NUREG-1905, Safety Evaluation Report Related to the License Renewal of James A. FitzPatrick Nuclear Power Plant

NUREG-1905 Safety Evaluation Report Related to the License Renewal of James A. FitzPatrick Nuclear Power Plant.

ML081510826
Person / Time
Site:	FitzPatrick
Issue date:	04/30/2008
From:	FitzPatrick, Entergy Nuclear Operations, Office of Nuclear Reactor Regulation
To:
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NUREG-1905
Download: ML081510826 (738)

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TU.S.P4IVC United States Nuclear Regulatory Commission NUREG-1 905 ProtectingPeople andthe Environment saf(y EwaýUBUa*O Repo*

Related to the License Renewal of James A. FtzPatrick Nuclear Power Plant Docket No. 50-333 Entergy Hud©l*aw Ft Pactkikl LLC En~te*irgy lHudlar Olpsraf~ons, IMc.-

Office of Nuclear Reactor Regulation

AVAILABILITY OF REFERENCE MATERIALS INNRC PUBLICATIONS NRC Reference Material Non-NRC Reference Material As of November 1999, you may electronically access Documents available from public and special technical NUREG-series publications and other NRC records at libraries include all open literature items, such as NRC's Public Electronic Reading Room at books, journal articles, and transactions, Federal http://www. nrc.gov/reading-rm.html. Register notices, Federal and State legislation, and Publicly released records include, to name a few, congressional reports. Such documents as theses, NUREG-series publications; FederalRegister notices; dissertations, foreign reports and translations, and applicant, licensee, and vendor documents and non-NRC conference proceedings may be purchased correspondence; NRC correspondence and internal from their sponsoring organization.

memoranda; bulletins and information notices; inspection and investigative reports; licensee event reports; and Commission papers and their Copies of industry codes and standards used in a attachments. substantive manner in the NRC regulatory process are maintained at-NRC publications in the NUREG series, NRC The NRC Technical Library regulations, and Title 10, Energy, in the Code of Two White Flint North FederalRegulations may also be purchased from one 11545 Rockville Pike of these two sources. Rockville, MD 20852-2738

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• U.S.NRC United States Nuclear Regulatory Commission NUREG-1905 ProtectingPeople and the Environment Safety Evaluation Report Related to the License Renewal of James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 Entergy Nuclear FitzPatrick, LLC Entergy Nuclear Operations, Inc.

Manuscript Completed: April 2008 Date Published: April 2008 Office of Nuclear Reactor Regulation Division of License Renewal

ABSTRACT This safety evaluation report (SER) documents the technical review of the James A. FitzPatrick Nuclear Power Plant (JAFNPP) license renewal application (LRA) by the United States (US)

Nuclear Regulatory Commission (NRC) staff (the staff). By letter dated July 31, 2006, Entergy Nuclear Operations, Inc. (ENO or the applicant) submitted the LRA in accordance with Title 10, Part 54, "Requirements for Renewal of Operating Licenses for Nuclear Power Plants," of the Code of FederalRegulations. ENO requests renewal of the JAFNPP operating license (Facility Operating License Number DPR-59) for a period of 20 years beyond the current expiration at midnight October 17, 2014.

JAFNPP is located approximately 7 miles northeast of Oswego, New York. The NRC issued the JAFNPP construction permit on May 20, 1970, and operating license on October 17, 1974.

JAFNPP is of a Mark 1, General Electric (GE) 4, boiling water reactor design. GE supplied the nuclear steam supply system and Stone and Webster originally designed and constructed the balance of the plant. The JAFNPP licensed power output is 2536 megawatt thermal with a gross electrical output of approximately 881 megawatt electric.

This SER presents the status of the staff's review of information submitted through November 05, 2007, the cutoff date for consideration in the SER. On July 31, 2007, the staff issued a draft SER which identified two open items that had to be resolved before the staff makes a final determination on the application. The two open items have now been resolved and SER Section 1.5 summarizes these items and its resolutions. SER Section 6 provides the staffs final conclusion on the review of the July 31, 2006, JAFNPP LRA, and all its subsequent amendment letters as listed in SER Appendix B.

ABBREVIATIONS

AC alternating current ACI American Concrete Institute ACRS Advisory Committee on Reactor Safeguards ACSR aluminum conductor steel reinforced ADAMS Agencywide Document Access and Management System ADS automatic depressurization system AEM aging effect/mechanism AERM aging effect requiring management AFW auxiliary feedwater AHU air handling unit AMC aging management structural AME aging management electrical AMM aging management mechanical AMP aging management program AMR aging management review ANSI American National Standards Institute AOV air operated valve APCSB Auxiliary and Power Conversion Systems Branch ARI alternate rod insertion ART adjusted reference temperature ASME American Society of Mechanical Engineers ASTM American Society for Testing and Materials ATWS anticipated transient without scram B&W Babcock and Wilcox BIP Bolting Integrity Program BOP balance-of-plant BTP Branch Technical Position BWR boiling water reactor BWROG Boiling Water Reactor Owners Group BWRVIP Boiling Water Reactor Vessel and Internals Program CAD containment air dilution CASS cast austenitic stainless steel CB&I Chicago Bridge and Iron CDF core damage frequency CEOG Combustion Engineering Owners Group CF chemistry factor CFR Code of Federal Regulations CHUG CHECKWORKS Users Group Cl confirmatory item CIl containment inservice inspection CLB current licensing basis CO 2 carbon dioxide CP containment purge xiii

CR condition report CRD control rod drive CRDRL control rod drive return line CWS circulating water system CS core spray CST condensate storage tank Cu copper CUF cumulative usage factor CRUSE Charpy upper-shelf energy DBA design basis accident DBD design basis document DBE design basis event DC direct current DHR decay heat removal ECCS emergency core cooling system EDG emergency diesel generator EFPY effective full power years EMA equivalent margin analysis ENN Entergy Nuclear North ENO Entergy Nuclear Operations EPIC Emergency Plant Information Computer EOL end of life EPRI Electric Power Research Institute EQ environmental qualification ESF engineered safety features ESW emergency service water FAC flow-accelerated corrosion Fen environmental fatigue life correction factor FERC Federal Energy Regulatory Commission FF fluence factor FMP Fatigue Monitoring Program FP fire protection FPC fuel pool cooling FPCC fuel pool cooling and cleanup FR FederalRegister FSAR final safety analysis report FSER final safety evaluation report ft-lb foot-pound FW feedwater GALL Generic Aging Lessons Learned Report GDC general design criteria or general design criterion GE General Electric GElS Generic Environmental Impact Statement xiv

GL generic letter GSI generic safety issue HELB high-energy line break HPCI high pressure coolant injection HPSI high pressure safety injection HT heat transfer HVAC heating, ventilation, and air conditioning HWC hydrogen water chemistry I&C instrumentation and controls IASCC irradiation-assisted stress corrosion cracking ID inside diameter IEEE Institute of Electrical and Electronics Engineers IGSCC inter-granular stress corrosion cracking IN Information Notice, insulation (electrical)

INPO Institute of Nuclear Power Operations IPA integrated plant assessment IPE Individual Plant Examination IR insulation resistance ISG interim staff guidance ISI inservice inspection ISP Integrated Surveillance Program JAFNPP James A. FitzPatrick Nuclear Power Plant KV or kV kilo-volt LCO limiting condition for operation LMS leakage monitoring system LOCA loss of coolant accident LR license renewal LRA license renewal application LRBD license renewal boundary drawings LRD license renewal document LRIS license renewal information system LRPD license renewal project document/report LRPG license renewal project guidelines MEB metal-enclosed bus MIC microbiologically influenced corrosion MS main steam MSIV main steam isolation valve MSLCS main steam leak collection system N2 nitrogen N/A not applicable n/cm 2 neutrons per square centimeter xv

NBVI nuclear boiling vessel instrumentation NDE nondestructive examination NEI Nuclear Energy Institute NFPA National Fire Protection Association Ni nickel NMCA noble metal chemical addition NPS nominal pipe size NRC US Nuclear Regulatory Commission NSW normal service water NWC normal water chemistry NYPA New York Power Authority OD outside diameter OGH off-gas holdup 01 open item PASNY Power Authority of the State of New York PASS post-accident sampling system PDI performance demonstration initiative PFM probabilistic fracture mechanics pH potential of hydrogen P&ID piping and instrumentation diagram/drawing ppb parts per billion ppm parts per million -

PSPM periodic surveillance and preventive maintenance P-T pressure-temperature PT penetrant testing PTS pressurized thermal shock PVC polyvinyl chloride PWR pressurized water reactor QA quality assurance RAI request for additional information RBCLC reactor building closed loop cooling RBCLCW reactor building closed loop cooling water RCIC reactor core isolation cooling RCPB reactor coolant pressure boundary RCS reactor coolant system RG regulatory guide RHR residual heat removal RHRSW residual heat removal service water RO refueling outage RPV reactor pressure vessel RR reactor recirculation RTNDT reference temperature. (nil ductility transition)

RV reactor vessel RVID Reactor Vessel Integrity Database xvi

RWCU reactor water cleanup SBO station blackout SC structure and component SCC stress-corrosion cracking SE Safety Evaluation SER Safety Evaluation Report SGT standby gas treatment system SIF stress intensification factor SIV safety injection valve SO 2 sulfur dioxide SOV solenoid valve SRP Standard Review Plan SRP-LR Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants SRV safety/relief valve SS sample system, stainless steel SSC system, structure, and component sol sub-open item SW service water TAP torus attached piping TB turbine building TBCLC turbine building closed loop cooling TES Teledyne Engineering Services TIP traversing incore probe TLAA time-limited aging analysis TS technical specification US United States UFSAR Updated Final Safety Analysis Report USE upper-shelf energy UT ultrasonic testing yr year Zn zinc 1/4 T one-fourth of the way through the vessel wall measured from the internal surface of the vessel xvii

SECTION 1 INTRODUCTION AND GENERAL DISCUSSION

1.1 Introduction

This document is a safety evaluation report (SER) on the license renewal application (LRA) for James A. FitzPatrick Nuclear Power Plant (JAFNPP) as filed by the Entergy Nuclear Operations, Inc. (ENO or the applicant). By letter dated July 31, 2006, ENO submitted its application to the United States (US) Nuclear Regulatory Commission (NRC) for renewal of the JAFNPP operating license for an additional 20 years. The NRC staff (the staff) prepared this report to summarize the results of its safety review of the LRA for compliance with Title 10, Part 54, "Requirements for Renewal of Operating Licenses for Nuclear Power Plants," of the Code of FederalRegulations (10 CFR Part 54). The NRC project manager for the license renewal review is Ngoc B. (Tommy) Le. Mr. Le may be contacted by telephone at 301-415-1458 or by electronic mail at NBL@nrc.gov. Alternatively, written correspondence may be sent to the following address:

License Renewal and Environmental Impacts Program US Nuclear Regulatory Commission Washington, DC 20555-0001 Attention: Ngoc B. (Tommy) Le, Mail Stop 011-F1 In its July 31, 2006, submission letter, the applicant requested renewal of the operating license issued under Section 104b (Operating License No. DPR-59) of the Atomic Energy Act of 1954, as amended, for JAFNPP for a period of 20 years beyond the current expiration at midnight October 17, 2014. JAFNPP is located approximately seven miles northeast of Oswego, New York. The NRC issued the JAFNPP construction permit on May 20, 1970, and the operating license on October 17, 1974. JAFNPP is of a Mark 1, GE 4, boiling water reactor design. GE supplied the nuclear steam supply system and Stone and Webster originally designed and constructed the balance of the plant. The JAFNPP licensed power output is 2536 megawatt thermal with a gross electrical output of approximately 881 megawatt electric. The updated final safety analysis report (UFSAR) shows details of the plant and the site.

The license renewal process consists of two concurrent reviews, a technical review of safety issues and an environmental review. The NRC regulations in 10 CFR Part 54, "Requirements For Renewal Of Operating Licenses For Nuclear Power Plant" and 10 CFR Part 51, "Environmental Protection Regulations for Domestic Licensing and Related Regulatory Functions," respectively, set forth requirements for these reviews. The safety review for the JAFNPP license renewal is based on (1) the applicant's LRA and its responses to the staff's requests for additional information (RAIs) and (2) the staff's onsite audits of the applicant's aging management programs and reviews. The applicant supplemented the LRA and provided clarifications through its responses to staff's RAls in audits, meetings, and docketed correspondence. Unless otherwise noted, the staff reviewed and considered information submitted through November 5, 2007. The staff reviewed information received after that date depending on the stage of the safety review and the volume and complexity of the information.

The public may view the LRA and all pertinent information and materials, including the UFSAR, at the NRC Public Document Room, on the first floor of One White Flint North, 11555 Rockville Pike, Rockville, MD 20852-2738 (301-415-4737 / 800-397-4209), and at the following public libraries: State University of New York Penfield Library, 7060 State Route 104, Oswego, New York 13126; and Oswego Public Library, 140-142 East Second Street, Oswego, New York 13126. In addition, the public may find the LRA, as well as materials related to the license renewal review, on the NRC Web site at http://www.nrc.gov.

This SER summarizes the results of the staff's safety review of the LRA and describes the technical details considered in evaluating the safety aspects of the unit's proposed operation for an additional 20 years beyond the term of the current operating license. The staff reviewed the LRA in accordance with NRC regulations and the guidance in the NUREG-1800, Revision 1, "Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants" (SRP-LR), dated September 2005.

SER Sections 2 through 4 address the staffs evaluation of license renewal issues considered during the review of the LRA. SER Section 5 is reserved for the report of the Advisory Committee on Reactor Safeguards (ACRS). The conclusions of this SER are in Section 6.

SER Appendix A is a table showing the applicant's commitments for renewal of the operating license. SER Appendix B is a chronology of the principal correspondence between the staff and the applicant regarding the LRA review. SER Appendix C is a list of principal contributors to the SER and Appendix D is a bibliography of the references in support of the staff's review.

In accordance with 10 CFR Part 51, the staff prepared a draft, plant-specific supplement to NUREG-1437, "Generic Environmental Impact Statement for License Renewal of Nuclear Plants (GELS)." This supplement discusses the environmental considerations for license renewal for JAFNPP. The staff issued draft plant-specific GElS Supplement 31, "Generic Environment Impact Statement for License Renewal of Nuclear Plants regarding James A.

FitzPatrick Nuclear Power Plant," on June 8, 2007 (ADAMS Accession No. ML071420019). The final plant-specific GElS Supplement 31, was issued on January 18, 2008.

1.2 License Renewal Background

Pursuant to the Atomic Energy Act of 1954, as amended, and NRC regulations, operating licenses for commercial power reactors are issued for 40 years and can be renewed for up to 20 additional years. The original 40-year license term was selected based on economic and antitrust considerations rather than on technical limitations; however, some individual plant and equipment designs may have been engineered for an expected 40-year service life.

In 1982, the staff anticipated interest in license renewal and held a workshop on nuclear power plant aging. This workshop led the NRC to establish a comprehensive program plan for nuclear plant aging research. From the results of that research, a technical review group concluded that many aging phenomena are readily manageable and pose no technical issues precluding life extension for nuclear power plants. In 1986, the staff published a request for comment on a policy statement that would address major policy, technical, and procedural issues related to license renewal for nuclear power plants.

In 1991, the staff published 10 CFR Part 54, the License Renewal Rule (Volume 56, page 64943, of the FederalRegister (56 FR 64943), dated December 13, 1991). The staff participated in an industry-sponsored demonstration program to apply 10 CFR Part 54 to a pilot plant and to gain the experience necessary to develop implementation guidance. To establish a scope of review for license renewal, 10 CFR Part 54 defined age-related degradation unique to license renewal; however, during the demonstration program, the staff found that certain aging effects on plant systems and components are managed during the period of initial license and that the scope of the review did not allow sufficient credit for existing plant programs, particularly the implementation of 10 CFR 50.65, "Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," which regulates management of plant-aging phenomena. As a result of this finding, the staff amended 10 CFR Part 54 in 1995.

As published May 8, 1995, in 60 FR 22461, amended 10 CFR Part 54 establishes a regulatory process simpler, more stable, and more predictable than the previous 10 CFR Part 54 process.

In particular, as amended, 10 CFR Part 54 focuses on the management of adverse aging effects rather than on the identification of age-related degradation unique to license renewal.

The staff made these rule changes to ensure that important systems, structures, and components (SSCs) will continue to perform their intended functions during periods of extended operation. In addition, the amended 10 CFR Part 54 process clarifies and simplifies the integrated plant assessment for consistency with the revised focus on passive, long-lived structures and components (SCs).

Concurrent with these initiatives, the staff pursued a separate rulemaking effort (61 FR 28467, June 5, 1996) and amended 10 CFR Part 51 to focus the scope of the review of environmental impacts of license renewal in order to fulfill NRC responsibilities under the National -

Environmental Policy Act of 1969.

1.2.1 Safety Review License renewal requirements for power reactors are based on two key principles:

(1) The regulatory process is adequate to ensure that the licensing bases of all currently operating plants maintain an acceptable level of safety with the possible exceptions of the detrimental aging effects on the functions of certain SSCs, as well as a few other safety-related issues, during the period of extended operation.

(2) The plant-specific licensing basis must be maintained during the renewal term in the same manner and to the same extent as during the original licensing term.

In implementing these two principles, 10 CFR 54.4, "Scope," defines the scope of license renewal as including those SSCs that (1) are safety-related, (2) the failure of which could affect safety-related functions, and (3) are relied on for compliance with the NRC fire protection, environmental qualification (EQ), pressurized thermal shock (PTS), anticipated transient without scram (ATWS), and station blackout (SBO) regulations.

Pursuant to 10 CFR 54.21(a), a license renewal applicant must review all SSCs within the scope of 10 CFR Part 54 to identify SCs subject to an aging management review (AMR). Those SCs subject to an AMR perform an intended function without moving parts or without change in configuration or properties and are not subject to replacement based on a qualified life or specified time period. As required by 10 CFR 54.21(a), license renewal applicants must 1-3

demonstrate that the aging effects will be managed such that the intended function(s) of those SCs will be maintained consistent with the current licensing basis (CLB) for the period of extended operation. However, active equipment is considered to be adequately monitored and maintained by existing programs. In other words, detrimental aging effects that may affect active equipment can be readily identified and corrected through routine surveillance, performance monitoring, and maintenance. Surveillance and maintenance programs for active equipment, as well as other maintenance aspects of plant design and licensing basis, are required throughout the period of extended operation.

Pursuant to 10 CFR 54.21(d), the LRA is required to include a UFSAR supplement with a summary description of the applicant's programs and activities for managing aging effects and an evaluation of time-limited aging analyses (TLAAs) for the period of extended operation.

License renewal also requires TLAA identification and updating. During the plant design phase, certain assumptions about the length of time the plant can operate are incorporated into design calculations for several plant SSCs. In accordance with 10 CFR 54.21(c)(1), the applicant must either show that these calculations will remain valid for the period of extended operation, project the analyses to the end of the period of extended operation, or demonstrate that the aging effects on these SSCs will be adequately managed for the period of extended operation.

In 2005, the NRC developed and issued Regulatory Guide (RG) 1.188, "Standard Format and Content for Applications to Renew Nuclear Power Plant Operating Licenses." This RG endorses Nuclear Energy Institute (NEI) 95-10, Revision 6, "Industry Guideline for Implementing the Requirements of 10 CFR Part 54 - The License Renewal Rule," issued in June-2005. NEI-95-10 details an acceptable method of implementing 10 CFR Part 54. The staff also used the SRP-LR in reviewing the LRA.

In the LRA, the applicant fully utilized the process defined in NUREG-1801, Revision 1, "Generic Aging Lessons Learned (GALL) Report," dated September 2005. The GALL Report summarizes staff-approved aging management programs (AMPs) for many SCs subject to an AMR. Ifan applicant commits to implementing these staff-approved AMPs, the time, effort, and resources for LRA review can be greatly reduced, improving the efficiency and effectiveness of the license renewal review process. The GALL Report summarizes the aging management evaluations, programs, and activities credited for managing aging for most SCs throughout the industry. The report is also a quick reference for both applicants and staff reviewers to AMPs and activities that can manage aging adequately during the period of extended operation.

1.2.2 Environmental Review

Part 51 of 10 CFR contains regulations on environmental protection. In December 1996, the staff revised the environmental protection regulations to facilitate the environmental review for license renewal. The staff prepared the GElS to document its evaluation of possible environmental impacts associated with nuclear power plant license renewals. For certain environmental impacts, the GElS contains generic findings that apply to all nuclear power plants and are codified in 10 CFR Part 51 Appendix B, "Environmental Effect of Renewing the Operating License of a Nuclear Power Plant," to Subpart A, "National Environmental Policy Act - Regulations Implementing Section 102(2)." Pursuant to 10 CFR 51.53(c)(3)(1), license renewal applicants may incorporate these generic findings in their environmental reports. In accordance with 10 CFR 51.53(c)(3)(ii), an environmental report also must include analyses of environmental impacts that must be evaluated on a plant-specific basis (i.e., Category 2 issues).

In accordance with the National Environmental Policy Act of 1969 and 10 CFR Part 51, the staff reviewed the plant-specific environmental impacts of license renewal, including whether there was new and significant information not considered in the GELS. As part of its scoping process, the staff held a public meeting on October 12, 2006, in Oswego, New York, to identify plant-specific environmental issues. Draft plant-specific GElS Supplement 31 documents the results of the environmental review and makes a preliminary recommendation as to the license renewal action. The staff held two other public meetings on August 1, 2007, in Oswego, New York, to discuss draft, plant-specific GElS Supplement 31. After considering comments on the draft, the staff published the final plant-specific GElS Supplement 31 separately from this report.

1.3 Principal Review Matters Part 54 of 10 CFR describes the requirements for renewal of operating licenses for nuclear power plants. The staff's technical review of the LRA was in accordance with NRC guidance and 10 CFR Part 54 requirements. Section 54.29, "Standards for Issuance of a Renewed License," of 10 CFR sets forth the license renewal standards. This SER describes the results of the staff's safety review.

Pursuant to 10 CFR 54.19(a)-, theNRC requires license renewal applicants to submit general information, which the applicant provided in LRA Section 1. The staff reviewed LRA Section 1 and finds that the applicant has submitted the required information.

Pursuant to 10 CFR 54.19(b), the NRC requires that LRAs include "conforming changes to the standard indemnity agreement, 10 CFR 140.92, Appendix B, to account for the expiration term of the proposed renewed license." On this issue, the applicant stated in the LRA:

... the agreement shall terminate at the time of expiration of the license specified in Item 3 of the Attachment to the agreement, which is the last to expire. Item 3 of the Attachment to the indemnity agreement, as revised by Amendment No. 10, lists JAFNPP operating license number DPR-59. The applicants request that conforming changes be made to Article VII of the indemnity agreement, and Item 3 of the Attachment to that agreement, specifying the extension of agreement until the expiration date of the renewed JAFNPP facility operating license sought in this application. In addition, should the license number be changed upon issuance of the renewal license, the applicants request that conforming changes be made to Item 3 of the Attachment, and other sections of the indemnity agreement as appropriate.

The staff intends to maintain the original license number upon issuance of the renewed license, if approved. Therefore, conforming changes to the indemnity agreement need not be made and the 10 CFR 54.19(b) requirements have been met.

Pursuant to 10 CFR 54.21, "Contents of Application - Technical Information," the NRC requires that LRAs contain (a) an integrated plant assessment, (b) a description of any CLB changes during the staff's review of the LRA, (c) an evaluation of TLAAs, and (d) an UFSAR supplement. LRA Sections 3 and 4 and Appendix B address the license renewal requirements.

of 10 CFR 54.21(a), (b), and (c). LRA Appendix A satisfies the license renewal requirements of 10 CFR 54.21(d).

Pursuant to 10 CFR 54.21(b), the NRC requires that, each year following submission of the LRA and at least three months before the scheduled completion of the staffs review, the applicant submit an LRA amendment identifying any CLB changes to the facility that affect the contents of the LRA, including the UFSAR supplement. The applicant has submitted such LRA amendments as listed in Appendix B of the SER and thus satisfies the license renewal requirements of 10 CFR 54.21(b).

Pursuant to 10 CFR 54.22, "Contents of Application - Technical Specifications," the NRC requires that the LRA include changes or additions to the technical specifications necessary to manage aging effects during the period of extended operation. In LRA Appendix D, the applicant stated that it had not identified any technical specification changes necessary for issuance of the renewed JAFNPP operating license. This statement adequately addresses the 10 CFR 54.22 requirement.

The staff evaluated the technical information required by 10 CFR 54.21 and 10 CFR 54.22 in accordance with NRC regulations and SRP-LR guidance. SER Sections 2, 3, and 4 document the staff's evaluation of the LRA technical information.

As required by 10 CFR 54.25, "Report of the Advisory Committee on Reactor Safeguards," the ACRS will issue a report documenting its evaluation of the staff's LRA review and SER. SER Section 5 is reserved for the ACRS report when issued. SER Section 6 documents the findings required by 10 CFR 54.29.

1.4 Interim Staff Guidance

License renewal is a living program. The staff, industry, and other interested stakeholders gain experience and develop lessons learned with each renewed license. The lessons learned address the staff's performance goals of maintaining safety, improving effectiveness and efficiency, reducing regulatory burden, and increasing public confidence. Interim staff guidance (ISG) is documented for use by the staff, industry, and other interested stakeholders until incorporated into such license renewal guidance documents as the SRP-LR and the GALL Report.

Table 1.4-1 shows the current set of ISGs, as well as theSER sections in which the staff addresses them.

Table 1.4-1 Current Interim Staff Guidance ISG Issue Purpose SER Section (Approved ISG Number)

Nickel-alloy components in the Cracking of nickel-alloy Not applicable (Pressurized Water reactor coolant pressure boundary components in the reactor pressure Reactors only)

(LR-ISG-19B) boundary.

ISG under development. NEI and EPRI-MRP will develop an augmented inspection program for GALL AMP XI.M1 1-B. This AMP will not be completed until the NRC approves an augmented inspection program for nickel-alloy base metal components and welds as proposed by EPRI-MRP.

Corrosion of drywell shell in Mark I To address concerns related to SER 3.5.2.2.1 containments corrosion of drywell shell in Mark I (LR-ISG-2006-01) containments.

1.5 Summary of Open Items and Resolutions

As a result of its review of the LRA, including additional information submitted through June 20, 2007, the staff identified the following open items (Ols). An item is considered open if, in the staff's judgement, it does not meet all applicable regulatory requirements at the time of the issuance of this SER. The staff has assigned a unique identifying number to each 01.

01 4.2.1-1: (SER Section 4.2.1 - Reactor Vessel Neutron Fluence)

The staff reviewed GE-NE-B1 100732-01 report on analysis of the 120 °capsule removed at 13.4 effective full power years (EFPYs) of operation submitted by the applicant to determine if calculation of fluence values were in accordance with the guidance of RG 1.190, "Calculational and Dosimetry Methods for Determining Pressure Vessel Neutron Fluence." The staff determined that the GE-NE-B1 100732-01 report did not conform to the RG 1.190. The applicant had stated at the time that it would submit a new fluence calculation to the staff for review when complete. This item was identified as 01 4.2.1-1 in the staff SER With Open Items issued on July 31, 2007.

The applicant, in its November 5, 2007, response to 01 4.2.1-1, submitted a summary of a new analysis for its determination of maximum pressure vessel neutron fluence.

The staff reviewed the applicant's new calculated values and found the new calculation acceptable as it is adhered with the guidance of RG 1.190. The staff had determined that the original values that were submitted in LRA remain bounded by the new calculated values; therefore, 014.2.1-1 is closed. The staff's evaluation of this item is detailed in SER Section 4.0.

As noted in the staffs SER with Open Items issued July 31, 2007, for 01 4.2.1-1, the applicant's reactor pressure vessel neutron fluence evaluation for the period of extended operation impacted the staff's review of other items in LRA Section 4.2.2.

As stated in the staffs SER with Open Items issued July 31, 2007, the staff had found information submitted for the following TLAA sections of the LRA acceptable pending resolution of 01 4.2.1-1. Now that 01 4.2.1-1 is resolved and closed, the staff finds the following sub-Ols (sOls) closed:

sOl 4.2.2-1: (SER Section 4.2.2 - Pressure-Temperature Limits)

The staff's review of P-T limits was based on the applicant's original fluence values in LRA Section 4.2.1. These original values had been previously found acceptable as documented in the previously issued SER with Open Items dated July 31, 2007. The staff finds that these original values remain bounded by the new calculated values submitted by the applicant in a letter dated November 5, 2007. Therefore, sOl 4.2.2-1 is now closed.

The staff determined that the TLAA for P-T limits is acceptable because (1) the projected 54 EFPY fluence and ART values are in fact less than the 200 OF suggested in RG 1.99, Section 3, and (2) changes to the P-T limit curves will be implemented by the license amendment process (i.e., through revisions of the plant TS) in accordance with 10 CFR 50.60 and 10 CFR Part 50, Appendix G.

s0l 4.2.3-1: (SER Section 4.2.3 - Charpy Upper-Shelf-Energy)

The staff determined that the applicant correctly used RG 1.99, Revision 2, Position 1 to calculate the predicted percentage decrease in upper-shelf energy (USE) conservatively for the period of extended operation. The staff also independently calculated (1) the end of life (EOL)

USE values for the beltline plate materials at 54 EFPY and (2) the equivalent margin analysis (EMA) of the percent drop in USE for the beltline weld materials through 54 EFPY. Verifying the drop in USE values from neutron irradiation using the RG 1.99, Revision 2 methodology, the staff finds that all the beltline materials meet 10 CFR Part 50, Appendix G, EOL USE or EMA requirements and SRP-LR Section 4.2.3.1.1.2 criteria for USE/EMA TLAAs in accordance with 10 CFR 54.21(c)(1)(ii). SER Table 4.2.3-1 summarizes the results of both the applicant's and the staff's independent USE/EMA calculations for the limiting plate and weld materials.

The staff's review was based on the fluence values provided by the applicant in LRA Section 4.2.1. The staff finds that the values that were submitted by the applicant's LRA submitted on August 1, 2006, remains bounded by the new calculated values submitted by the applicant in a letter dated November 5, 2007. Therefore, sOl 4.2.3-1 is now closed.

sOl 4.2.4-1: (SER Section 4.2.4 - Adjusted Reference Temperature)

The staff confirmed that lower shell axial welds 2-233 A, B, and C fabricated from Heat No. 27204/12008 were the limiting 1/4T reference temperature (nil-ductility transition) (RTNDT) reactor vessel components. The staff calculated a limiting 1/4T RTNDT value of 132.1 OF for this plate material based on the chemistry factor (CF) table for plate/forging materials in RG 1.99, Revision 2 and a 1/4T fluence of 0.174 x 10"s n/cm 2 (E > 1.0 MeV) at 54 EFPY. The 1/4T RTNDT 1-8

value calculated by the staff at 54 EFPY is within 3.2 OF of that calculated (i.e., 135.3 OF) by the applicant for this material. As the staff's independent 1/4T RTNOT value agreed with that calculated by the applicant, the staff found the applicant's calculated and projected limiting 1/4T RTNOT value for the reactor vessel at 54 EFPY valid and found the TLAA on 1/4T RTNDT values for the reactor vessel through 54 EFPY acceptable in accordance with 10 CFR 54.21(c)(1)(ii).

The staffs review was based on the applicant's fluence values in LRA Section 4.2.1. The staff finds that the values that were submitted by the applicant's LRA on August 1, 2006, remains bounded by the new calculated values submitted by the applicant in a letter dated November 5, 2007. Therefore, sOl 4.2.4-1 is now closed.

s0l 4.2.5-1: (SER Section 4.2.5 - Reactor Vessel Circumferential Weld Inspection Relief)

The staff finds the applicant's evaluation for this TLAA acceptable because the 54 EFPY conditional failure probability for the reactor vessel circumferential welds is bounded by the analysis in the staff SER dated July 28, 1998, and the applicant will use procedures and training to limit cold over-pressure events during the period of extended operation. This analysis satisfies the evaluation requirements of the staff SER dated July 28, 1998; however, the applicant still must request relief from the circumferential weld examination for the period of extended operation in accordance with 10 CFR 50.55a.

The staff's review was based on the applicant's fluence values in LRA Section 4.2.1. The staff finds that the values that were submitted by the applicant's LRA submitted on August 1, 2006, remains bounded by the new calculated values submitted by the applicant in a letter dated November 5i 2007. Therefore, sOl 4.2.5-1 is now closed.

s0l 4.2.6-1: (See SER Section 4.2.6 - Reactor Vessel Axial Weld Failure Probability)

The staff reviewed LRA Section 4.2.6, to verify pursuant to 10 CFR 54.21(c)(1)(ii) that the analyses have been projected to the end of the period of extended operation. The staff reviewed the applicant's TLAA of the reactor vessel axial weld failure probability, as summarized in LRA Section 4.2.6, and its response to RAI 4.2.6.1 dated February 12, 2007, supplemented by letter dated June 20, 2007, and determines that the applicant appropriately described how the conditional failure probability for the reactor vessel axial welds is bounded by the analysis in the staff supplemental SER dated March 7, 2000, on the BWRVIP-05 Report for the period of extended operation. The staff therefore finds the applicant's TLAA Section 4.2.6 and UFSAR supplement summary description A.2.2.1.6 acceptable. The staff concludes that the applicant's TLAA for the reactor vessel axial weld failure probability comply with the 10 CFR 54.21 (c)(1)(ii) TLAA acceptance criterion.

The staff's review was based on the applicant's fluence values in LRA Section 4.2.1. The staff finds that the new calculated value submitted by the applicant in a letter dated November 5, 2007 remains bounded by the value that Was submitted by the applicant's LRA submitted on August 1, 2006. Therefore, sOl 4.2.6-1 is now closed.

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s0l B.1.24-3: (See SER Section 3.0.3.2.16 - Reactor Vessel Surveillance Program)

On the basis of the staff's review for LRA item B.1.24 discussed in SER Section 3.0 and the new calculated fluence value submitted by the applicant in a letter dated November 5, 2007, the staff finds that the values that were submitted by the applicant's LRA submitted on August 1, 2006, remains bounded by the new calculated values submitted by the applicant in a letter dated November 5, 2007. Therefore, the applicant's implementation of the Integrated Surveillance Program (ISP), as specified in the BWRVIP-1 16 Report, remains valid and as such, the various attributes in the ISP are not affected by the new methodology of calculating the neutron fluence values. The staff finds that the applicant has demonstrated that the effects of aging due to loss of fracture toughness of the reactor pressure vessel beltline region will be adequately managed, so that the intended functions will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3). Therefore, sOl B.1.24-3 is now closed.

01 4.3.3-1: (SER Section 4.3.3 - Effects of Reactor Water Environment on Fatigue Life)

By letter dated August 14, 2007, as supplemented by letter dated November 5, 2007, the applicant responded to RAI 4.3.3-1 and resolved the staffs issue identified in 01 4.3.3-1.

In these letters, the applicant amended the LRA and supplemented Commitment No. 20 to justify its environmentally-assisted fatigue analysis. The November 5, 2007, letter clarified that Option 1 of Commitment No. 20 for refined CUF calculations is consistent with NRC recommendations for periodic CUF updates in "monitoring and trending" (i.e., program element 4) of GALL AMP X.M1, "Metal Fatigue of the Reactor Coolant Pressure Boundary,"

and for "corrective actions" in GALL AMP X.M1. The applicant also clarified that Options 2 and 3 of Commitment No. 20 are corrective actions consistentwith those recommended in "corrective action" (i.e., program element 7) of the same GALL AMP. With these clarifications, the applicant amended the LRA to bring Commitment No. 20 within the scope of the Fatigue Monitoring Program and to credit this AMP as the basis for acceptance of this TLAA as in accordance with 10 CFR 54.21(c)(1)(iii).

After reviewing the letter dated August 14, 2007, as supplemented by the letter dated November 5, 2007, the staff finds the applicant's clarification of these changes consistent with NRC recommendations in GALL AMP X.M1 and therefore are acceptable. The staff concludes that the applicant's response is acceptable and, therefore, 01 4.3.3.1 is closed. The staff's evaluation of the applicant's response is detailed in SER Section 4.3.3.

1.6 Summary of Confirmatory Items

As a result of its review of the LRA, including additional information submitted through November 5, 2007, the staff identified no confirmatory items. An item is considered confirmatory if the staff and the applicant have reached a satisfactory resolution but the applicant has not yet formally submitted the resolution. The staff has assigned a unique identifying number to each confirmatory item, if any.

There are no confirmatory items in this SER 1-10

1.7 Summary of Proposed License Conditions

Following the staff's review of the LRA, including subsequent information and clarifications from the applicant, the staff identified three proposed license conditions.

The first license condition requires the applicant to include the UFSAR supplement required by 10 CFR 54.21(d) in the next UFSAR update required by 10 CFR 50.71(e) following the issuance of the renewed license.

The second license condition requires future activities described in the UFSAR supplement to be completed prior to the period of extended operation.

The third license condition requires the implementation of the most recent staff-approved version of the Boiling Water Reactor Vessels and Internals Project (BWRVIP) Integrated Surveillance Program (ISP) as the method to demonstrate compliance with the requirements of 10 CFR Part 50, Appendix H. Any changes to the BWRVIP ISP capsule withdrawal schedule must be submitted for NRC staff review and approval. Any changes to the BWRVIP ISP capsule withdrawal schedule which affects the time of withdrawal of any surveillance capsules must be incorporated into the licensing basis. If any surveillance capsules are removed without the intent to test them, these capsules must be stored in a manner which maintains them in a condition which would support re-insertion into the reactor pressure vessel, if necessary.

SECTION 2 STRUCTURES AND COMPONENTS SUBJECT TO AGING MANAGEMENT REVIEW

2.1 Scoping and Screening Methodology

2.1.1 Introduction

Title 10, Section 54.21, "Contents of Application Technical Information," of the Code of Federal Regulations (10 CFR Part 54.21), requires for each license renewal application (LRA) an integrated plant assessment (IPA) listing structures and components (SCs) subject to an aging management review (AMR) from all of the systems, structures, and components (SSCs) within the scope of license renewal.

