PLA-6399, Response to Request for Additional Information for the Review of the License Renewal Application (LRA) Sections B.2.48, 3.0.3, 3.3.1 and 3.3.2
| ML082400092 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 08/08/2008 |
| From: | Mckinney B Susquehanna |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| PLA-6399 | |
| Download: ML082400092 (19) | |
Text
Britt T. McKinney Sr. Vice President & Chief Nuclear Officer PPL Susquehanna, LLC 769 Salem Boulevard Berwick, PA 18603 Tel. 570.542.3149 Fax 570.542.1504 btmckinney@pplweb.com II -
"0 PP 180048W U. S. Nuclear Regulatory Commission Document Control Desk Mail Stop OP 1-17 Washington, DC 20555 SUSQUEHANNA STEAM ELECTRIC STATION REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE SUSQUEHANNA STEAM ELECTRIC STATION UNITS 1 AND 2, LICENSE RENEWAL APPLICATION (LRA)
SECTIONS B.2.48, 3.0.3, 3.3.1 AND 3.3.2 PLA-6399 Docket Nos. 50-387 and 50-388 References.
"Application for Renewed Operating License Numbers NPF-14 and NPF-22, dated September 13, 2006.
"Request for Additional Information for the Review of the Susquehanna Steam Electric Station, Units 1 and 2 License Renewal Application, "dated July 9, 2008.
In accordance with the requirements of 10 CFR 50, 51, and 54, PPL requested the renewal of the operating licenses for the Susquehanna Steam Electric Station (SSES)
Units 1 and 2 in Reference 1.
Reference 2 is a request for additional information (RAI) related to License Renewal Application (LRA) Sections B.2.48, 3.0.3, 3.3.1 and 3.3.2. The enclosure to this letter provides the question responses and the additional requested information.
There are no new regulatory commitments contained herein as a result of the attached responses. However, License Renewal commitment #42 is revised in response to RAI B.2.48-1.
If you have any questions, please contact Mr. Duane L Filchner at (610) 774-7819.
A. 0 pe4z,
I Document Control Desk PLA-6399 I declare, under penalty of perjury, that the foregoing is true and correct.
Executed on:
Enclosure:
PPL Responses to NRC's Request for Additional Information (RAI)
Copy: NRC Region I Ms. E. H. Gettys, NRC Project Manager, License Renewal, Safety Mr. R. Janati, DEP/BRP Mr. F. W. Jaxheimer, NRC Sr. Resident Inspector Mr. A. L. Stuyvenberg, NRC Project Manager, License Renewal, Environmental
Enclosure to PLA-6399 PPL Responses to NRC's Request for Additional Information (RAI)
Enclosure to PLA-6399 Page 1 of 16 RAI B.2.48-1:
In the aging management program (AMP) B.2.48 Pre v'entive Maintenance Activities -
Reactor Core Isolation Cooling/High Pressure Cooling Injection (RCIC/HPCI) Turbine Casings program, under the "detection of aging effects" program element, the applicant does not provide sufficient detail about this program element. The Standard Review Plan and License Renewal (SRP-LR) Section A. 1.2.3.4.1 states, "Detection of aging effects should occur before there is a loss of the structure and component intended function(s).
The parameters to be monitored or inspected should be appropriate to ensure that the structure and component intended function(s) will be adequately maintained for license renewal under all Current License Basis (CLB) design conditions. This includes aspects such as method or technique (e.g., visual, volumetric, surface inspection), frequency, sample size, data collection and timing of new/one-time inspections to ensure timely detection of aging effects. Provide information that links the parameters to be monitored or inspected to the aging effects being managed."
