ULNRC-05946, 1 License Renewal Application Request for Additional Information (RAI) 2.3.4.2-1a Response and RAI 2.1-2 Supplemental Response
| ML13011A026 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 01/10/2013 |
| From: | Ameren Missouri |
| To: | Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML130110026 | List: |
| References | |
| ULNRC-05946 | |
| Download: ML13011A026 (16) | |
Text
ULNRC-05946 January 10, 2013 Page 1 of 7 CALLAWAY PLANT UNIT 1 LICENSE RENEWAL APPLICATION REQUEST FOR ADDITIONAL INFORMATION (RAI) 2.3.4.2-1a RESPONSE and RAI 2.1-2 SUPPLEMENTAL RESPONSE
ULNRC-05946 January 10, 2013 Page 2 of 7 RAI 2.3.4.2-1a By letter dated July 2, 2012, the applicant stated in its response to RAI 2.3.4.2-1 that the safety-related scoping boundary for the main steam piping concludes at the wall between the auxiliary building and turbine building due to equivalent anchors characterized as "no break zones."
Additionally, in its response to RAI 2.1-2 by letter dated August 9, 2012, the applicant stated that the attached main steam piping, which extends from the "no break zone" and inside the turbine building, was not included within the scope of license renewal. The exclusion of this attached piping appears to contradict the scoping methodology in license renewal application (LRA)
Section 2.1.2.2, which states:
Nonsafety-related SSCs that are directly connected to safety-related SSCs were included within the scope of license renewal to ensure structural integrity of the safety-related SSC up to the first seismic anchor or equivalent anchor past the safety/nonsafety interface.
The staff requests that the applicant justify excluding the attached main steam piping, which extends from the "no break zone" area and into the turbine building, from the scope of license renewal.
Callaway Response "No break zones" are areas of high-energy piping where breaks are not postulated because the stresses are limited. For the main steam and main feedwater piping, no break zones extend from the anchors in the reactor building wall to outside the torsional restraints in the auxiliary building-turbine building wall. They are defined in FSAR-SP Sections 10.3.2.2 and 10.4.7.2.2, and are shown on Figure 3.6-1, Sheets 1, 2, and 3.
The no break zones meet the requirements of NRC Branch Technical Position MEB 3-1. As described in FSAR-SP Section 3.6.2.1.1, the maximum stress in the no break zones does not exceed 1.8 Sh per equation (9), Subarticle NC-3652 of ASME Section III when subjected to the combined loadings of internal pressure, deadweight, and postulated pipe break beyond the no break zone. Thus, a postulated pipe break beyond the no break zone does not prevent the components within the no break zone from performing their intended functions. For the main steam and main feedwater systems, the piping in the auxiliary building is safety related, and within the no break zone. The connected piping in the turbine building is non-safety related.
The connected, non-safety related piping in the turbine building is not within the scope of license renewal because a pipe break in this area will not prevent the connected safety related components from performing their intended function.
Guidance provided in NEI 95-10, Appendix F, requires that non-safety related components directly connected to safety related components up to and including the first equivalent anchor beyond the safety/non-safety interface be included within the scope of license renewal. The above argument for excluding attached piping from the scope of license renewal is not included in NEI 95-10, Appendix F, guidance. Thus, LRA Section 2.1.2.2 has been revised as shown on Amendment 19 in Enclosure 2, to state that an exception to NEI 95-10, Appendix F, is taken for main steam and main feedwater piping based on the no break zones described above.
For the main feedwater system, non-safety related piping in the turbine building connected to the safety related piping in the auxiliary building was originally included within the scope of
ULNRC-05946 January 10, 2013 Page 3 of 7 license renewal. For consistency with the main steam system, the non-safety related main feedwater system piping in the turbine building has been removed from the scope of license renewal. LRA Section 2.3.4.3 and Table 3.4.2-3 have been revised as shown on Amendment 19 in Enclosure 2, to remove the non-safety related main feedwater system components in the turbine building from the scope of license renewal. In addition, license renewal boundary drawing LR-CW-AE-M-22AE01, which includes only non-safety related components in the turbine building, has been deleted, and license renewal boundary drawing LR-CW-AE-M-22AE02 has been revised to show that the non-safety related main feedwater piping in the turbine building connected to the safety related piping in the auxiliary building is not within the scope of license renewal.
The use of no break zones for the steam generator blowdown system is similar to the main steam and main feedwater systems, but the no break zones for the steam generator blowdown system end in the auxiliary building. The steam generator blowdown system includes safety related piping downstream of the no break zones, extending to the auxiliary building-turbine building wall. Therefore, it is necessary to include the connected non-safety related steam generator blowdown piping in the turbine building within the scope of license renewal. Although no changes to the LRA are required for the steam generator blowdown system, license renewal boundary drawing LR-CW-BM-M-22BM01 has been revised to clarify the location of the interface between the safety related and non-safety related piping.
Corresponding Amendment Changes Refer to the Enclosure 2 Summary Table "Amendment 19, LRA Changes from RAI Responses, for a description of LRA changes with this response.
ULNRC-05946 January 10, 2013 Page 4 of 7 RAI 2.1-2
Background:
Title 10, Section 54.4, Scope, of the CFR states, in part:
(a) Plant systems, structures and components within the scope of this part are -
(1) Safety-related systems, structures, and components which are those relied upon to remain functional during and following design-basis events (as defined in 10 CFR 50.49 (b)(1)) to ensure the following functions -
(i) The integrity of the reactor coolant pressure boundary; (ii) The capability to shut down the reactor and maintain it in a safe shutdown condition; or (iii) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures comparable to those referred to in 10 CFR 50.34(a)(1), 10 CFR 50.67(b)(2), or 10 CFR 100.11, as applicable.