LRA Section 2.1, "Scoping and Screening Methodology," describes the methodology for identifying SSCs at the James A. FitzPatrick Nuclear Power Plant (JAFNPP), within the scope of license renewal and SCs subject to an AMR. The staff of the United States (US) Nuclear Regulatory Commission (NRC) (the staff) reviewed the Entergy Nuclear Operations, Inc. (ENO or the applicant) scoping and screening methodology to determine whether it meets the scoping requirements of 10 CFR 54.4(a) and the screening requirements of 10 CFR 54.21.

In developing the scoping and screening methodology for the LRA, the applicant considered the requirements of 10 CFR Part 54, "Requirements for Renewal of Operating Licenses for Nuclear Power Plants" (the Rule), statements of consideration on the Rule, and Regulatory Guide (RG) 1.188, which endorses the guidance of Nuclear Energy Institute (NEI) 95-10, Revision 6, "Industry Guideline for Implementing the Requirements of 10 CFR Part 54 - The License Renewal Rule," dated June 2005. The applicant also considered the correspondence between the staff, other applicants, and the NEI.

2.1.2 Summary of Technical Information in the Application

LRA Sections 2 and 3 state the technical information required by 10 CFR 54.4 and 54.21(a).

LRA Section 2.1 describes the process for identifying SSCs meeting the license renewal scoping criteria of 10 CFR 54.4(a) and the process for identifying SCs subject to an AMR as required by 10 CFR 54.21(a)(1 ). The applicant provided the results of the process for identifying such SCs in the following LRA sections:

° Section 2.2, "Plant Level Scoping Results"

° Section 2.3, "Scoping and Screening Results: Mechanical Systems"

" Section 2.4, "Scoping and Screening Results: Structures"

" Section 2.5, "Scoping and Screening Results: Electrical and Instrumentation and Control Systems" 2-1

LRA Section 3, "Aging Management Review Results," states the applicant's aging management results in the following LRA sections:

• Section 3.1, "Reactor.Vessel, Internals and Reactor Coolant System"

• Section 3.2, "Engineered Safety Features Systems"

• Section 3.3, "Auxiliary Systems"

• Section 3.4, "Steam and Power Conversion Systems"

• Section 3.5, "Structures and Component Supports"

• Section 3.6, "Electrical and Instrumentation and Controls" LRA Section 4, "Time-Limited Aging Analyses," states the applicant's evaluation of time-limited aging analyses.

2.1.3 Scoping and Screening Program Review

The staff evaluated the LRA scoping and screening methodology in accordance with the guidance in Section 2.1, "Scoping and Screening Methodology," of NUREG-1800, Revision 1, "Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants" (SRP-LR), dated September 2005. The following regulations form the basis for the acceptance criteria for the scoping and screening methodology review:

• 10 CFR 54.4(a) as to identification of plant SSCs within the scope of the Rule

• 10 CFR 54.4(b) as to identification of the_ intended functions of plant systems and structures within the scope of the Rule 10 CFR 54.21 (a)(1) and 10 CFR 54.21(a)(2) as to the methods utilized by the applicant to identify plant SCs subject to an AMR With the guidance of the corresponding SRP-LR sections, the staff reviewed, as part of the applicant's scoping and screening methodology, the activities described in the following LRA sections:

" Section 2.1 to ensure that the applicant described a process for identifying SSCs within the scope of license renewal in accordance with 10 CFR 54.4(a)

• Section 2.2 to ensure that the applicant described a process for identifying SCs subject to an AMR in accordance with 10 CFR 54.21(a)(1) and 10 CFR 54.21(a)(2)

The staff conducted a scoping and screening methodology audit at JAFNPP in Oswego, New York during the week of September 26-29, 2006. The audit focused on whether the applicant had developed and implemented adequate guidance for the scoping and screening of SSCs by the methodologies in the LRA and the requirements of the Rule. The staff reviewed implementation of the project level guidelines and topical reports describing the applicant's scoping and screening methodology. The staff discussed with the applicant details of the implementation and control of the license renewal program and reviewed administrative control documentation and selected design documentation used by the applicant during the scoping and screening process. The staff reviewed the applicant's processes for quality assurance (QA) for development of the LRA. The staff reviewed the quality attributes of the applicant's aging management program (AMP) activities described in LRA Appendix A, "Updated Final Safety 2-2

Analysis Report Supplement," and LRA Appendix.B, "Aging Management Programs and Activities" and the training and qualification of the LRA development team. The staff reviewed scoping and screening results reports for the main steam (MS) system and trenches, valve pits, manholes, and duct banks for the applicant's appropriate implementation of the methodology outlined in the administrative controls and for results consistent with the current licensing basis (CLB) documentation.

2.1.3.1 Implementation Proceduresand Documentation Sources for Scoping and Screening The staff reviewed the applicant's scoping and screening implementation procedures as documented in the audit report dated March 27, 2007, to verify whether the process for identifying SCs subject to an AMR was consistent with the LRA and the SRP-LR. Additionally, the staff reviewed the scope of CLB documentation sources and the applicant's process for appropriate consideration of CLB commitments and for adequate implementation of the procedural guidance during the scoping and screening process.

2.1.3.1.1 Summary of Technical Information in the Application In LRA Section 2.1, the applicant addressed the following information sources for the license renewal scoping and screening process:

0 updated final safety analysis report (UFSAR) a -technical specifications- -..

• safety classification documents

• safety system function sheets

• fire hazards analysis

• safe shutdown analysis

• design-basis documents (DBDs)

" equipment database

" maintenance rule basis documents

" plant layout drawings and license renewal boundary drawings (LRBDs)

" station drawings The applicant stated that it used this information to specify the functions of plant systems and structures. It then compared these functions to the 10 CFR 54(a)(1)-(3) scoping criteria to determine whether the plant system or structure function is within the scope of license renewal and used these sources to develop the list of structures and components subject to an AMR.

The LRBDs show the systems within the scope of license renewal highlighted in color.

2.1.3.1.2 Staff Evaluation Scopinq and Screening Implementation Procedures. As documented in the audit report, the staff reviewed the applicant's scoping and screening methodology implementation procedures, including license renewal project guidelines (LRPGs), license renewal project documents/reports (LRPDs), AMR reports (specifically AMMs - mechanical, AMEs - electrical, and AMCs - structural), for consistency with the requirements of the Rule, the Standard Review Plan for License Renewal (SRP-LR), and NEI 95-10.

The staff found the overall process for implementing 10 CFR Part 54 requirements included in the LRPGs, LRPDs and AMRs consistent with the Rule and industry guidance. The staff found guidance for identifying plant SSCs within the scope of the Rule, including guidelines for identifying SC component types within the scope of license renewal subject to an AMR, in the LRPGs, LRPDs and AMRs. The review of these procedures focused on the consistency of the detailed procedural guidance with information in the LRA reflecting implementation of staff positions in the SRP-LR, interim staff guidance documents, and the information in request for additional information (RAI) responses dated November 22, 2006.

After reviewing the LRA and supporting documentation, the staff finds LRA Section 2.1 consistent with the scoping and screening methodology instructions. The applicant's methodology has sufficiently detailed guidance for the scoping and screening implementation process followed in the LRA.

Sources of Current Licensing Basis Information. For JAFNPP, system safety functions are stated in safety classification documents, the Maintenance Rule SSC basis documents for each system, and in DBDs for systems for which DBDs were written. The staff considered the safety objectives in the UFSAR system descriptions and identified objectives meeting the safety-related criterion of 10 CFR 54.4(a)(1) as system intended functions.

The staff reviewed the scope and depth of the applicant's CLB information to verify whether the applicant's methodology had identified all SSCs within the scope of license renewal as well as component types requiring AMRs. As defined in 10 CFR 54.3(a), the CLB applies NRC requirements, written licensee commitments for compliance with, and operation within, applicable NRC requirements, and plant-specific design bases docketed and in effect. The CLB includes NRC regulations, orders, license conditions, exemptions, technical specifications, design-basis information in the most recent UFSAR, and licensee commitments in docketed correspondence like licensee responses to NRC bulletins, generic letters, and enforcement actions as well as commitments in NRC safety evaluations or licensee event reports.

During the audit, the staff reviewed the applicant's information sources and samples of such information, including the UFSAR, DBDs, controlled plant reference drawings, LRBDs, and Maintenance Rule information.

In addition, the applicant's license renewal process indicated additional potential sources of plant information pertinent to the scoping and screening process, including licensing correspondence, a fire hazards analysis, safety evaluations, and design documentation (e.g.,

engineering calculations and design specifications). The staff verified that the applicant's detailed LRPGs required use of the CLB source information in developing scoping evaluations.

The component database is the applicant's primary repository for component safety classification information. During the audit, the staff reviewed the applicant's administrative controls for component database safety classification data. Plant administrative procedures describe these controls and govern their implementation.

Based on a review of the administrative controls and a sample of the component database component safety classifications, the staff concluded that the applicant's measures to control the integrity and reliability of component database safety classification data are adequate, and, therefore, that the component database is a source of component data sufficiently controlled to support scoping and screening evaluations.

During the staff's review of the applicant's CLB evaluation process, the applicant discussed with the staff the incorporation of CLB updates and the process for adequate incorporation into the license renewal process. The staff determined that the LRA Section 2.1 description of the CLB and related documents of the scoping and screening process is consistent with SRP-LR guidance. In addition, the staff reviewed technical reports supporting reliance on SSCs to demonstrate compliance with safety-related criteria, nonsafety-related criteria, and regulation of the five events specified in 10 CFR 54.4(a)(1)-(3). The applicant's LRPGs comprehensively listed documents supporting scoping and screening evaluations. The staff found these design documentation sources useful in reviewing the applicant's initial scope of SSCs for consistency with the CLB.

2.1.3.1.3 Conclusion

Based on its review of LRA Section 2.1, the detailed scoping and screening implementation procedures, and the results from the scoping and screening audit, the staff concludes that the applicant's scoping and screening methodology considers CLB information consistently with SRP-LR and RG 1.188; and, therefore, is acceptable.

2.1.3.2 Quality Controls Applied to LRA Development 2.1.3.2.1 Staff Evaluation The staff reviewed the applicant's quality controls for adequate implementation of scoping and screening methodologies in the LRA. Although it did not develop the LRA under a 10 CFR Part 50, Appendix B, QA program, the applicant used the following QA processes during the LRA development:

" The applicant developed License Renewal Project Plan JAF-RPT-05-LRPO1 as the QA guide implemented for LRA preparation.

" Written procedures governed implementation of the scoping and screening methodology. A tracking system accounted for dates when procedures were originally issued and subsequently revised.

• The applicant reviewed previous RAIs for whether the LRA addressed pertinent issues.

" The Offsite and Onsite Safety Review Committees reviewed the LRA prior to its submission to the staff.

" The QA committee examined the license renewal procedures and documents for whether the LRA was in accordance with 10 CFR 54.4.

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2.1.3.2.2 Conclusion Based on its review of pertinent LRA development guidance, discussion with the applicant's license renewal personnel, and information from the staff's review of the JAFNPP's quality audit reports, the staff concludes that these QA activities meet current regulatory requirements and add assurance that LRA development activities have been according to LRA descriptions.

2.1.3.3 Training 2.1.3.3.1 Staff Evaluation The staff reviewed the applicant's training process for consistent and appropriate guidelines and methodology for the scoping and screening activities.

The license renewal scoping and screening activities and LRA development were accomplished by Entergy, Areva, and JAFNPP personnel trained under the License Renewal Project Plan, which included training requirements for both corporate and onsite personnel and indicated the level of training appropriate to each license renewal task.

Corporate level training of Entergy and Areva personnel required comprehension of license renewal procedures, guidelines, formats, industrial documents, scoping, screening, and industry guidance and regulations required for scoping and screening activities and LRA development.

As a training record the applicant developed a training check list of procedures and documents studied and levels of knowledge expected from class attendance. Onsite level training ensured a general understanding of the license renewal process and terminology so JAFNPP license renewal personnel could evaluate license renewal documents for technical accuracy.

The staff reviewed completed qualification and training records of several of the applicant's license renewal personnel and also reviewed completed check lists. The staff determined that these records adequately document the required training for applicant personnel. Additionally, after discussions with the applicant's license renewal personnel during the audit, the staff verified that the applicant's personnel were knowledgeable about the license renewal process requirements and specific technical issues within their areas of responsibility.

2.1.3.3.2 Conclusion Based on discussions with the applicant's license renewal personnel responsible for the scoping and screening process and review of selected design documentation supporting the process, the staff concludes that the applicant's personnel understood the requirements and adequately implemented the scoping and screening methodology documented in the LRA. The staff concludes that the license renewal personnel were adequately trained and qualified for license renewal activities.

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2.1.3.4 Conclusion of Scoping and Screening ProgramReview Based on its review of LRA Section 2.1, review of the applicant's detailed scoping and screening implementation procedures, discussions with the applicant's LRA personnel, and review of the scoping and screening audit results, the staff concludes that the applicant's scoping and screening program is consistent with SRP-LR guidance and, therefore, acceptable.

2.1.4 Plant Systems, Structures, and Components Scoping Methodology LRA Section 2.1.1 describes the methodology for scoping SSCs pursuant to 10 CFR 54.4(a) and the plant scoping process for systems and structures.

Specifically, the scoping process developed a list of plant systems and structures with intended functions as the bases for their inclusion within the scope of license renewal (as defined in 10 CFR 54.4(b)) by comparison of the system or structure functions with 10 CFR 54.4(a) criteria. The systems list was developed from the component database and the structures list from the UFSAR, Maintenance Rule documentation, plant layout drawings, and structure-specific system codes in the component database. As described by the applicant, for mechanical system scoping, a system is defined as the collection of components in the equipment database assigned to the system code. System functions are based on component functions.

Finally, the applicant evaluated the components in the systems and stFuctures within the scope of license renewal. The LRBDs depicted the in-scope system boundary of SCs subject to AMRs. The following sections address the applicant's scoping methodology as described in the LRA.

2.1.4.1 Application of the Scoping Criteriain 10 CFR 54.4(a)(1) 2.1.4.1.1 Summary of Technical Information in the Application LRA Section 2.1 .1.1 describes the 10 CFR Part 54 scoping methodology as to 10 CFR 54.4(a)(1 ) safety-related criteria, stating that systems and structures with safety functions as defined by 10 CFR 54.4(a)(1) are within the scope of license renewal. Intended functions for mechanical systems and structures were based on applicable plant licensing and design documents including the UFSAR, technical specifications, safety system function sheets, the fire hazards analysis, the safe shutdown analysis, DBDs, Maintenance Rule basis documents, and various station drawings as required. The applicant also confirmed that all plant conditions of normal operation, abnormal operational transients, design-basis accidents, internal and external events, and natural phenomena for which the plant must be designed had been considered for license renewal scoping under 10 CFR 54.4(a)(1)(i) through (iii) criteria.

Corporate and site procedures control the component and structure quality classifications.

Further, the applicant's definition of an SSC as safety-related is the same in 10 CFR 54.4 with the exception of the guidelines for offsite exposures. Section 54.4 of 10 CFR refers to 10 CFR 50.34(a)(1), 10 CFR 50.67(b)(2), and 10 CFR 100.11 dose guidelines. The exposure guidelines of 10 CFR 50.34(a)(1) do not apply because the construction permit was issued before January 10, 1997. For plants (including JAFNPP) with construction permits issued 2-7

before January 10, 1997, 10 CFR 50.34(a)(1) refers to the guidelines of 10 CFR Part 100, which are included in the applicants definition. The exposure guidelines of 10 CFR 50.67(b)(2) address the alternate source term, which the applicant has credited in the refueling accident analysis. The applicant reviewed the systems and components credited in this limited use of 10 CFR 50.67 for inclusion within the scope of license renewal.

2.1.4.1.2 Staff Evaluation Pursuant to 10 CFR 54.4(a)(1), the applicant must consider all safety-related SSCs relied upon to remain functional during and following a design basis event (DBE) to ensure (a) the integrity of the reactor coolant pressure boundary, (b) the ability to shut down the reactor and maintain it in a safe shutdown condition, or (c) the ability to prevent or mitigate the consequences of accidents that could cause offsite exposures comparable to those of 10 CFR 50.34(a)(1),

10 CFR 50.67(b)(2), or 10 CFR 100.11.

As to identification of DBEs, SRP-LR Section 2.1.3 states:

The set of DBEs as defined in the Rule is not limited to Chapter 15 (or equivalent) of the UFSAR. Examples of DBEs that may not be described in this chapter include external events, such as floods, storms, earthquakes, tornadoes, or hurricanes, and internal events, such as a high energy line break. Information regarding DBEs as defined in, 10 CFR 50.49(b)(1) may be found in any chapter of the facility UFSAR, the Commission's regulations, NRC orders, exemptions, or license'conditions within the CLB. These sources should also be reviewed to -..

identify SSCs relied upon to remain functional during and following DBEs (as defined in 10 CFR 50.49(b)(1)) to ensure the functions described in 10 CFR 54.4(a)(1).

The applicant scoped SSCs for the 10 CFR 54.4(a)(1) criterion with the LRPGs, piping and instrumentation diagrams (P&IDs), and other information sources as guidance in the preparation, review, verification, and approval of the scoping evaluations for adequate scoping results.

The staff reviewed these guidance documents for the applicant's evaluation of safety-related SSCs, and sampled the applicant's scoping reports for methodology implemented in accordance with those written instructions. In addition, the staff discussed the methodology and results with the applicant's personnel responsible for these evaluations. Specifically, the staff reviewed a sample of the license renewal scoping results for the MS and high-pressure coolant injection (HPCI) systems and for the structural components (e.g., trenches, valve pits, manhole, and duct bank structures) for additional assurance that the applicant had implemented its scoping methodology adequately as to 10 CFR 54.4(a)(1). The staff verified that the scoping results for each of the sampled systems were consistent with the methodology, that the SSCs performing intended functions were credited, and that the bases for the results and intended functions were described adequately. The staff verified that the applicant had used pertinent engineering and licensing information to credit SSCs required to be within the scope of license renewal in accordance with 10 CFR 54.4(a)(1) criteria.

To facilitate the identification of SSCs within the scope of license renewal according to 10 CFR 54.4(a) criteria, the applicant developed a license renewal information system (LRIS) 2-8

with detailed design description information about all plant systems and structures and their relevant functions and developed a list of safety-related SCs initially using the list in the component database. The applicant used component database safety-classification fields to consider systems or structures with safety-related components for inclusion within the scope of the license renewal. SC1 component safety classification fields corresponded to 10 CFR 54.4(a) criteria and the SCI database safety-classification and related plant system drawings were the applicant's starting points for specific components required to meet the 10 CFR 54.4(a)(1) criterion.

During the audit, the applicant described the process for evaluating components classified as safety-related with no safety-related intended function. As part of the process, the applicant stated, safety classifications of several components were re-evaluated to reconcile differences between scoping determinations and facility database or CLB information. The applicant evaluated safety-related components not performing intended functions and described explicitly in the LRPDs the rationale for their exclusion from the scope of license renewal. The applicant further evaluated the component database for components classified as safety-related but performing no safety-related functions for verification that the CLB does not credit them for such functions. Such verifications are documented in the scoping evaluations in the license renewal results document.

The staff reviewed the safety classification criteria for consistency between the CLB and the Rule definitions and the applicant's evaluation of the differences between the Rule definition and the site-specific definition of "safety-related" for whether the applicant addressed adequately all SSCs potentially meeting 10 CFR 54.4(a)(1) requirements. The applicant -

documented this evaluation in the LRA and in its onsite LRPDs. As part of license renewal development, the applicant stated, the site-specific definition of "safety-related" was nearly identical to the Rule definition with the following exception:

The CLB definition regarding potential off-site exposure limits refers to 10 CFR 50.100 whereas the rule also references comparable guidelines in 10 CFR 50.34(a)(1), 10 CFR 50.67(b)(2), and 10 CFR Part 100 respectively.

During the audit, the staff reviewed the applicant's evaluation of the Rule and CLB definitions as to 10 CFR 54.4(a)(1). Based on this review, the staff verified that 10 CFR 50.34(a)(1) does not apply because it covers construction permit applications since January 10, 1997. For such a plant, 10 CFR 50.34(a)(1 ) refers to the guidelines of 10 CFR Part 100, which are included in the applicants definition. In addition, the applicant has amended its operating license to allow use of an alternative source term for fuel handling accident analysis in accordance with 10 CFR 50.67.

The change to 10 CFR 50.67 dose limits does not affect the applicant's safety classification definition; however, the applicant included all SSCs within the scope of license renewal as a result of its use of the alternative source term. The staff reviewed the applicant's evaluation and discussed it with the applicant's license renewal team. The staff determined that the applicant adequately evaluated the differences between the applicant's definition and the Rule definition of "safety-related" and that these differences did not cause any components to be considered safety-related beyond those in the CLB.

2.1.4.1.3 Conclusion Based on this sample review, discussions with the applicant, and review of the applicant's 2-9

scoping process, the staff determines that the applicant's methodology for identifying systems and structures meets 10 CFR 54.4(a)(1) scoping criteria and, therefore, is acceptable.

2.1.4.2 Application of the Scoping Criteriain 10 CFR 54.4(a)(2) 2.1.4.2.1 Summary of Technical Information in the Application LRA Section 2.1.1.2 describes the scoping methodology as to 10 CFR 54.4(a)(2) nonsafety-related criteria. The applicant's 10 CFR 54.4(a)(2) scoping methodology was based on guidance from RG 1.188. The applicant's evaluation of the impacts of nonsafety-related SSCs that met 10 CFR 54.4(a)(2) criteria used two major categories: (1) functional failure and (2) physical failure. Summary descriptions of these two categories follow:

Functional Failure of Nonsafety-Related SSCs. SSCs required to perform functions in support of safety-related components were classified as safety-related and within the scope of license renewal in accordance with 10 CFR 54.4(a)(1). The applicant reviewed engineering and licensing documents (UFSAR, Maintenance Rule scoping documents, and DBDs) for exceptions included within the scope of license renewal in accordance with 10 CFR 54.4(a)(2).

For the few exceptions of nonsafety-related components that must support safety functions, LRA Section 2.3 describes the system intended functions and includes the components in the appropriate AMRs.

Physical Failures of Nonsafety-Related SSCs. The applicant evaluated the impact of physical failures of nonsafety-related SSCs within the scope of license renewal in-accordance with 10 CFR 54.4(a)(2) under the following two categories:

(1) Nonsafety-Related SSCs Directly Connected to Safety-Related SSCs. The applicant evaluated certain nonsafety-related components and piping outside the safety class pressure boundary required to be structurally sound to maintain the pressure boundary integrity of safety-related piping. These components perform a structural support function. For piping in this structural boundary, pressure integrity is not required (except for spatial interaction between nonsafety-related and safety-related SSCs); however, piping within the safety class pressure boundary depends on the structural boundary piping and supports for the system to fulfill its safety function.

For JAFNPP, the "structural boundary" is defined as the portion of a piping system outside the safety class pressure boundary yet relied upon for its structural support.

(2) Nonsafety-Related SSCs with the Potentialfor Spatial Interaction with Safety-Related SSCs. The applicant considered various modes of spatial interactions when evaluating potential spatial interaction between nonsafety-related systems and safety-related SSCs and addressed them in the following categories:

physical impact (e.g., seismic Class Il/I) or flooding pipe whip, jet impingement, or harsh environment from piping rupture damage due to leakage or spray from nonsafety-related SSCs.

As documented in the audit report, the results of the applicant's evaluation of nonsafety-related 2-10

SSCs affecting safety-related SSCs were incorporated into the license renewal project report, which describes the 10 CFR 54.4(a)(2) review and the AMR of nonsafety-related systems and components affecting safety-related systems. These results, described in LRA Sections 2.1.1.2 and 2.3.3.14, were input to the scoping and screening process.

2.1.4.2.2 Staff Evaluation Pursuant to 10 CFR 54.4(a)(2), the applicant must consider all nonsafety-related SSCs the failure of which could prevent satisfactory performance of safety-related SSCs relied upon to remain functional during and following a DBE to ensure (a) the integrity of the reactor coolant pressure boundary, (b) the ability to shut down the reactor and maintain it in a safe shutdown condition, or (c) the ability to prevent or mitigate the consequences of accidents that could cause offsite exposures comparable to those of 10 CFR 50.34(a)(1), 10 CFR 50.67(b)(2), or 10 CFR 100.11.

RG 1.188, Revision 1, "Standard Format and Content for Applications to Renew Nuclear Power Plant Operating Licenses," dated September 2005, endorses the use of NEI 95-10, Revision 6, for methods the staff considers acceptable for compliance with 10 CFR Part 54 in preparing license renewal applications. NEI 95-10, Revision 6, addresses the staff positions on 10 CFR 54.4(a)(2) scoping criteria, nonsafety-related SSCs typically identified in the CLB, consideration of missiles, cranes, flooding, high-energy line breaks, nonsafety-related SSCs connected to safety-related SSCs, nonsafety-related SSCs in proximity of safety-related SSCs, and the mitigative and preventive options in nonsafety-related and safety-related SSCs interactions. - . . . .. . . . . . .....

The staff states that applicants should not consider hypothetical failures but rather base their evaluation on the plant's CLB, engineering judgement and analyses, and relevant operating experience, describing operating experience as all documented plant-specific and industry-wide experience useful in determining the plausibility of a failure. Documentation would include NRC generic communications and event reports, plant-specific condition reports, such industry reports as safety operational event reports, and engineering evaluations.

The staff reviewed LRA Sections 2.1.1.2 and 2.3.3.14, where the applicant described the scoping methodology for nonsafety-related criteria in accordance with 10 CFR 54.4(a)(2). In addition, the staff reviewed the 10 CFR 54.4(a)(2) license renewal project report prepared by the applicant as described in Safety Evaluation Report (SER) Section 2.1.4.2.1. The applicant's evaluations were in accordance with the guidance of NEI 95-10, Revision 6, on the treatment of SSCs meeting 10 CFR 54.4(a)(2) criteria. SER Section 2.1.4.2.1 also describes the applicant's evaluation of nonsafety-related SSCs meeting 10 CFR 54.4(a)(2) criteria based on "functional failure" and "physical failure" categories.

Based on a review of the LRA information and the aging management report for 10 CFR 54.4(a)(2) criteria and discussions with the applicant during the audit, the staffs evaluation as to the applicant's categories follows in detail.

The applicant evaluated 10 CFR 54.4(a)(2) SSCs with the four categories from the NRC guidance to the industry on identification and treatment of such SSCs:

(1) Nonsafety-Related SSCs Required for Functions that Support Safety-Related SSCs -

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The nonsafety-related SSCs required to perform functions in support of safety-related functions were classified as safety-related in the applicant's equipment database and included within the scope of license renewal in accordance with 10 CFR 54.4(a)(1). The applicant's 10 CFR 54.4(a)(2) aging management report addresses this criterion. For exceptions to this approach where nonsafety-related components are required to support safety functions, the appropriate AMR included the equipment. Exceptions are containment equipment drains, vacuum priming and air removal, and the offgas portion of gas handling (all three support standby gas treatment (SGT)); fuel pool cooling and cleanup (support secondary means of pool makeup); residual heat removal (RHR)

(nonsafety-related portions support fuel pool cooling); condensate storage (supports emergency core cooling system (ECCS)); and MS leak collection system. These systems classified as nonsafety-related are required to perform a functions to support safety-related functions and were included within the scope of license renewal in accordance with 10 CFR 54.4(a)(2). The staff found that the applicant had implemented an acceptable method for scoping of nonsafety-related systems performing functions that support safety-related intended functions.

(2) Nonsafety-Related Systems Connected to and Structurally Supporting Safety-Related SSCs - To identify the nonsafety-related SSCs directly connected to and required to be structurally sound to maintain the integrity of safety-related SSCs, the applicant has used a bounding approach (described in NEI 95-10, Appendix F), a seismic analysis, and engineering judgment. The applicant reviewed each mechanical system safety-related to nonsafety-related interface for components located between the

. interface-and the structural boundary or equivalent anchor (if used). The applicant included all nonsafety-related SSCs within the scope of license renewal and within the analyzed structural boundary in accordance with 10 CFR 54.4(a)(2). For structural boundaries not indicated on drawings, the applicant included within the scope of license renewal portions of the nonsafety-related SSCs beyond the safety-related SSCs to the first equivalent anchor or seismic anchor. The LRA also indicates that if the structural boundary for the interface of nonsafety-related and safety-related could not be determined the nonsafety-related SSCs were included to a point beyond the interface to a base-mounted component, flexible connection, or the end of the piping run in accordance with NEI 95-10, Appendix F, guidance describing the use of "bounding criteria" for determining the portion of nonsafety-related SSCs to be included within the scope of license renewal. This method assured inclusion of the nonsafety-related piping systems in the design-basis seismic analysis within the scope of license renewal. The applicant's license renewal 10 CFR 54.4(a)(2) aging management report depicts these nonsafety-related systems and components at nonsafety-related/safety-related boundaries. This report also lists the AMR results of the component types with the corresponding intended functions, materials, environments, aging effects, and programs.

As to the use of equivalent anchors, staff discussions with the applicant's project team during the audit revealed that equivalent anchors, flexible connections, and buried piping were not used. Additionally, LRA Section 2.1.2.1.2 and the license renewal 10 CFR 54.4(a)(2) aging management report further confirm that its evaluation of each mechanical system for safety-related to nonsafety-related interfaces and the first structural boundary including seismic anchors, the bounding approach, was based on the guidance of NEI 95-10, Appendix F.

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(3) Nonsafety-Related SSCs with the Potential for Spatial Interaction with Safety-Related SSCs - As reported in SER Section 2.1.4.2.1, the applicant considered physical impact or flooding; pipe whip, jet impingement, or harsh environments; and fluid leakage or spray when evaluating the potential for spatial interactions between nonsafety-related systems and safety-related SSCs. The applicant used a spaces approach for scoping of nonsafety-related systems with potential spatial interaction with safety-related SSCs focused on the interaction between nonsafety-related and safety-related SSCs located in the same space. A "space" was defined as a room or cubicle separated from other spaces by substantial objects (e.g., walls, floors, and ceilings). The space was defined to limit any potential interaction between nonsafety-related and safety-related SSCs to the space.

As related to physical impact or flooding, and as described in the LRA, the applicant considered situations where nonsafety-related supports for nonseismic (including seismic Il/I) piping systems and electrical conduit and cable trays with potential for spatial interaction with safety-related SSCs are included within the scope of license renewal per 10 CFR 54.4(a)(2) and subject to an AMR. Civil/structural aging management reports address these supports and components as commodities. In the applicant's earthquake experience there are no occurrences of welded steel pipe segments falling. The applicant concluded that, as long as the effects of aging on piping system supports are managed, falling of piping systems is not plausible except if due to flow-accelerated corrosion and the piping section itself is not within the scope for 10 CFR 54.4(a)(2) due to a physical impact hazard. The applicant evaluated missiles that could be generated from internal or external events like failure of rotating equipment. The nonsafety-related design features which protect safety-related*SSCs from such missiles are within the scope of license renewal.

In addition, the applicant evaluated overhead-handling systems for structural failure that could cause damage to any system and prevent the accomplishment of a safety function.

Nonsafety-related overhead-handling equipment determined to have a possible impact on safety-related SSCs was included within the scope of license renewal.

As to pipe whip, jet impingement, and harsh environment, the applicant evaluated nonsafety-related portions of high-energy lines against 10 CFR 54.4(a)(2) criteria. The applicant's evaluation was based on a review of the UFSAR and relevant site documentation.

The applicant's high-energy systems were evaluated for component parts of safety-related high-energy lines that can affect safety-related equipment.

If the applicant's high-energy line break analysis assumed that a nonsafety-related piping system would not fail or assumed failure only at specific locations, that piping system (i.e.,

piping, equipment and supports) was included within the scope of license renewal per 10 CFR 54.4(a)(2) criteria and subject to an AMR for reasonable assurance that those assumptions remain valid through the period of extended operation. Also, as addressed in the LRPD for 10 CFR 54.4(a)(2) review, the applicant studied the reference documents with high-energy line break analysis for inside as well as outside containment and indicated high-energy lines for the MS, HPCI, reactor core isolation cooling (RCIC), core spray (CS), and reactor water clean-up systems. Many of these systems were safety-related and included within the scope of license renewal in accordance with 10 CFR 54.4(a)(1). The remaining nonsafety-related high-energy lines with potential interaction.with safety-related SSCs were included within the scope of license renewal in accordance with 10 CFR 54.4(a)(2).

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For spray or leakage effects, the applicant evaluated moderate- and low-energy systems with the potential for spatial interactions of spray and leakage. Nonsafety-related systems and nonsafety-related portions of safety-related systems with the potential for spray or leakage that could prevent safety-related SSCs from performing required safety functions were considered within the scope of license renewal. The applicant used a "spaces" approach for nonsafety-related SSCs located within the same space as safety-related SSCs. As described in the LRA, a space is a room or cubicle separated from other spaces by substantial objects (e.g.,

walls, floors, and ceilings). The space was defined to limit any potential interaction between nonsafety-related and safety-related SSCs to the space. The applicant.documented in its scoping results (license renewal document (LRD)) report the evaluation of each mechanical system for potential spatial interaction with safety-related SSCs as documented in the staff audit report. After documenting the mechanical systems, the applicant evaluated system functions for whether the system contained fluid, air, or gas. Based on spray or leakage and operating experience, the applicant excluded nonsafety-related SSCs containing air or gas from the scope of license renewal. The applicant then evaluated the mechanical systems for components located within safety-related structures. Those liquid-filled systems with components located within safety-related structures then were evaluated for components located within spaces containing safety-related SSCs. Nonsafety-related SSCs containing fluid and located within spaces containing safety-related SSCs, were included within the scope of license renewal.

Protective features (e.g., whip restraints, spray shields, supports, missile or flood barriers) preventing physical impact and fluid leakage, spray, or flooding are installed to protect safety-related SSCs against spatial interaction with-nonsafety-related SSCs. Such protective features credited in the plant design were included within the scope of license renewal and are subject to an AMR.

2.1.4.2.3 Conclusion Based on its review, the staff determines that the applicant's methodology for identifying systems and structures meets 10 CFR 54.4(a)(2) scoping criteria and, therefore, is acceptable.

This determination is based on a review of sample systems, discussions with the applicant, and review of the applicant's scoping process.

2.1.4.3 Application of the Scoping Criteriain 10 CFR 54.4(a)(3) 2.1.4.3.1 Summary of Technical Information in the Application LRA Section 2.1.1.3 describes the methodology for identifying SSCs within the scope of license renewal. Mechanical systems and structures that perform fire protection (FP), anticipated transient without scram (ATWS), or station blackout (SBO) intended functions were included within the scope of license renewal. LRA Sections 2.3 and 2.4 indicate mechanical systems and structures with 10 CFR 54.4(a)(3) intended functions. For example, LRA Section 2.3.2.2 states that the CS system has a 10 CFR 54.4(a)(3) intended function. The CS system is credited in the 10 CFR Part 50 Appendix R safe shutdown capability analysis (10 CFR 50.48). LRA Section 2.4.3 states that the radioactive waste building has one 10 CFR 54.4(a)(3) intended function. The radioactive waste building houses equipment credited for FP (10 CFR 50.48). All electrical and instrumentation and control (I&C) systems and electrical equipment in mechanical 2-14

systems were included within the scope of license renewal.

Fire Protection. LRA Section 2.1.1.3.1, "Commission's Regulations for Fire Protection (10 CFR 50.48)," describes the scoping of mechanical systems and structures required to demonstrate compliance with the FP requirements in 10 CFR 50.48. From its CLB the applicant indicated the mechanical systems and structures relied upon to meet 10 CFR Part 50 Appendix R and 10 CFR 50.48 requirements. Mechanical systems and structures credited with FP and fire detection and mitigation in areas with safety-related equipment and equipment credited with safe shutdown in a fire were included within the scope of license renewal.

Environmental Qualification (EQ). LRA Section 2.1.1.3.2, "Commission's Regulations for Environmental Qualification (10 CFR 50.49)," describes the 10 CFR 50.49 EQ requirements. All electrical and I&C systems and electrical equipment in mechanical systems were included within the scope of license renewal. Consequently, environmentally-qualified equipment was included within the scope of license renewal.

Pressurized Thermal Shock. These requirements do not apply to JAFNPP, a boiling-water reactor.

Anticipated Transient Without Scram. LRA Section 2.1.1.3.4, "Commission's Regulations for Anticipated Transients Without Scram (10 CFR 50.62)," describes the scoping of mechanical systems and structures required to demonstrate compliance with 10 CFR 50.62 ATWS requirements. Mechanical systems and structures that perform 10 CFR 50.62 intended functions were included within the scope of license renewal.- -

Station Blackout. LRA Section 2.1.1.3.5, "Commission's Regulations for Station Blackout (10 CFR 50.63)," describes the scoping criteria. The applicant developed a four-hour coping analysis to address 10 CFR 50.63 requirements. Based on the its CLB for SBO, the applicant determined system intended functions in support of 10 CFR 50.63 requirements. Based on staff guidance in SRP-LR Section 2.5.2.1.1, the applicant conservatively included certain switchyard components required to restore offsite power within the scope of license renewal even though those components are not relied on in safety analyses or plant evaluations for functions that demonstrates compliance with SBO regulations (10 CFR 50.63). The applicant uses a bounding approach to scoping for electrical equipment. Onsite electrical systems and electrical equipment in mechanical systems are included by default within the scope of license renewal.

Consequently, electrical equipment supporting 10 CFR 50.63 requirements was included within the scope of license renewal.

2.1.4.3.2 Staff Evaluation The staff reviewed the applicant's approach to indicating mechanical systems and structures relied upon to perform functions related to the four regulated BWR events as described in 10 CFR 54.4(a)(3). As part of this review, the staff discussed the methodology with the applicant, reviewed the documentation developed to support the approach, and evaluated a sample of the mechanical systems and structures indicated as within the scope of 10 CFR 54.4(a)(3) criteria.