Please provide the following information:
- 1. Method used to inspect (i.e., type of visual inspection, VT-I or VT-2)
- 2. Frequency of inspections
- 3. Type of data collected PPL Response:
Inspection of the RCIC and HPCI pump turbine internals, including the casings, is a skill-based visual inspection performed by Mechanical Maintenance personnel. The inspection is performed in accordance with procedures and includes loose parts, mechanical damage, corrosion, erosion, pitting, scale deposits, and other abnormal wear patterns. The inspection procedure for the HPCI turbine contains a specific step to perform a visual inspection of the turbine casing. The procedure for the RCIC turbine does not include this step and will be enhanced to include a specific step to perform a visual inspection of the turbine casing. LRA Commitment #42 is revised to reflect this change. The inspection procedure is based on the manufacturers Installation, Operation &
Maintenance (IOM) manual and the applicable EPRI Turbine Maintenance Guide for inspection guidance.
The inspections are currently planned to be performed on a 10-year frequency, based on the results of past inspections and NEIL Boiler & Machinery Insurance Inspection requirements.
The visual inspections verify that the condition of the HPCI and RCIC casings and gland cases is acceptable. No specific data is required to be collected per the inspection program. The results of the inspections are documented as part of the preventive
Enclosure to PLA-6399 Page 2 of 16 maintenance work package. Any deficiencies noted, based on the inspection criteria in the IOM and the EPRI Turbine Maintenance Guide, are entered into the corrective action program for evaluation.
The Preventive Maintenance Activities - RCIC/HPCI Turbine Casings (LRA Commitment #42) is revised as follows to include a specific step to perform a visual inspection of the RCIC turbine casing.
The text in LRA Section B.2.48, under the Required Enhancements heading (on LRA page B-148) is revised by addition (bold italics) and deletion (st*ikethfeugh) as follows:
Required Enhancements NORe The Preventive Maintenance Activities - RCICIHPCI Turbine Casings program procedure for the Reactor Core Isolation Cooling turbine will be enhanced to include a specific step to perform a visual inspection of the turbine casing.
> The text in LRA Commitment Table A-1 (on LRA page A-50) is revised by addition (bold italics) and deletion (s-f4kethe-eugh) as follows:
- 42) Preventive Existing program is credited with the A.1.2.39 Rgi....
Prior Maintenance following enhancement:
to the period Activities -
Include a specific step to perform a of extended RCIC/HPCI visual inspection of the RCIC operation Turbine turbine casing.
Casings RAI-B.2.48-2:
In the AMP B.2.48 Preventive Maintenance Activities - RCIC/HPCI Turbine Casings program, under the "operating experience" program element, the license renewal application (LRA) states, "The elements that comprise the Preventive Maintenance Activities - RCIC/HPCI Turbine Casings program are consistent with industry practice and have proven effective in maintaining the material condition of the RCIC and HPCI pump turbines, including casings."
What industry practice are you referring to? Also, please provide a justification of how a monitoring program can maintain the material condition of the RCIC and HPCI pump turbines, and whether visual inspections can be used to stop loss of materials.
Enclosure to PLA-6399 Page 3 of 16 PPL Response:
Standard industry practice is to perform periodic disassembly and inspection of the turbines in accordance with the recommendations of the vendor, as contained in the vendor instruction manual. Industry guidance for maintenance and troubleshooting of Terry turbines is referenced in the maintenance work documents. Industry operating experience and events are evaluated and the program is adjusted as needed.
Visual inspection provides indication of the material condition but is not intended to prevent the effects of aging. It is more accurate to state that the program manages the material conditions of the turbine casings. Management of the condition is provided by means of periodic visual inspection to detect the effects of aging and to correct degradation should conditions warrant.
The Preventive Maintenance Activities - RCIC/HPCL Turbine Casings is revised as follows to clarify the operating experience program element. The clarification to the detection of aging effects element is also included in this amendment.
B.2.48 Preventive Maintenance Activities - RCIC/HPCI Turbine Casings
) The text in LRA Section B.2.48, under the Detection of Aging Effects bullet and the first paragraph of the Operating Experience bullet (on LRA page B-147) are revised by addition (bold italics) and deletion (s44kethfeugh) as follows:
Detection of Aging Effects In accordance with the information provided in the Monitoring and Trending element, the Preventive Maintenance Activities - RCIC/HPCI Turbine Casings will detects loss of material prior to any loss of component intended functions. The program relies on visual inspection to identify surface degradation. Inspections are performed on a nominal 10-year frequency based on results of past inspections and on industry experience.
