surfaces to manage loss of material.

This is revised to read:

Diesel generator Perform internal visual and other NDE inspections of a (DG) system representative sample of DG exhaust gas components to manage loss of material and cracking.

Perform intercooler operability testing to manage fouling for stainless steel tubes and aluminum fins.

Perform visual inspection of a representative sample of DG service air component internal surfaces to manage loss of material.

Reference:

Response to RAI 3.3.2.2.3.3-1