The applicant's implementing procedures describe the process for indicating systems and structures within the scope of license renewal, stating that all mechanical systems and 2-15

structures performing intended functions for 10 CFR 54.4(a)(3) were included within the scope of license renewal and that the scoping results are in the applicants scoping results report, which also describes the information sources, including the UFSAR, the system safety function sheets, and the system design basis documents, for mechanical systems and structures credited for response to regulated events.

Fire Protection. The LRD states that the applicant used the Fire Hazard Analysis, Fire Protection, and Appendix R Program; the Safe Shutdown Capability Reassessment; and the Technical Requirements Manual to indicate mechanical systems and structures included within the scope of license renewal for FP. The LRD shows the mechanical systems included within the scope of license renewal because they perform 10 CFR 50.48 intended functions, summarizes scoping results for mechanical systems, and identifies 26 mechanical systems with one or more 10 CFR 50.48 intended functions. The report also indicates structures within the scope of license renewal because they perform 10 CFR 50.48 functions and summarizes scoping results for ten structures with one or more 10 CFR 50.48 intended functions. A summary of the scoping results for structures indicates 14 with one or more 10 CFR 50.48 intended functions. The staff reviewed the Fire Hazard Analysis, Fire Protection, and Appendix R Program; the Safe Shutdown Capability Reassessment; the Technical Requirements Manual; and the results reports to verify the SSCs to be included within the scope of license renewal for FP and determined that the methodology had been appropriate.

Environmental Qualification. Using a bounding scoping approach for electrical equipment, the applicant included by default all electrical systems and all electrical equipment in mechanical systems, including equipment relied upon to perform functions that demonstrate compliance with EQ regulations, within the scope of license renewal.

As documented in the audit report, for the EQ-regulated event, after reviewing the LRA and the applicant's implementation procedures, results reports, and the master equipment list for EQ components to verify that the applicant had indicated SSCs included within the scope of license renewal for EQ, the staff determined that the methodology had been applied appropriately.

Anticipated Transient Without Scram. The applicant's scoping results report indicates the mechanical systems included within the scope of license renewal because they perform 10 CFR 50.62 intended functions. For example, the control rod drive (CRD) system has one intended function, alternate rod insertion during an ATWS. The report summarizes the scoping results for mechanical systems, indicates that the CRD and standby liquid control (SLC) systems perform 10 CFR 50.62 intended functions, and includes one structure within the scope of license renewal because it performs a 10 CFR 50.62 intended function. The reactor building was included within the scope of licensee renewal because it houses equipment credited for ATWS.

Station Blackout. The applicant's scoping results report states that mechanical systems and structures credited with the four-hour coping duration were included within the scope of license renewal. The applicant conservatively included within the scope of license renewal switchyard components required to restore offsite power even though those components are not relied on in safety analyses or plant evaluations to perform functions demonstrating compliance with SBO regulation (10 CFR 50.63). The report identified mechanical systems included within the scope of license renewal because they perform 10 CFR 50.63 intended functions. For example, the RCIC system has an intended function to provide makeup water to the reactor vessel during 2-16

SBO. The report summarizes the scoping results for mechanical systems and indicates four with one or more 10 CFR 50.62 intended functions. The report also indicates structures included within the scope of license renewal because they perform 10 CFR 50.62 functions. For example, the transformer/switchyard support structures have an intended function to support equipment credited for SBO. The report summarizes the scoping results for structures and indicates five structures with one or more 10 CFR 50.62 intended functions.

2.1.4.3.3 Conclusion Based on the sample review, discussions with the applicant, and review of the applicant's scoping process, the staff determines that the applicant's methodology for identifying systems and structures is consistent with Interim Staff Guidance 2 (ISG-2) for meeting the requirements of the SBO Rule (10 CFR 50.63) and; thus, has met 10 CFR 54.4(a)(3) scoping criteria and is, therefore, acceptable.

2.1.4.4 Plant-Level Scoping of Systems and Structures 2.1.4.4.1 Summary of Technical Information in the Application System and Structure Level Scopinq. As documented in the audit report, the applicant documented its methodology for scoping SSCs in accordance with 10 CFR 54.4(a) in the LRPGs, project documents, and aging management report. The applicant's approach to system and structure scoping stated in the site guidance was consistent with the methodology described in LRA Section 2.1.Particularly, the LRPG specifies-that-license renewal scoping personnel use CLB documents to describe the system or structure including a list of functions it is required to perform. Sources of information on the CLB for systems include the USAR, DBDs, the component database, Maintenance Rule scoping reports, control drawings, and docketed correspondence. The applicant then determined whether the system or structure functions met 10 CFR 54.4(a) scoping criteria. The applicant documented the results of the plant-level scoping process in accordance with the LRPGs.

The systems and structures scoping report contained in the LRDs provided these results.

Information in the results report includes a structure or system description, the functions it performs, system realignment (as applicable), intended functions, the 10 CFR 54.4(a) scoping criteria met, references, and the bases for the classification of the system or structure intended functions. During the scoping methodology audit, the staff reviewed a sampling of LRD reports and concluded that the applicant reported scoping results in an appropriate level of detail to document the scoping process.

Based on a review of the LRA, the scoping and screening implementation procedures, and a sampling review of system and structure scoping results during the methodology audit, the staff finds the applicant's scoping methodology for systems and structures meeting the requirements of 10 CFR 50.54. In particular, the staff determines that the applicant's methodology reasonably indicates systems and structures within the scope of license renewal and their intended functions.

Component Level Scopina. After indicating the systems and structures within the scope of license renewal, the applicant reviewed mechanical systems and structures for components in 2-17

each system and structure within the scope of license renewal. The structural and mechanical components that supported intended functions were considered within the scope of license renewal and screened to determine whether an AMR was required. All electrical components within the scope of mechanical and electrical systems were included within the scope of license renewal as commodity groups. The applicant considered three component classifications during this stage of the scoping methodology: mechanical, structural, and electrical. The component database and controlled plant drawings comprehensively listed plant components. The applicant used component type and unique component identification numbers for each component within the scope of license renewal and subject to an AMR.

Commodity Groups Scopinq. Initially the applicant included all electrical components within the scope of mechanical and electrical systems as separated commodity groups. The applicant screened out many electrical component types considered active according to RG 1.188 and the SRP-LR as not meeting the passive criteria and not subject to an AMR. LRA Section 2.1.2.3 describes the commodity groups for evaluating all in-scope electrical components subject to an AMR.

Structural components were grouped as structural commodity types based on materials of construction. LRA Section 2.1.2.2.1 shows the various structural commodity groups including:

" steel

• threaded fasteners

" concrete

• fire- barriers Insulation. LRA Section 2.4.4, "Bulk Commodities," states that insulation may have the specific intended functions of (1) controlling heat load during design-basis accidents (DBAs) in areas with safety-related equipment or (2) maintaining integrity so falling insulation does not damage safety-related equipment (reflective metallic-type reactor vessel insulation). As such insulation is included within the scope of license renewal as a commodity group in applications where it performs either intended function.

Consumables. LRA Section 2.1.2.4, "Consumables," addresses short-lived items. The applicant used the guidance in SRP-LR Table 2.1-3 to evaluate consumables, dividing them into the following four categories for purposes of license renewal: (a) packing, gaskets, component seals, and O-rings, (b) structural sealants, (c) oil, grease, and filters, and (d) system filters, fire extinguishers, fire hoses, and air packs.

Group (a) subcomponents are not relied upon to form a pressure-retaining function and, therefore, not subject to an AMR. Group (b) subcomponents are structural sealants for structures within the scope of license renewal that require an AMR. Group (c) subcomponents are periodically replaced and monitored for condition according to plant procedures and, therefore, not subject to an AMR. Group (d) consumables are subject to replacement based on National Fire Protection Association (NFPA) standards according to plant procedures and, therefore, not subject to an AMR.

2.1.4.4.2 Staff Evaluation The staff reviewed the applicant's methodology for scoping plant systems and components for 2-18

consistency with 10 CFR 54.4(a). The applicant documented the methodology for identifying mechanical SSCs within the scope of license renewal in the license renewal results report and plant level scoping results in LRA Tables 2.2-1a for mechanical systems and 2.2-3 for structures. The scoping process defined the entire plant in terms of systems and structures.

Specifically, the applicant used the LRPGs to indicate the systems and structures subject to 10 CFR 54.4 review, to describe the processes for recording the results of the review, and to determine whether the system or structure performed intended functions consistent with 10 CFR 54.4(a) criteria. The process was completed for all systems and structures to address the entire plant. The applicant's personnel initially reviewed systems and structures in the CLB.

The staff noted that a system or structure was presumed to be within the scope of license renewal if it performed one or more safety-related functions or met other scoping criteria per the Rule as determined by CLB review. Mechanical and structural component types that support intended functions and all component types in electrical systems were considered within the scope of license renewal and placed in commodity groups. The applicant screened electrical commodity groups further to determine whether they required An AMR. The staff found no discrepancies with the applicant's methodology.

The staff reviewed the applicant's methodology for generating commodity groups. The LRDs indicate separate commodity groups for various mechanical, structural, and electrical components. The staff reviewed the commodity group level functions evaluated by the applicant in accordance with 10 CFR 54.4(a). This evaluation determined whether the commodity group was within the scope of license renewal. The staff found the methodology acceptable.

The staff reviewed the scoping process results documented in the scoping results report in accordance with the LRPGs. This documentation adequately described how the system or structure are meeting its 10 CFR 54.4(a) scoping criteria requirements. The staff also reviewed a sample of the applicant's scoping documentation and concluded that it had a level of detail appropriate to document the scoping process.

The staff reviewed the applicant's evaluation of plant insulation as documented in the license renewal results report and the bulk commodities AMR. The applicant indicated insulation as within the scope of license renewal and subject to an AMR based on the intended functions of heat transfer reduction and structural or functional support to nonsafety-related SCs the failure of which could prevent performance of safety-related functions. Both mirror and nonmirror insulation were evaluated. The staff finds the applicant's methods and conclusions on insulation acceptable.

The staff reviewed the scoping and screening of consumables and finds that the applicant followed the process described in SRP-LR and appropriately categorized consumables in accordance with the guidance. The applicant initially evaluated plant consumables for whether any met the criteria requiring an AMR (e.g., structural sealants). Additionally, the applicant cited all industry guidelines (e.g., NFPA standards) used as the basis for replacement of any item.

2.1.4.4.3 Conclusion Based on its review of the LRA, mechanical system and structures results reports, scoping and screening implementation procedures, and a sampling of system scoping results during the audit, the staff concludes that the applicant's scoping methodology for plant SSCs, commodity 2-19

groups, insulation, and consumables is acceptable. In particular, the staff determines that the applicant's methodology reasonably identifies systems, structures, component types, and commodity groups within the scope of license renewal and their intended functions.

2.1.4.5 MechanicalComponent Scoping 2.1.4.5.1 Summary of Technical Information in the Application LRA Section 2.1 describes the methodology for identifying mechanical system components within the scope of license renewal. For mechanical systems, components that support system intended functions are within the scope of license renewal. For mechanical system scoping, the applicant defined a system as the collection of components in the component database assigned to the system code. The applicant determined system intended functions by the functions performed by those components. Definition of a system by database components is generally consistent with Maintenance Rule scoping documents and safety classification procedure. The applicant evaluated each mechanical system against 10 CFR 54.4 criteria to determine which system components performed intended functions consistent with the scoping criteria.

LRA Section 2.1.2.1.3, "Mechanical System Drawings," describes how the LRBDs are prepared to indicate system portions that support system intended functions within the scope of license renewal.

Boundary flags-are marked-with safety-to-nonsafety class-breaks to indicate system intended function boundaries for system in-scope portions. Components within these boundary flags and class breaks support system intended functions within the scope of license renewal.

Components subject to an AMR (i.e., passive, long-lived components that support system intended functions) are highlighted with color coding to indicate which system AMR evaluated the components. Drawings with only highlighting and no boundary flags indicate that all components on the drawing support the system intended functions unless excluded by safety-to-nonsafety class breaks.

2.1.4.5.2 Staff Evaluation The staff reviewed LRA Section 2.1 and the guidance in LRPGs, LRDs, and aging management reports to complete the review of mechanical scoping process. The program guidelines and aging management reports state instructions for evaluating individual mechanical system components by the scoping criteria. The applicant utilized CLB documents when determining whether a system or component is within the scope of 10 CFR 54.4(a). Examples of these sources included, but were not limited to, the UFSAR, Maintenance Rule database, separate ATWS, EQ, FP and SBO documents, technical specifications, and SERs. Additional sources of mechanical component information included the component database and individual system flow diagrams.

The applicant evaluated mechanical system diagrams to create license renewal boundaries for each system showing-the in-scope components and evaluated components supporting safety-related functions or regulated events further during the screening process for whether they should be subject to an AMR.

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Nonsafety-related components connected to safety-related components and providing structural support at the safety/nonsafety interface or components the failure of which could prevent satisfactory accomplishment of a safety-related function due to spatial interaction with safety-related SSCs are included within the scope of license renewal and in the AMR for the 10 CFR 54.4(a)(2) evaluation but not specifically highlighted on the license renewal drawings.

As part of the applicant's verification process, the list of mechanical components within the scope of license renewal was compared to the data in the LRIS and the component database to confirm the scope of components in the system.

The staff reviewed the implementation guidance and the CLB documents for mechanical system scoping and found the guidance and CLB source information acceptable to indicate mechanical components and support structures in mechanical systems within the scope of license renewal. The staff conducted detailed discussions with the applicant's license renewal project management personnel, reviewed documentation of the scoping process, and assessed whether the applicant had applied the scoping methodology outlined in the LRA and implementation procedures appropriately and whether the scoping results were consistent with CLB requirements. The staff found the applicant's procedural methodology consistent with the description LRA Section 2.1 and the guidance of SRP-LR Section 2.1 and adequately implemented.

Scoping Methodology for the Main Steam System. LRA Section 2.3.4.2, "Main Steam," states the scoping and screening methodology results for SSCs within the nonsafety-related MS system, which accomplishes the following scoping criteria of the Rule.

The MS system has the following 10 CFR 54.4(a)(1) intended functions:

• Main steam isolation valve (MSIV) and MS line drain valve isolation support

• Provision of steam to HPCI turbine

• Maintenance of reactor coolant pressure boundary (RCPB) integrity up to and including the downstream MSIV

• MSIV leakage collection and release

" MS leak collection system isolation valve isolation support

• Maintenance of N2 pressure boundary in containment

° Maintenance of the boundary between the reactor cavity and the MS lines during refueling, testing, and maintenance activities The MS system has the following 10 CFR 54.4(a)(2) intended functions:

Support of MS leak collection system operation by nonsafety-related MS line piping downstream of the MSIVs Maintenance of nonsafety-related component integrity so no physical interaction with safety-related components could prevent satisfactory accomplishment of a safety function 2-21

The MS system has the following 10 CFR 54.4(a)(3) intended functions:

" FP as credited in the 10 CFR Part 50 Appendix R safe shutdown analysis (10 CFR 50.48)

" Provision of steam to the HPCI and RCIC turbines during SBO (10 CFR 50.63)

As part of the audit, the staff reviewed the applicant's methodology for indicating MS mechanical component types meeting the scoping criteria as defined in the Rule. The staff also reviewed the scoping methodology implementation procedures and discussed the methodology and results with the applicant. The staff verified that the applicant had used pertinent engineering and licensing information to determine the MS mechanical component type within the scope of license renewal. As part of the review process, the staff evaluated each system intended function of the MS system, the basis for inclusion of the intended function, and the process for indicating the system components credited with intended functions. The staff verified that the applicant had highlighted system P&IDs to develop the system boundaries in accordance with procedural guidance. The applicant was knowledgeable about the process and conventions for establishing boundaries as defined in the license renewal implementation procedures. Additionally, the staff verified that the applicant independently had verified the results in accordance with the governing procedures. Specifically, other license renewal personnel knowledgeable about the system independently had evaluated the marked-up drawings for accurate system intended functions. The applicant completed additional cross-discipline verification and independent evaluation of the highlighted drawings before final approval of thescoping,_

2.1.4.5.3 Conclusion Based on its review of the LRA, scoping implementation procedures, and a sample of mechanical component scoping results for the CS system, the staff concludes that the applicant's methodology for identifying mechanical components within the scope of license renewal meets 10 CFR 54.4(a) requirements.

2.1.4.6 Structural Component Scoping 2.1.4.6.1 Summary of Technical Information in the Application LRA Section 2.1 describes the methodology for identifying structures within the scope of license renewal. Initially the applicant identified all plant structures and SBO-related nonplant structures and structure intended functions from CLB documents (e.g., the UFSAR, the Maintenance Rule document for buildings and structures, safety classification procedures, the fire hazards analysis, and the safe shutdown capability assessment). Structures with 10 CFR 54.4(a) intended functions were included within the scope of license renewal and listed in LRA Table 2.2-3, structures not within the scope of license renewal in LRA Table 2.2-4. LRA Section 2.4 describes the scoping results for individual structures within the scope of license renewal. LRA Section 2.4.3 describes various structures within the turbine building complex and yard structures and their seismic classifications based on design requirements. For example, manholes and duct banks were included within the scope of license renewal because they support safety-related and nonsafety-related equipment within thescope of license renewal.

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2.1.4.6.2 Staff Evaluation The staff reviewed the applicant's approach to identifying structures relied upon for functions described in 10 CFR 54.4(a). In this review, the staff discussed the methodology with the applicant, reviewed the supporting documentation, and evaluated the scoping results for several structures within the scope of license renewal.

The LRPGs describe the applicant's process for identifying structures within the scope of license renewal and state that all structures with intended functions must be included and scoping results documented in the scoping results report, which lists all structures evaluated and describes the procedures for identifying them by use of the plant UFSAR, Maintenance Rule document, fire hazards analysis, and safe shutdown capability analysis.

The staff reviewed the applicant's implementation procedures and scoping results reports.

Structural scoping considered all plant buildings, yard structures, and SBO related nonplant structures. The scoping results report specifies the intended function(s) for each structure required for compliance with one or more 10 CFR 54.4(a) criteria. Structural component intended functions were based on the guidance of NEI 95-10, and the SRP-LR. The applicant determined structure evaluation boundaries by developing a complete description of each structure as to its intended functions. The scoping results report documents a list. of structures, evaluation results for the 10 CFR 54.4(a) criteria for each structure, a description of structural intended functions, and source reference information for the functions.

The staff conducted detailed discussions with the-applicant's license renewal -team and reviewed documentation pertinent to the scoping process. The staff assessed whether the scoping methodology outlined in the LRA and procedures had been implemented appropriately and whether the scoping results were consistent with CLB requirements. In these audit activities the staff found no discrepancies between the methodology documented and the implementation results.

2.1.4.6.3 Conclusion Based on its review of the LRA, the applicant's detailed scoping implementation procedures, and a sampling of structural scoping results, the staff concludes that the applicant's methodology for identification of structural component types within the scope of license renewal meets 10 CFR 54.4(a) requirements and, therefore, is acceptable.

2.1.4.7 Electrical Component Scoping 2.1.4.7.1 Summary of Technical Information in the Application LRA Section 2.1.1, "Scoping Methodology," describes the scoping process for electrical systems and components. For purposes of system level scoping, plant electrical and I&C systems were included within the scope of license renewal. Electrical and I&C components in mechanical systems were included in the evaluation of electrical systems. LRA Section 2.1.1 refers to LRA Section 2.5, "Scoping and Screening Results: Electrical and Instrumentation and Control Systems," which states that the default inclusion of plant electrical and I&C systems within the scope of license renewal reflects the method used for the scoping of electrical 2-23

systems, which is different from the methods used for mechanical systems and structures. The applicant's approach to electrical and I&C components included components in the review unless specifically screened out. When used with the plant spaces approach, this method eliminated the need for unique identification of every component and its specific location and gave assurance no component was excluded from an AMR.

2.1.4.7.2 Staff Evaluation As documented in the audit report, the staff evaluated LRA Sections 2.1.1 and 2.5 and the applicant's implementing procedures and aging management reports governing the electrical scoping methodology. The scoping phase for electrical components began with the placement within the scope of license renewal of all plant system electrical components and nonplant electrical systems including switchyard components required for SBO. Switchyard components required to restore offsite power also were included conservatively within the scope of license renewal even though those components are not relied on in safety analyses or plant evaluations for functions demonstrating compliance with SBO regulation (10 CFR 50.63). The staff determined that the data sources for scoping included the component data base, the station single line drawing, and the cable design procurement specifications. The staff reviewed portions of the data sources and selected several examples of components for which the applicant demonstrated the process for determining whether electrical components were within the scope of license renewal.

2.1.4.7.3 Conclusion Based on its review of the LRA, the applicant's detailed scoping implementation procedures, and a sampling of electrical scoping results, the staff concludes that the applicant's methodology for identification of electrical components within the scope of license renewal meets 10 CFR 54.4(a) requirements and, therefore, is acceptable.

2.1.4.8 Conclusion for Scoping Methodology Based on its review of the LRA and the scoping implementation procedures, the staff determines that the applicant's scoping methodology is consistent with SRP-LR guidance and has identified SSCs within the scope of license renewal in accordance with the requirements of 10 CFR 54.4(a)(1), (2), and (3). Therefore, the staff concludes that the applicant's methodology meets 10 CFR 54.4(a) requirements.

2.1.5 Screening Methodology 2.1.5.1 General Screening Methodology After identifying systems and structures within the scope of license renewal, the applicant implemented a process for identifying SCs subject to an AMR in accordance with 10 CFR 54.21.

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2.1.5.1.1 Summary of Technical Information in the Application LRA Section 2.1.2, "Screening Methodology," describes the method of identifying components from in-scope systems and structures subject to AMRs. The screening consists of the following steps:

Identification of long-lived or passive components for each in-scope mechanical system, structure, and electrical commodity group Identification of the license renewal intended function(s) for all mechanical and structural component types and electrical commodity groups Active components were screened out and, therefore, required no AMR. The screening process also identified short-lived components and consumables. The short lived components are not subject to an AMR. Consumables are a special class of items that include packing, gaskets, component seals, O-rings, oil, grease, component filters, system filters, fire extinguishers, fire hoses, and air packs. Structural sealants for structures were the only consumables within the scope of license renewal requiring an AMR.

2.1.5.1.2 Staff Evaluation Pursuant to 10 CFR 54.21, each LRA must contain an IPA that indicates SCs within the scope of license renewal subject to an AMR. The IPA must indicate components that perform intended Junctions without moving parts or a chang~e in co~nfiguration or propepries(passive) as well as components not subject to periodic replacement after a qualified life or specified time period (long-lived). The IPA describes and justifies the methodology for determining the passive and long-lived SCs and demonstrates that the effects of aging on those SCs will be adequately managed to maintain intended functions under all design conditions imposed by the plant-specific CLB for the period of extended operation.

The staff reviewed the applicant's methodology to determine whether mechanical and structural component types and electrical commodity groups within the scope of license renewal should be subject to an AMR. The applicant implemented a process for determining which SCs were subject to AMRs in accordance with 10 CFR 54.21 (a)(1). LRA Section 2.1.2 describes the screening of component types and commodity groups within the scope of license renewal.

The screening process evaluated these in-scope component types and commodity groups to determine which were long-lived and passive and, therefore, subject to an AMR. The staff reviewed LRA Sections 2.3, 2.4, and 2.5, which presents the results of the process, and the screening results reports for the MS system and structures.

The applicant discussed with the staff the processes for each discipline and provided administrative documentation that describes the screening methodology. Specific methodology, mechanical, electrical, and structural, is addressed below.

2.1.5.1.3 Conclusion Based on its review of the LRA, the screening implementation procedures, and a sampling of screening results, the staff determines that the applicant's screening methodology is consistent 2-25

with SRP-LR guidance and capable of identifying passive, long-lived components within the scope of license renewal and subject to an AMR. The staff determines that the applicant's process for identifying component types and commodity groups subject to an AMR meets 10 CFR 54.21 requirements and, therefore, is acceptable.

2.1.5.2 Mechanical Component Screening 2.1.5.2.1 Summary of Technical Information in the Application LRA Section 2.1.2.1, "Screening of Mechanical Systems," describes the screening methodology for passive and long-lived mechanical components and their support structures subject to AMRs. License renewal drawings were prepared to indicate system portions that support system intended functions within the scope of license renewal (except systems within the scope of 10 CFR 54.4(a)(2) for physical interactions). In addition, the drawings show components subject to an AMR. Boundary flags in conjunction with safety-to-nonsafety class breaks indicate system intended function boundaries as noted on the drawings. All components within these boundary flags and class breaks support system intended functions within the scope of license renewal. Passive, long-lived components that support system intended functions are highlighted to indicate that they are subject to an AMR.

2.1.5.2.2 Staff Evaluation As documented in the audit report, the staff evaluated the mechanical screening methodology in LRA 2.1.2.1, "Screening of-Mechanical Systems,".the LRDs, LRPGs,-and the aging -...

management reports. The mechanical system screening process began with the results from the scoping process. The applicant reviewed each mechanical system flow diagram for passive and long-lived components. To identify system components required to perform system intended functions, the applicant initially listed mechanical system components based on information from controlled system diagrams and the component database. The LRPGs and LRDs explain in detail how (1) to determine system boundaries, (2) to indicate components within specific flow paths required for intended functions, and (3) to determine system and interdisciplinary interfaces (e.g., mechanical/structural, mechanical/electrical, structural/electrical). After entering these components into the LRIS database, from the component database the applicant confirmed that all system components had been considered.

Where the mechanical system flow diagrams of large vendor-supplied components (e.g.,

compressors, emergency diesel generators (EDGs)) were not in sufficient detail, the applicant reviewed component drawings or vendor manuals as necessary for individual components.

The staff reviewed the results of the boundary evaluation, discussed it with the applicant, and verified that mechanical system evaluation boundaries were established for each system within the scope of license renewal. The applicant determined these boundaries by mapping the pressure boundary of system-level license renewal intended functions onto the controlled-system drawings. Mechanical component types were loaded into a scoping and screening database for further review for inclusion of all component types. For a component type not already in the LRIS, the applicant created a component type for use in the LRIS database. A 2-26

preparer and an independent reviewer comprehensively evaluated the boundary drawings for completeness and accuracy of the review results. As part of the evaluation, the applicant also benchmarked system passive and long-lived components against previous LRAs for similar systems.

As part of the audit, the staff reviewed the applicant's methodology for determining which SCs meet the screening criteria of the Rule. The staff verified the applicant's implementation of the staff SRP guidance and RG 1.188 in the screening. The staff found that the applicant had developed sufficiently detailed procedures for the screening of mechanical systems, had implemented those procedures, and had documented the results adequately in aging management reports.

Additionally, the staff reviewed the screening of the MS and HPCI systems. The staff reviewed the system intended functions and source documents for the system, the MS and HPCI P&IDs, and the results documented in the aging management report. The staff found no discrepancies with the evaluation and determined that the applicant adequately followed the process documented in the LRDs and adequately documented the results in the aging management reports.

2.1.5.2.3 Conclusion Based on its review of the LRA, the screening implementation procedures, and a sample of MS and HPCI systems screening results, the staff determines that the applicant's mechanical component screening methodology is consistent with SRP-;LR guidance. The staff -concludes- -

that the applicant's methodology for identification of passive, long lived mechanical components within the scope of license renewal and subject to an AMR meets 10 CFR 54.21(a)(1) requirements; and, therefore, is acceptable.

2.1.5.3 Structural Component Screening 2.1.5.3.1 Summary of Technical Information in the Application LRA Sections 2.1.2.2 and 2.4 describe the methodology for structural screening. LRA Section 2.1.2.2 states that specific structural components are determined for each structure within the scope of license renewal from the CLB (drawings, etc.). Passive and long-lived structural components with intended functions were subject to an AMR. The applicant used the SRP-LR and NEI 95-10, Appendix B, for the identification of passive structural components.

Structural components (e.g., door, gate, pipe support, strut, or siding) were categorized as steel, threaded fasteners, concrete, fire barriers, elastomers, earthen structures, or fluoropolymers and lubrite sliding surfaces. LRA Section 2.4 summarizes the screening results for structures. For example, LRA Section 2.4.3 and LRA Table 2.4-3 summarize the screening results for manholes and duct banks. Structural components common to all structures (e.g.,

mirror insulation) were categorized as bulk commodities. LRA Section 2.4.4 and LRA Table 2.4-4 summarize the screening results for structural bulk commodities.

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2.1.5.3.2 Staff Evaluation The staff reviewed the applicant's methodology for identifying structural components subject to an AMR by 10 CFR 54.21(a)(1). In this review, the staff discussed the methodology with the applicant, reviewed the supporting documentation, and evaluated the screening results for several structures within the scope of license renewal.

As described in the audit report, the applicant's aging management reports details the applicant's process for screening structural components subject to AMRs. The report states that all passive and long-lived structural components that perform intended functions are subject to AMRs. In addition, separate aging management reports describe the screening results for major structural groups and bulk commodities.

The staff reviewed the applicant's methodology for structural screening described in the noted LRA sections, the applicant's implementation guidance, and its aging management reports. The applicant's screening, in accordance with its implementation guidance, recorded pertinent structure design information, components, materials, environments, and aging effects.

The staff verified that the applicant had used the lists of passive SCs in the regulatory guidance and supplemented them with additional items unique to the site or for which there were no direct matches (i.e., material/environment combinations) to the generic lists.

The boundary for a structure was the entire building including base slabs, foundations, walls, beams, slabs, and steel superstructure. The aging management reports indicate for each

-individual SCwhether the-component is subject to-an -AMR and identifies it-asa-component;-

component type (e.g., door, gate, anchor support, strut, or siding), or material. The applicant discussed with the staff in detail that the screening methodology as well as the screening reports for a selected group of structures.

2.1.5.3.3 Conclusion Based on its review of the LRA, the applicant's detailed screening implementation procedures, and a sampling of structural screening results, the staff concludes that the applicant's methodology for identification of passive, long lived structural component types within the scope of license renewal and subject to an AMR meets 10 CFR 54.21(a)(1) requirements; and, therefore, is acceptable.

2.1.5.4 Electrical Component Screening 2.1.5.4.1 Summary of Technical Information in the Application LRA Section 2.1.2.3, "Screening of Electrical and Instrumentation and Control Systems,"

addresses the use of NEI 95-10, Appendix B, "Typical Structure, Component and Commodity Groupings and Active/Passive Determinations for the Integrated Plant Assessment," which identifies passive electrical commodities. The applicant cross-referenced electrical commodity groups to the appropriate NEI 95-10 commodity, which identified the passive commodity groups.

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The applicant determined that most electrical and I&C commodity groups are active and do not require an AMR. Two passive electrical and I&C commodity groups meet the 10 CFR 54.21(a)(1)(i) criterion (components that perform intended functions without moving parts or change in configuration):

° High-voltage insulators

° Cables and connections, bus, electrical portions of electrical and I&C penetration assemblies Additionally, the applicant considered the pressure boundary function of some electrical and I&C components identified in NEI 95-10, Appendix B, (flow elements, vibration probes) in the mechanical AMRs as applicable. Electrical components supported by structural commodities (cable trays, conduit and cable trenches) were included. in the structural AMRs.

The applicant reviewed the passive electrical components for those replaced based on a qualified life and therefore not subject to an AMR. The applicant determined that the components included in the EQ of the Electric Components Program per 10 CFR 50.49 (EQ) are replaced based on qualified life and, therefore are not subject to an AMR. The applicant determined that there would be AMRs for the passive, non-EQ electrical and I&C components.

2.1.5.4.2 Staff Evaluation The staff reviewed the applicant's methodology for electrical screening in LRA Section 2.1.2.3

_and the applicant's irmpLementatiojn procedures and aging management reports. Theapplicant.

used the screening process described in these documents for electrical commodity groups subject to AMRs. The applicant used the component database, the single-line drawings, and cable procurement specifications as data sources of electrical and I&C components including fuses-holders. The applicant determined there were no fuse-holders outside active devices and subject to an AMR.

The applicant assembled a table of seven commodities determined to meet the passive criteria.

The seven commodities were grouped in accordance with NEI 95-10 as (1) cables and connections, (2) electrical portions of penetration assemblies, (3) metal-enclosed buses, (4) switchyard buses, (5) transmission conductors, (6) uninsulated ground conductors, and (7) high-voltage insulators. These seven commodities were grouped further as (1) high-voltage insulators and (2) cables and connections, buses, and electrical portions of electrical and I&C penetration assemblies as described in the LRA. The applicant evaluated passive commodities for whether they were subject to replacement based on a qualified life or specified time period (short-lived) or long-lived. The applicant determined that the remaining passive, long-lived components were subject to an AMR. The staff reviewed the screening of selected components to verify the correct implementation of the LRPGs and aging management reports.

2.1.5.4.3 Conclusion The staff reviewed the LRA, procedures, electrical drawings, and a sample of the screening methodology results. The staff determined that the applicant's methodology was consistent with the description in the LRA and with the applicant's implementing procedures. Based on a review of information in the LRA, the applicant's screening implementation procedures, and a sampling review of electrical screening results, the staff finds the applicant's methodology for 2-29

identification of electrical commodity groups subject to an AMR consistent with 10 CFR 54.21 (a)(1) and, therefore, acceptable.

2.1.5.5 Conclusion for Screening Methodology Based on its review of the LRA and the screening implementation procedures, discussions with the applicant's staff, and a sample review of screening results, the staff determines that the applicant's screening methodology is consistent with the guidance of the SRP-LR and has identified passive, long-lived components within the scope of license renewal and subject to an AMR. The staff concludes that the applicant's methodology is consistent with the requirements of 10 CFR 54.21(a)(1) and, therefore, acceptable.

2.1.6 Summary of Evaluation Findings The information in LRA Section 2.1, the supporting information in the scoping and screening implementation procedures and reports, the information presented during the scoping and screening methodology audit, and the applicant's responses to the staff's RAIs dated November 29, 2006, formed the basis of the staffs determination that the applicant's scoping and screening methodology was consistent with the requirements of the Rule. Based on this determination, the staff concludes that the applicant's methodology for identifying SSCs within the scope of license renewal and SCs requiring an AMR is consistent with the requirements of 10 CFR 54.4 and 10 CFR 54.21(a)(1), and, therefore, acceptable.

2.2 Plant-Level Scoping Results

2.2.1 Introduction

In LRA Section 2.1, the applicant described the methodology for identifying SSCs within the scope of license renewal. In LRA Section 2.2, the applicant used the scoping methodology to determine which SSCs must be included within the scope of license renewal. The staff reviewed the plant-level scoping results to determine whether the applicant has properly identified all systems and structures relied upon to mitigate design basis events (DBEs), as required by 10 CFR 54.4(a)(1 ), systems and structures the failure of which could prevent satisfactory accomplishment of any safety-related functions, as required by 10 CFR 54.4(a)(2), and systems and structures relied on in safety analyses or plant evaluations to perform functions required by regulations referenced in 10 CFR 54.4(a)(3).

2.2.2 Summary of Technical Information in the Application

LRA Tables 2.2-1a, 2.2-1b, and 2.2-3 list respectively plant mechanical systems, electrical and I&C systems, and structures within the scope of license renewal. LRA Tables 2.2-2 and 2.2-4 list respectively plant mechanical systems and structures not within the scope of license renewal. Based on the DBEs considered in the plant's CLB, other CLB information as to nonsafety-related systems and structures, and certain regulated events, the applicant identified plant-level systems and structures within the scope of license renewal as defined by 10 CFR 54.4.

2.2.3 Staff Evaluation

In LRA Section 2.1, the applicant described its methodology for identifying systems and structures within the scope of license renewal and subject to an AMR. The staff reviewed the scoping and screening methodology and provides its evaluation in SER Section 2.1. To verify that the applicant properly implemented its methodology, the staff's review focused on the implementation results shown in LRA Tables 2.2-1a, 2.2-1b, 2.2-2, 2.2-3, and 2.2-4, to confirm that there were no omissions of plant-level systems and structures within the scope of license renewal.

The staff determined whether the applicant properly identified the systems and structures within the scope of license renewal in accordance with 10 CFR 54.4. The staff reviewed selected systems and structures that the applicant did not identify as falling within the scope of license renewal to verify whether the systems and structures have any intended functions requiring their inclusion within the scope of license renewal. The staff's review of the applicant's implementation was conducted in accordance with the guidance in SRP-LR Section 2.2, "Plant-Level Scoping Results."

The staff sampled the contents of the UFSAR based on the systems and structures listed in LRA Tables 2.2-1a, 2.2-1 b, 2.2-2, 2.2-3, and 2.2-4 to determine if there were any systems or structures that may have intended functions within the scope of license renewal, as defined by 10 CFR 54.4, but were omitted from the scope of license renewal. The staff found no omissions.

2.2.4 Conclusion The staff reviewed LRA Section 2.2 and the UFSAR supporting information to determine whether the applicant failed to identify any systems and structures within the scope of license renewal. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified in accordance with 10 CFR 54.4 the systems and structures that are within the scope of license renewal.

2.3 Scoping and Screening Results: Mechanical Systems

This section documents the staff's review of the applicant's scoping and screening results for mechanical systems. Specifically, this section discusses:

0 reactor coolant system 0 engineered safety features

• auxiliary systems a steam and power conversion systems In accordance with the requirements of 10 CFR 54.21(a)(1), the applicant must list passive, long-lived SOs within the scope of license renewal and subject to an AMR. To verify that the applicant properly implemented its methodology, the staff's review focused on the implementation results. This focus allowed the staff to confirm that there were no omissions of mechanical system components that meet the scoping criteria and are subject to an AMR.

The staff's evaluation of the information in the LRA was the same for all mechanical systems.

The objective was to determine whether the applicant has identified, in accordance with 10 CFR 54.4, components and supporting structures for mechanical systems that appear to meet the license renewal scoping criteria. Similarly, the staff evaluated the applicant's screening results to verify that all passive, long-lived components were subject to an AMR in accordance with 10 CFR 54.21(a)(1).