- Operating Experience The elements that comprise the Preventive Maintenance Activities - RCIC/HPCI Turbine Casings are based on manufacturer recommendations and eRAst8Rt with industry pastiG8 guidance and have proven effective in maintaining managing the material condition of the RCIC and HPCI pump turbines, including the casings.
Enclosure to PLA-6399 Page 4 of 16 Preventative Maintenance Activities - HCIC/HPCI Casings RAI 3.0.3.3.48-1:
For the "detection of aging effects" program element, the staff reviewed the program in accordance with SRP-LR Section A. 1.2.3.4-1 and determined that there was insufficient information in the LRA. What is the method of inspection? What is the frequency of inspections? What kind of data will be taken and how will it be stored?
PPL Response:
PPL response to RAI B.2.48-1 provides the requested information.
RAI 3.0.3.3.48-2:
In the "operating experience" program element, the applicant states that this monitoring program will ensure that the material condition will be maintained. Please explain how a monitoring program can ensure how monitoring for loss of material will maintain the material condition.
PPL Response:
PPL response to RAI B.2.48-2 provides the requested information.
RAI 3.3.2-1:
The LRA has indicated Generic Note H for 3.3.2 line items, 3.3.2-11, 3.3.2-21, 3.3.2-26, and 3.3.2-30 for the emergency service water, the reactor building chilled water, the residual heat removal service water, and the service water system. Generic Note H states, "Aging effect not in the Generic Aging Lessons Learned (GALL) Report (Chapter IV) for this component, material, and environment combination." Plant-specific Note 0347 states, that in order for stress corrosion cracking to occur, the copper alloys would have to have >15% Zinc or >8% Aluminum and there would have to be ammonia or ammonium compounds present. The staff does not know whether the Area-Based Non-Safety Affecting Safety (NSAS) Inspection Program is adequate to manage the stress corrosion cracking of copper alloys because there is not enough information provided in the LRA.
For instance, what are the specific compositions of the copper alloys, what are possible sources of ammonia or ammonia compounds for these systems, and what is the condition of the copper piping and piping components in terms of residual stresses? Also, has Susquehanna Steam Electric Station ever experienced any stress corrosion cracking of copper piping and piping components in any of these systems?
Enclosure to PLA-6399 Page 5 of 16 PPL Response:
The specific compositions of the copper alloys are nrt known, therefore they are conservatively assumed to contain >15% Zinc and therefore potentially would be subject to stress corrosion cracking (SCC) in the presence of ammonia.
As stated in plant-specific note 0347, ammonia may result from organic decay or as a result of microbial activity. As the presence of ammonia cannot be ruled out, it is assumed to exist in the raw water environment and to create the potential for SCC in copper alloys. The condition of the piping and piping components in terms of residual stresses is not known and the potential for cracking cannot be ruled out. SSES has not experienced cracking of copper piping and piping components in the subject systems due to SCC.
The Area-Based NSAS Inspection is credited for piping and piping components that perform only a structural integrity function for license renewal.
Aging Management Review Related RAts RAI 3.3.2.2.7.2-1:
In the discussion column of Table 3.3.1, Item 3.3.1-17, the LRA states that Flow-Accelerated Corrosion (FAC) Program is applicable to the Reactor Water Cleanup (RWCU) system valve bodies and that the FAC Program is credited to manage loss of material due to FAC, and Note H is used. This line item addresses loss of material due to general, pitting and crevice corrosion. Please justify why loss of material due to FAC is addressed in this Table 1 line item with Note H, which is not consistent with the GALL Report.
PPL Response:
There is no line item in GALL Chapter VII Section E3, Reactor Water Cleanup System (BWR), for loss of material due to flow accelerated corrosion (FAC). Therefore, comparison to Chapter VII of the GALL should not have been made for valve bodies subject to FAC. Similar to other line items in Table 3.3.2-25 for which the FAC Program was credited for loss of material due to FAC, comparison should have been to GALL item VIII.D2-8.