In its scoping evaluation, the staff reviewed the applicable LRA sections and component drawings, focusing on components that have not been identified as within the scope of license renewal. The staff reviewed relevant licensing basis documents, including the UFSAR, for each mechanical system to determine whether the applicant has omitted from the scope of license renewal components with intended functions delineated under 10 CFR 54.4(a). The staff also reviewed the licensing basis documents to determine whether the LRA specified all intended functions delineated under 10 CFR 54.4(a). The staff requested additional information to resolve any omissions or discrepancies identified.

After its review of the scoping results, the staff evaluated the applicant's screening results. For those SCs with intended functions, the staff sought to determine whether (1) the functions are performed with moving parts or a change in configuration or properties or (2) the SCs are subject to replacement after a qualified life or specified time period, as described in 10 CFR 54.21 (a)(1 ). For those meeting neither of these criteria, the staff sought to confirm that these SCs were subject to an AMR, as required by 10 CFR 54.21(a)(1). The staff requested additional information to resolve any omissions or discrepancies identified.

In addition, the staff developed a "Two-Tier Scoping Review Process" to evaluate balance-of-plant (BOP) systems. There are 57 mechanical systems in the LRA among which 26 are BOP systems, that include most of the auxiliary systems and all the steam and power conversion systems. The staff performed a two-tier scoping review for these BOP systems.

In the two-tier scoping review, the staff reviewed the LRA and UFSAR description focusing on the system intended function to screen all the BOP systems into two groups based on the following screening criteria:

" safety importance/risk significance

" potential for system failure to cause failure of redundant safety system trains

" operating experience indicating likely passive failures

• systems subject to omissions based on previous LRA reviews Examples of the safety important/risk significant systems are the feedwater system, the emergency diesel generator (EDG) system, and the service water (SW) system based on the results of Individual Plant Examination (IPE) for JAFNPP.:An example of a system whose failure could result in common cause failure of redundant trains is a drain system providing flood protection. Examples of systems with operating experience indicating likely passive failures include MS system, feedwater system, and SW system. Examples of systems with identified omissions in previous LRA reviews include fuel pool cooling and cleanup system, and makeup water sources to safety systems.

From the 26 BOP systems, the staff selected 16 systems for a Tier-2 (detailed) scoping review as described above. For the remaining 10 BOP systems, the staff performed a Tier-1 (not 2-32

requiring detailed boundary drawings) review of the LRA and UFSAR that would identify apparent missing components for an AMR. However, Tier-2 requires the review of detailed boundary drawings in accordance with SRP-LR Section 2.3. The following is a list of the 10 Tier-1 systems:

a auxiliary boiler and accessories

• city water 9 extraction steam a feedwater heater vents and drains

• plumbing, sanitary and lab

• raw water treatment

• secondary plant drains

• steam seal

• turbine lube oil

• vacuum priming and air The staff verified that there is no risk significant system in the above list by examining the results of the JAFNPP IPA. None of the above 10 systems are dominant contributors to core damage frequency (CDF), nor are these systems involved in the dominant initiating events.

The following is a list of the 16 Tier-2 systems:

• service water

• emergency- diesel- generator

• fuel oil

• fuel pool cooling and cleanup

• service, instrument and breathing air

• reactor building closed cooling water

" radwaste and plant drains

• security generator

" circulating water

" containment equipment drains

• main turbine generator

" sample

" turbine building closed loop cooling

" condensate

" main steam

" feedwater 2.3.1 Reactor Coolant System LRA Section 2.3.1 states that the reactor coolant system (RCS), also called the nuclear boiler system, includes mechanical components in the following subsystems:

• reactor vessel (includes the reactor vessel and reactor vessel internals)

• reactor water circulation

• reactor vessel instrumentation

• recirculation flow control 2-33

• control rod drive

• neutron monitoring The applicant .described the supporting SCs of the RCS in the following LRA sections:

" 2.3.1.1 reactor vessel

" 2.3.1.2 reactor vessel internals

" 2.3.1.3 reactor coolant pressure boundary The staffs findings on review of LRA Sections 2.3.1.1 - 2.3.1.3 are in SER Sections 2.3.1.1 -

2.3.1.3, respectively. The staff's review of the RCS subsystems proceeded as follows.

Summary of Technical Information in the Application. LRA Section 2.3.1 describes the RCS subsystems. Summaries of each subsystem follow.

Reactor Vessel System. The reactor vessel and internals make up the reactor vessel system.

The purpose of the reactor vessel is to contain and support the reactor core and vessel internals and to provide a barrier to the release of radioactive materials from the core. The reactor vessel includes the vessel shell, top and bottom heads, nozzles and penetrations, internal and external attachments and vessel supports. The purpose of the reactor vessel internals is to properly distribute the flow of coolant delivered to the vessel, to locate and support the fuel assemblies, and to provide an inner volume containing the core that can be flooded following a break in the nuclear system process barrier external to the reactor pressure vessel. The reactor vessel internals-include the-core structureshroud support assembly,- -....

control rod guide tubes, fuel support pieces, incore flux monitor guide tubes, steam dryer, guide rods, jet pump assemblies and jet pump instrumentation, core spray distribution lines, the differential pressure and liquid control line, surveillance sample holders, and feedwater spargers.

The reactor vessel system has safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related reactor vessel system SSCs potentially could prevent the satisfactory accomplishment of'a safety-related function.

Reactor Water Recirculation.The purpose of the reactor water recirculation system is to provide a variable moderator (coolant) flow to the reactor core for adjusting reactor power level.

The reactor water recirculation system has safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related reactor water recirculation system SSCs potentially could prevent the satisfactory accomplishment of a safety-related function.

Reactor Vessel Instrumentation.The purpose of reactor vessel instrumentation is to monitor reactor vessel parameter information to ensure sufficient control of the key parameters to facilitate safe operation of the plant. Measurements of temperature, pressure, differential pressure, flow, level and core power are transmitted to protective systems, control systems and to the reactor control room for operator information. Mechanical portions of the system support the measurement of hydraulic parameters. Piping from the reactor vessel and recirculation system passes outside primary containment to the reactor building where most sensors are located. The reactor vessel instrumentation system also includes unused primary. containment piping penetrations.

The reactor vessel instrumentation has safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related reactor vessel instrumentation SSCs potentially could prevent the satisfactory accomplishment of a safety-related function.

Recirculation Flow Control.The purpose of the recirculation flow control system is to control the speed of the two reactor water recirculation pumps by varying the electrical frequency of the power supply for the pumps. A variable frequency, alternating current (AC) motor-generator set located outside the drywell supplies power to each recirculation pump motor. The pump motor is electrically connected to the generator and is started by engaging the variable speed coupling between the generator and its drive motor. By varying the coolant flow rate through the core, power level may be changed. The system is arranged to allow manual control room operator action. The rotating inertia of the motor-generator set supports a slow coastdown of flow following some transients; however, the recirculation flow control system is not credited in any of the design basis events.

The failure of nonsafety-related recirculation flow control system SSCs potentially could prevent the satisfactory accomplishment of a safety-related function.

Neutron Monitoring. The purpose of the neutron monitoring traversing incore probe (TIP) subsystem is to provide a signal proportional to the neutron flux, at any axial location wherever

-power range detector assemblies-are located.Each TIP channel-(orsubsystem) uses a gamma detector attached to a titanium-sheathed signal and drive cable, which is driven from outside the primary containment by a drive mechanism. The flexible cable is contained by guide tubes that continue into the reactor core. The guide tubes are a part of the power range detector assembly. The TIP subsystem includes QA I primary containment isolation valve assemblies on each guide tube entering the primary containment. These valves are closed except when the TIP subsystem is in operation, or to support system testing or maintenance activities. Each isolation valve assembly consists of a ball valve that closes when the TIP probe is withdrawn and a cable shearing valve that can shear off the probe if containment isolation is required. The valves are part of the containment boundary. Otherwise, this is an instrumentation system.

The neutron monitoring TIP system has safety-related components relied upon to remain functional during and following DBEs.

Control Rod Drive System. The purpose of the CRD system is to provide reactivity control by positioning the control rods to control power generation in the core. When required, the control rod drive system is designed to insert the control rods with sufficient speed to limit fuel barrier damage. The control rod drive system includes the control rod blades, the control rod drive mechanisms, and the components, piping and valves of the control rod drive hydraulic system.

The CRD system has safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related CRD system SSCs potentially could prevent the satisfactory accomplishment of a safety-related function. In addition, the CRD system performs functions that support fire protection and ATWS.

LRA Table 2.3.3-14-3 identifies the following CRD system component types within the scope of 2-35

license renewal and subject to an AMR:

" bolting

• filter housing

" flow element

° heat exchanger (shell)

• orifice

" piping

" pump casing o sight glass

• strainer housing

" thermowell

" tubing

• valve body The CRD component intended function within the scope of license renewal is to provide a pressure boundary.

2.3.1.1 Reactor Vessel 2.3.1.1.1 Summary of Technical Information in the Application LRA Section 2.3.1.1 describes the reactor vessel, which contains the nuclear fuel core, core support structures;- control-rods; and other parts-of the reactor core. -The major components-of the reactor vessel include the reactor vessel shell, lower head, upper closure head, flanges, studs, nuts, nozzles and safe ends.

LRA Table 2.3.1-1 identifies the following reactor vessel component types within the scope of license renewal and subject to AMR:

• attachment and supports

• bolting

• nozzles and penetrations

" safe ends, thermal sleeves, caps and flanges, and shell and heads The reactor vessel component intended functions within the scope of license renewal include:

" pressure boundary

" structural or functional support for safety-related equipment 2.3.1.1.2 Staff Evaluation The staff reviewed LRA Section 2.3.1.1 and the UFSAR using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.

During its review, the staff evaluated the system functions described in the LRA and UFSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those 2-36

components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21 (a)(1).

2.3.1.1.3 Conclusion The staff reviewed the LRA to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staff's review determined whether the applicant failed to identify any components subject to an AMR.

The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the reactor vessel components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).

2.3.1.2 Reactor Vessel Internals 2.3.1.2.1 Summary of Technical Information in the Application LRA Section 2.3.1.2 describes the reactor vessel internals, which are installed inside the reactor pressure vessel to properly distribute the flow of coolant delivered to the vessel, to locate and support the fuel assemblies, and to provide an inner volume containing the core that can be flooded following a break in the nuclear system process barrier external to the reactor pressure vessel.

LRA Table 2.3.1-2 identifies the following reactor vessel internals component types within the scope of license renewal and subject to an AMR:

" control rod guide tubes

" core spray lines

• core support

" core support rim bolts

• fuel support pieces

• incore flux monitors

• jet pump assemblies

• jet pump castings

• shroud

• shroud stabilizers

• shroud support

• steam dryers

• top guide assembly The reactor vessel internals component intended functions within the scope of license renewal include:

• flow distribution

• boundary of a volume in which the core can be flooded and adequately cooled in the event of a breach in the nuclear system process barrier external to the reactor vessel 2-37

• pressure boundary

• structural or functional support for safety-related equipment

• structural integrity so loose parts are not introduced 2.3.1.2.2 Staff Evaluation The staff reviewed LRA Section 2.3.1.2 and the UFSAR using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.

During its review, the staff evaluated the system functions described in the LRA and UFSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).

2.3.1.2.3 Conclusion The staff.reviewed the LRA to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR.

The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the reactor vessel internals components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).

2.3.1.3 Reactor Coolant PressureBoundary 2.3.1.3.1 Summary of Technical Information in the Application LRA Section 2.3.1.3 describes the RCPB. The following systems, in whole or in part, comprise the RCPB:

" control rod drive

" core spray

• feedwater

• high-pressure coolant injection

• main steam

" nuclear boiler vessel instruments

" reactor core isolation cooling

" reactor water recirculation

" reactor water cleanup

" residual heat removal

" standby liquid control LRA Table 2.3.1-3 identifies the following RCPB component types within the scope of license renewal and subject to AMR:

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" bolting

" condensing chambers

" drive

" driver mount

• filter housing

• flow elements

• orifices

• piping and fittings less than 4 inches nominal pipe size (NPS)

• piping and fittings greater than or equal to 4 inches NPS

• pump casing and cover

• pump cover thermal barrier

• restrictors

• rupture disc

• tank (CRD accumulator)

• tank (CRD scram discharge volume)

• thermal sleeves (FW)

• thermowells less than 4 inches NPS (NBVI, RWR)

• tubing

• valve bodies less than 4 inches NPS

• valve bodies greater than or equal to 4 inches NPS The RCPB component intended functions within the scope of license renewal include:

" flow control or spray pattern

" pressure boundary The staff also identified that LRA Table 2.3.3-14-2 identifies the following RCS component types within the scope of license renewal and subject to an AMR:

" bolting

" filter housing

• flow element

• heat exchanger (shell)

" orifice

" piping

" pump casing

" sight glass

• strainer housing

" tubing

" valve body The RCS component intended function within the scope of license renewal is to provide a pressure boundary.

2.3.1.3.2 Staff Evaluation The staff reviewed LRA Section 2.3.1.3 and the UFSAR using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.

During its review, the staff evaluated the system functions described in the LRA and UFSAR to 2-39

verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21 (a)(1).

2.3.1.3.3 Conclusion The staff reviewed the LRA to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staff's review determined whether the applicant failed to identify any components subject to an AMR.

The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the RCPB components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).

2.3.2 Engineered Safety Features LRA Section 2.3.2 identifies the engineered safety features SCs subject to an AMR for license renewal.

The applicant described the supporting SCs of the engineered safety features in the following LRA sections:

• 2.3.2.1 residual heat removal

• 2.3.2.2 core spray system

• 2.3.2.3 automatic depressurization

• 2.3.2.4 high pressure coolant injection

• 2.3.2.5 reactor core isolation cooling

• 2.3.2.6 gas handling

• 2.3.2.7 primary containment penetrations The staff s findings on review of LRA Sections 2.3.2.1 - 2.3.2.7 are in SER Sections 2.3.2.1 -

2.3.2.7, respectively.

2.3.2.1 Residual Heat Removal System 2.3.2.1.1 Summary of Technical Information in the Application LRA Section 2.3.2.1 describes the RHR system, which restores and maintains the coolant inventory in the reactor vessel so that the core is adequately cooled after a loss of coolant accident (LOCA) and cools the core during a normal shutdown. The system also cools the containment for condensation of steam from blowdowns in design basis LOCAs. In addition, the RHR service water system reliably supplies cooling water for RHR under post-accident and shutdown conditions. The RHR system has the following modes of operation: (1) low-pressure coolant injection, (2) containment spray, (3) steam condensing, (4) shutdown cooling, (5) alternate shutdown cooling, (6) suppression pool cooling, (7) fuel pool cooling, and (8) RHR service water to RHR cross tie.

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In low-pressure coolant injection mode, the RHR system restores and maintains the coolant inventory in the reactor vessel after a LOCA. The containment spray mode reduces drywell pressure following a LOCA. In the containment spray mode, the RHR pumps transfer water from the suppression chamber through the RHR heat exchangers and heat exchanger bypass lines, where the RHR service water removes heat. The cool water is diverted to two redundant spray headers to lower drywell and containment pressure. The steam condensing mode may be operated in conjunction with the RCIC system as directed by emergency operating procedures in case of a loss of the main condenser. During reactor isolation, reactor steam may be relieved via the relief valves to the suppression chamber where it is condensed and subcooled. Decay heat is transferred to the RHR service water by the RHR heat exchangers used as direct steam condensers. The shutdown cooling mode during normal shutdown and cooldown dumps steam from the reactor vessel to the main condenser acting as a heat sink. The RHR pumps complete reactor cooldown by pumping reactor coolant from recirculation loop B through the RHR heat exchangers, which transfer heat to RHR service water. The cooled reactor coolant returns to the reactor vessel via either recirculation loop. The alternate shutdown cooling mode provides a cooling path if the normal shutdown cooling path is inoperable. The RHR pumps take suction from the suppression pool, pass it through the RHR heat exchangers, and inject it into the vessel via the RHR injection valves. Water overflows into the MS lines, and safety relief valves (SRVs) open for flow to the suppression pool. The suppression pool cooling mode of RHR takes suction from the suppression pool, passes it through the RHR heat exchangers, and returns flow to the suppression pool. This mode of operation is designed to remove heat from the suppression pool. The fuel pool cooling mode takes suction from the fuel pool cooling system, passes it through the RHR heat exchangers, and discharges Lt back to the fuel pool cooling system. This mode of operation assists in fuel pool cooling during reactor shutdown periods as an alternate cooling system operation and is not a safety function. The emergency reactor vessel fill mode provides a cross-tie between the RHR service water system and RHR piping. The RHR service water pumps take suction from the service water system and inject it into the reactor vessel through the RHR piping.

The RHR system has safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related RHR SSCs potentially could prevent the satisfactory accomplishment of a safety-related function. In addition, the RHR system performs functions that support fire protection.

LRA Tables 2.3.2-1 and 2.3.3-14-4 identify the following RHR system component types within the scope of license renewal and subject to AMR:

• bolting

• cyclone separator

• flow element

• heat exchanger (bonnet)

• heat exchanger (shell)

• heat exchanger (tubes)

• nozzle

• orifice

• piping

• pump casing

• sight glass

• steam trap 2-41

" strainer

" strainer housing

• thermowell

• tubing

• valve body The RHR system component intended functions within the scope of license renewal include:

• flow control

" filtration

" heat transfer

• pressure boundary 2.3.2.1.2 Staff Evaluation The staff reviewed LRA Sections 2.3.2.1 and 2.3.3.14, and UFSAR Sections 4.8.1, 4.8.3, 4.8.4, 4.8.5, and 9.7.3 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section' 2.3.

During its review, the staff evaluated the system functions described in the LRA and UFSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21 (a)(1).

2.3.2.1.3 Conclusion

The staff reviewed the LRA to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staff's review determined whether the applicant failed to identify any components subject to an AMR.

The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the RHR system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).

2.3.2.2 Core Spray System

2.3.2.2.1 Summary of Technical Information in the Application LRA Section 2.3.2.2 describes the CS system, which protects the core by spraying water over the fuel assemblies to remove decay heat following the postulated design basis LOCA. As part of the ECCS, the CS system maintains core coolant inventory to prevent fuel damage and, in conjunction with the primary and secondary containments, limit the release of radioactive materials to the environs following a LOCA to keep resulting radiation exposures within 10 CFR Part 100 guideline values. The CS system consists of two redundant pumping loops, each with a motor-driven centrifugal pump, piping, valves, spray spargers, control logic, and instrumentation and controls. The pump suction is normally supplied from the suppression pool 2-42

but may be lined up to the condensate storage tank (CST) after reactor shutdown. The CST supports CS system operation for injection flow testing, for transfer of condensate to the reactor, or for core cooling. During LOCA-initiated CS operation, the CS pumps take suction from the suppression pool and discharge water over the top of the core. Water leaks through the break in the RCPB into the drywell. The leaking water drains through the pressure suppression vents back to the suppression pool, establishing a closed loop. The CS keep-full subsystem keeps the CS system discharge piping full. The subsystem consists of a hold pump with its associated piping, valves, instruments, and controls.

The CS system has safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related CS SSCs potentially could prevent the satisfactory accomplishment of a safety-related function. In addition, the CS system performs functions that support fire protection.

LRA Tables 2.3.2-2 and 2.3.3-14-8 identify the following CS system component types within the scope of license renewal and subject to AMR:

• bolting

• cyclone separator

" flow element

" orifice

• piping

" pump casing

" sight glass

• strainer

• tubing

• valve body The CS system component intended functions within the scope of license renewal include:

• flow control

• filtration

• pressure boundary 2.3.2.2.2 Staff Evaluation The staff reviewed LRA Sections 2.3.2.2 and 2.3.3.14, and UFSAR Section 6.4 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.

During its review, the staff evaluated the system functions described in the LRA and UFSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).

Based on its review, the staff found that LRA Section 2.3.2.2 includes within the scope of license renewal CS system portions that meet 10 CFR 54.4 scoping requirements. LRA Table 2.3.2-2, "Core Spray System," also includes CS system components subject to an AMR by 10 CFR 54.4(a) and 10 CFR 54.21(a)(1 ). The staff found no omissions.

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2.3.2.2.3 Conclusion

The staff reviewed the LRA to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staff's review determined whether the applicant failed to identify any components subject to an AMR.

The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the CS system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).

2.3.2.3 Automatic Depressurization 2.3.2.3.1 Summary of Technical Information in the Application LRA Section 2.3.2.3 describes the automatic depressurization system (ADS), which prevents over-pressurization of and provides automatic depressurization for small breaks in the reactor coolant system, allowing the low-pressure coolant injection and CS systems to inject water into the reactor vessel. The system includes safety relief valves (SRVs), the SRV discharge lines to the suppression pool, and the MS lines from the reactor vessel out to but not including the first MS isolation valve. The SRVs are on the MS lines within the drywell between the reactor vessel and the first MS isolation valves. The valves are dual-purpose in that they relieve pressure by normal mechanical action or by automatic action of an electric-pneumatic control system. The relief by normal mechanical action prevents over-pressurization of the reactor coolant system.

The depressurization by automatic action of the control system reduces reactor coolant system pressure during a small-break LOCA.

The ADS has safety-related components relied upon to remain functional during and following DBEs. In addition, the ADS performs functions that support fire protection.

LRA Table 2.3.2-3 identifies the following ADS component types within the scope of license renewal and subject to AMR:

" bolting

" piping

• T-quencher

" valve body The ADS component intended function within the scope of license renewal is to provide a pressure boundary.

2.3.2.3.2 Staff Evaluation The staff reviewed LRA Section 2.3.2.3 and UFSAR Sections 4.4, 6.4.2, and 7.4.3.3 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.

During its review, the staff evaluated the system functions described in the LRA and UFSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those 2-44

components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21 (a)(1).

The staff's review of LRA Section 2.3.2.3 found an area in which additional information was necessary to complete the review of the applicant's scoping and screening results. The applicant responded to the staff's RAI as follows.

In RAI 2.3.2.3-1 dated January 12, 2006, the staff noted that UFSAR page 498 states that each of the 11 SRVs has a nitrogen accumulator. Such pneumatic accumulators ensure SRV ability to depressurize the vessel in the event of a small to intermediate line break concurrent with an HPCI failure and an interruption of the pneumatic supply to the accumulators for short-term ADS SRV capability. Long-term operation of the SRVs is assured with the seismically-qualified lines to the accumulators. LRA Table 2.3.2-3 does not list accumulators as within the scope of license renewal; therefore, the staff asked the applicant to indicate whether the accumulators had been included within the scope of license renewal and, if so, the LRA table and subcomponent group that include the subject component or, if not, to justify the exclusion.

In its response dated February 12, 2007, the applicant stated that the accumulators are included within the scope of license renewal as part of the service, instrument, and breathing air system as shown on license renewal drawing FM-29A and in LRA Tables 2.3.3-10 and 3.3.2-10 as a component type of tank exposed to an internal environment of gas.

Based on its review, the staff finds the applicant's response to RAI 2.3.2.3-1 acceptable because of the inclusion of the component. The staffs concern described in RAI 2.3.2.3-1 is resolved.

2.3.2.3.3 Conclusion The staff reviewed the LRA to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staff's review determined whether the applicant failed to identify any components subject to an AMR.

The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the ADS components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).

2.3.2.4 High-PressureCoolant Injection 2.3.2.4.1 Summary of Technical Information in the Application LRA Section 2.3.2.4 describes the HPCI system, which limits the release of radioactive materials to the environs following a LOCA to keep radiation exposures within 10 CFR Part 100 guideline values. This limited release is achieved primarily by maintaining core coolant inventory to prevent fuel damage. The HPCI system consists of a steam turbine-driven centrifugal main pump, a booster pump, piping, valves, controls, and instrumentation. The HPCI system is designed to pump water into the reactor vessel over a wide range of pressures. The system uses demineralized water supplied by a common header from the two CSTs and can also draw 2-45

from the suppression pool, pumping water from either source into the reactor vessel via a feedwater line. Flow is distributed within the reactor vessel through feedwater spargers. The HPCI system turbine gland seals are vented to the HPCI system gland seal condenser and part of the water from the HPCI system booster pump is routed through the condenser for cooling purposes. Non-condensable gases from the gland seal condenser are vented by a gland exhauster to the standby gas treatment system. An HPCI lube oil system supplies the main pump, turbine (including thrust bearing), and speed reducer bearings with oil. A motor-driven pump supplies the lube oil system when speed is too low for the shaft-driven pump. This system contains a lube oil cooler supplied with water from the booster pump discharge.

The HPCI system has safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related HPCI SSCs potentially could prevent the satisfactory accomplishment of a safety-related function. In addition, the HPCI system performs functions that support fire protection and SBO.

LRA Tables 2.3.2-4 and 2.3.3-14-14 identify the following HPCI system component types within the scope of license renewal and subject to AMR:

" bearing housing

• blower housing

• bolting

" drain pot

" filter housing

" flow element

" gear box housing

" governor housing

" heat exchanger (bonnet)

• heat exchanger (shell)

" heat exchanger (tubes)

" orifice

• piping

" pump casing

• rupture disk

• sight glass

• steam trap

" strainer

" tank

" thermowell

" tubing

" turbine casing

" valve body The HPCI system component intended functions within the scope of license renewal include:

" filtration

" flow control

" heat transfer

• pressure boundary 2.3.2.4.2 Staff Evaluation 2-46

The staff reviewed LRA Sections 2.3.2.4 and 2.3.3.14, and UFSAR Sections 6.4 and 8.11 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.

During its review, the staff evaluated the system functions described in the LRA and UFSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21 (a)(1).

2.3.2.4.3 Conclusion The staff reviewed the LRA to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staff's review determined whether the applicant failed to identify any components subject to an AMR.

The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the HPCI system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).

2.3.2.5 Reactor Core Isolation Cooling 2.3.2.5.1 Summary of Technical Information in the Application LRA Section 2.3.2.5 describes the RCIC system, which cools the core during reactor isolation by pumping makeup water into the reactor vessel when its water level is low. The RCIC system also provides makeup water to the reactor vessel during total loss of offsite power. The RCIC system consists of a steam-driven turbine-pump unit, valves, and piping capable of delivering make-up water to the reactor vessel. The RCIC system normally takes suction from the demineralized water in the CSTs with back-up supply available from the suppression pool. The RCIC system also connects to the RHR system alignment with it when the RHR system operates in the steam condensing mode. RCIC injection to the vessel is through the feedwater line. The RCIC system shares suction points and full-flow test lines with the HPCI system.

The RCIC system has safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related RCIC SSCs potentially could prevent the satisfactory accomplishment of a safety-related function. In addition, the RCIC system performs functions that support fire protection and SBO.

LRA Tables 2.3.2-5 and 2.3.3-14-7 identify the following RCIC system component types within the scope of license renewal and subject to AMR:

• bolting

• filter housing

• flow meter housing

• governor housing

• heat exchanger (bonnet) 2-47

• heat exchanger (shell)

• orifice

• piping

• pump casing

• rupture disk

• sight glass

• steam trap

• strainer

• strainer housing

• tank

• thermowell

• tubing

• turbine casing

• valve body The RCIC system component intended functions within the scope of license renewal include:

• flow control

• filtration

• pressure boundary 2.3.2.5.2 Staff Evaluation The staff reviewed LRA Sections 2.3.2.5 and 2.3.3.14, and UFSAR Section 4.7 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.

During its review, the staff evaluated the system functions described in the LRA and UFSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).

Based on its review, the staff found that LRA Section 2.3.2.5 includes within the scope of license renewal RCIC portions that meet 10 CFR 54.4 scoping requirements. LRA Table 2.3.2-5, "Reactor Core Isolation Cooling," also includes RCIC components subject to AMRs by 10 CFR 54.4(a) and 10 CFR 54.21(a)(1). The staff found no omissions.

2.3.2.5.3 Conclusion The staff reviewed the LRA to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staff's review determined whether the applicant failed to identify any components subject to an AMR.

The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the RCIC system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).

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2.3.2.6 Gas Handling 2.3.2.6.1 Summary of Technical Information in the Application LRA Section 2.3.2.6 describes the gas-handling system, which includes mechanical components in the off-gas-holdup (OGH) and SGT subsystems. The OGH system collects, processes, holds, and controls the gaseous radioactive waste released from the main condenser air ejector. Discharge of this gas to the atmosphere is through the main stack, which is also the release point for gaseous waste from the start-up mechanical vacuum pump (condenser air removal pump) and the gland seal condenser (steam packing exhauster). The SGT system processes gaseous effluent from the primary and secondary containments when required to limit the discharge of radioactive materials to the environs and limit exfiltration from the secondary containment during periods of primary containment isolation. The system functions as part of the secondary containment system. The SGT system is designed to limit the release of radioactive material to the environment to keep the offsite dose from a postulated DBA within 10 CFR Part 100 or 10 CFR 50.67(b)(2) limits. During normal plant operation, the SGT system treats potentially radioactive gases prior to discharge to the environment.

The gas-handling system has safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related gas-handling SSCs potentially could prevent the satisfactory accomplishment of a safety-related function.

LRA Tables 2.3.2-6 and 2.3.3-14-1 identify the following gas handling system component types within the scope of license renewal and subject to AMR:

" bolting

" damper housing

" duct

" fan housing

" filter

• filter unit housing

• flow element

, orifice

" piping

• sight glass

" tubing

" valve body The gas-handling system component intended functions within the scope of license renewal include:

" flow control

" filtration

" pressure boundary 2.3.2.6.2 Staff Evaluation The staff reviewed LRA Sections 2.3.2.6 and 2.3.3.14, and UFSAR Sections 5.3.3.4 and 11.4 2-49

using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.

During its review, the staff evaluated the. system functions described in the LRA and UFSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21 (a)(1).

Based on its review, the staff found that LRA Section 2.3.2.6 includes within the scope of license renewal SGT system portions that meet 10 CFR 54.4 scoping requirements. LRA Table 2.3.2-6, "Standby Gas Treatment System Components Subject to Aging Management Review," also includes SGT system components subject to an AMR by 10 CFR 54.4(a) and 10 CFR 54.21(a)(1) The staff found no omissions.

2.3.2.6.3 Conclusion The staff reviewed the LRA to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staff's review determined whether the applicant failed to identify any components subject to an AMR.

The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the gas handling system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).

2.3.2.7 PrimaryContainmentPenetrations 2.3.2.7.1 Summary of Technical Information in the Application LRA Section 2.3.2.7 describes the primary containment penetrations system, which limits the release of fission products in the event of a postulated DBA so that offsite doses do not exceed 10 CFR Part 100 guideline values. The primary containment system is of the pressure suppression type and houses the reactor vessel, the reactor recirculating loops, and other branch connections of the reactor coolant system. The system includes a drywell, a pressure suppression chamber which stores a large volume of water, the connecting vent system between the drywell and the pressure suppression pool, isolation valves, the vacuum relief system, the RHR subsystems for containment cooling, and instrumentation and instrument connections for periodic integrated containment leakage rate tests during reactor shutdowns.

The primary containment penetrations system has safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related primary containment penetration SSCs in the potentially could prevent the satisfactory accomplishment of a safety-related function.

LRA Tables 2.3.2-7 and 2.3.3-14-10 identify the following primary containment penetrations system component types within the scope of license renewal and subject to AMR:

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° bolting

• piping

" tubing

" valve body The primary containment penetrations system component intended function within the scope of license renewal is to provide a pressure boundary.

2.3.2.7.2 Staff Evaluation The staff reviewed LRA Sections 2.3.2.7 and 2.3.3.14, and UFSAR Section 5.2 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.

During its review, the staff evaluated the system functions described in the LRA and UFSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).

Based on its review, the staff found that LRA Section 2.3.2.7 includes within the scope of license renewal primary containment penetration portions that meet 10 CFR 54.4 scoping requirements. LRA Table 2.3.2-7, "Primary Containment Penetrations," also includes primary containment penetration components subject to an AMR by 10 CFR 54.4(a) and 10 CFR 54.21(a)(1) The staff found no omissions.

2.3.2.7.3 Conclusion The staff reviewed the LRA to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staff's review determined whether the applicant failed to identify any components subject to an AMR.

The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the primary containment penetrations system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).

2.3.3 Auxiliary Systems LRA Section 2.3.3 identifies the auxiliary systems SCs subject to an AMR for license renewal.

The applicant described the supporting SCs of the auxiliary systems in the following LRA sections:

" 2.3.3.1 standby liquid control

" 2.3.3.2 service water

" 2.3.3.3 emergency diesel generator

" 2.3.3.4 fuel oil 2-51

2.3.3.5 fire protection - water

" 2.3.3.6 fire protection - CO 2

" 2.3.3.7 heating, ventilation, and air conditioning

• 2.3.3.8 containment purge, containment atmosphere dilution, and post-accident sampling

• 2.3.3.9 fuel pool cooling and cleanup

• 2.3.3.10 service, instrument, and breathing air

• 2.3.3.11 reactor building closed loop cooling water

• 2.3.3.12 radwaste and plant drains

• 2.3.3.13 security generator

• 2.3.3.14 miscellaneous systems in scope for (a)(2)

The staffs findings on review of LRA Sections 2.3.3.1 - 2.3.3.14 are in SER Sections 2.3.3.1 -

2.3.3.14, respectively.

2.3.3.1 Standby Liquid Control 2.3.3.1.1 Summary of Technical Information in the Application LRA Section 2.3.3.1 describes the SLC system, a backup method to bring and maintain the reactor subcritical from the most reactive conditions as reactor coolant cools. Maintaining subcriticality thus ensures that the fuel barrier is not threatened by overheating in the improbable event that not enough control rods can be inserted to counteract the positive reactivity effects of a colder moderator. The SLC system consists of a stainless steel boron solution tank, a test water tank, a drain tank, two positive-displacement pumps, two explosive valves, local valves, and controls mounted in the reactor building outside the primary containment. The liquid flows through stainless steel piping into the reactor vessel and discharges below the core support plate where it mixes with the cooling water rising through the core.

The SLC system has safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related SLC SSCs potentially could prevent the satisfactory accomplishment of a safety-related function. In addition, the SLC system performs functions that support ATWS.

LRA Tables 2.3.3-1 and 2.3.3-14-5 identify the following SLC component types within the scope of license renewal and subject to AMR:

" bolting

" accumulator

" orifice

• piping

• pump casing

• strainer housing 2-52

• tank

" thermowell

" tubing

" valve body The SLC system component intended function within the scope of license renewal is to provide a pressure boundary.

2.3.3.1.2 Staff Evaluation The staff reviewed LRA Sections 2.3.3.1 and 2.3.3.14, and UFSAR Section 3.9 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.

During its review, the staff evaluated the system functions described in the LRA and UFSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).

2.3.3.1.3 Conclusion The staff reviewed the LRA to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staff's review determined whether the applicant failed to identify any components subject to an AMR.

The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the SLC system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).

2.3.3.2 Service Water 2.3.3.2.1 Summary of Technical Information in the Application LRA Section 2.3.3.2 describes the service water (SW) system, which provides cooling water to safety-related and nonsafety-related plant components. The SW system is a heat sink during normal operation for the turbine building and reactor building heat loads. Three nonsafety-related pumps in the screenwell-pumphouse building take suction from Lake Ontario.

Two pumps normally operate and discharge through automatic self-cleaning strainers into a common manifold. The return flow from the system enters the circulating water discharge tunnel where it mixes with the circulating water flowing back into Lake Ontario. The emergency SW system cools ECCS components and other equipment essential to safe reactor shutdown following a design basis LOCA. The emergency SW system consists of two independent supply loops, each supplied from one emergency service water pump in a separate bay in the pumphouse, taking suction from Lake Ontario. Twin basket strainers are located at each pump discharge. When in operation, the system discharges to the circulating water discharge tunnel and back to Lake Ontario. The control room and relay room air handling units, normally supplied cooling flow by a closed loop glycol system, also can be supplied by either the 2-53

emergency or normal SW system.

The SW system water has safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related SW SSCs potentially could prevent the satisfactory accomplishment of a safety-related function. In addition, the service water performs functions that support fire protection.

LRA Tables 2.3.3-2 and 2.3.3-14-30 identify the following SW system component types within the scope of license renewal and subject to AMR:

" bolting

• flow element

" orifice

" piping

" pump casing

" strainer

" strainer housing

" tank o thermowell

• tubing

" valve body The SW system component intended functions within the scope of license renewal include:

• flow control

" filtration

• pressure boundary 2.3.3.2.2 Staff Evaluation The staff reviewed LRA Sections 2.3.3.2 and 2.3.3.14, and UFSAR Section 9.7 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.

In conducting its Tier-2 review fo the BOP two-tier review process, the staff evaluated the system functions described in the LRA and UFSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).

The staff's review of LRA Sections 2.3.3.2 and 2.3.3.14 found areas in which additional information was necessary to complete the review of the applicant's scoping and screening results. The applicant responded to the staff's RAIs as follows.

In RAI 2.3.3.2-1 dated January 19, 2007, the staff noted that license renewal drawing LRA-M-46A shows at locations B6, B7, and B8 four isolation valves for the drain lines and four isolation valves on SW supply lines to the electrical bay cooling units. The license renewal boundary for each section of piping ends at the QA-I boundary including the reducer; however, 2-54

the isolation valves (at each supply line and at each drain line) upstream of the reducer and piping between the reducer and isolation valves labeled as SEISMIC I are not shown as within the scope of license renewal. The staff requested from the applicant additional information on why these piping and isolation valves are.not within the scope of license renewal and justification for the boundary locations as to 10 CFR 54.4(a) requirements.

In its response dated February 14, 2007, the applicant stated that the license renewal drawings identify the SEISMIC I boundaries uniquely. The portions of the system required to maintain pressure boundary for the system to perform its safety intended functions are identified in the site component database as QA-I and within the system intended function boundary flags. The SEISMIC I boundary identifies portions of the system that are seismically qualified category I but not necessarily safety-related or QA-I. The portions of the system that were included in the AMR, as shown by the highlighting on the license renewal drawing, include those required to maintain the pressure boundary so functions defined in 10 CFR54.4(a)(1) or (a)(3) can be performed.

The applicant also indicated in response to this RAI that the determination of whether a component meets the 10 CFR 54.4(a)(2) scoping criterion is based on structural/seismic boundary locations or the component location in a building, whether it contains gas or liquid, and its proximity to safety-related equipment. The applicant also stated that their conservative spaces approach to scoping in accordance with 10 CFR 54.4(a)(2) included almost all mechanical systems within the scope of license renewal (see Table 2.3.3.14-A). System portions beyond the QA-I boundary shown as SEISMIC I were included within the scope of license renewal in the 10 CFR54.4(a)(2) review but are not highlighted on license renewal drawings.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.2-1 acceptable because it confirmed inclusion of the SEISMIC I category SW piping in question within the scope of license renewal and subject to an AMR; therefore, the staff's concern described in RAI 2.3.3.2-1 is resolved.

In RAI 2.3.3.2-2 dated January 19, 2007, the staff noted that license renewal drawing LRA-FM-20B shows, at location E5, SW piping 22"-WS-151-57 as within the scope of license renewal. The line is continued on license renewal drawing LRA-FM-46A, at location B5. The continuation on license renewal drawing LRA-FM-46A does not show the piping as within the scope of license renewal nor include a license renewal boundary. The line is continued on a third drawing, license renewal drawing LRA-FM-36A, not provided by the applicant. The staff requested from applicant additional information on why this section of piping is not within the scope of license renewal and justification for the boundary locations under 10 CFR 54.4(a).

In its response dated February 14, 2007, the applicant stated that the piping on license renewal drawings LRA-FM-6A and LRA-FM-36A is the discharge pipe from the SW system to the circulating water discharge. Pressure boundary integrity is not required for this portion of the system because this piping is downstream of the cooled components. This piping is, therefore, not subject to an AMR as part of the SW system review. As explained in LRA Section 2.1.2.1.3, piping required for structural support or for potential spatial interaction with safety-related equipment was included in the 10 CFR 54.4(a)(2) review but not highlighted on the license renewal drawings,.

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Based on its review, the staff finds the applicant's response to RAI 2.3.3.2-2 acceptable because it adequately described the SW piping in question continued on license renewal drawing LRA-FM-36A previously unavailable for review. The staff accepts the applicant's explanation that this piping is downstream from all safety-related components, is not required for pressure integrity, and, therefore, is not within the scope of license renewal for 10 CFR 54.4(a)(1 ) or (a)(3). Therefore, the staff's concern described in RAI 2.3.3.2-2 is resolved.

In RAI 2.3.3.2-3 dated January 19, 2007, the staff noted that license renewal drawing LRA-M-46A shows, at location C4, SW piping 8" WCS-151-114 continued from license renewal drawing LRA-FM-15A, location C1. Valve ESW-23 and piping upstream are labeled QA-I.

Neither of the continuation drawings (LRA-FM-1 5A and LRA-FM-36A) was submitted as part of the LRA. The staff requested from the applicant additional information as to why this section of QA-I piping from valve ESW-23 and upstream are not within the scope of license renewal and justification for the boundary locations under 10 CFR 54.4(a).

In its response dated February 14, 2007, the applicant stated that valve ESW-23 and the attached piping are the discharge of the reactor building closed loop cooling water system to the SW discharge piping. The drawing showed these components incorrectly as QA-I. They are no longer classified as safety-related because this flow path is not needed for that system's intended functions. Piping required for structural support or for potential spatial interaction with safety-related equipment was included in the 10 CFR 54.4(a)(2) review but not highlighted on the license renewal drawings.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.2-3 acceptable because it correct the initial submission. The QA-I classification on the drawing submitted with the LRA was in error. As this section of piping in not QA-1, the staff agrees that the piping is not subject to an AMR for 10 CFR54.4(a)(1 ) or (a)(3); therefore, the staff's concern described in RAI 2.3.3.2-3 is resolved.

In RAI 2.3.3.2-4 dated April 25, 2007, the staff requested from the applicant additional information specifying what SW system portion is included within the 10 CFR 54.4(a)(2) scope of license renewal. The information was requested because SW system SSCs are located in many areas of the plant, and the information in the LRA was not detailed sufficiently to determine whether any SSCs that should have been included within the scope of license renewal per 10 CFR 54.4(a)(2) had been omitted.

In its response dated May 17, 2007, the applicant indicated that the passive mechanical components within the 10 CFR 54(a)(2) scope of license renewal were the SW system components located in the cable tunnel, EDG building, electric bay area, motor-generator set room, primary containment, reactor building, gas treatment building, screenwell house, SW pump house, and turbine building. The applicant also indicated that SW SSCs in the auxiliary boiler building, in the turbine building below elevation 260 and on elevation 260 outside grid coordinates 260-8D through 13G, and in the pump house in areas below elevation 255 or areas on elevation 272 outside coordinates SW272-25A, 26A are not within the 10 CFR 54.4(a)(2) scope of license renewal because there are no safety-related components in these buildings or areas.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.2-4 acceptable 2-56

because it clearly specified the plant areas with SW system SSCs and included within the 10 CFR 54.4(a)(2) scope of license renewal SW SSCs in all the areas of the plant with potential spatial interaction with safety-related components. The staff's concern described in RAI 2.3.3.2-4 is resolved.

2.3.3.2.3 Conclusion The staff reviewed the LRA, accompanying license renewal drawings, and RAI responses to determine whether the applicant failed to identify any SSCs within the scope of license renewal.

The staff finds no such omissions. In addition, the staff's review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the SW system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).

2.3.3.3 Emergency Diesel Generator 2.3.3.3.1 Summary of Technical Information in the Application LRA Section 2.3.3.3 describes the EDG system, which supplies onsite AC power adequate for the safe shutdown of the reactor following abnormal operational transients and postulated accidents. The EDG system includes four diesel generator units, each with an air start system and fuel oil system. Each EDG includes several mechanical auxiliary systems that support operation. Each engine has a closed-loop jacket water cooling system which circulates corrosion-inhibiting coolant through the engine cylinder liners, lube oil cooler, and turbocharger after-coolers during engine operation. Each engine is equipped with three engine-driven lube oil gear pumps, which circulate clean, cool lubricating oil during engine operation. Each engine has a combustion air intake system, which draws air through the air intake filter from a hooded opening in the EDG building roof into the compressor side of the turbocharger. The exhaust system, consisting of the turbocharger, muffler, piping, and expansion joint, removes the combustion gases through the roof.

The EDG system has safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related EDG SSCs potentially could prevent the satisfactory accomplishment of a safety-related function. In addition, the EDG system performs functions that support fire protection.

LRA Tables 2.3.3-3 and 2.3.3-14-41 identify the following EDG system component types within the scope of license renewal and subject to AMR:

" bolting

" compressor housing

• duct

• duct flexible connection

" expansion joint

" filter housing

" heat exchanger (bonnet) 2-57

" heat exchanger (fins)

" heat exchanger (housing)

" heat exchanger (shell)

" heat exchanger (tubes)

" heater housing

" lubricator housing

" motor housing

" muffler

" orifice

" piping

" pump casing

" sight glass

" strainer

• strainer housing

• tank

" thermowell

" tubing

" valve body The EDG system component intended functions within the scope of license renewal include:

" flow control

" filtration

" heat transfer

" pressure boundary 2.3.3.3.2 Staff Evaluation The staff reviewed LRA Sections 2.3.3.3 and 2.3.3.14, Sections 2.2 and 3.1.51 of Entergy Report No. JAF-RPT-05-AMM30, and UFSAR Sections 8.6.1, 8.6.2, 8.6.3, and 8.6.4 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.

In conducting its Tier-2 review of the BOP two-tier review process, the staff evaluated the system functions described in the LRA and UFSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).

2.3.3.3.3 Conclusion The staff reviewed the LRA to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staff's review determined whether the applicant failed to identify any components subject to an AMR.

The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the EDG system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).

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2.3.3.4 Fuel Oil 2.3.3.4.1 Summary of Technical Information in the Application LRA Section 2.3.3.4 describes the fuel oil system, which stores and transfers fuel oil to the EDG and fire protection systems. Fuel oil system components include bulk storage tanks, day tanks, transfer pumps, piping, and valves. Each diesel generator unit has an independent fuel oil system with a main fuel storage tank, a day tank, and pumps. Two full-capacity motor-driven pumps fill the day tank from the storage tank. An engine-driven pump and a direct current (DC) motor-driven pump move fuel from the day tank to the fuel injectors as two redundant engine fuel pumping systems.

The fuel oil system has safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related fuel oil SSCs potentially could prevent the satisfactory accomplishment of a safety-related function. In addition, the fuel oil system performs functions that support fire protection.

LRA Table 2.3.3-4 identifies the following fuel oil system component types within the scope of license renewal and subject to AMR:

" bolting

" flame arrestor flow meter housing

• injector housing

• piping

• pump casing

• strainer

• strainer housing

• tank

• tubing

• valve body The fuel oil system component intended functions within the scope of license renewal include:

" flow control

" filtration

• pressure boundary 2.3.3.4.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.4 and UFSAR Sections 8.6 and 9.8.3 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.

In conducting its Tier-2 review of the BOP two-tier review process, the staff evaluated the system functions described in the LRA and UFSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and 2-59

long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).

2.3.3.4.3 Conclusion =

The staff reviewed the LRA to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staff's review determined whether the applicant failed to identify any components subject to an AMR.

The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the fuel oil system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).

2.3.3.5 FireProtection - Water 2.3.3.5.1 Summary of Technical Information in the Application LRA Section 2.3.3.5 describes the fire protection-water system, which provides adequate fire protection capability in all areas of the plant where a fire hazard may exist. The FP-water system consists of a water supply, pumping facilities, and distribution piping and components necessary for fire suppression. Water from Lake Ontario passes through the screenwell for a reliable supply of fresh water for fire fighting. Electric motor and diesel engine-driven water pumps discharge into the yard main and an underground loop encircling the entire plant that supplies water to fixed fire suppression systems, interior hose stations, and exterior fire hydrants. Manual fire suppression is available from exterior fire hydrants surrounding the power block and from hose stations located inside power block areas. Fire suppression by at least one manually-controlled hose stream is available in all areas except the primary containment. The fixed FP systems include deluge and preaction systems with unpressurized empty pipes controlled by a heat detection system, pressurized wet pipe systems, and pressurized dry pipe systems with air in the pipes and automatic "closed" sprinkler heads. An air foam system with a timed air foam discharge cycle blankets the condenser pit as well as oil floating on any water accumulation in the pit. A manually-initiated water foam system is a backup to the HPCI pump room water spray system. Foam pickup tubes and applicator nozzles are for manual firefighting.

The failure of nonsafety-related FP-water SSCs potentially could prevent the satisfactory accomplishment of a safety-related function. The FP-water system also performs functions that support FP.

LRA Tables 2.3.3-5 and 2.3.3-14-38 identify the following FP-water system component types within the scope of license renewal and subject to AMR:

" bolting

" expansion joint

• filter housing

• flow element

• gear box housing

• heat exchanger (bonnet)

• heat exchanger (shell) 2-60

" heat exchanger (tube)

" heater housing

" muffler

" nozzle

" orifice

" piping

" pump casing

" sight glass

" strainer

" strainer housing

• tank

• tubing

• turbocharger housing

" valve body The FP-water system component intended functions within the scope of license renewal include:

" flow control

" filtration

" heat transfer

" pressure boundary 2.3.3.5.2 Staff Evaluation The staff reviewed LRA Sections 2.3.3.5 and 2.3.3.14, and UFSAR Section 9.8 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.

During its review, the staff evaluated the system functions described in the LRA and UFSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).

The staff also reviewed the safety evaluation (SE) dated August 1, 1979, approving the applicant's Fire Protection Program and supplemental SE reports listed in Operating License Condition 2.C(3). The applicant's FP CLB refers to this SE and summarizes the Fire Protection Program and 10 CFR 50.48 commitments using Branch Technical Position (BTP) Auxiliary and Power Conversion Systems Branch (APCSB) 9.5-1, "Guidelines for Fire Protection for Nuclear Power Plants," dated May 1, 1976, and BTP APCSB 9.5-1, Appendix A, dated August 23, 1976.

The staff then reviewed those components that the applicant indicated as within the scope of license renewal for whether the applicant had omitted any passive and long-lived components subject to an AMR in accordance with 10 CFR 54.21(a)(1).

The staff's review of LRA Section 2.3.3.5 found areas in which additional information was necessary to complete the review of the applicant's scoping and screening results. The applicant responded to the staff's RAIs as follows.

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In RAI 2.3.3.5-1 dated January 12, 2007, the staff stated:

LRA drawing LRA-FB-48A-0 shows the motor driven vertical turbine make up pump (P-3), hydropneumatic tank (TK-4), and associated components as out of scope (i.e., not colored in blue). The staff requests that the applicant verify whether the motor driven vertical turbine make up pump, hydropneumatic tank, and associated components are in the scope of license renewal in accordance with 10 CFR 54.4(a) and subject to an AMR in accordance with 10 CFR 54.21(a)(1). If they are excluded from the scope of license renewal and not subject to an AMR, the staff requests that the applicant provide justification for the exclusion.

In its response dated February 12, 2007, the applicant stated:

The motor driven jockey fire pump (76-P-3) maintains fire system pressure during standby operations. As shown at coordinate C-3 on drawing LRA-FB-48A, this component is outside the quality class 'M' (augmented quality) boundary that defines components required for 10 CFR 50.48 at JAFNPP. However, the pump and its associated components support standby operation of the fire water system and are being included in the scope of license renewal and subject to aging management review. No changes are required to Table 2.3.3-5 to include these components. Because the component types of pump casing, piping, valve body, and sight glass exposed to raw water are already included in Table 3.3.2-5 and credit the Fire Water System Program as the aging management program, a change to Table 3.3.2-5 for these component types is not required. For the hydro pneumatic tank, the following aging management review results are added to Table 3.3.2-5.

Component type Tank Intended function Pressure boundary Material Carbon steel Environment Raw water Aging Effect Requiring Management Loss of material Aging Management Program Fire Water System NUREG 1801 Vol. 2 Item VII.G-24 (A-33)

Table 1 Item 3.3.1-68 Notes B Based on its review, the staff finds the applicant's response to RAI 2.3.3.5-1 acceptable because it included the jockey pump, hydro-pneumatic tank (TK-4), and their components within the scope of license renewal and subject to an AMR. The staff concludes that the motor-driven jockey fire pump, hydro-pneumatic tank (TK-4), and their components are included correctly. The staff's concern described in RAI 2.3.3.5-1 is resolved.

In RAI 2.3.3.5-2 dated January 12, 2007, the staff stated:

LRA drawing LRA-FB-48A-0 shows the yard fire hydrants to be in scope (i.e.,

colored in blue). The LRA Table 2.3.3-5, 'Fire Protection-Water System Components Subject to Aging Management Review,' and Table 3.3.2-5, 'Fire 2-62

Protection-Water System Summary of Aging Management Evaluation,' do not list yard fire hydrants for the Fire Protection-Water System. According to JAFNPP commitments to satisfy Appendix A to Branch Technical Position (BTP)

Auxiliary and Power Conversion Systems Branch (APCSB) 9.5-1, 'Guidelines for Fire Protection for Nuclear Power Plants,' May 1, 1976,' August 23, 1976 JAFNPP letter dated January 11, 1977, states that: 'the condensate storage tanks located outdoors are protected by outside fire hydrants and associated hose houses and equipment.' The staff requests that the applicant verify whether the yard fire hydrants are subject to an AMR in accordance with 10 CFR 54.21(a)(1). If they are excluded from an AMR, the staff requests that the applicant provide justification for the exclusion and address how the aging of those hydrants will be managed for the extended period of operation to ensure providing an effective hose stream when required. Furthermore, fire hydrants are considered passive and long-lived components in accordance with 10 CFR 54.21.

In its response dated February 12, 2007, the applicant stated:

The yard fire hydrants are subject to aging management review as shown on LRA-FB-49A and are included in the component type 'valve body' listed in Table 2.3.3-5. The corresponding line item in Table 3.3.2-5 is valve body with material gray cast iron and environment raw water (int).

Based on its review, the staff finds the applicant's response to RAI 2.3.3.5-2 acceptable because it committed to interpret yard fire hydrants as included in the "valve body," which is within the scope of license renewal and subject to an AMR. The staff is adequately assured that the applicant will consider yard fire hydrants for the fire suppression appropriately during aging management; therefore, the staff's concern described is RAI 2.3.3.5-2 is resolved.

In RAI 2.3.3.5-3, dated January 12, 2007, the staff stated:

LRA drawing LRA-FB-48A-0 shows the sprinkler heads to be in scope (i.e.,

colored in blue). The LRA Table 2.3.3-5, 'Fire Protection-Water System Components Subject to Aging Management Review,' and Table 3.3.2-5, 'Fire Protection-Water System Summary of Aging Management Evaluation,' do not list sprinkler heads for the Fire Protection-Water System. The staff requests that the applicant verify whether the sprinkler heads are subject to an AMR in accordance with 10 CFR 54.21(a)(1). If they are excluded from an AMR, the staff requests that the applicant provide justification for the exclusion.

In its response dated February 12, 2007, the applicant stated:

Sprinkler heads are subject to aging management review as shown on LRA-FB-49A and are included in the component type,'nozzle' listed in Tables 2.3.3-5 and 3.3.2-5. Materials are carbon steel and copper alloy > 15%

Zn.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.5-3 acceptable because it adequately explained that the sprinkler heads in question are subject to an AMR.

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Furthermore, the applicant stated that the sprinkler heads are represented in LRA Tables 2.3.3-5 and 3.3.2-5 by the component type "nozzles." Therefore, the staff's concern described in RAI 2.3.3.5-3 is resolved.,

In RAI 2.3.3.5-4 dated January 12, 2007, the staff stated:

LRA drawing LRA-FB-49A-0 shows the east diesel fire pump and Screenwell Building fire suppression system and associated components as out of scope (i.e., not colored in blue). The staff requests that the applicant verify whether the east diesel fire pump and Screenwell Building fire suppression system and associated components are in the scope of license renewal in accordance with 10 CFR 54.4(a) and subject to-an AMR in accordance with 10 CFR 54.21(a)(1).

If they are excluded from the scope of license renewal and not subject to an AMR, the staff requests that the applicant provide justification for the exclusion.

In its response dated February 12, 2007, the applicant stated:

The east diesel fire pump (76-P-4) is a backup to the main diesel fire pump (76-P-1) and electric fire pump (76-P-2) which supply all normal fire water loads.

It is not required to comply with the requirements of 10 CFR 50.48 as described in Technical Requirements Manual (TRM) Section B 3.7.H and is therefore not in scope for license renewal. The screenwell building fire suppression system is shown on LRA-FB-49A at coordinates D1 to G1. This system is highlighted as subject to aging management review with the exception of the components on thedischarge of the east diesel fire pump which is not required for 10 CFR 50.48 compliance, and its components are included in LRA Table 3.3.2-5.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.5-4 acceptable. The east diesel fire pump backs up the main diesel fire pump (76-P-1) and is not credited to meet BTP APCSB 9.5-1, Appendix A, which requires redundant fire water pumps with independent power supplies and controls. The applicant has redundant vertical-shaft centrifugal fire pumps for the water supply system, one electric motor-driven and the other diesel-driven; therefore, the staff finds that the applicant correctly excluded the east diesel fire pump from the scope of license renewal from an AMR. The applicant included the screenwell building fire suppression system and its components within the scope of license renewal and subject to an AMR. The staff concludes that the screenwell building fire suppression system and its components are included correctly. The staff's concern described in RAI 2.3.3.5-4 is resolved.

In RAI 2.3.3.5-5 dated January 12, 2007, the staff stated:

Section 4.3.1.3 of the Safety Evaluation (SE) dated August 1, 1979, states that a 30 gpm automatic electric driven centrifugal jockey pump is located in the same room as the electric motor driven fire pump. The jockey pump takes suction from the intake sump to maintain about 150 psig in the fire water system yard loop.

The jockey pump and its associated components appear to have fire protection intended functions required for compliance with 10 CFR 50.48 as stated in 10 CFR 54.4. The staff requests that the applicant verify whether the jockey pump and its associated components are in the scope of license renewal in accordance with 10 CFR 54.4(a) and subject to an AMR in accordance with 2-64

10 CFR 54.21(a)(1). If they are excluded from: the scope of license renewal and not subject to an AMR, the staff requests that the applicant provide justification for the exclusion.

In its response dated February 12, 2007, the applicant stated:

The motor driven jockey fire pump (76-P-3) maintains fire system pressure during standby operations. As shown at coordinate C-3 on drawing LRA-FB-48A, this component is outside the quality class 'M' (augmented quality) boundary that defines components required for 10 CFR 50.48 at JAFNPP. However, the pump and its associated components support standby operation of the fire water system and are being included in the scope of license renewal and subject to aging management review. Because the component types of pump casing, piping, valve body, and sight glass exposed to raw water are already included in Tables 2.3.3-5 and 3.3.2-5 and credit the Fire Water System Program as the aging management program, a change to the LRA tables for these component types is not required.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.5-5 acceptable because it included the motor-driven jockey fire pump (76-P-3) and its components within the scope of license renewal and subject to an AMR. The staff concludes that the motor-driven jockey fire pump and its components are included correctly. The staff's concern described in RAI 2.3.3.5-5 is resolved.

In RAI 2.3.3.5-6 dated January 12, 2007, the staff stated:

Section 4.3.1.4 of the SE dated August 1, 1979, discusses interior hose stations in plant areas. The staff requests that the applicant to verify whether these interior hose stations and their associated components are in the scope of license renewal in accordance with 10 CFR 54.4(a) and subject to an AMR in accordance with 10 CFR 54.21(a)(1). If they are excluded from the scope of license renewal and not subject to an AMR, the staff requests that the applicant provide justification for the exclusion.

In its response dated February 12, 2007, the applicant stated:

The interior hose stations have intended functions that are required for 10 CFR 54.4(a)(3) and are therefore included in the scope of license renewal.

These hose stations are included in the structural aging management review in the 'Fire hose reels' line item in LRA Tables 2.4-4 and 3.5.2-4, for bulk commodities. Piping and valve components supplying raw water to the hose reels are included in Tables 2.3.3-5 and 3.3.2-5 and credit the Fire Water System Program as the aging management program. As stated in LRA Section B.1.13.2, the fire hoses on these hose reels are periodically replaced and are therefore not subject to aging management review. This is consistent with NUREG-1800, Table 2.1-3 which classifies fire hoses as consumables.

Based on its review, the staff finds the applicant'sresponse to RAI 2.3.3.5-6 acceptable because it adequately explained that the interior hose stations in question are within the scope 2-65

of license renewal and subject to an AMR. The applicant stated that LRA Tables 2.4-4 and 3.5.2-4 includes the hose stations in the structural AMR.in the "Fire hose reels" line item for bulk commodities. LRA Tables 2.3.3-5 and 3.3.2-5 include piping and valve components supplying raw water to the hose reels. The staff's assurance that the applicant will consider the interior hose stations and their components for firefighting appropriately during plant aging management is adequate; therefore, the staff's concern described in RAI 2.3.3.5-6 is resolved.

In RAI 2.3.3.5-7 dated January 12, 2007, the staff stated:

Section 4.3.1.5 of the SE dated August 1, 1979, discusses preaction sprinkler systems provided in the recirculation pumps motor generator set room and in the emergency diesel generator rooms. The LRA does not list preaction sprinkler systems and their associated components provided in the recirculation pumps motor generator set room and in the emergency diesel generator rooms as being in scope and subject to an AMR. The staff requests that the applicant verify whether the preaction sprinkler systems and their associated components are in the scope of license renewal in accordance with 10 CFR 54.4(a) and subject to an AMR in accordance with 10 CFR 54.21(a)(1). If they are excluded from the scope of license renewal and not subject to an AMR, the staff requests that the applicant provide justification for the exclusion.

In its response dated February 12, 2007, the applicant stated:

Pre-action sprinkler systems and associated components in the recirculation pumps motor generator set room (LRA-FB-49A, coordinate G-6) and emergency diesel generator rooms (LRA-FB-49A, coordinate F-2) are subject to aging management review with components included in LRA Tables 2.3.3-5 and 3.3.2-5 and highlighted on referenced LRA drawings.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.5-7 acceptable because it committed to include pre-action sprinkler systems and their components installed in the recirculation pumps motor generator set and EDG rooms within the scope of license renewal and subject to an AMR. Therefore, the staff's assurance that the applicant will consider the fire water systems for fire suppression in the recirculation pumps motor generator set and EDG rooms appropriately during aging management is adequate and the staffs concern described in RAI 2.3.3.5-7 is resolved.

In RAI 2.3.3.5-8 dated January 12, 2007, the staff stated:

Section 4.3.1.5 of the SE dated August 1, 1979, discusses manual water spray systems in the HPCI pump room and reactor core isolation coolant (RCIC) pump room; in the vicinity of the standby gas treatment (SGT) system charcoal filters, hydrogen seal oil unit, and turbine generator bearing boxes; and in the reactor feed-pump turbine area and piping area. The LRA does not list manual water spray systems provided in HPCI and RCIC pump rooms; in the vicinity of the SGT system charcoal filters, hydrogen seal oil unit, and turbine generator bearing boxes; and in the reactor feed-pump turbine area and piping area as being in scope and subject to an AMR. The staff requests that the applicant verify whether the manual water spray systems and their associated components 2-66

are in the scope of license renewal in accordance with 10 CFR 54.4(a) and subject to an AMR in accordance with 10 CFR 54.21(a)(1). If they are excluded from the scope of license renewal and not subject to an AMR, the staff requests that the applicant provide justification for the exclusion.

In its response dated February 12, 2007, the applicant stated:

Water spray systems in the HPCI pump rooms (LRA-FB-49A, coordinate F-7),

RCIC pump rooms (LRA-FB-49A, coordinate F-7), SGT system charcoal filters (LRA-FM-49A, coordinates F-7), hydrogen seal oil unit (LRA-FB-49A, coordinate E-3), turbine generator bearing boxes (LRA-FB-49A, coordinate G-5), and reactor feed pump turbine and piping area (LRA-FB-49A, coordinates D-3, F-3) are subject to aging management review with components included in LRA Tables 2.3.3-5 and 3.3.2-5 and highlighted on referenced LRA drawings.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.5-8 acceptable because it indicated the water spray systems in the HPCI and RCIC pump rooms, SGT system charcoal, turbine generator bearing boxes, and reactor feed pump turbine and piping area highlighted on the license renewal drawings. Therefore, the staff's assurance that the applicant will consider the water spray systems for fire suppression of the HPCI and RCIC pump rooms, SGT system charcoal, turbine generator bearing boxes, and reactor feed pump turbine and piping area appropriately during aging management is adequate and the staff's concern described in RAI 2.3.3.5-8 is resolved.

In RAI 2.3.3.5-9 dated January 12, 2007, the staff stated:

Section 4.5 of the SE dated August 1, 1979, discusses flood drains provided in all plant areas protected with fixed water fire suppression system. The curbs/dikes are provided for liquid tanks in the diesel fire pump area, the dirty oil storage rooms, and main oil sump room to contain oil and fire water. The LRA does not list flood drains and curbs/dikes as being in scope and subject to an AMR. The staff requests that the applicant verify whether the flood drains and curbs/dikes are in the scope of license renewal in accordance with 10 CFR 54.4(a) and subject to an AMR in accordance with 10 CFR 54.21(a)(1).

If they are excluded from the scope of license renewal and not subject to an AMR, the staff requests that the applicant provide justification for the exclusion.

In its response dated February 12, 2007, the applicant stated:

Drain system components provided for protection of equipment from fire suppression water are in scope and subject to aging management review. They are part of the radwaste and plant drains system described in Section 2.3.3.12 of the LRA. The components subject to aging management review in this system are described in LRA Tables 2.3.3-12 and 3.3.2-12. "Flood curbs" are structural commodities that are in scope and subject to aging management review and included in LRA Tables 2.4-4 and 3.5.2-4, for bulk commodities.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.5-9 acceptable.

Although the SE addresses these floor drains as parts of the fire suppression system, they are 2-67

not included in LRA Section 2.3.3.5, "Fire Protection-Water," LRA Table 2.3.3.5, "Fire Protection-Water System," or LRA Table 3.3.2-5, "Fire Protection-Water System Summary of Aging Management Evaluation." Instead, they are included in LRA Section 2.3.3.12, "Radwaste and Plant Drains," LRA Table 2.3.3-12 "Radwaste and Plant Drains Systems," and LRA Table 3.3.2-12, "Radwaste and Plant Drains Summary of Aging Management Evaluation," as within the scope of license renewal and subject to an AMR. Flood drains are listed as flood curbs in the structural commodities and are within the scope of license renewal and subject to an AMR. The flood drains are included in LRA Tables 2.4-4 and 3.5.2-4 for bulk commodities.

Because the applicant has committed to interpret these floor drains as included in the radioactive waste system within the scope of license renewal and subject to an AMR, the staff's assurance that the applicant will consider floor drains for fire suppression appropriately during plant aging management is adequate. Therefore, the staff's concern described in RAI 2.3.3.5-9 is resolved.

In RAI 2.3.3.5-10 dated January 12, 2007, the staff stated:

Section 4.11 of the SE dated August 1, 1979, discusses the installation of fire resistance coating on exposed structural steel in the plant areas where the failure of exposed structural steel supporting fire barriers (floors, walls, and ceilings) could impair the safe-shutdown capability of the plant. These areas include the reactor building, turbine building, control building, diesel generator building, and others. The LRA does not list three-hour rated fire resistance coating for exposed structural steel as being in scope and subject to an AMR.

The staff requests that the applicant verify whether the fire resistance coating for structural steel is in scope of license renewal in accordance with 10 CFR 54.4(a) and subject to an AMR in accordance with 10 CFR 54.21(a)(1). If structural fire resistance coating is excluded from the scope of license renewal and not subject to an AMR, the staff requests that the applicant provide justification for the exclusion.

In its response dated February 12, 2007, the applicant stated:

Flame retardant coatings are in scope and subject to aging management review and are included in the line item "Fire proofing" in LRA Tables 2.4-4 and 3.5.2-4, for bulk commodities..

Based on its review, the staff finds the applicant's response to RAI 2.3.3.5-10 acceptable because LRA Tables 2.4-4 and 3.5.2-4 list flame retardant coatings as fire proofing in the line item in under bulk commodities as within the scope of license renewal and subject to an AMR.

Therefore, the staff's assurance that the applicant will consider structural steel flame retardant coatings for FP appropriately during aging management is adequate. Therefore, the staff's concern described in RAI 2.3.3.5-10 is resolved.

In RAI 2.3.3.5-11 dated January 12, 2007, the staff stated that the applicant is required to meet BTP APCSB 9.5-1, Appendix A. According to the applicant's commitments, its letter dated January 11, 1977, states that:

The Emergency Diesel Generator A and C combined ventilation air intake is located approximately 40 ft from the Station Reserve Transformer, T-3. This air 2-68

intake is approximately 10 ft above the ground. It is not practicable to seal this opening with a 3 hr fire barrier or by a combination of opening seals and water spray.

The Power Authority does not consider it necessary to provide a 3 hr fire barrier between the ventilation opening and the transformer for the following reasons:

1) The transformer is protected by an automatic water spray deluge system in accordance with NFPA 13.

The staff asked the applicant to verify whether the automatic water deluge system for Station Reserve Transformer T-3 is within the 10 CFR 54.4(a) scope of license renewal and subject to an AMR by 10 CFR 54.21(a)(1). If excluded from the scope of license renewal and not subject to an AMR, the staff asked the applicant to justify the automatic water deluge system's exclusion.

In its response dated February 12, 2007, the applicant stated, as shown on license renewal drawing LRA-FB-49A at location E-3, the automatic water deluge system protecting Station Reserve Transformer T-3 is within the scope of license renewal, subject to an AMR, and included in LRA Tables 2.3.3.5 and 3.3.2-5.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.5-11 acceptable because it included the automatic water deluge system and its components protecting its station reserve transformer within the scope of license renewal and subject to an AMR.

Therefore, the staff's concern described in RAI 2.3.3.5-11 is resolved.

2.3.3.5.3 Conclusion The staff reviewed the LRA to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staff's review determined whether the applicant failed to identify any components subject to an AMR.

The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the FP-water system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).

2.3.3.6 Fire Protection- C02 2.3.3.6.1 Summary of Technical Information in the Application LRA Section 2.3.3.6 describes the FP-C0 2 system, which provides FP in areas where use of a water spray or a sprinkler system is not feasible. There are fixed total flooding carbon dioxide (C0 2 ) suppression systems for the cable spreading room, cable run rooms, relay room, each of the two electrical bay switchgear rooms, and each of the two emergency diesel-generator switchgear rooms. Liquid C02 is stored in two refrigerated low-pressure tanks. A three-ton low-pressure storage tank supplies the systems in the EDG switchgear rooms and a nearby C02 system hose reel station in the turbine building. A ten-ton low-pressure storage tank supplies the remaining systems and two hose stations and also provides C02 to purge the main 2-69

generator hydrogen system.

The FP-C0 2 system performs functions that support FP.

LRA Tables 2.3.3-6 and 2.3.3-14-38 identify the following FP-C0 2 system component types within the scope of license renewal and subject to an AMR:

0 bolting

• coil 0 nozzle 0 piping

• tank

" tubing

" valve body The FP-C0 2 system component intended function within the scope of license renewal is to provide a pressure boundary.

2.3.3.6.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.6 and UFSAR Section 9.8 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.

During its review, the staff evaluated the system functions described in the LRA and UFSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).

The staff also reviewed the SE dated August 1, 1979, approving the applicant's Fire Protection Program and supplemental SE reports listed in Operating License Condition 2.C(3). The FP CLB refers to this SE and summarizes the Fire Protection Program and 10 CFR 50.48 commitments using BTP APCSB 9.5-1 and BTP APCSB 9.5-1, Appendix A guidance. The staff then reviewed those components that the applicant included within the scope of license renewal to verify that the applicant did not omit any passive and long-lived components subject to an AMR in accordance with 10 CFR 54.21(a)(1).

The staffs review of LRA Section2.3.3.6 found areas in which additional information was necessary to complete the review of the applicant's scoping and screening results. The applicant responded to the staff's RAIs as follows.

In RAI 2.3.3.6-1 dated January 12, 2007, the staff stated that LRA Section 2.3.3.6 describes the CO 2 fire suppression system as within the scope of the license renewal and subject to an AMR.

The AMP for the CO 2 fire suppression system does not appear in LRA Section B.1.13, "Fire Protection Program." GALL AMP XI.M26, "Fire Protection," which describes C02 fire suppression system aging management, requires that an AMP to evaluate the periodic visual inspection and function test at least every six months for signs of system degradation. Material conditions that may affect system performance (e.g., corrosion, mechanical damage, or 2-70

damage to dampers) are observed during these tests. The staff asked the applicant to describe in LRA Section B.1.13 the AMP and operating experience for the CO 2 fire suppression system.

In its response dated February 12, 2007, the applicant stated that, although LRA Table 3.3.2-6 credits the Fire Protection Program for the management of C02 fire suppression system component aging effects, the system was omitted inadvertently from the description of the Fire Protection Program. The applicant revised the LRA Section B.1.13.1 program description to include the following sentence:

The Fire Protection Program also includes management of the aging effects on the intended function of the C02 fire suppression system.

The applicant also added to LRA Section B.1.13.1 the following exception to the GALL Report:

Attributes Affected Exception

3. Parameters The functional test of the CO2 fire suppression system is Monitored/Inspected performed on a 24-month basis as listed in the current licensing basis for JAF. This frequency is sufficient to ensure

4. Detection of Aging Effects system availability and operability based on station operating history and to ensure that aging effects will be properly managed through the period of extended operation.

The staff accepted the position that, in the absence of age-related degradation adversely affecting system operation and provided that visual inspections of component external surfaces are performed every six months, the periodicity specified in the CLB for functional testing of the C02 system is sufficient to ensure system availability and operability.

LRA Section B. 1.13 already describes C02 fire suppression system operating experience in the following statements:

QA audits and surveillances in 2002 and 2003 revealed that the material condition of system equipment was good and met licensing requirements. The audits and surveillances revealed no issues or findings that could impact effectiveness of the program to manage aging effects for fire protection components.

In March 2005, NRC completed a triennial fire protection team inspection to assess whether the plant has implemented an adequate fire protection program and that post-fire safe shutdown capabilities have been established and are being properly maintained. Results confirmed that plant personnel were maintaining the fire protection systems in accordance with their fire protection program and identifying program deficiencies and implementing appropriate corrective actions.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.6-1 acceptable because it states that LRA Section B.1.13.1 omitted the C02 fire suppression system AMP inadvertently from the description of the Fire Protection Program. The applicant revised LRA Section B.1.13.1 to include the C02 fire suppression system AMP. LRA Table 3.3.2-6 includes 2-71

the C02 fire suppression system component AMR. The staff's assurance that the applicant will consider the C02 fire suppression system and its components appropriately during plant aging management is adequate. Therefore, the staff's concern described in RAI 2.3.3.6-1 is resolved.

In RAI 2.3.3.6-2 dated January 12, 2007, the staff stated that LRA Tables 2.3.3-6 and 3.3.2-6 exclude several types of C02 fire suppression system components that appear in license renewal drawing LRA-FB-56A-0 colored purple:

• strainer

" strainer housing

" filter housing

" heater housing

• orifice

• siren body

" pipe supports

" couplings

" odorizer

" threaded connections

• pneumatic actuators The staff asked the applicant to determine for each whether the component should be included in LRA Tables 2.3.3-6 and 3.3.2.6, and, if not, to justify the exclusion.