The subject line item is revised to refer to the GALL item addressing FAC. A similar change is made for a Table 3.3.2-25 item for piping. Table 3.3.1, Item 3.3.1-17 is revised to remove the discussion related to FAC.
The LRA is amended as follows to make the necessary changes.
Enclosure to PLA-6399 Page 6 of 16 The following line item in LRA Table 3.3.1 (on LRA page 3.3-57) is revised by deletion (stiikethfeiugh).
Table 3.3.1 Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of the GALL Report Item Component/Commodity Aging Aging Management Further Discussion Number Effect/Mechanism Programs Evaluation Recommended 3.3.1-17 Steel piping, piping Loss of material Water Chemistry and Yes, detection of Consistent with NUREG-1 801.
components, and piping due to general, One-Time Inspection aging effects is elements exposed to treated pitting, and crevice to be evaluated The BWR Water Chemistry water corrosion Program and the Chemistry Program Effectiveness Inspection are credited to manage loss of material for steel components that are exposed to treated water.
This item is also applicable to accumulators and regenerative heat exchangers, for which Note C is used.
This item is also applied for lo66 o f Im.atoeri*A.' duo-ton FAC for ReaGctr Water Cleanup"-p Systom valvobde
. The Flow-I Corro-at-n GFF R(FAC)
Program is credptited-to m~anage loss o..,atorial due to FAG, and Note H is usmed.
Further evaluation is documented in Section 3.3.2.2.7.2.
Enclosure to PLA-6399 Page 7 of 16 The following line items in LRA Table 3.3.2-25 (on LRA pages 3.3-311 and 3.3-3 12) are revised by addition (bold italics) and deletion (stfike+1 feti.h).
Table 3.3.2-25 Aging Management Review Results - Reactor Water Cleanup System Component Intended Aging Effect Aging NUREG-1801 Commodity Function Material Environment Requiring Management Volume 2 Table 1 Item Notes Management Programs Item Flow-Accelerated Pressure Treated Water Loss of Acrroio
-VWE.4&
-, 3. &
17
-H-A Piping Boundary aron ee (Internal)
Material (FAC)
VIII.D2-8 3.4.1-29 0355 Program Flow-Pressure Treated Water Loss of Accelerated iH..3...-.A Valve Bodies Boundary Carbon Steel (Internal)
Material Corrosion VIII.D2-8 3.4.1-29 0355 (FAg)
Program
.1
t!
S'
ý,
I.
1,
1 Enclosure to PLA-6399 Page 8 of 16 RAI 3.3.2.2.7.2-2:
In the discussion column of Table 3.3.1, Item 3.3.1-17, the LRA credits Boiling-Water Reactor Water Chemistry, Chemistry Effectiveness Inspection and the FAC Programs, and references Section 3.3.2.2.7.2 for further evaluation. However, Section 3.3.2.2.7.2 does not address FAC Program. Please clarify why the FAC Program is not addressed in Section 3.3.2.2.7.2.
PPL Response:
Based on the response to RAI 3.3.2.2.7.2-1, line items in LRA Table 3.3.2-25 for loss of material due to flow-accelerated corrosion (FAG) should not have been compared to a GALL line item that rolled up to Table 3.3.1, Item 3.3.1-17. The response to RAI 3.3.2.2.7.2-1 amended the LRA to make the necessary changes.
Therefore, based on the amendment to the LRA made in response to RAI 3.3.2.2.7.2-1, no further changes to the LRA are required.
RAI 3.3.2.3.25-1:
In Table 3.3.2-25, RWCU system, the applicant credits FAC Program to manage the aging effect of loss of material due to FAC of carbon steel piping and valve bodies in a treated water environment and has referenced Note H. The definition of Note H implies that these line items are not consistent with the GALL Report.