In its response dated February 12, 2007, the applicant stated that the pneumatic actuators are active components and therefore not subject to an AMR. Pipe supports are subject to an AMR and included in LRA Table 2.4-4 with AMR results in LRA Table 3.5.2-4 under "Component and piping supports."

There are no strainer, strainer housing, filter housing, heater housing, siren body, or odorizer component types in the FP-C0 2 system, nor are they shown on license renewal drawing LRA-FB-56A-0. Orifice, coupling, and threaded connection component types which contain C02 are subject to an AMR and included in the component type "Piping" in LRA Tables 2.3.3-6 and 3.3.2.6.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.6-2 acceptable.

Although the applicant states that it considers these components included in other line items, the LRA line item descriptions do not actually list all these components specifically. The applicant properly included the following components with the other line items within the scope of license renewal and subject to an AMR: pipe supports, orifice, coupling, and threaded connection. The staff's assurance that the applicant will consider these components appropriately during plant aging management is adequate. The staff finds that the LRA did not include pneumatic actuators in the line item descriptions. The staff recognizes that the applicant's interpretation of this component as active (short-lived component) will result in more vigorous oversight of its condition and performance. Because the applicant has interpreted pneumatic actuators as active, which is not within the scope of 10 CFR 50.54, the staff concludes that their exclusion from the scope of license renewal is correct and that they are not subject to an AMR. The staff finds that the following components in questions are not parts of the CO2 system: strainer, strainer housing, filter housing, heater housing, siren body, or odorizer; therefore, the staff's concern described in RAI 2.3.3.6-2 is resolved.

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In RAI 2.3.3.6-3 dated January 12, 2007, the staff stated that, according to the applicant's commitments to satisfy BTP APCSB 9.5-1, Appendix A, its letter dated January 11, 1977, states that

... the plant computer room is located within a wire fence area inside the relay room... The relay room (including computer room) is protected by a total flooding C02 system with outside backup by a water hose station and portable C02 extinguisher.

UFSAR Section 9.8.3.11 states that, "Halon is used for fire protection in the Emergency and Plant Information Computer (EPIC) Room where it is not desirable to use a water spray or a sprinkler system." The staff asked the applicant to verify whether the flooding C02 fire suppression system or Halon fire suppression system in the EPIC room is within the 10 CFR 54.4(a) scope of license renewal and subject to an AMR by 10 CFR 54.21(a)(1). If the C02 or Halon fire suppression system is excluded from the scope of license renewal and not subject to an AMR, the staff requested justification for the exclusion.

In its response dated February 12, 2007, the applicant stated that the EPIC system is neither safety-related nor credited to support a safe-shutdown in any fire scenarios to demonstrate compliance with 10 CFR 50.48 and that, therefore, the Halon system in the EPIC room is not required to support 10 CFR 50.48 and not within the scope of license renewal nor subject to an AMR.

As stated in LRA Section 2.3.3.6 and shown in LRA Table 2.3.3-6, the total flooding C02 fire suppression system for the relay room is within the scope of license renewal. LRA Table 3.3.2-6 lists and license renewal drawing LRA-FB-56A shows AMR results for components in this system portion.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.6-3 acceptable. The staff finds that the EPIC system is not safety-related, cannot affect safety-related equipment by spatial interaction, is not required for safe-shutdown, and, therefore, has no 10 CFR 54.4(a)(2) intended function and that the applicant correctly excluded the Halon system in the EPIC room from the scope of license renewal and from any AMR. The total flooding C02 fire suppression system for the relay room is within the scope of license renewal and subject to an AMR. LRA Table 3.3.2-6 lists and license renewal drawing LRA-FB-56A shows AMR results for the components in this system portion. Therefore, the staff's concern described in RAI 2.3.3.6-3 is resolved.

2.3.3.6.3 Conclusion The staff reviewed the LRA to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR.

The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the fire protection-CO 2 system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).

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2.3.3.7 Heating, Ventilation, and Air Conditioning 2.3.3.7.1 Summary of Technical Information in the Application LRA Section 2.3.3.7 describes the heating, ventilation, and air conditioning (HVAC) system, which controls the station air temperatures and the flow of airborne radioactive contaminants to ensure the operability of station equipment and the accessibility and habitability of station buildings and compartments. The HVAC systems include numerous systems which together comprise plant HVAC equipment, including:

" reactor building ventilation

" turbine building ventilation

• drywell ventilation and cooling

" radwaste building ventilation

• control room and relay room ventilation and cooling

" administration building ventilation and cooling

" screenwell and water treatment ventilation system

• EDG building HVAC

° ventilation radiation monitoring subsystem of process radiation monitor system

" security building ventilation The reactor building ventilation system controls ambient temperatures, humidity, and the flow of potentially airborne radioactive contaminants for operability of equipment and accessibility and habitability of plant buildings and compartments. The turbine building ventilation system controls plant ambient temperature, humidity, and the flow of potentially airborne radioactive contaminants. The turbine building ventilation system supplies filtered and tempered outdoor air to the operating floor and all other areas below the operating floor. The drywell ventilation and cooling system circulates cooled nitrogen around the drywell, including areas around the reactor recirculation pumps and motors, the control rod drive area, and the annular space between the reactor vessel and the primary shield. The radwaste building ventilation system removes heat rejected from operating equipment compartments to maintain required space temperatures. The control and relay rooms ventilation and cooling system provides adequate ventilation, heating, cooling, and relative humidity for those rooms. The control and relay room air conditioning systems operate independently of other plant HVAC services. These systems must operate at all times during normal, shutdown, and DBA conditions. The administration building ventilation and cooling system provides adequate ventilation, heating, cooling, and relative humidityfor areas within the administration building. This system includes the administration building ventilation and cooling, administration and support building ventilation and cooling, warehouse building ventilation and cooling, station battery room ventilation and cooling, SW for admin building cooling, and technical support center/EPIC room ventilation. The screenwell and water treatment ventilation system provides ventilation and heating within the screenwell / water treatment building. The EDG building HVAC conditioning system heats and ventilates the EDG rooms and EDG sWitchgear rooms. The process radiation monitor system, which monitors process liquid and gas lines that may serve as discharge routes for radioactive materials, consists of a number of radiation monitors and monitoring subsystems with automatic actions and control room indications. The security access building houses a propane-powered generator for backup power to selected security loads and yard lighting. For engine cooling, the building is equipped with air intake louvers and discharge ducts with air movement produced by 2-74

the engine fan.

The HVAC system has safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related HVAC SSCs potentially could prevent the satisfactory accomplishment of a safety-related function. In addition, the HVAC system performs functions that support fire protection.

LRA Tables 2.3.3-7, 2.3.3-14-11, 2.3.3-14-32, 2.3.3-14-33, 2.3.3-14-34, 2.3.3-14-35, and 2.3.3-14-36 identify the following HVAC system component types within the scope of license renewal and subject to AMR:

" bolting

" compressor housing

" damper housing

" duct

• duct flexible connection

" fan housing

" filter housing

" flow element

• heat exchanger (bonnet)

" heat exchanger (fins)

" heat exchanger (housing)

" heat exchanger (shell)

" heat exchanger (tubes)

" heat exchanger (tubesheet)

• . louver housing

• orifice

• piping

• pump casing

• sight glass

• strainer

• strainer housing

" tank

• tubing

" valve body The HVAC system component intended functions within the scope of license renewal include:

" flow control

" filtration

" heat transfer

• pressure boundary 2.3.3.7.2 Staff Evaluation The staff reviewed LRA Sections 2.3.3.7 and 2.3.3.14, and UFSAR Sections 9.9.3.3, 9.9.3.4, 5.2.3.7, 9.9.3.5, 9.9.3.11, 9.9.3.6, 9.9.3.10, 9.9.3.7, 9.9.3.9, and 7.12 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.

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During its review, the staff evaluated the system functions described in the LRA and UFSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).

2.3.3.7.3 Conclusion The staff reviewed the LRA to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staff's review determined whether the applicant failed to identify any components subject to an AMR.

The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the HVAC system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).

2.3.3.8 ContainmentPurge, ContainmentAtmosphere Dilution, and Post-Accident Sampling 2.3.3.8.1 Summary of Technical Information in the Application LRA Section 2.3.3.8 describes the containment purge (CP), containment atmosphere dilution (CAD), and post-accident sampling system (PASS), which includes the primary containment atmosphere control and dilution system, drywell purge ventilation supply and exhaust systems, venting and vacuum relief system, and PASS. The system establishes and maintains the desired atmosphere in the primary containment, provides the means to control the relative oxygen concentration by inerting the containment atmosphere with nitrogen or deinerting it with outside air, monitors containment hydrogen and oxygen concentrations, and controls primary containment pressure and differential pressure via makeup to or venting from the drywell and suppression chamber. The system also provides nitrogen to pneumatically-operated I&C in the containment and a meas to collect and analyze liquid and gaseous samples from containment following a LOCA.

The containment atmosphere is monitored via redundant dual-range hydrogen and oxygen analyzers sampling at four separate locations, three in the drywell and one in the torus. The sample lines are redundant to each analyzer. The primary containment is deinerted by fresh outside air from a vent and purge supply fan. During both inerting and deinerting processes, the SGT system processes gas purged from the torus and drywell before exhausting it to the atmosphere. Nitrogen makeup maintains drywell pressure, drywell-to-torus differential pressure, and primary containment oxygen concentration within required limits. Instrumentation and pneumatically-operated valves in the primary containment are supplied with nitrogen gas instead of air to prevent a buildup of oxygen in the containment. Containment isolation valves outside the primary containment for the RBCLC water system also are supplied with nitrogen.

The PASS obtains representative liquid and gaseous samples from within the primary containment and gaseous samples from within the secondary containment for radio-chemical and chemical analyses in a LOCA. From interpretation of this data, the extent of core damage 2-76

and other radiological and chemical conditions in the plant can be predicted. The basic system consists of a liquid and gas sample station in the reactor water recirculation pump motor generator set room outside the secondary containment structure. The system is also designed to provide useful samples under conditions ranging from normal shutdown and power operation to design-basis LOCA.

The CP, CAD, and PASS has safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related CP, CAD, and PASS SSCs potentially could prevent the satisfactory accomplishment of a safety-related function. In addition, the CP, CAD, and PASS performs functions that support FP.

LRA Tables 2.3.3-8 and 2.3.3-14-15 identify the following CP, CAD and PASS component types within the scope of license renewal and subject to AMR:

• bolting

• filter housing

" flow element

" heat exchanger (coil)

" heat exchanger (tubes)

" heater housing

" orifice

" piping

• pump casing

• sample trap

" tank

• tubing

• valve body The CP, CAD, and PASS component intended functions within the scope of license renewal include:

" heat transfer

• pressure boundary 2.3.3.8.2 Staff Evaluation The staff reviewed LRA Sections 2.3.3.8 and 2.3.3.14, and UFSAR Sections 5.2.3.6, 5.2.3.7, 5.2.3.8, 5.2.3.14, and 9.14.4 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.

During its review, the staff evaluated the system functions described in the LRA and UFSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21 (a)(1).

On the basis of its review the staff found that LRA Section 2.3.3.8 includes CP, CAD and PASS portions that meet 10 CFR 54.4 scoping requirements within the scope of license renewal. LRA 2-77

Table 2.3.3-8 also include CP, CAD and PASS components subject to an AMR by 10 CFR 54.4(a) and 10 CFR Part 54.21(a)(1). The staff found no omissions.

2.3.3.8.3 Conclusion The staff reviewed the LRA to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staff's review determined whether the applicant failed to identify any components subject to an AMR.

The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the containment purge, containment atmosphere dilution, and post-accident sampling system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).

2.3.3.9 Fuel Pool Cooling and Cleanup 2.3.3.9.1 Summary of Technical Information in the Application LRA Section 2.3.3.9 describes the fuel pool cooling and cleanup (FPCC) system, which provides a criticality safe underwater storage location for spent fuel assemblies requiring shielding and cooling during storage and handling. The construction and configuration of the spent fuel racks preclude the possibility of criticality under normal and abnormal conditions. The spent fuel pool, fuel pool gates, and connected cooling system piping are arranged for a minimum level over fuel seated in the pool to shield plant personnel adequately. The FPCC system controls spent fuel storage pool temperature, maintains spent fuel storage pool water clarity, and minimizes the concentration of fission and corrosion products in the spent fuel storage pool. The FPCC system cools and purifies the spent fuel storage pool by passing the pool water through two heat exchangers, transferring heat to the reactor building closed loop cooling water system. Water purity and clarity in the spent fuel storage pool, reactor head cavity, and reactor internals storage pit are maintained by filtering and demineralizing. There is additional capability to add water to the pool through a cross-tie to the RHR system when normal makeup system is lost and pool water level is threatened due to heavy pool water inventory loss.

The FPCC system has safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related FPCC SSCs potentially could prevent the satisfactory accomplishment of a safety-related function.

LRA Tables 2.3.3-9 and 2.3.3-14-12 identify the following FPCC system component types within the scope of license renewal and subject to AMR:

" bolting

" diffuser

" flow element

" heat exchanger (shell)

" neutron absorber

" orifice

• piping 2-78

" pump casing

" tank

" thermowell

" tubing

• valve body The FPCC system component intended functions within the scope of license renewal include:

• flow control

• neutron absorption

• pressure boundary 2.3.3.9.2 Staff Evaluation The staff reviewed LRA Sections 2.3.3.9 and 2.3.3.14, Sections 2.2 and 3.1.14 of Entergy Report No. [[::JAF-RPT-05|JAF-RPT-05]],-AMM30, and UFSAR Sections 9.3 and 9.4 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.

In conducting its Tier-2 review of the BOP two-tier review process, the staff evaluated the system functions described in the LRA and UFSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not -omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).

The staff's review of LRA Sections 2.3.3.9 and 2.3.3.14 found an area in which additional information was necessary to complete the review of the applicant's scoping and screening results. The applicant responded to the staff's RAI as follows.

In RAI 2.3.3.9-1 dated January 19, 2007, the staff noted that license renewal drawing LRA-FM-19A, at locations F3 and F4, shows lines W19-151-1A, 1B, and 17 from skimmer surge tanks TK-8A and TK-8B to surge tank drain valve VGW-15A as not within the scope of license renewal. The piping and components upstream from VGW-15A are labeled SEISMIC I.

The staff requested additional information as to why these pipe and component sections are not within the 10 CFR 54.4(a) scope of license renewal and justification for the boundary locations.

In its response dated February 14, 2007, the applicant stated:

The seismic I boundaries are uniquely identified on the license renewal drawings. The portions of the system required to maintain pressure boundary for the system to perform its safety functions are identified in the site component database as QA category I and identified within the system intended function boundary flags. The seismic I boundary identifies those portions of systems that are seismically qualified category I but not necessarily safety-related or QAI.

The portions of the system that Were included in the aging management review as shown by the highlighting on the LRA drawing include the portions of the system required to maintain the pressure boundary and ensure that functions defined in 10CFR54.4(a)(1) or (a)(3) can be performed.

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The portions of the system beyond the QA I boundary that are identified as Seismic I were included in scope as part of the 10 CFR 54.4(a)(2) review, but are not highlighted on individual LRA drawings, as described in LRA Section 2.1.2.1.3.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.9-1 acceptable because it adequately justified omission of the piping sections in question from the scope of license renewal under 10 CFR 54.4(a)(1) and 10 CFR 54.4(a)(3). The staff agrees that integrity of these piping sections is not required to maintain the pressure boundary. The applicant further explained that system portions beyond the QA I boundary shown as SEISMIC I were included within the scope of license renewal in the 10 CFR 54.4(a)(2) review. Therefore, the staff's concern described in RAI 2.3.3.9-1 is resolved.

2.3.3.9.3 Conclusion The staff reviewed the LRA to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staff's review determined whether the applicant failed to identify any components subject to an AMR.

The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the FPCC system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).

2.3.3.10 Service, Instrument,and BreathingAir 2.3.3.10.1 Summary of Technical Information in the Application LRA Section 2.3.3.10 describes the service, instrument, and breathing air system, which provides a continuous supply of oil-free compressed air directed to plant breathing air, instrumentation, and general plant services. The compressed air to the breathing, instrument, and service air subsystems is supplied by three air compressors arranged in parallel to discharge air through individual air receivers with a common discharge header feeding three instrument air dryers. This common discharge header also supplies air to the breathing air headers and the instrument air headers after passing through two air dryers installed in parallel.

Each of the dryers has pre-filters and after-filters to ensure that no particulate matter enters the system. The breathing air system has a breathing air accumulator. Instrument air is available as a backup to drywell instrumentation and controls, which are normally supplied with nitrogen via the instrument air line. Nitrogen is used so any leakage will not dilute the nitrogen-inerted primary containment. The normal source of nitrogen is the primary containment atmosphere control and dilution system.

The service, instrument, and breathing air system has safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related service, instrument, and breathing air SSCs potentially could prevent the satisfactory accomplishment of a safety-related function.

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LRA Tables 2.3.3-10 and 2.3.3-14-25 identify the following service, instrument, and breathing air system component types within the scope of license renewal and subject to AMR:

" bolting

• piping

" quick connect

" tank

• tubing

• valve body The service, instrument, and breathing air system component intended function within the scope of license renewal is to provide a pressure boundary.

2.3.3.10.2 Staff Evaluation The staff reviewed LRA Sections 2.3.3.10 and 2.3.3.14, Sections 2.2 and 3.1.28 of Entergy Report No. JAF-RPT-05-AMM30, and UFSAR Section 9.11 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.

In conducting its Tier-2 review of the BOP two-tier review process, the staff evaluated the system functions described in the LRA and UFSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).

The staff's review of LRA Sections 2.3.3.10 and 2.3.3.14 found an area in which additional information was necessary to complete the review of the applicant's scoping and screening results. The applicant responded to the staffs RAIs as follows.

In RAI 2.3.3.10-1 dated January 19, 2007, the staff noted that license renewal drawing LRA-M-29A-0, at location G7, shows that the in-scope nitrogen supply for RCPB air operated valves (AOVs) 02AOV-17 and 02AOV-18 does not extend to the actuator but terminates at the downstream side of solenoid valves (SOVs) SOV-1 7 and SOV-1 8, respectively. The staff requested pursuant to 10 CFR 54.4(a) additional clarification for why the in-scope boundaries for the nitrogen supply lines to 02AOV-17 and 02AOV-18 do not extend to the actuator and justification for the boundary locations.

In its response dated February 14, 2007, the applicant stated:

The safety-related function of 02AOV-17 and 02AOV-18, to maintain Reactor Coolant Pressure Boundary integrity, is performed with the valves closed and does not require pneumatic pressure. Since these valves vent the reactor vessel head to the drywell equipment drain sump, the valves would only be opened with the reactor shutdown and depressurized. Thus, the ability to open the valves is non-safety-related, and does not meet any scoping criteria for License Renewal.

The safety-related function of the drywell pneumatic header is to supply pneumatic pressure to open the safety-relief valves (SRVs) when required.

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Normally closed 02SOV-17 and 02SOV-18 perform this safety-related function, and are therefore in scope for License Renewal under 10 CFR 54.4(a)(1) with the intended pressure boundary function. Nitrogen supply lines downstream of the SOVs are isolated from the SRV pneumatic supply, and have no intended function for License Renewal.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.10-1 acceptable because the piping in question connecting the AOVs and the SOVs has no safety-related function. The AOVs, boundary valves to maintain RCPB integrity, during operation are passive components in the closed position. The SOVs, which maintain instrument air system boundary integrity, are also passive components during operation in the closed position. Therefore, the staff's concern described in RAI 2.3.3.10-1 is resolved.

2.3.3.10.3 Conclusion The staff reviewed the LRA to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staff's review determined whether the applicant failed to identify any components subject to an AMR.

The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the service, instrument, and breathing air system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).

2.3.3.11 Reactor Building Closed Loop Cooling Water 2.3.3.11.1 Summary of Technical Information in the Application LRA Section 2.3.3.11 describes the reactor building closed loop cooling water (RBCLCW) system, which cools equipment in the reactor building during normal plant operations and provides a barrier between systems containing radioactive fluids and the non-radioactive SW system pumped directly from and to the lake. The RBCLCW system consisting of a normally independent closed loop piping arrangement is normally in operation cooling nonsafety-related loads in the reactor building and drywell. The RBCLCW system penetrates the primary containment in nine locations to provide cooling water to heat loads within the drywell. The RBCLCW system has three centrifugal pumps taking suction from the reactor building cooling water return loop for a cooling water flow. SW cools the RBCLCW heat exchangers. A surge tank on the suction side of the pumps accommodates system volume changes, maintains static pressure in the loop, detects gross leaks in the RBCLCW system, and allows for the addition of makeup water. Makeup water to the RBCLCW system from the demineralized water storage tank is supplied by a connection from the demineralized water transfer pump to the surge tank.

The RBCLCW system has safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related RBCLCW SSCs potentially could prevent the satisfactory accomplishment of a safety-related function. In addition, the RBCLCW system performs functions that support fire protection.

LRA Tables 2.3.3-11 and 2.3.3-14-9 identify the following RBCLCW system component types within the scope of license renewal and subject to AMR:

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" accumulator

" bolting

• filter housing

" flow element

" heat exchanger (shell)

" orifice

• piping

• pump casing

• tank

• tubing

• valve body The RBCLCW system component intended functions within the scope of license renewal include:

0 flow control

• pressure boundary 2.3.3.11.2 Staff Evaluation The staff reviewed LRA Sections 2.3.3.11 and 2.3.3.14, Sections 2.2 and 3.1.11 of Entergy Report No. JAF-RPT-05-AMM30, and UFSAR Section 9.5 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.

In conducting its Tier-2 review of the BOP two-tier review process, the staff evaluated the system functions described in the LRA and UFSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).

The staff's review of LRA Sections 2.3.3.2 and 2.3.3.14 found an area in which additional information was necessary to complete the review of the applicant's scoping and screening results. The applicant responded to the staff's RAI as follows.

In RAI 2.3.3.11-1 dated January 19, 2007, the staff noted that license renewal drawing LRA-M-1 5-B, at locations C4, C7, F4, and F7, shows four RBCLCW containment isolation valves on supply lines to the drywell. The license renewal boundary for each section of piping ends at the AOV; however, piping and components upstream from the boundary are labeled SEISMIC I. The staff requested pursuant to 10 CFR 54.4(a) additional information on why the following listed pipe and component sections are not within the scope of license renewal and justification for the boundary locations:

• license renewal drawing LRA-FM-15-B, location C4, upstream from AOV 130B through valve 23B

• license renewal drawing LRA-FM-1 5-B, location C7, upstream from AOV 130A through valve 23A 2-83

license renewal drawing LRA-FM-15-B, location F4, upstream from AOV 132A through valve 20A license renewal drawing LRA-FM.-15-B, location F7, upstream from AOV 132B through valve 20B In its response dated February 14, 2007, the applicant stated that SEISMIC I boundaries are identified uniquely on the license renewal drawings. Final safety analysis report (FSAR)-Table 7.3-1 shows the penetration portions required to maintain pressure boundary for containment within the system intended function boundary flags. The SEISMIC I boundary identifies those systems that are seismically qualified category I but not necessarily required for containment integrity. System portions included in the AMR as shown by the highlighting on the license renewal drawing include those required to maintain the pressure boundary and ensure containment integrity.

The applicant also stated that portions of the system beyond the containment boundary shown as seismic I were included within the scope of license renewal in the 10 CFR 54.4(a)(2) review but not highlighted on individual license renewal drawings.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.11-1 acceptable because the piping sections in question are not required to maintain containment integrity and, therefore, not within the scope of license renewal for 10 CFR 54.4(a)(1 ) or 10 CFR 54.4(a)(3).

The staff agrees that integrity of these piping sections is not required to maintain the pressure boundary; therefore, the staff's concern described in RAI 2.3.3.11-1 is resolved.

2.3.3.11.3 Conclusion The staff reviewed the LRA, accompanying scoping boundary drawings, and RAI responses to determine whether the applicant failed to identify any SSCs within the scope of license renewal.

The staff finds no such omissions. In addition, the staff's review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the RBCLCW'system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).

2.3.3.12 Radwaste and PlantDrains 2.3.3.12.1 Summary of Technical Information in the Application LRA Section 2.3.3.12 describes the radwaste and plant drains system, which collects, treats, and disposes of radioactive and potentially radioactive liquid and solid wastes in a controlled and safe manner. These wastes are collected in sumps and drain tanks at various locations throughout the plant and then transferred to the appropriate collection tanks in the radioactive waste building prior to treatment, storage, and disposal. Processed liquid wastes are either returned to the condensate system or discharged from the plant in a controlled manner. The wastes are collected, treated, and disposed of according to their conductivity and radioactivity.

The system is divided into several subsystems so that the liquid wastes from various sources can be segregated and processed separately. The system also drains fire suppression water 2-84

flow in a fire so that water buildup will not impact safety-related equipment. Process solid wastes are collected, dewatered, packaged, and stored in shielded compartments prior to offsite shipment. The yard storm drains system collects and transfers rain runoff to the storm sewers. The floor and roof drainage system collects and removes waste liquids from their

• points of origin and to transfer them to suitable treatment and/or disposal areas in a controlled manner. The system includes non-radioactive floor and roof drains from all areas of the plant.

The radwaste and plant drains system has safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related radwaste and plant drains SSCs potentially could prevent the satisfactory accomplishment of a safety-related function. In addition, the radwaste and plant drains system performs functions that support fire protection.

LRA Tables 2.3.3-12, 2.3.3-14-13 and 2.3.3-14-45 identify the following radwaste and plant drains system component system types within the scope of license renewal and subject to an AMR:

" bolting

" filter housing

" flow element

" orifice

" piping

• pump casing

" sight glass a steam trap

" strainer housing

• tank a tubing 8 valve body 0 sight glass The radwaste and plant drains system component intended function within the scope of license renewal include:

" pressure boundary

" drainage flowpath 2.3.3.12.2 Staff Evaluation The staff reviewed LRA Sections 2.3.3.12 and 2.3.3.14, Sections 2.2, 3.1.15, 3.1.44, and 3.1.46 of Entergy Report No. JAF-RPT-05-AMM30, and UFSAR Sections 9.13, 11.2, and 11.3 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.

In conducting its Tier-2 review fo the BOP two-tier review process, the staff evaluated the system functions described in the LRA to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and 2-85

long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).

The staff's review of LRA Sections 2.3.3.12 found an area in which additional information was necessary to complete the review of the applicant's scoping and screening results. The applicant responded to the staff's RAI as follows.

In RAI 2.3.3.12-1 dated April 25, 2007, the staff requested additional information on the radwaste and plant drains system and on specific components required to support the 10 CFR 54.4(a)(3) function.

In its response, by letter dated May 17, 2007, the applicant stated that the plant drains system has a network of four-inch piping to remove approximately 100 gpm of fire fighting water in various plant areas and buildings and that components included within the scope of license renewal were the sump pumps, floor drain piping and valves, sump pump suction and discharge piping and valves, and tanks that supported the function.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.12-1 acceptable because it clearly indicated plant areas and radwaste and plant drains system components included within the scope of 10 CFR 54.4(a)(3). The staff's concern described in RAI 2.3.3.12-1 is resolved.

2.3.3.12.3 Conclusion The staff reviewed the LRA, RAI responses, and scoping boundary drawings, to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staff's review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the radwaste and plant drains system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).

2.3.3.13 Security Generator 2.3.3.13.1 Summary of Technical Information in the Application LRA Section 2.3.3.13 describes the security generator system, equipment necessary for maintaining site security, including the security generator, which provides necessary lighting for certain areas.

The security generator system performs functions that support fire protection.

LRA Table 2.3.3-13 identifies the following security generator system component types within the scope of license renewal and subject to an AMR:

" bolting

" expansion joint 2-86

• filter housing

• heat exchanger (shell)

• heat exchanger (tubes)

• piping

• pump casing

• silencer

• *strainer

• strainer housing

• tank

• tubing

• valve body The security generator system component intended functions within the scope of license renewal include:

" filtration

" heat transfer

" pressure boundary 2.3.3.13.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.13 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.

In conducting its Tier-2 review fo the BOP two-tier review process, the staff evaluated the system functions described in the LRA and UFSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).

The staff reviewed components that the applicant indicated as within the scope of license renewal to verify that the applicant had not omitted any passive and long-lived components subject to an AMR by 10 CFR 54.21(a)(1). Based on its review, the staff found that, in addition to the component types listed in LRA Table 2.3.3-13, an additional component, sight glass, should have been included within the 10 CFR 54.4(a)(3) scope of license renewal. The applicant, in Amendment 11 dated May 17, 2007, has added the component type sight glass to LRA Table 2.3.3-13.

2.3.3.13.3 Conclusion The staff reviewed the LRA and inspected the security generator to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staff's review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the security generator system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).

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2.3.3.14 Miscellaneous Systems In-Scope for 10 CFR 54.4(a)(2)

LRA Section 2.3.3.14 describes the miscellaneous systems within the scope of license renewal under 10 CFR 54.4(a)(2). Such systems interact with safety-related systems in one of two ways: (1) a functional failure where the failure of a nonsafety-related SSC to perform its function impacts a safety function or (2) a physical failure where a safety function is impacted by the loss of structural or mechanical integrity of an SSC in physical proximity to a safety-related component.

LRA Section 2.3.3.14 states that functional failures of nonsafety-related SSCs which could impact a safety function are identified in previous LRA sections.

LRA Table 2.3.3.14-A shows systems within the scope of license renewal with potential for physical interactions with safety-related components. Of these systems, the following are not described elsewhere in the LRA:

• reactor water cleanup

• extraction steam

• decay heat removal (DHR)

" feedwater heater vents and drains

" circulating water

• turbine building closed loop cooling (TBCLC)

" vacuum priming and air removal

• turbine lube oil

• secondary plant drains

• raw water treatment

" contaminated equipment drains

• auxiliary gas treatment

• plumbing, sanitary and lab

" city water

" auxiliary boiler and accessories

" main turbine generator

" sample system

" steam seal 2.3.3.14A Reactor Water Cleanup 2.3.3.14A.1 Summary of Technical Information The RWCU system maintains high reactor water purity to limit chemical and corrosive action, fouling, and deposition on heat transfer surfaces. The RWCU system removes corrosion products to limit impurities for neutron activation and resultant radiation from deposition of corrosion products. The system also decreases reactor coolant system inventory during heatup.

The failure of nonsafety-related RWCU SSCs potentially could prevent the satisfactory accomplishment of a safety-related function. In addition, the RWCU system performs functions that support fire protection.

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LRA Table 2.3.3-14-6 identifies the following RWCU system component types within the scope of license renewal and subject to an AMR:

• bolting

• demineralizer

• flow element

• 'heat exchanger (shell)

• orifice

• piping

• pump casing

• sight glass

• strainer housing

• tank

• thermowell

• tubing

• valve body The RWCU system component intended function within the scope of license renewal is to provide a pressure boundary.

2.3.3.14A.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.14 using the evaluation methodology described in SER Section 2.3 and the guidance in.SRP-LR Section 2.3.

During its review, the staff evaluated the system functions described in the LRA and UFSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).

After examining the IPE results to confirm that the RWCU system poses no significant risk, the staff completed a Tier-1 review, which does not require detailed boundary drawings. The system is not a dominant contributor to core damage frequency, nor is it involved in the dominant initiating events.

2.3.3.14A.3 Conclusion The staff reviewed the LRA to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staff's review determined whether the applicant failed to identify any components subject to an AMR.

The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the miscellaneous systems in-scope for 10 CFR 54.4(a)(2) components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).

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2.3.3.14B Extraction Steam 2.3.3.14B.1 Summary of Technical Information The extraction steam system transports steam to components of the steam and power conversion system. The extraction steam system supplies steam from the turbine extraction points to loads like the feedwater heaters and reactor feed pump turbines. The extraction steam system includes the moisture separator reheaters and the steam reboiler system.

The failure of nonsafety-related extraction steam SSCs potentially could prevent the satisfactory accomplishment of a safety-related function.

LRA Table 2.3.3-14-17 identifies the following extraction steam system component types within the scope of license renewal and subject to an AMR:

" bolting

• expansion joint

" flow element

• heat exchanger (shell)

" orifice

" piping

" strainer housing

" tank

• thermowell

• tubing

• valve body The extraction steam system component intended function within the scope of license renewal is to provide a pressure boundary.

2.3.3.14B.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.14 and UFSAR Sections 9.18, 10.1, 10.2 and 10.8 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.

The staff verified that the extraction steam system poses no significant risk by examining the IPE results, and therefore, performed a Tier-1 review which does not require detailed boundary drawings. The system is not a dominant contributor to core damage frequency, nor is it involved in the dominant initiating events.

During its review, the staff evaluated the system functions described in the LRA and UFSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).

2.3.3.14B.3 Conclusion 2-90

The staff reviewed the LRA to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staff's review determined whether the applicant failed to identify any components subject to an AMR.

The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the extraction steam system components in-scope for 10 CFR 54.4(a)(2) components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).

2.3.3.14C Decay Heat Removal 2.3.3.14C.1 Summary of Technical Information The DHR system provides an alternate means of decay heat removal from the spent fuel pool.

The DHR system can also cool the reactor core when the reactor pressure vessel head has been removed, the reactor cavity flooded, and the fuel transfer gates removed by utilizing natural convection currents established between the spent fuel pool and the reactor cavity.

The failure of nonsafety-related DHR SSCs potentially could prevent the satisfactory accomplishment of a safety-related function.

LRA Table 2.3.3-14-18 identifies the following DHR system component types within the scope of license renewal and subject to an AMR:

" bolting

• flow element

• heat exchanger (shell)

" piping

" pump casing

• strainer housing

• tubing

• valve body The DHR system component intended function within the scope of license renewal is to provide a pressure boundary.

2.3.3.14C.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.14 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.

During its review, the staff evaluated the system functions described in the LRA and UFSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).

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After examining the IPE results to confirm that the DHR steam system poses no significant risk, the staff completed a Tier-1 review, which does not require detailed boundary drawings. The system is not a dominant contributor to core damage frequency, nor is it involved in the dominant initiating events.

2.3.3.14C.3 Conclusion The staff reviewed the LRA to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staff's review determined whether the applicant failed to identify any components subject to an AMR.

The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the miscellaneous systems in-scope for 10 CFR 54.4(a)(2) components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).

2.3.3.14D FeedwaterHeater Vents and Drains 2.3.3.14D.1 Summary of Technical Information The feedwater heater vents and drains system supports feedwater heating in the condensate system. The system consists of the piping, valves, instruments, and controls that maintain appropriate shell side levels in the feedwater heaters. Drains cascade from the highest to lowest pressure heater and to the main condenser. Heater vents are also connected to the condenser.

The failure of nonsafety-related feedwater heater vents and drains SSCs potentially could prevent the satisfactory accomplishment of a safety-related function.

LRA Table 2.3.3-14-21 identifies the following feedwater heater vents and drains system component types within the scope of license renewal and subject to an AMR:

" bolting

" orifice

• piping

" sight glass

" thermowell

• tubing

• valve body The feedwater heater vents and drains system component intended function within the scope of license renewal is to provide a pressure boundary.

2.3.3.14D.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.14 and UFSAR Section 10.8 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.

The staff verified that the feedwater heater vents and drains system poses no significant risk by 2-92

examining the IPE results, and therefore, performed a Tier-1 review which does not require detailed boundary drawings. The system is not a dominant contributor to core damage frequency, nor is it involved in the dominant initiating events.

During its review, the staff evaluated the system functions described in the LRA and UFSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).

2.3.3.14D.3 Conclusion The staff reviewed the LRA to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staff's review determined whether the applicant failed to identify any components subject to an AMR.

The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the feedwater heater vents and drains system components in-scope for 10 CFR 54.4(a)(2) components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).

2.3.3.14E CirculatingWater 2.3.3.14E.1 Summary of Technical Information The circulating water system supplies the main condenser continuously with cooling water to remove heat rejected by the turbine exhaust and turbine bypass steam as well as from other exhausts over the full range of operating loads.

The failure of nonsafety-related circulating water SSCs potentially could prevent the satisfactory accomplishment of a safety-related function.

LRA Table 2.3.3-14-22 identifies the following circulating water system component types within the scope of license renewal and subject to an AMR:

• bolting

• piping

• pump casing

• tank

• tubing

• valve body The circulating water system component intended function within the scope of license renewal is to provide a pressure boundary.

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2.3.3.14E.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.14 and UFSAR Section 10.6 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.

During its review, the staff evaluated the system functions described in the LRA and UFSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).

The staff's review of LRA Section 2.3.3.14 found an area in which additional information was necessary to complete the review of the applicant's scoping and screening results. The applicant' responded to the staff's RAI as follows.

In RAI 2.3.3.14-2, dated April 25, 2007, the staff requested additional information on a number of systems included in LRA Section 2.3.14, including the circulating water system. Specifically the staff asked the applicant to indicate the circulating water system parts included within the 10 CFR 54.4(a)(2) scope of license renewal.

In its response dated May 17, 2007, the applicant indicated that it had used the component database for the locations of the circulating water system components. Potential 10 CFR 54.4(a)(2) passive mechanical components in the system are located in the screenwell house and turbine building. All system components except those in the turbine building in areas below elevation 260 and on elevation 260 outside grid coordinates 260-8D through 13G and in the screenwell pump house below elevations 255 or areas on elevation 272 outside building grid coordinates SW272-25A and 26A are included within the 10 CFR 54.4(a)(2) scope of license renewal. There is no safety-related equipment in the excluded areas and, thus, no potential for spatial interaction of nonsafety-related with safety-related SSCs; therefore, the applicant's exclusion of the components in these areas is justified.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.14-2 acceptable because it clearly indicated the plant areas and circulating water system components included within the 10 CFR 54.4(a)(2) scope of license renewal. The staff's concern about the circulating water system described in RAI 2.3.3.14-2 is resolved.

2.3.3.14E.3 Conclusion The staff reviewed the LRA and RAI responses to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staff's review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the circulating water system components in-scope for 10 CFR 54.4(a)(2) components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).