However, the applicant has identified the GALL Report Item VII.E3-18, which is for loss of material due to general, pitting and crevice corrosion.
Please justify why a GALL Report item is identified, if the line item is not consistent with the GALL Report.
PPL Response:
There is no line item in GALL Chapter VII Section E3, Reactor Water Cleanup System (BWR), for loss of material due to flow accelerated corrosion (FAC).
Therefore, comparison to Chapter VII of the GALL should not have been made for steel piping and valve bodies subject to FAC. Similar to other line items in Table 3.3.2-25 for which the FAC Program was credited for loss of material due to FAC, comparison should have been to GALL Item VIII.D2-8.
The subject line items for piping and valve bodies were revised in response to RAI 3.3.2.2.7.2-1 to refer to GALL Item VIII.D2-8 which is applicable to FAC. GALL Item VIII.D2-8 rolls up to Table 3.3.1, Item 3.4.1-29. Table 3.3.1, Item 3.3.1-17
Enclosure to PLA-6399 Page 9 of 16 was revised in response to RAI 3.3.2.2.7.2-1 to remove the discussion related to FAC.
RAI 3.3.2.3.25-2:
Note H states that aging effect is not in NUREG-1801 for this component, material and environment combination. Yet in the same table, the LRA has another line item for the same component, material and aging effect combination with an aging effect of loss of material due to FAC where the LRA has referenced Note A and correctly identified the GALL Report Item VIII.D2-8.
Please justify why Note H is used in one case and Note A for another in the same system.
PPL Response:
There is no line item in GALL Chapter VII Section E3, Reactor Water Cleanup System (BWR), for loss of material due to flow accelerated corrosion (FAC).
Therefore, comparison to Chapter VII of the GALL should not have been made for the steel piping and valve bodies subject to FAC for which a Note H was used.
Similar to other line items in Table 3.3.2-25 for which the FAC Program was credited for loss of material due to FAC, comparison should have been to GALL Item VIII.D2-8.
The subject line items for piping and valve bodies in LRA Table 3.3.2-25 were revised in response to RAI 3.3.2.2.7.2-1 to refer to GALL Item VIII.D2-8, which is applicable to FAC, and a Note A was applied. GALL Item VIII.D2-8 rolls up to Table 3.3.1, Item 3.4.1-29. The necessary changes to LRA Table 3.3.1 were made in response to RAI 3.3.2.2.7.2-1.
RAI 3.3.2.1-1:
Two lines in Table 3.3.2-13, fire protection system, for heat exchanger tube components, which reference Table 1 Item 3.3.1-83 and Note E, the applicant has credited Fire Water System Program to manage the aging effects of reduction in heat transfer. However, in Table 3.3.1, Item 3.3.1-83, the discussion column does not credit Fire Water System Program. Please resolve this discrepancy.
PPL Response:
Line item 3.3.1-83 in LRA Table 3.3.1 is incorrect in that it does not address the Fire Water System Program. The LRA is amended as follows to clarify that line
Enclosure to PLA-6399 Page 10 of 16 item 3.3.1-83 credits the Fire Water System Program for heat exchanger tube components in the Fire Protection System.
In addition, line item 3.3.1-83 in LRA Table 3.3.1 is revised to correct the aging effect to be managed by the Piping Corrosion Program stated under the Discussion column. The aging effect should be reduction in heat transfer as reflected in LRA Tables 3.3.2-4, 3.3.2-7, 3.3.2-9, 3.3.2-13, and 3.3.2-23.
Enclosure to PLA-6399 Pagel 1 of 16 AGING MANAGEMENT OF AUXILIARY SYSTEMS The following text in LRA Table 3.3.1 (on LRA page 3.3-91) is revised by addition (bold italics) and deletion (str-kethfettgh).