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2.3.3.14F Turbine Building Closed Loop Cooling 2.3.3.14F.1 Summary of Technical Information The TBCLC system cools auxiliary equipment in the turbine building and in the radioactive waste building. It also provides makeup seal water to the condenser air removal pumps and the condenser water box vacuum priming pumps.

The failure of nonsafety-related TBCLC SSCs potentially could prevent the satisfactory accomplishment of a safety-related function.

LRA Table 2.3.3-14-23 identifies the following TBCLC system component types within the scope of license renewal and subject to an AMR:

" bolting

• piping

" strainer housing

• tank

" thermowell

• tubing

" valve body The TBCLC system component intended function within the scope of license renewal is to provide a pressure boundary.

2.3.3.14F.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.14 and UFSAR Section 9.6 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.

In conducting its Tier-2 review of the BOP two-tier review process, the staff evaluated the system functions described in the LRA and UFSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).

The staff's review of LRA Section 2.3.3.14 found an area in which additional information was necessary to complete the review of the applicant's scoping and screening results. The applicant responded to the staff's RAI as follows.

In RAI 2.3.3.14-2 dated April 25, 2007, the staff requested additional information on a number of systems included in LRA Section 2.3.14, including the TBCLC system. Specifically the staff asked for the TBCLC system part included within the scope of license renewal and why the TBCLC pumps and heat exchangers were not subject to an AMR.

In its response dated May 17, 2007, the applicant indicated that it had used the component 2-95

database for locations-of TBCLC components. Potential 10 CFR 54.4(a)(2) passive mechanical components in the system are located in the turbine building, auxiliary boiler room, and radwaste building. Components in the auxiliary boiler building, the radwaste building, and turbine building in areas below elevation 260 and on elevation 260 outside grid coordinates 260-8D through 13G are not within the scope of license renewal as there are no safety-related components in these buildings or areas. The applicant stated that the TBCLC pumps and heat exchangers in turbine building areas with a floor elevation below 260 were located in an area with no safety-related equipment or components and so excluded from the scope of license renewal.

Based on its review, the staff finds the applicant's acceptable because it clearly indicated the plant areas'and components of the TBCLC system and justified the exclusion of the TBCLC pumps and heat exchangers. The staff's concern about the TBCLC system described in RAI 2.3.3.14-2 is resolved.

2.3.3.14F.3 Conclusion The staff reviewed the LRA and RAI responses to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staff's review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the turbine building closed loop cooling system components in-scope for 10 CFR 54.4(a)(2) components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21 (a)(1).

2.3.3.14G Vacuum Primingand Air Removal 2.3.3.14G.1 Summary of Technical Information The vacuum priming and air removal system removes all air and noncondensable gases from the condenser. The system also processes turbine gland seal leakoff.

The failure of nonsafety-related vacuum priming and air removal SSCs potentially could prevent the satisfactory accomplishment of a safety-related function.

LRA Table 2.3.3-14-24 identifies the following vacuum priming and air removal system component types within the scope of license renewal and subject to an AMR:

• bolting

" heat exchanger (shell)

• piping

• pump casing

• sight glass

" tank

• tubing

" valve body 2-96

The vacuum priming and air removal system component intended function within the scope of license renewal is to provide a pressure boundary.

2.3.3.14G.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.14 and UFSAR Section 10.4 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.

The staff verified that the vacuum priming and air removal system poses no significant risk by examining the IPE results, and therefore, performed a Tier-1 review which does not require detailed boundary drawings. The system is not a dominant contributor to core damage frequency, nor is it involved in the dominant initiating events.

During its review, the staff evaluated the system functions described in the LRA and UFSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).

2.3.3.14G.3 Conclusion The staff reviewed the LRA to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staff's review determined whether the applicant failed to identify any components subject to an AMR.

The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the vacuum priming and air removal system components in-scope for 10 CFR 54.4(a)(2) components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).

2.3.3.14H Turbine Lube Oil 2.3.3.14H.1 Summary of Technical Information The turbine lube oil system provides clean lubricating oil to the lubrication oil reservoirs of the main turbine generator, the reactor feed pump turbines, and the main generator shaft hydrogen seals. The turbine lube oil system includes the main turbine oil reservoir, a turbine oil conditioner, clean, dirty, and waste oil storage tanks, and the interconnecting piping, pumps, valves, instrumentation, and controls.

The failure of nonsafety-related turbine lube oil SSCs potentially could prevent the satisfactory accomplishment of a safety-related function.

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LRA Table 2.3.3-14-26 identifies the following turbine lube oil system component types within the scope of license renewal and subject to an AMR:

• bolting

• piping

• pump casing

• sight glass

" strainer housing

" tank

" thermowell

" tubing

• valve body The turbine lube oil system component intended function within the scope of license renewal is to provide a pressure boundary.

2.3.3.14H.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.14 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.

The staff verified that the turbine lube oil system poses no significant risk by examining the IPE results, and therefore, performed a Tier-1 review which does not require detailed boundary drawings. The system is not a dominant contributor to core damage frequency, nor is it involved in the dominant initiating events.

During its review, the staff evaluated the system functions described in the LRA and UFSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21 (a)(1).

2.3.3.14H.3 Conclusion The staff reviewed the LRA and to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR.

The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the turbine lube oil system components in-scope for 10 CFR 54.4(a)(2) components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).

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2.3.3.141 Secondary Plant Drains 2.3.3.141.1 Summary of Technical Information The secondary plant drains system provides a drain flowpath from steam and power conversion system components to the main condenser and includes piping, valves, instrumentation, and controls to handle drainage from various systems including MS, extraction steam, and vacuum priming and air removal systems.

The failure of nonsafety-related secondary plant drains SSCs potentially could prevent the satisfactory accomplishment of a safety-related function.

LRA Table 2.3.3-14-27 identifies the following secondary plant drains system component types within the scope of license renewal and subject to an AMR:

• bolting

• orifice

" piping

• strainer housing

• thermowell

• tubing

• valve body The secondary plant drains system component intended function within the scope of license renewal is to provide a pressure boundary.

2.3.3.141.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.14 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.

The staff verified that the secondary plant drains system poses no significant risk by examining the IPE results, and therefore, performed a Tier-1 review which does not require detailed boundary drawings. The system is not a dominant contributor to core damage frequency, nor is it involved in the dominant initiating events.

During its review, the staff evaluated the system functions described in the LRA and UFSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in' accordance with the requirements of 10 CFR 54.21 (a)(1).

2.3.3.141.3 Conclusion The staff reviewed the LRA to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staff's review determined whether the applicant failed to identify any components subject to an AMR.

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The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the secondary plant drains system components in-scope for 10 CFR 54.4(a)(2) components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).

2.3.3.14J Raw Water Treatment 2.3.3.14J.1 Summary of Technical Information The raw water treatment system supplies treated water suitable for plant makeup and other demineralized water requirements.

The failure of nonsafety-related raw water treatment SSCs potentially could prevent the satisfactory accomplishment of a safety-related function.

LRA Table 2.3.3-14-28 identifies the following raw water treatment system component types within the scope of license renewal and subject to an AMR:

" bolting

• filter housing

" orifice

" piping

" pump casing

• sight glass

" strainer housing

" tubing

• valve body The raw water treatment system component intended function within the scope of license renewal is to provide a pressure boundary.

2.3.3.14J.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.14 and UFSAR Section 9.10 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.

The staff verified that the raw water treatment system poses no significant risk by examining the IPE results, and therefore, performed a Tier-1 review which does not require detailed boundary drawings. The system is not a dominant contributor to core damage frequency, nor is it involved in the dominant initiating events.

During its review, the staff evaluated the system functions described in the LRA and UFSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).

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2.3.3.14J.3 Conclusion The staff reviewed the LRA to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staff's review determined whether the applicant failed to identify any components subject to an AMR.

The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the raw water treatment system components in-scope for 10 CFR 54.4(a)(2) components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).

2.3.3.14K ContaminatedEquipment Drains 2.3.3.14K.1 Summary of Technical Information The contaminated equipment drains system collects and transfers waste liquids to suitable treatment or disposal areas in a controlled manner. The system consists of piping and components which drain contaminated or potentially contaminated waste from equipment and floor drains to the radioactive waste system for processing.

The failure of nonsafety-related contaminated equipment drains SSCs potentially could prevent the satisfactory accomplishment of a safety-related function.

LRA Table 2.3.3-14-29 identifies the following contaminated equipment drains system component types within the scope of license renewal and subject to an AMR:

" bolting

" piping

" sight glass

" valve body The contaminated equipment drains system component intended function within the scope of license renewal is to provide a pressure boundary.

2.3.3.14K.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.14, UFSAR Sections 9.13, 9.14 and 11.2, and Entergy Report No. JAF-RPT-05-AMM30, Sections 2.2 and 3.1.32, using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.

In conducting its Tier-2 review of the BOP two-tier review process, the staff evaluated the system functions described in the LRA and UFSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).

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The staff's review of LRA Section 2.3.3.14 found an area in which additional information was necessary to complete the review of the applicant's scoping and screening results. The applicant responded to the staff's RAI as follows.

In RAI 2.3.3.14-2 dated April 25, 2007, the staff requested additional information on a number of systems in LRA Section 2.3.3.14, including the contaminated equipment drain system.

Specifically the staff asked which part of the contaminated equipment drain system was within the scope of license renewal.

In its response dated May 17, 2007, the applicant indicated that it had used the component database for the locations of the contaminated equipment drain system components. Potential 10 CFR 54.4(a)(2) passive mechanical components in the system are located in the reactor building.

As the complete system is in the reactor building, where all SSCs are within the 10 CFR 54.4(a)(2) scope of license renewal, all contaminated equipment drain system components are within the scope of license renewal.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.14-2 acceptable. The staff's concern about the contaminated equipment drain system described in RAI 2.3.3.14-2 is resolved.

2.3.3.14K.3 Conclusion The staff reviewed the LRA and RAI responses to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staff's review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the contaminated equipment drain system components in-scope for 10 CFR 54.4(a)(2) components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).

2.3.3.14L Auxiliary Gas Treatment 2.3.3.14L.1 Summary of Technical Information The auxiliary gas treatment system supports the reactor vessel head removal by processing radioactive gases that accumulate under the reactor vessel head during plant outages. During outages the system also uses portable hoses or ducts to remove radioactive gasses around contaminated equipment. A removable duct section connects the reactor vessel head to the auxiliary gas treatment system consisting of a demister, high-efficiency filters, charcoal filter, and a fan. The processed gas then is discharged to the reactor building ventilation system exhaust or to the SGT system.

The failure of nonsafety-related auxiliary gas treatment SSCs potentially could prevent the satisfactory accomplishment of a safety-related function.

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LRA Table 2.3.3-14-31 identifies the following auxiliary gas treatment system component types within the scope of license renewal and subject to an AMR:

" bolting

" damper housing

• duct The auxiliary gas treatment system component intended function within the scope of license renewal is to provide a pressure boundary.

2.3.3.14L.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.14 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.

During its review, the staff evaluated the system functions described in the LRA and UFSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).

After examining the IPE results to confirm that the auxiliary gas treatment system poses no significant risk, the staff completed a Tier-1 review, which does not require detailed boundary drawings. The system is not a dominant contributor to core damage frequency, nor is it involved in the dominant initiating events.

2.3.3.14L.3 Conclusion The staff reviewed the LRA to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staff's review determined whether the applicant failed to identify any components subject to an AMR.

The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the miscellaneous systems in-scope for 10 CFR 54.4(a)(2) components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).

2.3.3.14M Plumbing, Sanitary,and Lab 2.3.3.14M.1 Summary of Technical Information The plumbing, sanitary, and lab system provides drinking water supplies and disposes of sanitary wastes during normal plant operation. This system includes the domestic water storage tank, potable water pump, potable water distribution piping, the shower waste storage tank and pump, and the laboratory vacuum equipment.

The failure of nonsafety-related plumbing, sanitary, and lab SSCs potentially could prevent the satisfactory accomplishment of a safety-related function.

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LRA Table 2.3.3-14-37 identifies the following plumbing, sanitary, and lab system component types within the scope of license renewal and subject to an AMR:

" bolting

• heat exchanger (shell)

• piping

" strainer housing

" valve body The plumbing, sanitary, and lab system component intended function within the scope of license renewal is to provide a pressure boundary.

2.3.3.14M.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.14 and UFSAR Section 9.12 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.

The staff verified that the plumbing, sanitary, and lab system poses no significant risk by examining the IPE results, and therefore, performed a Tier-1 review which does not require detailed boundary drawings. The system is not a dominant contributor to core damage frequency, nor is it involved in the dominant initiating events.

During its review, the staff evaluated the system functions described in the LRA and UFSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).

2.3.3.14M.3 Conclusion The staff reviewed the LRA to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staff's review determined whether the applicant failed to identify any components subject to an AMR.

The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the plumbing, sanitary, and lab system components in-scope for 10 CFR 54.4(a)(2) components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).

2.3.3.14N City Water 2.3.3.14N.1 Summary of Technical Information The city water system distributes potable water to various locations around the plant site. The system consists of the piping and valves from the Oswego water supply to distribution systems in buildings around the site and to such others as the potable water and water treatment systems.

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The failure of nonsafety-related city water SSCs potentially could prevent the satisfactory accomplishment of a safety-related function.

LRA Table 2.3.3-14-39 identifies the following city water system component types within the scope of license renewal and subject to an AMR:

• bolting

" piping

" valve body The city water system component intended function within the scope of license renewal is to provide a pressure boundary.

2.3.3.14N.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.14 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.

The staff verified that the city water steam system poses no significant risk by examining the IPE results, and therefore, performed a Tier-1 review which does not require detailed boundary drawings. The system is not a dominant contributor to core damage frequency, nor is it involved in the dominant initiating events.

During its review, the staff evaluated the system functions described in the LRA and UFSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).

2.3.3.14N.3 Conclusion The staff reviewed the LRA to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staff's review determined whether the applicant failed to identify any components subject to an AMR.

The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the city water system components in-scope for 10 CFR 54.4(a)(2) components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).

2.3.3.140 Auxiliary Boiler and Accessories 2.3.3.140.1 Summary of Technical Information The auxiliary boiler and accessories system heats the plant building spaces during planned operation by a forced-circulation hot water system for recirculation air heating and a hot water-ethylene glycol system for heating outside air introduced into ventilation systems. The plant heating system consists of two package hot water boilers, two hot water circulating 2-105

pumps, three hot water-glycol circulating pumps, two fuel oil transfer pumps, one 170,000-gallon fuel storage tank, two compression tanks, piping, valves, combustion controls, and instrumentation.

The failure of nonsafety-related auxiliary boiler and accessories SSCs potentially could prevent the satisfactory accomplishment of a safety-related function.

LRA Table 2.3.3-14-40 identifies the following auxiliary boiler and accessories system component types within the scope of license renewal and subject to an AMR:

° bolting

" flow element

• piping

" tubing

" valve body The auxiliary boiler and accessories system component intended function within the scope of license renewal is to provide a pressure boundary.

2.3.3.140.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.14 and UFSAR Section 9.9.3.2 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.

The staff verified that the auxiliary boiler and accessories system poses no significant risk by examining the IPE results, and therefore, performed a Tier-1 review which does not require detailed boundary drawings. The system is not a dominant contributor to core damage frequency, nor is it involved in the dominant initiating events.

During its review, the staff evaluated the system functions described in the LRA and UFSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).

2.3.3.140.3 Conclusion The staff reviewed the LRA to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staff's review determined whether the applicant failed to identify any components subject to an AMR.

The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the auxiliary boiler and accessories in-scope for 10 CFR 54.4(a)(2) components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).

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2.3.3.14P Main Turbine Generator 2.3.3.14P.1 Summary of Technical Information The main turbine generator system receives steam from the boiling water reactor, economically converting a portion of the thermal energy in the steam to electric energy and extracting steam for feedwater heating.

The failure of nonsafety-related main turbine generator SSCs potentially could prevent the satisfactory accomplishment of a safety-related function.

LRA Table 2.3.3-14-42 identifies the following main turbine generator system component types within the scope of license renewal and subject to an AMR:

" bolting

" filter housing

" heat exchanger (shell)

" piping

" pump casing

" sight glass

• strainer housing

• tank

• thermowell

• tubing

• turbine casing

• valve body The main turbine generator system component intended function within the scope of license renewal is to provide a pressure boundary.

2.3.3.14P.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.14 and UFSAR Section 10.2 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.

In conducting its Tier-2 review of the BOP two-tier review process, the staff evaluated the system functions described in the LRA and UFSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).

The staff's review of LRA Section 2.3.3.14 found an area in which additional information was necessary to complete the review of the applicant's scoping and screening results. The applicant responded to the staff's RAI as follows.

In RAI 2.3.3.14-2 dated April 25, 2007, the staff requested additional information on a number of systems in LRA Section 2.3.3.14, including the main turbine generator system. Specifically 2-107

the staff asked which part of the main turbine generator system was within the scope of license renewal.

In its response dated May 17, 2007, the applicant indicated that it had used the component database for the locations of the main turbine generator system components. Potential 10 CFR 54.4(a)(2) passive mechanical components in the system are located in the turbine building, and all passive components in the system were within the 10 CFR 54.4(a)(2) scope of license renewal.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.14-2 acceptable because it clarified that all main turbine generator system components are within the scope of license renewal. The staff's concern about the main turbine generator system described in RAI 2.3.3.14-2 is resolved.

2.3.3.14P.3 Conclusion The staff reviewed the LRA and RAI responses to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the main turbine generator system components in-scope for 10 CFR 54.4(a)(2) components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).

2.3.3.14Q Sample System 2.3.3.14Q. 1 Summary of Technical Information The sample system monitors the operational performance of plant equipment. Samples are taken from various streams and locations. There are two sample sinks, one in the reactor building and one in the radioactive waste building. Most samples are sent to these sinks to facilitate sampling and reduce exposure to plant personnel. Samples are taken to the laboratory for appropriate analysis. In addition, continuous automatic monitoring and alarm of undesirable conditions uses in-line detectors when necessary.

The failure of nonsafety-related sample system SSCs potentially could prevent the satisfactory accomplishment of a safety-related function.

LRA Table 2.3.3-14-43 identifies the following sample system component types within the scope of license renewal and subject to an AMR:

• bolting

• heat exchanger (tubes)

• piping

• pump casing

• sight glass

• tubing 2-108

0 valve body The sample system component intended function within the scope of license renewal is to provide a pressure boundary.

2.3.3.14Q.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.14 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.

In conducting its Tier-2 review of the BOP two-tier process, the staff evaluated the system functions described in the LRA and UFSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).

The staff's review of LRA Section 2.3.3.14 found an area in which additional information was necessary to complete the review of the applicant's scoping and screening results. The applicant responded to the staff's RAI as follows.

In RAI 2.3.3.14-2 dated April 25, 2007, the staff requested additional information on a number of systems in LRA Section 2.3.3.14, including the sample system. Specifically the staff asked which part of the sample system was within the scope of license renewal.

In its response dated May 17, 2007, the applicant indicated that it had used the component database for the locations of the sample system components. The applicant also indicated that the potential 10 CFR 54.4(a)(2) passive mechanical components in the system are located in the turbine building but that all system passive components were within the 10 CFR 54.4(a)(2) scope of license renewal.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.14-2 acceptable because it clarified that all sample system components are within the scope of license renewal.

The staffs concern about the sample system described in RAI 2.3.3.14-2 is resolved.

2.3.3.14Q.3 Conclusion The staff reviewed the LRA and RAI responses to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staff's review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the sample system components in-scope for 10 CFR 54.4(a)(2) components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).

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2.3.3.14R Steam Seal 2.3.3.14R.1 Summary of Technical Information The steam seal system prevents steam leakage out of and air leakage into the turbine or condenser. The system consists of the steam seal regulator, steam seal header, and piping to the steam packing exhauster. Steam is supplied to the steam seal system from the gland seal reboiler system. Sealing steam is supplied to the sub-atmospheric glands of the low-pressure turbine and the reactor feed pump turbine from the steam seal header. The outer ends of all glands are routed to the steam packing exhauster, which is maintained at a slight vacuum by the exhaust blowers.

The failure of nonsafety-related steam seal SSCs potentially could prevent the satisfactory accomplishment of a safety-related function.

LRA Table 2.3.3-14-44 identifies the following steam seal system component types within the scope of license renewal and subject to an AMR:

• bolting

" piping

" tubing

• valve body The steam seal system component intended function within the scope of license renewal is to provide a pressure boundary.

2.3.3.14R.2 Staff Evaluation The staff reviewed LRA Section 2.3.3.14 and the UFSAR using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.

The staff verified that the steam seal system poses no significant risk by examining the IPE results, and therefore, performed a Tier-1 review which does not require detailed boundary drawings. The system is not a dominant contributor to core damage frequency, nor is it involved in the dominant initiating events.

During its review, the staff evaluated the system functions described in the LRA and UFSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).

2.3.3.14R.3 Conclusion The staff reviewed the LRA to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staff's review determined whether the applicant failed to identify any components subject to an AMR.

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The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the steam seal system components in-scope for 10 CFR 54.4(a)(2) components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21 (a)(1).

The remaining systems shown in LRA Table 2.3.3.14-A as within the scope of license renewal with potential for physical interaction with safety-related components are addressed elsewhere in other LRA sections listed here:

0 2.3.1 CRD

• 2.3.1 reactor coolant a 2.3.2.1 RHR 0 2.3.2.2 CS 0 2.3.2.4 HPCI 0 2.3.2.5 RCIC 0 2.3.2.6 gas-handling 0 2.3.2.7 primary containment

• 2.3.3.1 SLC

• 2.3.3.2 SW

• 2.3.3.3 EDG

• 2.3.3.5 FP

• 2.3.3.7 administration building ventilation and cooling

• 2.3.3.7 drywell ventilation and cooling

• 2.3.3.7 process radiation monitors

• 2.3.3.7 reactor building ventilation

• 2.3.3.7 screenwell and water treatment ventilation and cooling

" 2.3.3.7 turbine building ventilation

" 2.3.3.8 CP, CAD, and PASS

" 2.3.3.9 FPCC

" 2.3.3.10 service, instrument, and breathing air

" 2.3.3.11 RBCLCW

" 2.3.3.12 radwaste

• 2.3.4.1 condensate

" 2.3.4.2 MS

" 2.3.4.3 feedwater 2-111

2.3.4 Steam and Power Conversion Systems LRA Section 2.3.4 identifies the steam and power conversion systems SCs subject to an AMR for license renewal.

The applicant described the supporting SCs of the steam and power conversion systems in the following LRA sections:

" 2.3.4.1 condensate

" 2.3.4.2 main steam

" 2.3.4.3 feedwater The staff's findings on review of LRA Sections 2.3.4.1 - 2.3.4.3 are in SER Sections 2.3.4.1 -

2.3.4.3, respectively.

2.3.4.1 Condensate 2.3.4.1.1 Summary of Technical Information in the Application LRA Section 2.3.4.1 describes the condensate system, which heats and supplies feedwater to the reactor. The condensate tanks supply water to the HPCI and RCIC systems. The condensate system includes main condensers, condensate pumps, condensate demineralizers, condensate booster pumps, feedwater heaters, CSTs, and condensate transfer pumps.

Condensate demineralizers maintain the required purity of feedwater to the reactor by removing suspended and dissolved solids and fission, activation, and corrosion products The full-flow, deep bed condensate demineralizer system consists of eight (one spare) mixed-bed ion exchangers and an external chemical regeneration facility. The CSTs receive system reject flow and provide condensate for any continuous or intermittent batch-type services, including plant system makeup and suppression pool makeup. Two condensate transfer pumps supply condensate to various loads, for which suction connections above the HPCI and RCIC suctions to the CSTs provide a 100,000-gallon reserve in each tank for the ECCS. The lower half of each tank is below ground level for tornado and SEISMIC protection of the 100,000-gallon reserve storage capacity. The condensate tanks are the preferred supply of water to the HPCI and RCIC systems while torus water storage provides a safety-related backup water supply.

The condensate has safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related condensate SSCs potentially could prevent the satisfactory accomplishment of a safety-related function. In addition, the condensate system performs functions that support fire protection and SBO.

LRA Tables 2.3.4-1 and 2.3.3-14-19 identify the following condensate system component types within the scope of license renewal and subject to an AMR:

" bolting

" flow element

" heat exchanger (shell)

• orifice

• piping 2-112

• .pump casing

• screen

• strainer housing

• tank

• thermowell

• tubing

• valve body The condensate system component intended functions within the scope of license renewal include:

" filtration

" pressure boundary 2.3.4.1.2 Staff Evaluation The staff reviewed LRA Sections 2.3.3.14 and 2.3.4.1 and UFSAR Sections 10.3, 10.7, 10.8, and 10.9 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.

In conducting its Tier-2 review fo the BOP two-tier review process, the staff evaluated the system functions described in the LRA and UFSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).

The staff's review of LRA Sections 2.3.3.2 and 2.3.3.14 found areas in which additional information was necessary to complete the review of the applicant's scoping and screening results. The applicant responded to the staff's RAIs as follows.

In RAI 2.3.4.1-1 dated January 19, 2007, the staff noted that two condensate storage tanks were the preferred source of water to the HPCI and RCIC systems during postulated small pipe breaks. Each tank must have a reserve storage capacity of 100,000 gallons and be capable of isolation from other systems. The tanks are designed for the required flow even if their portions above ground are destroyed by tornado or earthquake. License renewal drawing LRA-FM-33-D indicates the nozzle penetration at the storage tanks as the license renewal boundary for system piping other than HPCI and RCIC with a possibility of a tank leak not capable of isolation. The staff requested pursuant to 10 CFR 54.4(a) additional information on why the piping from nozzle penetrations to the nearest isolation valves is not within the scope for license renewal and justification for the boundary locations.

In its response dated February 14, 2007, the applicant stated that the schematic license renewal drawing LRA-FM-33-D does not show actual nozzle locations. The tank nozzles in question (N-2, N-3, N-1 1, N-7, N-9, N-8, C-3, N-5, N-1 0, and C-2 on tank TK-1 2A and N-2, N-3, N-1 1, N-7, N-9, N-8, C-3, N-5, N-1 0, and C-2 on tank TK-1 2B) are located in the upper half of the tank (above the required reserve supply) and their failure would not impact condensate storage tank ability to perform the intended function. Therefore, the nozzles, valves, and piping 2-113

in question are not subject to an AMR.

Based on its review, the staff finds the applicant's response to RAI 2.3.4.1-1 acceptable because it confirmed that failure of these components will not prevent the tanks from retaining the required minimum storage capacity of 100,000 gallons. Therefore, the staff's concern described in RAI 2.3.4.1-1 is resolved.

In RAI 2.3.4.1-2 dated January 19, 2007, the staff noted that two condensate storage tanks are the preferred sources of water to the HPCI and RCIC systems during postulated small pipe breaks. The tanks are designed for the required flow even if their portions above ground are destroyed by tornado or earthquake. License renewal drawing LRA-FM-25-A indicates the nozzle penetrations at the storage tanks as the license renewal boundaries on the crosstie line for the two tanks with the possibility of a tank leak not capable of isolation. The staff requested pursuant to 10 CFR 54.4(a) additional information on why the piping from N-1 to valve 02A on condensate storage tank A and piping from N-1 to valve 02B on condensate storage tank B are not within the scope of license renewal and justification for the boundary locations.

In its response dated February 14, 2007, the applicant stated that these nozzles (nozzle N-1 on CST A and CST B) are located well above the tank portion required to maintain the minimum volume for supply to the HPCI and RCIC pumps. Therefore, pressure boundary integrity of these lines is not required and they are not subject to an AMR.

Based on its review, the staff finds the applicant's response to RAI 2.3.4.1-2 acceptable because it confirmed that failure of these components will not prevent the tanks from retaining the required minimum storage capacity of 100,000 gallons. Therefore, the staff's concern described in RAI 2.3.4.1-2 is resolved.

2.3.4.1.3 Conclusion The staff reviewed the LRA, scoping boundary drawings, the response to the requested inspection item, and RAI responses to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staff's review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the condensate system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).

2.3.4.2 Main Steam 2.3.4.2.1 Summary of Technical Information in the Application LRA Section 2.3.4.2 describes the MS system, which carries steam from the reactor vessel through the primary containment to the MS turbine and supplies steam to the HPCl and RCIC turbines when required. The MS leak collection system collects and processes leakage across the seats of the MS isolation valves and stem packing leakage from the MS isolation valves outside containment following a design-basis LOCA. The MS leak collection system monitors and routes the non-condensables of the packing gland leak-off of outboard MS isolation valves 2-114

to the SGT system, which processes effluent of the MS leak collection system and exhausts it through the stack.

The MS system has safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related MS SSCs potentially could prevent the satisfactory accomplishment of a safety-related function. In addition, the MS system performs functions that support fire protection and SBO.

The MS system component types within the scope of license renewal and subject to an AMR are included in LRA Sections 2.3.3.10, 2.3.2.6, 2.3.1, and 2.3.3.14. LRA Table 2.3.3-14-16 identifies the following MS system nonsafety-related component types within the scope of license renewal and subject to an AMR:

" bolting

• piping

• strainer housing

" thermowell

" tubing

" valve body The MS system nonsafety-related component intended function within the scope of license renewal is to provide a pressure boundary.

2.3.4.2.2 Staff Evaluation The staff reviewed LRA Sections 2.3.3.14 and 2.3.4.2 and UFSAR Sections 4.6, 4.11, 6.4.1, 9.19, and 10.5 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.

In conducting its Tier-2 review for the BOP two-tier review process, the staff evaluated the system functions described in the LRA and UFSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).

The staff's review of LRA Section 2.3.4.2.2 found an area in which additional information was necessary to complete the review of the applicant's scoping and screening results. The applicant responded to the staff's RAI as follows.

In RAI 2.3.4-1 dated April 25, 2007, the staff requested additional information on the scoping and screening of the MS and the feedwater systems. LRA Section 2.3.4.2.2 does not indicate clearly the specific MS components within the scope of license renewal but indicates that system components were included in the scoping of systems addressed in other LRA sections.

The staff asked which MS components were within the scope of license renewal and where in the LRA they were evaluated.

In its response dated May 17, 2007, the applicant indicated the MS components within the scope of license renewal, the class 1 MS components evaluated with the RCS, the MSLCS 2-115

components with the SGT system, and the MSIV accumulators with the instrument air system.

The applicant also indicated that all of the system components inside the primary containment, reactor building, and turbine building except for areas below elevation 260 or on elevation 260 outside coordinates 260-8D throughl3G were within the 10 CFR 54.4(a)(2) scope of license renewal. Components in turbine building areas below elevation 260 or on elevation 260 outside coordinates 260-8D throughl3G were excluded because there are no safety-related components.

Based on its review, the staff finds the applicant's response to RAI 2.3.4-1 acceptable because it specified the MS system portions within the 10 CFR 54.4(a)(2) scope of license renewal and adequately justified the excluded components. The staff's concern described in RAI 2.3.4-1 is resolved.

2.3.4.2.3 Conclusion The staff reviewed the LRA, the response to the requested inspection item, and scoping boundary drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staffs review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the MS system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).

2.3.4.3 Feedwater 2.3.4.3.1 Summary of Technical Information in the Application LRA Section 2.3.4.3 describes the feedwater system, which heats and supplies feedwater to the reactor. The feedwater system includes the zinc injection system, which through addition of small amounts of ionic zinc reduces hot spots and post-shutdown radiation levels in the reactor coolant system due to reduced cobalt activation. The system consists of skid-mounted injection equipment connected to the reactor feedwater pump piping by a bypass recirculation loop around the feedwater pumps.

The feedwater system has safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related feedwater SSCs potentially could prevent the satisfactory accomplishment of a safety-related function.

The feedwater system component types within the scope of license renewal and subject to an AMR are included in LRA Sections 2.3.1 and 2.3.3.14. LRA Table 2.3.3-14-20 identifies the following feedwater system nonsafety-related component types within the scope of license renewal and subject to an AMR:

• bolting

• orifice

• piping

• thermowell 2-116

" tubing

• valve body The feedwater system nonsafety-related component intended function within the scope of license renewal is to provide a pressure boundary.

2.3.4.3.2 Staff Evaluation The staff reviewed LRA Sections 2.3.3.14 and 2.3.4.3 and UFSAR Sections 9.21 and 10.8 using the evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.

In conducting its Tier-2 review fo the BOP two-tier review process, the staff evaluated the system functions described in the LRA and UFSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).

The staffs review of LRA Section 2.3.4.2.2 found an area in which additional information was necessary to complete the review of the applicant's scoping and screening results. The applicant responded to staff's RAI as follows.

In RAI 2.3.4-1 dated April 25, 2007, the staff requested additional information on the scoping and screening of the MS and the feedwater systems. LRA Section 2.3.4.2.2 does not indicate clearly the specific MS components within the scope of license renewal but indicates that system components were included in the scoping of systems addressed in other LRA sections.

The staff asked which MS components were within the scope of license renewal and where in the LRA they were evaluated.

In its response dated May 17, 2007, the applicant explained that indicated the feedwater system components within the 10 CFR 54.4(a)(1) or 10 CFR 54.4(a)(3) scope of license renewal are shown on license renewal drawing LRA-FM-34A, and prefixed with "34" or "FWS," designations for the feedwater system. The applicant indicated that the components highlighted were evaluated in the RCS section. The applicant also indicated that the system components in the turbine building, except for areas below elevation 260 or on elevation 260 outside coordinates 260-8D throughl3G, were within the 10 CFR 54.4(a)(2) scope of license renewal. Components in turbine building areas below elevation 260 or on elevation 260 outside coordinates 260-8D throughl3G were excluded because there are no safety-related components in these areas.

Based on its review, the staff finds the applicants response to RAI 2.3.4-1 acceptable because it specified the feedwater system portions within the 10 CFR 54.4(a)(2) scope of license renewal and adequately justified the excluded components. The staff's concern described in RAI 2.3.4-1 is resolved.

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2.3.4.3.3 Conclusion The staff reviewed the LRA, the response to the requested inspection item, and scoping boundary drawings to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staff's review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the feedwater system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).

2.4 Scoping and Screening Results: Structures

This section documents the staffs review of the applicant's scoping and screening results for structures. Specifically, this section discusses:

• reactor building and primary containment

" water control structures

" turbine building complex and yard structures

• • . bulk commodities In accordance with the requirements of 10 CFR 54.21(a)(1), the applicant must list passive, long-lived SCs within the scope of license renewal and subject to an AMR. To verify that the applicant properly implemented its methodology, the staff's review focused on the implementation results. This focus allowed the staff to confirm that there were no omissions of structures and components that meet the scoping criteria and are subject to an AMR.

The staff's evaluation of the information in the LRA was the same for all structures. The objective was to determine whether the applicant has identified, in accordance with 10 CFR 54.4, components and supporting structures for structures that appear to meet the license renewal scoping criteria. Similarly, the staff evaluated the applicant's screening results to verify that all passive, long-lived components were subject to an AMR in accordance with 10 CFR 54.21(a)(1).

In its scoping evaluation, the staff reviewed the applicable LRA sections and component drawings, focusing on components that have not been identified as within the scope of license renewal. The staff reviewed relevant licensing basis documents, including the UFSAR, for each structure to determine whether the applicant has omitted from the scope of license renewal components with intended functions delineated under 10 CFR 54.4(a). The staff also reviewed the licensing basis documents to determine whether the LRA specified all intended functions delineated under 10 CFR 54.4(a). The staff requested additional information to resolve any omissions or discrepancies identified.

After its review of the scoping results, the staff evaluated the applicant's screening results. For those SCs with intended functions, the staff sought to determine whether (1) the functions are performed with moving parts or a change in configuration or properties or (2) the SOs are subject to replacement after a qualified life or specified time period, as described in 10 CFR 54.21(a)(1). For those meeting neither of these criteria, the staff sought to confirm that 2-118

these SCs were subject to an AMR, as required by 10 CFR 54.21(a)(1). The staff requested additional information to resolve any omissions or discrepancies identified.

2.4.1 Reactor Building and Primary Containment 2.4.1.1 Summary of Technical Information in the Application LRA Section 2.4.1 describes the reactor building and primary containment. The reactor building totally encloses the primary containment, the refueling and reactor servicing areas, the new and spent fuel storage facilities, and other reactor auxiliary systems. It serves as a containment during reactor refueling and maintenance operations when the primary containment is open and as an additional barrier when the primary containment is functional.

The reactor building structure is SEISMIC Class I, constructed of monolithic reinforced concrete floors and walls to the refueling level. A reinforced concrete mat placed in an excavation cut out of bedrock supports the reactor building structure and prevents settlement. The reactor building structural steel includes floor framing for platforms inside the drywell and suppression chamber.

The primary containment limits the release of fission products in a postulated DBA so that offsite doses do not exceed 10 CFR Part 100 guideline values. The primary containment is a Mark I low-leakage pressure suppression containment housing the reactor vessel, the reactor recirculation loops, and other branch connections of the reactor coolant system. Major components of primary containment include a drywell, a pressure suppression chamber, and the connecting vent system between the drywell and torus. The drywell surrounds the reactor vessel, connects to the reactor building along its lower portion, and is laterally supported by the building along its upper portion. The primary containment consists of the drywell, torus, inner refueling bellows, and primary shield wall.

The drywell is a carbon steel structure enclosed in reinforced concrete for shielding. It houses the reactor vessel and its components. The torus is a carbon steel pressure vessel anchored to and supported by the reinforced concrete foundation slab of the reactor building. The inner refueling bellows seal between the reactor vessel flange and the surrounding drywell permits flooding of the space above the vessel during refueling. The refueling bellows consists of a stainless steel bellows, backing plates, a spring seal, and removable guard rings. The primary shield wall is a high-density concrete cylinder surrounding the vessel to attenuate neutron and gamma radiation from the reactor, to allow access and maintenance of the drywell, and to limit damage from radiation exposure to area components.

The reactor building and the primary containment have safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related reactor building and primary containment SSCs potentially could prevent the satisfactory accomplishment of a safety-related function. In addition, the reactor building and the primary containment perform functions that support fire protection and SBO.

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LRA Table 2.4-1 identifies the following reactor building and primary containment component types within the scope of license renewal and subject to an AMR:

• steel

• other metals

" concrete The reactor building and primary containment component intended functions within the scope of license renewal include:

" shelter or protection to safety-related equipment, including radiation shielding and pipe whip restraint

" rated fire barrier to confine or retard a fire from spreading

" protective barrier for flood events

" heat sink during SBO or DBA

" missile barrier

" pressure boundary

" structural or functional support to nonsafety-related equipment whose failure could impact safety-related equipment

" structural or functional support for safety-related equipment 2.4.1.2 Staff Evaluation The staff reviewed LRA Section 2.4.1 and UFSAR Sections 5.1.2, 5.1.3, 5.2, 5.3, 12.3.1, and 12.4.5. using the evaluation methodology described in SER Section 2.4 and the guidance in SRP-LR Section 2.4, "Scoping and Screening Results: Structures."

During its review, the staff evaluated the structural component functions described in the LRA and UFSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).

The staff's review of LRA Section 2.4.1 found areas in which additional information was necessary to complete the evaluation of the applicant's scoping and screening results. The applicant responded to the staff's RAIs as follows.

LRA Section 2.4-1, "Reactor Building and Primary Containment," under Inner Refueling Bellows and Bulkhead Assembly does not state the makeup of the bulkhead assembly clearly. In RAI 2.4.1-1 dated November 29, 2006, the staff requested a list of bulkhead assembly components within the scope of license renewal and a drawing of the bulkhead assembly.

In its response dated December 28, 2006, the applicant stated that bulkhead assembly components are not within the scope of license renewal. They are nonsafety-related and are 2-120

not required to demonstrate compliance with 10 CFR 54.4(a)(3). The applicant indicated that LRA Table 3.5.2-1, page 3.5-58 line item "inner refueling bellows" and the corresponding LRA Table 2.4-1, page 2.4-20 line item were included inadvertently. The cited GALL Report line item (C-20) is for bellows for vent pipe downcomer parts of the primary containment pressure boundary. The inner refueling bellows is not a containment pressure boundary component.

Failure of these bellows or the assembly will not prevent satisfactory accomplishment of a safety function. Leakage, if any, through the bellows is directed to a drain system in the lower drywell, and thus will stay in the drywell.

Based on its review, the staff finds the applicant's response to RAI 2.4.1-1 acceptable. The staff's concern described in RAI 2.4.1-1 is resolved.

LRA Table 2.4-1 does not include drywell head closure bolts and double-gasketed drywell heads. These components have the intended function of the drywell pressure boundary. In RAI 2.4.1-2 dated November 29, 2006, the staff requested justification for their exclusion from the scope of license renewal.

In its response dated December 28, 2006, the applicant stated that the drywell head closure bolts are included in item ASME Classes 1, 2, 3 and MC supports bolting in LRA Table 2.4-4.

The drywell head gasket is within the scope of license renewal but replaced every time the head is removed on a specified frequency and, therefore, not subject to an AMR.

Based on its review, the staff found the applicant's response unacceptable and requested a clear description of the bolts in Table 2.4-4 because they have the important function to maintain the drywell pressure boundary.

In a supplemental response dated April 24, 2007, the applicant included the drywell head closure bolts in LRA Table 2.4-1, revised the LRA Table 2.4-1, page 2.4-19, item, "Drywell head manway cover," to read "Drywell head manway cover and drywell head closure bolts," and revised the LRA Table 3.5.2-1, page 3.5-56 item, "Drywell head manway cover," to read "Drywell head manway cover and drywell head closure bolts."

Based on its review, the staff finds the applicant's response to RAI 2.4.1-2 acceptable. The staff's concern described in RAI 2.4.1-2 is resolved.

In RAI 2.4.1-3 dated November 29, 2006, the staff stated that LRA Table 2.4-1 does not show refueling cavity seal components within the scope of license renewal. Proposed license renewal interim staff guidance LR-ISG-2006-01, "Plant Specific Aging Management Program for inaccessible Areas of Boiling Water Reactor Mark 1 Steel Containment Drywell Shell," .

published in the FederalRegister on May 9, 2006, states that the most likely cause of corrosion of the drywell shell in the sand-pocket areas (near the bottom of the drywell) and in the spherical portion of the drywell at higher elevations is water in the gap between the drywell and the concrete shield. The water source was leakage through the seal between the drywell and the refueling cavity and through the cracked stainless steel liner of the refueling cavity wall.

Therefore, the staff asked the applicant to include all the refueling cavity seal components within the scope of license renewal and to provide a drawing that depicts the refueling cavity seal components.

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In its response dated December 28, 2006, the applicant stated that the proposed license renewal interim staff guidance LR-ISG-2006-01 states that, if moisture is detected or suspected in the inaccessible area on the exterior of the drywell shell, any component source of moisture (e.g., the refueling seal) should be included within the scope of license renewal subject to an AMR. There has been no detected leakage causing moisture in the vicinity of the sand cushion and none has been detected or suspected on the inaccessible areas of the drywell shell.

Therefore, consistent with the interim staff guidance, the refueling seal is not subject to an AMR.

The applicant's letter attached drawings depicting the refueling cavity seal components.

By letter dated April 2, 2007, the staff requested the applicant's response to the following specific questions:

(1) Is the refueling drain/seal pipe obstruction-free?

(2) What maintenance activities or administrative procedures are in place for the drain in the trough area?

(3) What is the condition of the stainless steel liner of the refueling cavity walls ?

In its response dated April 24, 2007, the applicant stated that the outer refueling bellows drains prevent refueling cavity leakage from entering the annulus air gap above the sand cushion. The outer refueling bellows drain lines were inspected prior to start-up from the 1988 refuel outage.

Five of the six refueling bellows leakage drain lines inspected through inspection ports were found to contain minor accumulation of debris including pieces of weld rod, indicating that it had been introduced during construction. The amount of debris did not affect the ability of the drain lines to perform their function. The applicant vacuumed and reinspected the lines and determined them to be clear and functional as designed. An inspection port could not be installed in the sixth line because of the piping configuration and the limited space available for access.

The applicant explained that the bellows assembly seals the trough area where the drain lines originate, preventing ingress of debris that could obstruct the lines. The only access to the area for the 1988 inspections was through the drain lines with a boroscope. This design and the redundancy in the number of drain lines make periodic inspections for whether the refueling bellows drain piping is free of obstructions unwarranted. Leakage through the outer refueling bellows, if any, flows into a common drain line with a flow indicator/switch that signals alarm in the control room in any event of bellows leakage. A functional test of the flow switch 19FIS-62 prior to every refueling outage (two-year frequency) verifies indicator/switch and control room annunciator functions. The applicant stated that there have been no failures of this test.

The applicant also stated that there has been no indication of refueling cavity steel liner leakage, which would enter the trough area below the refueling bellows assembly and from there flow into the drain system equipped with the flow alarm. There has been no actuation of the flow alarm during refueling outages.

The applicant explained that leakage exceeding the capacity of the six drain lines (four 4-inch drain lines and two 2-inch drain lines) would enter the annulus air gap and be detected flowing from three of the four annulus air gap drains in the torus room. The applicant examined the air 2-122

gaps through the drain lines using fiber optic cables in 1988 and recently in April 2007 and has detected to date no evidence of moisture that could corrode the drywell shell. In the future, if it detects any evidence of moisture, the applicant will determine additional inspection activities as appropriate. Although no formal inspection or maintenance procedure is required for the refueling cavity liner, routine observation during refueling operations and monitoring of the refueling bellows drain system and alarm have detected no liner leakage.

Based on its review, the staff finds the applicant's response to RAI 2.4.1-3 acceptable because there have been no problems with the (1) refueling drain/seal, (2) refueling bellows, or (3) refueling pool liner. Moreover, the flow indicator switch alerts the applicant of any drain malfunction. The staff's concern described in RAI 2.4.1-3 is resolved.

In RAI 2.4.1-4 dated November 29, 2006, the staff stated that LRA Table 2.4-1 does not include the metal drywell sump screens that functionally support safety-related equipment. The staff requested justification for their exclusion from the scope of license renewal.

In its response dated December 28, 2006, as supplemented April 24, 2007, the applicant provided additional information and stated that the drywell sumps have no screens.

Based on the staff's review, the staff finds the applicant's response acceptable. The staff's concern described in RAI 2.4.1-4 is resolved.

In RAI 2.4.1-5 dated November 29, 2006, the staff stated that LRA Table 2.4-1 does not include the reinforced concrete shield plugs that shield the top of the drywell. Exclusion of the reinforced concrete shield plugs from the scope of license renewal may lead to long-term unmanaged degradation of the plugs (e.g., full sectional concrete cracking, rebar corrosion, loss of bond, partial spalling or cracking of concrete due to handling, loss of load-carrying capacity of plug attachments) with a seismic Il/I implication potentially affecting the structural, integrity of the drywell head. The staff requested justification for their exclusion from the scope of license renewal.

In its response dated December 28, 2006, the applicant stated that the reinforced shield plugs that shield the top of the drywell are in LRA Table 2.4-4, "Bulk Commodities," under the line item "Manways, hatches, and hatch covers."

The applicant's response was not acceptable to the staff. In a letter dated April 2, 2007, the staff asked the applicant to list reinforced shield plugs separately from manways and hatches in LRA Table 2.4-4.

In its response dated April 24, 2007, the applicant added concrete shield plugs as a separate line item on LRA Table 2.4-1 under the component "concrete."

Accordingly, LRA Table 3.5.2-1 was revised to add the new line item with the material grouping

concrete."

Based on its review, the staff finds the applicant's response to RAI 2.4.1-5 acceptable. The staff's concern described in RAI 2.4.1-5 is resolved.

In RAI 2.4.1-6 dated November 29, 2006, the staff stated that LRA Table 2.4-1 does not show spent fuel rack neutron-absorbing material within the scope of license renewal. Long-term 2-123

unmanaged degradation of the component may reduce the margin of nuclear sub-criticality in the fuel pool excessively. The staff requested justification for this exclusion from the scope of license renewal.

In its response dated December 28, 2006, the applicant stated that the spent fuel rack neutron-absorbing material is within the scope of license renewal, addressed in LRA Section 2.3.3.9, and listed in LRA Table 2.3.3-9 with AMR results in LRA Table 3.3.2-9.

Based on its review, the staff finds the applicant's response to RAI 2.4.1-6 acceptable. The staff's concern described in RAI 2.4.1-6 is resolved.

2.4.1.3 Conclusion The staff reviewed the LRA and related structural components to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staff's review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the reactor building and primary containment components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).

2.4.2 Water Control Structures 2.4.2.1 Summary of Technical Information in the Application LRA Section 2.4.2 describes the water control structures, which include the intake structure, the intake tunnel, the screenwell-pumphouse structure, and the discharge tunnel. The intake structure protects the inlet of the circulating water intake tunnel for a clear flow path for cooling water into the tunnel. The reinforced concrete intake structure sits on the lake bottom approximately 900 feet from the shoreline. Post-tensioned tendons anchor the main structure to the natural bedrock below the lake bottom. A fan-shaped intake constructed of precast concrete sections on the shoreward side of the main structure is anchored to the bedrock with grouted rock bolts. Bar racks at the intake area prevent entrance of large debris. The circulating water intake tunnel is the flow path for cooling water from the intake structure to the screenwell-pumphouse structure housing the condenser circulating water pumps, normal service water pumps, emergency service water pumps, residual heat removal service water pumps, fire protection system supply pumps, and water treatment tanks and equipment. The circulating water discharge tunnel is the return flowpath of cooling water from the screenwell-pumphouse to the lake. The failure of this SEISMIC Class II structure could impact the proper operation of the emergency service water system.

The water control structures have safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related water control structure SSCs potentially could prevent the satisfactory accomplishment of a safety-related function. In addition, the water control structures perform functions that support fire protection.

LRA Table 2.4-2 identifies the following water control structure component types within the 2-124

scope of license renewal and subject to an AMR:

• steel

• other metals

• concrete The water control structure component intended functions within the scope of license renewal include:

shelter or protection to safety-related equipment, including radiation shielding and pipe whip restraint

• rated fire barrier to confine or retard a fire from spreading

• protective barrier for flood events

• heat sink during SBO or DBA

• missile barrier

• structural or functional support to nonsafety-related equipment the failure of which could impact safety-related equipment

• structural or functional support for fire protection, EQ, PTS, ATWS, or SBO

• structural or functional support for safety-related equipment 2.4.2.2 Staff Evaluation The staff reviewed LRA Section 2.4.2 and UFSAR Sections 12.2.2, 12.3.6, and 12.3.7 using the evaluation methodology described in SER Section 2.4 and the guidance in SRP-LR Section 2.4.

During its review, the staff evaluated the structural component functions described in the LRA and UFSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).

The staff's review of LRA Section 2.4.2 found areas in which additional information was necessary to complete the review of the applicant's scoping and screening results. The applicant responded to the staff's RAIs as follows.

In RAI 2.4.2-1 dated November 29, 2006, the staff noted that LRA Section 2.4-2 under "Discharge Tunnel" states that "failure of this Class IIstructure could impact the proper operation of the emergency service water system." The staff requested additional information about the potential consequences of a screenwell-pumphouse (Class IIstructure) failure.

Specifically, the staff asked the applicant what appropriate measures it had taken to prevent failure of this structure with adverse effects on the proper operation of the emergency SW system.

In its response dated December 28, 2006, the applicant stated that the AMR produced 2-125

appropriate measures for managing the effects of aging to prevent failure of this structure with adverse effects on the proper operation of the emergency SW system. SW discharge flow is routed to the lake via the discharge tunnel. Failure of the discharge tunnel could restrict the normal SW discharge to the lake. Aging management of the screenwell-pumphouse and the discharge tunnel is part of the Structures Monitoring Program as specified in LRA Table 3.5.2-2.

Based on its review, the staff finds the applicant's response to RAI 2.4.2-1 acceptable because it included in the Structural Monitoring Program aging management of the screenwell-pump house and the discharge tunnel to prevent failure of these structures. The staff's concern described in RAI 2.4.2-1 is resolved.

In RAI 2.4.2-2 dated November 29, 2006, the staff noted that LRA Table 2.4-2 does not include intake structure anchors and post-tensioned tendons that anchor the main structure to the natural bedrock below the lake bottom. The staff requested justification for the exclusion of these components from the scope of license renewal and a summary of operating experience with settlement of the intake structure.

In its response dated December 28, 2006, the applicant stated that the anchorage system for the intake structure is by post-tensioned rock bolts within the scope of license renewal under anchorages/embedments in LRA Section 2.4.4. The applicant also stated that operating experience indicated no settlement of the intake structure or degradation of the rock anchor system (Reference JAF-RPT-05-LRD05).

Based on its review, the staff finds the applicant's response to RAI 2.4.2-2 acceptable as the post-tension bolts are in the AMP and that its operating experience indicated no intake structure settlement or rock anchor system degradation. The staff's concern described in RAI 2.4.2-2 is resolved.

In RAI 2.4.2-3 dated November 29, 2006, the staff stated that LRA Table 2.4-2 lists "Beams, columns, floor slabs, and walls" as a component and "Exterior walls" as another. The staff requested the applicant to clarify by listing all structural members under each component.

In its response dated December 28, 2006, the applicant stated that, "Beams, columns, floor slabs and walls," are defined as substructure or superstructure concrete parts of the primary structural support function of a building or structure (e.g., structural columns, support girders, and beams) and "exterior walls" as walls that form the perimeter base of a structure with their primary surface or both surfaces exposed to an outdoor or soil environment (i.e., exposed to weather).

Based on its review, the staff finds the applicant's response to RAI 2.4.2-3 acceptable because it adequately clarified the component groups. The staff's concern described in RAI 2.4.2-3 is resolved.

2.4.2.3 Conclusion The staff reviewed the LRA and related structural components to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staff's review determined whether the applicant failed to identify any 2-126

components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the water control structures components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).

2.4.3 Turbine Building Complex and Yard Structures 2.4.3.1 Summary of Technical Information in the Application LRA Section 2.4.3 describes the turbine building complex and yard structures:

" administration and control room building

" CST foundation and retaining wall

" electric bay

" EDG building

• main stack

" manholes and duct banks

" nitrogen building

" radioactive waste building

" security building

" SGT building

" transformer/switchyard support structures

" transmission tower and foundation

" turbine building including feedwater heater bay The administration and control room building housing the offices and work areas of the plant operating personnel is situated between the reactor building and turbine building. This structure consists of the control room for operating all facilities of the plant, the relay room, cable spreading room, battery rooms, and control and relay room HVAC room.

The CST foundation and retaining wall support and protect the CSTs and their equipment. The two CSTs rest on reinforced concrete foundations. The lower half of each stainless steel tank is below ground level for tornado and SEISMIC protection from collapse of the surrounding soil by a circular, reinforced concrete retaining wall. A reinforced concrete shield wall borders the CST area to the north, west, and south of the tanks, shielding and protecting personnel protection from radiation.

The electric bay housing various motor-generator sets and both 4160 V and 600 V switchgear is part of the turbine building. The east and west cable tunnels under the electric bays separate routing for redundant electrical and control services. The electric bays and cable tunnels are SEISMIC Class I reinforced concrete structures with a reinforced concrete roof supported on structural steel framing. The roof and exterior walls protect the interior equipment from tornado damage.

The diesel generator building housing four EDGs is a one-story reinforced concrete structure with a concrete roof supported by steel. The four EDG foundations are of reinforced concrete isolated from the remainder of the structure. Concrete or reinforced concrete block walls separate each diesel generator unit from the adjacent unit. Building construction is to SEISMIC 2-127

Class I and tornado protection design criteria. Each diesel generator unit has its own independent fuel oil system consisting of a main fuel storage tank, a day tank, and pumps. The main tanks are buried below the subgrade and anchored to the rock foundation.

The main stack is an unlined, free-standing, SEISMIC Class I reinforced concrete structure founded on a reinforced concrete mat anchored to bedrock with grouted reinforcing rods. The stack sits on a circular filter room of reinforced concrete that houses dilution fans, off-gas filters, and monitoring equipment.

Manholes and duct banks for underground routing of cables and piping are structural components of concrete or reinforced concrete construction.

The nitrogen building housing containment air dilution equipment including liquid nitrogen storage tanks is at the south end of the reactor building with north and east side walls- and floor constructed of reinforced concrete. The remaining walls are steel frame with metal siding. The roof is constructed of metal decking, insulation, and built-up roofing.

The SEISMIC Class II radioactive waste building is located east of the water treating building and houses the equipment to handle liquid and solid radioactive wastes from the reactor building and turbine building equipment.

The security building houses the security generator credited as a source of backup power to the security lighting system, including the perimeter fence lighting, which illuminates exterior access and egress in a fire with loss of 115KV offsite power.

The SGT building is a poured-in-place reinforced concrete structure adjacent to the reactor building southeast corner. All construction joints below grade have preformed water stops for water-tightness and vertical joints above grade for airtightness. The roof is constructed of reinforced concrete.

The transformer/switchyard support structures physically support the reserve service transformers T2 or T3 and the other switchyard components in the SBO recovery path. These support structures include the transformer foundations, transformer pothead foundations and support steel, and foundations for the switchyard breakers.

The transmission towers physically support the transmission lines in the SBO recovery path.

The transmission tower structures are the tower foundations and tower steel. The SEISMIC Class II transmission tower is of galvanized steel construction on a reinforced concrete foundation.

The turbine building and heater bay house the main turbine generator, condensate/feedwater system, and other plant auxiliary systems. The building is a reinforced concrete structure with concrete floors supported by structural steel. The superstructure housing the turbine building crane is a structural steel frame covered with insulated metal siding and a metal roof deck with insulation and built-up roofing. The interior walls of the turbine building are reinforced concrete or concrete block designed to shield plant personnel and equipment from radiation and protect them from fire. The SEISMIC Class II heater bay housing the feedwater heaters as part of the turbine building is constructed of reinforced concrete below ground level with concrete and grating floors supported by structural steel. The superstructure of one exterior wall and roof has 2-128

a structural steel frame. The exposed wall is insulated metal siding and the roof is of metal deck construction with insulation and built-up roofing except directly over the heaters where it is of reinforced concrete for radiation protection.

The turbine building complex and yard structures have safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related turbine building complex and yard structure SSCs potentially could prevent the satisfactory accomplishment of a safety-related function. In addition, the turbine building complex and yard structures perform functions that support fire protection and SBO.

LRA Table 2.4-3 identifies the following turbine building complex and yard structure component types within the scope of license renewal and subject to an AMR:

• steel

" other metals

" concrete The turbine building complex and yard structure component intended functions within the scope of license renewal include:

shelter or protection to safety-related equipment, including radiation shielding and pipe whip restraint

• rated fire barrier to confine or retard a fire from spreading

• missile barrier

• pressure boundary

• structural or functional support to nonsafety-related equipment the failure of which could impact safety-related equipment

• structural or functional support for fire protection, EQ, PTS, ATWS, or SBO

• structural or functional support for safety-related equipment 2.4.3.2 Staff Evaluation The staff reviewed LRA Section 2.4.3 and UFSAR Sections 5.2.3.8.6, 8.4, 8.5, 10.9.3, 12.2.2, 12.3.1, 12.3.2, 12.3.3, 12.3.4, 12.3.5, 12.3.9, and 12.3.12, and using the evaluation methodology described in SER Section 2.4 and the guidance in SRP-LR Section 2.4.

During its review, the staff evaluated the structural component functions described in the LRA and UFSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).

The staff's review of LRA Section 2.4.3 found areas in which additional information was necessary to complete the review of the applicant's scoping and screening results. The applicant responded to the staff's RAls as follows.

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In RAI 2.4.3-1 dated November 29, 2006, the staff noted that UFSAR Section 12.3.9 states, "The stack is not specifically designed to resist a tornado." The staff needed additional information about the potential interaction between seismic Class II SSCs and tornado-induced failure of the main stack. Specifically, the staff asked the applicant what appropriate measures it had taken to prevent interactions between the main stack and nearby seismic Class I and Class II SSCs the failure of which might have adverse effects on seismic Class I SSCs.

In its response dated December 28, 2006, the applicant confirmed that a tornado-induced failure of the main stack would not interact with nearby seismic Class II SSCs the failure of which might cause loss of seismic Class I SSC intended functions. As stated in LRA Section 2.4.3, the main stack is a seismic Class I reinforced concrete structure located sufficiently far from other seismic Class I structures to preclude interaction, including that caused by interaction with nearby seismic Class II SSCs the failure of which might have adverse effects on seismic Class I SSCs.

By letter dated April 2, 2007, the staff requested the applicant to demonstrate with a sketch showing the distance from the stack to seismic Classes I and II structures with potential tornado-induced interaction that the main stack is sufficiently far from seismic class I structures.

In its response dated April 24, 2007, the applicant stated that the main stack is designed as a seismic Class I structure but not for tornado loads. The nearest seismic Class I or II structure to the stack is the SGT room at a distance slightly less than the "topple" zone of the main stack.

Site drawings FY-12B and FY-12D (attached to the response) show the main stack and reactor track bay (which contains the SGT room). Calculation JAF-CALC-BYM-04122 confirmed a crushing and "breaking" main stack failure mode at a location above the base. The calculation conclusion states that interaction of a main stack failure with the SGT room is unlikely. For license renewal, the main stack is within the scope of license renewal and subject to an AMR.

the Structures Monitoring Program manages the effects of aging on the main stack.

Based on its review, the staff finds the applicant's response to RAI 2.4.3-1 acceptable because, after examining the locations of the nearby structures and components, the applicant concluded that interaction of a main stack failure with seismic Class I or II structures is unlikely. The staff agrees with the applicant's conclusion. The staff's concern described in RAI 2.4.3-1 is resolved.

In RAI 2.4.3-2 dated November 29, 2006, the staff noted that LRA Section 2.4-3 states that, "The main steam lines to the turbine generator from the reactor are housed in a reinforced concrete tunnel that enters the turbine building after passing under the adjacent administration building." The staff needed additional information about the potential interaction between the administration building and any failure of main steam lines. Specifically, the staff asked the applicant what appropriate measures it had taken to prevent failure of the MS lines with adverse effect on the administration building.

In its response dated December 28, 2006, the applicant stated that LRA Section 2.3.4.2 addresses and LRA Table 3.3.2-14-16 lists the MS lines. Appropriate measures (AMPs) are in place to manage the effects of aging and to prevent MS line failure and the potential effect on the administration building.

Based on its review, the staff finds the applicant's response to RAI 2.4.3-2 acceptable. The staff's concern described in RAI 2.4.3-2 is resolved.

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In RAI 2.4.3-3 dated November 29, 2006, the staff noted that LRA Table 2.4-3 lists "Exterior walls" as a component. The staff could not determine whether this component included the main stack, MS line tunnel, and electric bay tunnel. The staff asked the applicant to include these components within the scope of license renewal.

In its response dated December 28, 2006, the applicant stated that exterior walls are defined as walls that form the perimeter base of a structure with their primary surface or both surfaces exposed to an outdoor or soil environment (i.e., exposed to weather). This definition would include the exterior walls of those structures listed.

Based on its review, the staff finds the applicant's response to RAI 2.4.3-3 acceptable. The staff's concern described in RAI 2.4.3-3 is resolved.

In RAI 2.4.3-4 dated November 29, 2006, the staff noted that LRA Table 2.4-3 does not include sumps that functionally support safety-related and nonsafety-related equipment. The staff requested justification for their exclusion from the scope of license renewal.

In its response dated December 28, 2006, the applicant stated that the in-scope unlined sumps in the east cable tunnel are parts of the concrete floor structure. There are no other sumps in the turbine building complex and yard structures that functionally support safety-related and nonsafety-related equipment. LRA Section 2.3.3.12 addresses turbine building equipment drain tanks within the scope of license renewal.

Based on its review, the staff finds the applicant's response to RAI 2.4.3-4 acceptable. The staffs concern described in RAI 2.4.3-4 is resolved.

2.4.3.3 Conclusion The staff reviewed the LRA and related structural components to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staff s review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the turbine building complex and yard structures components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).

2.4.4 Bulk Commodities 2.4.4.1 Summary of Technical Information in the Application LRA Section 2.4.4 describes the bulk commodities, which are structural components or commodities that perform or support intended functions of in-scope SSCs.

Bulk commodities have safety-related components relied upon to remain functional during and following DBEs. The failure of nonsafety-related bulk commodity SSCs potentially could prevent the satisfactory accomplishment of a safety-related function. In addition, the bulk commodities 2-131

perform functions that support fire protection.

LRA Table 2.4-4 identifies the following bulk commodity component types within the scope of license renewal and subject to an AMR:

• steel and other metals

• bolted connections

• concrete

• other materials The bulk commodities component intended functions within the scope of license renewal include:

" shelter or protection to safety-related equipment, including radiation shielding and pipe whip restraint

" rated fire barrier to confine or retard a fire from spreading

" protective barrier for flood events

" insulation

• missile barrier

• pressure boundary

• structural or functional support to nonsafety-related equipment whose failure could impact safety-related equipment

" structural or functional support for fire protection, EQ, PTS, ATWS, or SBO

• structural or functional support for safety-related equipment 2.4.4.2 Staff Evaluation The staff reviewed LRA Section 2.4.4 using the evaluation methodology described in SER Section 2.4 and the guidance in SRP-LR Section 2.4.

During its review, the staff evaluated the structural component functions described in the LRA and UFSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).

In RAI 2.4.4-1 dated November 29, 2006, the staff noted that LRA Table 2.4-4 lists bulk commodities. The location of each component was unclear to the staff. The staff requested a description of all listed commodities as well as a comprehensive listing of components, component supports, and locations for each commodity.

In its response dated December 28, 2006, the applicant explained that, as stated in LRA Section 2.4.4, LRA Table 2.4-4 lists the bulk commodities common to in-scope structures.

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Commodities unique to any specific structure are included in the review for that structure (LRA Sections 2.4.1 through 2.4.3). The commodities listed in LRA Table 2.4-4 are within the scope of license renewal and subject to an AMR regardless of the in-scope structure in which located.

Components classified as bulk commodities typically have no unique component identification numbers. Therefore, a comprehensive listing of components and locations is not feasible.

Based on its review, the staff finds the applicant's response to RAI 2.4.4-1 acceptable because the staff agrees with the applicant's reasons for not listing bulk commodities. The staff's concern described in RAI 2.4.4-1 is resolved.

In RAI 2.4.4-2 dated November 29, 2006, the staff noted that LRA Table 2.4-4 lists "insulation" with intended functions. It was unclear to the staff why "Support for Criterion (a)(1) equipment" was not an intended function when the LRA Table 2.0-1 definition of the intended function of "insulation" meant to apply to safety-related and nonsafety-related components is "provide insulating characteristics to reduce heat transfer." The staff requested additional information on insulation and a list of in-scope components with insulation included with their intended functions.

In its response dated December 28, 2006, the applicant stated that LRA Table 2.4-4 lists two functions for insulation. LRA Table 2.0-1 defines the first, "Insulation," as, "Provide insulating characteristics to reduce heat transfer." This function applies to safety-related and nonsafety-related components. LRA Table 2.0-1 defines the second function, "Support for Criterion (a)(2) equipment," as, "Provide structural or functional support to nonsafety-related equipment whose failure could impact safety-related equipment." This definition means nonsafety-related insulation must maintain integrity so falling insulation does not damage safety-related equipment. Therefore, "Support for Criterion (a)(1) equipment" need not be listed as a separate intended function for insulation.

The applicant also stated that examples of in-scope components with insulation addressed by this LRA Table 2.4-4 line item are the recirculation system piping, valves, and pump casings and MS SRVs. The applicant evaluated insulation as a commodity because development of a list of individual components insulated was not practical. Therefore, a list of insulated components is not available.

Based on its review, the staff finds the applicant's response to RAI 2.4.4-2 acceptable because it explained the intended functions of the insulation and clarified component insulation included within the scope of the license renewal. The staff's concern described in RAI 2.4.4-2 is resolved.

In RAI 2.4.4-3 dated November 29, 2006, the staff stated that LRA Section 2.4.4 includes review of bulk commodities such as structural components or commodities that support intended functions of in-scope SSCs. It is not clear from the review of LRA Tables 2.4-4, "Bulk Commodities Summary of Components Subject to Aging Management Review," and 3.5.2-4, "Bulk Commodities Summary of Aging Management Evaluation," that the structural fire barriers (walls, ceilings, floors, and slabs) are within the scope of license renewal in accordance with 10 CFR 54.4(a) and subject to an AMR in accordance with 10 CFR 54.21(a)(1). If these structural fire barriers are excluded from the scope of license renewal and not subject to an AMR, the staff requested that the applicant provide justification for the exclusion.

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In its response dated December 28, 2007, the applicant stated that the structural fire barriers (walls, ceilings, floors and slabs) are within the scope of license renewal and subject to an AMR. They are listed within the tables of the associated structures with an intended function "FB." The AMP for these commodities is the Fire Protection Program.

Based on its review, the staff finds the applicant's response to RAI 2.4.4-3 acceptable because structural fire barriers in question were identified to be within the scope of license renewal and subject to an AMR. The applicant stated that the structural fire barriers, i.e., walls, ceilings, floors and slabs are represented in the LRA tables of the associated structures with an intended function "FB." Therefore, the staff concludes that the structural fire barriers are correctly included within the scope of license renewal and subject to an AMR. The staff's concern described in RAI 2.4.4-1 is resolved.

2.4.4.3 Conclusion The staff reviewed the LRA and related structural components to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staff's review determined whether the applicant failed to identify any components subject to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the bulk commodities components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).

2.5 Scoping and Screening Results: Electrical and Instrumentation and Control Systems

This section documents the staffs review of the applicant's scoping and screening results for electrical and instrumentation and controls (I&C) systems.

In accordance with the requirements of 10 CFR 54.21(a)(1), the applicant must list passive, long-lived SCs within the scope of license renewal and subject to an AMR. To verify that the applicant properly implemented its methodology, the staff's review focused on the implementation results. This focus allowed the staff to confirm that there were no omissions of electrical and I&C system components that meet the scoping criteria and are subject to an AMR.

The staff's evaluation of the information in the LRA was the same for all electrical and I&C systems. The objective was to determine whether the applicant has identified, in accordance with 10 CFR 54.4, components and supporting structures for electrical and I&C systems that appear to meet the license renewal scoping criteria. Similarly, the staff evaluated the applicant's screening results to verify that all passive, long-lived components were subject to an AMR in accordance with 10 CFR 54.21(a)(1).

In its scoping evaluation, the staff reviewed the applicable LRA sections and component drawings, focusing on components that have not been identified as within the scope of license renewal. The staff reviewed relevant licensing basis documents, including the UFSAR, for each electrical and I&C system to determine whether the applicant has omitted from the scope of 2-134

license renewal components with intended functions delineated under 10 CFR 54.4(a). The staff also reviewed the licensing basis documents to determine whether the LRA specified all intended functions delineated under 10 CFR 54.4(a). The staff requested additional information to resolve any omissions or discrepancies identified.

After its review of the scoping results, the staff evaluated the applicant's screening results. For those SCs with intended functions, the staff sought to determine whether (1) if the functions are performed with moving parts or a change in configuration or properties or (2) the SCs are subject to replacement after a qualified life or specified time period, as described in 10 CFR 54.21(a)(1). For those meeting neither of these criteria, the staff sought to confirm that these SCs were subject to an AMR, as required by 10 CFR 54.21 (a)(1). The staff requested additional information to resolve any omissions or discrepancies identified.

2.5.1 Summary of Technical Information in the Application

LRA Section 2.5.1 describes the electrical and I&C systems, which are included within the scope of license renewal as are electrical and I&C components in mechanical systems. The default inclusion of plant electrical and I&C systems within the scope of license renewal reflects the method for the IPAs of electrical systems. This method is different from those for IPAs of mechanical systems and structures.

The basic philosophy of the electrical and I&C components IPA is to include components not specifically screened out. When used with the plant spaces approach, this method eliminates the need for unique identification of every component and its specific location so components are not improperly excluded from AMR. The electrical and I&C IPA begins with commodity groups of similar electrical and I&C components with common characteristics and component intended functions of the groups. The IPA eliminates commodity groups and specific plant systems from further review as it examines intended functions of commodity groups. In addition to the plant electrical systems the IPA conservatively includes within the scope of license renewal certain switchyard components required to restore offsite power following an SBO.

The electrical and I&C system performs functions that support SBO.

LRA Table 2.5-1 identifies the following electrical and I&C system component types within the scope of license renewal and subject to an AMR:

• cable connections (metallic parts)

" electrical cables and connections not subject to 10 CFR 50.49 EQ requirements

" electrical cables not subject to 10 CFR 50.49 EQ requirements used in instrumentation circuits

• fuse holders (insulation material)

" high-voltage insulators (for SBO)

" metal-enclosed bus (non-segregated bus for SBO), connections

" metal-enclosed bus (non-segregated bus for SBO), insulation/insulators

. metal-enclosed bus (non-segregated bus for SBO) enclosure assemblies 2-135

• oil-filled cable system (passive mechanical for SBO)

" oil-filled cable system (passive electrical for SBO)

" switchyard bus (switchyard bus for SBO), connections

• transmission conductors (transmission conductors for SBO), connections The electrical and I&C system component intended functions within the scope of license renewal include:

• electrical connections for voltage, current, or signals

• insulation and support for electrical conductors

• pressure boundary

• structural or functional support for fire protection, EQ, PTS, ATWS, or SBO 2.5.2 Staff Evaluation The staff reviewed LRA Section 2.5.1 and the UFSAR using the evaluation methodology described in SER Section 2.5 and the guidance in SRP-LR Section 2.5, "Scoping and Screening Results: Electrical and Instrumentation and Controls Systems."

During its review, the staff evaluated the system functions described in the LRA and UFSAR to verify that the applicant has not omitted from the scope of license renewal any components with intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components that the applicant has identified as within the scope of license renewal to verify that the applicant has not omitted any passive and long-lived components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).

In RAI 2.5-1 dated January 12, 2007, the staff asked the applicant to clarify why the switchyard bus was not shown in license renewal Figure 2.5-1 even though included in the list of components/commodity groups subject to an AMR.

In its response dated February 12, 2007, the applicant stated that the switchyard bus within the scope of license renewal and subject to an AMR consists of short sections that connect to the 115 kilo-volt (kV) underground oil-filled transmission cables at reserve station service transformer (T2) and switchyard breaker (10022). Also included are the short sections that connect to the overhead transmission conductors at reserve station service transformer (T3) and switchyard breaker (10012). The applicant updated license renewal Figure 2.5-1.

Based on its review, the staff finds the applicant's response to RAI 2.5-1 acceptable. The staff's concern described in RAI 2.5-1 is resolved.

2.5.3 Conclusion

The staff reviewed the LRA and UFSAR, and the supplemental information in the applicant's letter dated February 12, 2007, to determine whether the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In addition, the staff's review determined whether the applicant failed to identify any components subject to an AMR.

The staff finds no such omissions. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the electrical and I&C system components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).

2.6 Conclusion for Scoping and Screening

The staff reviewed the information in LRA Section 2, "Scoping and Screening Methodology for Identifying Structures and Components Subject to Aging Management Review and Implementation Results," and determines that the applicant's scoping and screening methodology was consistent with 10 CFR 54.21(a)(1) and the staff's positions on the treatment of safety-related and nonsafety-related SSCs within the scope of license renewal and on SCs subject to an AMR is consistent with the requirements of 10 CFR 54.4 and 10 CFR 54.21(a)(1).

On the basis of its review; the staff concludes that the applicant has adequately identified those systems and components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).

The staff concludes that there is reasonable assurance that the applicant will continue to conduct the activities authorized by the renewed license in accordance with the CLB and any changes to the CLB in order to comply with 10 CFR 54.21 (a)(1), in accordance with the Atomic Energy Act of 1954, as amended and NRC regulations.