Table 3.3.1 Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of the GALL Report Table 3.3.1 Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of the GALL Report Item Component / Commodity Aging Effect /
Aging Management Further Discussion Number Mechanism Programs Evaluation Recommended 3.3.1-83 Stainless steel and copper alloy Reduction of heat Open-Cycle Cooling No Consistent with NUREG-1801, heat exchanger tubes exposed to transfer due to Water System with exceptions.
raw water fouling The Piping Corrosion Program is credited to manage less of material reduction in heat transfer for stainless steel and copper alloy heat exchanger tubes that are exposed to raw water. -
The Fire Water System Program is credited to manage reduction of heat transfer due to fouling of copper alloy heat exchanger tubes that are exposed to raw water in the Fire Protection System.
Enclosure to PLA-6399 Page 12 of 16 RAI 3.3.2.2.10.5-1:
In the discussion column of Table 3.3.1, Item 3.3.1-27, the applicant states that the System Walkdown Program, the Cooling Units Inspection, and the Supplemental Piping/Tank Inspection are credited to manage'loss of material and references Section 3.3.2.2.10.5 for further evaluation. However, Section 3.3.2.2.10.5 does not address the Supplemental Piping/Tank Inspection. Please resolve this discrepancy.
PPL Response:
The LRA is amended as follows to address the Supplemental Piping/Tank Inspection in LRA Section 3.3.2.2.10.5 based on LRA Table 3.3.1, Item 3.3.1-27, and the associated aging management review results tables.
AGING MANAGEMENT OF AUXILIARY SYSTEMS
" The following text in LRA Section 3.3.2.2.10.5 (on LRA page 3.3-45) is revised by addition (bold italics).
3.3.2.2.10.5 HVAC Piping, Piping Components, and Piping Elements and Ducting The Cooling Units Inspection is a one-time inspection credited with detecting and characterizing the condition of aluminum and stainless steel HVAC components exposed to condensation. The Supplemental Piping/Tank Inspection is a one-time inspection credited with detecting and characterizing the condition of stainless steel components that are exposed to moist air, particularly the aggressive alternate wet/dry environment that exists at air-water interfaces. The System Walkdown Program is credited for managing loss of material due to pitting and crevice corrosion for the external surfaces of stainless steel HVAC components exposed to condensation.
RAI 3.3.1-6:
In the discussion column of Table 3.3.1, Item 3.3.1-27, the applicant states that the Cooling Units Inspection will also detect and characterize cracking of aluminum HVAC cooling unit fins, for which Note H is used. However, a review of the Table-2 did not identify a line item where this is identified. Please clarify where in Table-2 the Cooling Units Inspection is credited for managing cracking of aluminum HVAC cooling unit fins.
PPL Response:
The Cooling Units Inspection is not credited for managing cracking of aluminum HVAC cooling unit fins in Table 2, or in LRA Section B.2.23, Cooling Units Inspection. The
Enclosure to PLA-6399 Page 13 of 16 Cooling Units Inspection is credited for reduction in heat transfer due to fouling of aluminum HVAC cooling unit fins.
LRA Table 3.3.1, Item 3.3.1-27, and the associated Section 3.3.2.2.10.5, are revised to remove the statement crediting the Cooling Units Inspection in conjunction with cracking of aluminum HVAC cooling unit fins.
Additionally, an LRA Table 3.3.2-23 line item for carbon steel drain pans in the Reactor Building HVAC System incorrectly credited GALL item VII.F 1-1 which rolls up to Table 3.3.1, Item 3.3.1-27. The Table 3.3.1 item is for stainless steel and aluminum components only. The LRA is amended to correctly credit GALL Item VII.I-1 1 for the carbon steel drain pans.
LRA Table 3.3.1, Item 3.3.1-27 is also amended to remove the statement that Note C is used for heat exchanger components. GALL item VII.F2-1 calls for a plant-specific program. Note E is the proper note in this circumstance and LRA Table 3.3.2-27 is amended to reflect these changes.
The following text in LRA Section 3.3.2.2.10.5 (on LRA page 3.3-45) is revised by deletion (st-kethfetigh).
3.3.2.2.10.5 HVAC Piping, Piping Components, and Piping Elements and Ducting The Cooling Units Inspection is a one-time inspection credited with detecting and characterizing the condition of aluminu.m and stainless steel HVAC components exposed to condensation. The System Walkdown Program is credited for managing loss of material due to pitting and crevice corrosion for the external surfaces of stainless steel HVAC components exposed to condensation.
Enclosure to PLA-6399 Page 14 of 16 AGING MANAGEMENT OF AUXILIARY SYSTEMS The following text in LRA Table 3.3.1 (on LRA page 3.3-66) is revised by addition (bold italics) and deletion (stkethfrough).
Table 3.3.1 Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of the GALL Report Table 3.3.1 Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of the GALL Report Item Component I Commodity Aging Effect /
Aging Management Further Discussion Number Mechanism Programs Evaluation Recommended 3.3.1-27 Stainless steel HVAC ducting Loss of material A plant-specific aging Yes, plant The System Walkdown and aluminum HVAC piping, due to pitting and management program specific Program, the Cooling Units piping components and piping crevice corrosion is to be evaluated.
Inspection, and the elements exposed to Supplemental Piping/Tank condensation Inspection are credited to manage loss of material for stainless steel and aluminum components that are exposed to condensation, for both HVAC and non-HVAC systems.
Note C is usod for heat cXchangcr cOMPOncntS.
The Cooling Units Inspection and the Supplemental Piping/Tank Inspection are one-time inspections that will detect and characterize loss of material. The Cooling Units lnspccti9n will also detectan characterize cracking of all umI l1l Im lVIIAC cooling unit fins, for which Note H is usd Further evaluation is documented in Section 3.3.2.2.10.5.
Enclosure to PLA-6399 Page 15 of 16 AGING MANAGEMENT OF AUXILIARY SYSTEMS The following text in LRA Table 3.3.2-23 (on LRA page 3.3-298) is revised by addition (bold italics) and deletion (sTa ike3MwttSgh).
Table 3.3.2-23 Aging Management Review Results - Reactor Building HVAC System Table 3.3.2-23 Aging Management Review Results - Reactor Building HVAC System Component Intended Aging Effect Aging NUREG-1801 Commodity Function Material Environment Requiring Management Volume 2 Table 1 Item Notes Management Programs Item Cooling Units, Raw Water Loss of Cooling Units Emergency (Internal)
Material Inspection VII.F1-3 3.3.1-72 E
SWGR and Pressure Load Center Boundary Carbon Steel RoomsIndoor Air Loss of System V4-FI-3.3-27
-E-A, (1/2E240A/B)
(External)
Material vil.1-11 3.3.1-58 0335 Drain Pans Program
Enclosure to PLA-6399 Page 16 of 16 AGING MANAGEMENT OF AUXILIARY SYSTEMS The following text in LRA Table 3.3.2-27 (on LRA page 3.3-331) is revised by addition (bold italics) and deletion Table 3.3.2-27 Aging Management Review Results - Sampling System Table 3.3.2-27 Aging Management Review Results - Sampling System Component Intended Aging Effect Aging NUREG-180 Componety F
Material Environment Requiring Management 1 Volume 2 Table 1 Item.
Notes Commodity Function Management Programs Item Chillers -
Closed Cooling condenser Treated Water Loss of Water VI0.C2-10 3.3.1-50 D,
channel/
(Internal)
Material Chemistry 0348
- header, Structural Stainless Program evaporator Integrity Steel shell, integral System piping/tubing Indoor Air Loss of Walkdown VISF2-1 3.3.1-27 E,
and tanks (External)
Material Program 0345 (1/2K207)
Heat Closed Cooling Exchangers/
Treated Water Loss of Water VII.C2-10 3.3.1-50 D,
Coolers -
(Internal)
Material Chemistry 0348 channel/head, Program shell Structural Stainless (1/2E224, Integrity Steel 1/2E225, Indoor Air Loss of System
-G-E, 1/2E226A/B, (External)
Material Walkdown VII.F2-1 3.3.1-27 0345 1/2E233, Program 1/2E237)