(2) All nonsafety-related systems, structures and components whose failure could prevent satisfactory accomplishment of any of the functions identified in (a)(1)(i), (ii), or (iii) of this section.
Issue:
During the on-site scoping and screening methodology audit the staff reviewed the license renewal application (LRA), the 10 CFR 54.4(a)(2) implementing documents and license renewal drawings, and also performed plant walkdowns. LRA Section 2.4-4 does not indicate that the turbine building contains safety-related SSCs, however, the applicable license renewal drawings were marked to indicate that safety-related piping components are located within the turbine building. During discussion with the applicant, the staff determined that the applicant had identified safety-related portions of the main steam supply system, main feedwater system and steam generator blowdown system located within the turbine building. However the applicant had performed an evaluation and concluded that the safety-related portions of the systems located within the turbine building were not included within the scope of license renewal in accordance with 10 CFR 54.4(a)(1). In addition, the applicant had not included the nonsafety-related SSCs located within the turbine building and within the proximity of safety-related SSCs, whose failure could prevent satisfactory accomplishment of the intended functions of safety-related SSCs, within the scope of license renewal in accordance with 10 CFR 54.4(a)(2).
Request:
The staff requests that the applicant describe the process used to identify and evaluate safety-related piping components located within the turbine building, the results of the evaluation, and the basis for any determination to not include safety-related SSCs within the scope of license renewal in accordance with 10 CFR 54.4(a)(1). In addition, describe the process used to identify and evaluate nonsafety-related SSCs located in the turbine building whose potential failure could impact safety-related SSCs, the results of the evaluation, and the basis for any determination to not include the nonsafety-related SSCs within the scope of license renewal in
ULNRC-05946 January 10, 2013 Page 5 of 7 accordance with 10 CFR 54.4(a)(2). The staff requests that the applicant perform a review of this issue and indicate if the review concludes that use of the scoping methodology precluded the identification of SSCs that should have been included within the scope of license renewal in accordance with 10 CFR 54.4(a). Describe any additional scoping evaluations performed to address the 10 CFR 54.4(a) criteria. List any additional SSCs included within the scope of license renewal as a result of the review, and any SCs for which AMRs were performed. For SCs for which AMRs were performed, describe the AMPs, as applicable, to be credited for managing the identified aging effects.
Callaway Response Various documentation sources were used to determine what components were within the scope of license renewal. One of the sources was the Callaway Equipment List (CEL), which is maintained in a database called EB Director. The CEL includes a field named Q-QUAL, which is used to flag whether or not a component is safety-related. The basis for determining whether a component is flagged as safety-related is the definition of safety-related in FSAR Section 1.1.7. The FSAR definition is consistent with the scoping criteria of 10 CFR 54.4(a)(1). All safety-related components in the CEL have a Y flag in the Q-QUAL field to indicate that they are safety-related.
During the scoping process, all components were considered to be safety-related if they had a Y flag in the Q-QUAL field of the CEL. Twelve piping segments were identified in the turbine building which had Y flags. These piping segments extended from the auxiliary building through the auxiliary building-turbine building wall and into the turbine building. They included four piping segments downstream of the four main steam isolation valves, four piping segments downstream of the blowdown isolation valves for each of the steam generators, and four piping segments upstream of the four main feedwater isolation valves. In addition, drain valves from three of the four blowdown lines also had Y flags in the Q-QUAL field. No other piping components in the turbine building have Y flags.
Since these piping segments had Y flags in the Q-QUAL field, they were initially considered to be within the scope of license renewal as safety-related components. From a review of FSAR Section 3.6.2.1.1e, High-Energy Piping in Containment Penetration Areas, and engineering evaluations, it was determined that the sections of the piping extending into the turbine building do not have a safety-related function. For the purpose of license renewal, new subcomponents were created representing the sections of piping within the turbine building. Since these subcomponents do not have a safety-related function, they are not within the scope of license renewal as safety-related components. The boundary drawings for the main steam system, steam generator blowdown system, and main feedwater system have been revised to indicate that the safety-related portion of these lines ends at the auxiliary building-turbine building wall.
A corrective action document has been initiated to change the Y flags to N in the Q-QUAL fields for the blowdown drain valves, and a note will be added to the CEL entry for all 12 piping segments stating that the section of the lines in the turbine building is not safety-related.
The main feedwater and steam generator blowdown systems were screened differently than the main steam system. For the main feedwater and steam generator blowdown systems, credit was not taken for the equivalent anchors in the auxiliary building-turbine building wall.
ULNRC-05946 January 10, 2013 Page 6 of 7 Therefore, the attached piping in the turbine building was put into the scope of license renewal as structural integrity attached.
The same approach was not taken for the main steam system because of the large number of components in the turbine building which would have to be included within the scope of license renewal for structural integrity attached. Therefore, credit was taken for the equivalent anchors at the auxiliary building-turbine building wall for the main steam system. Since the safety-related portion of the main steam lines end at the auxiliary building-turbine building wall, the attached main steam piping in the turbine building was not put into the scope of license renewal.
"No break zones" are areas of high-energy piping where breaks are not postulated because the stresses are limited. For the main steam and main feedwater piping, no break zones extend from the anchors in the reactor building wall to outside the torsional restraints in the auxiliary building-turbine building wall. They are defined in FSAR-SP Sections 10.3.2.2 and 10.4.7.2.2, and are shown on Figure 3.6-1, Sheets 1, 2, and 3.
The no break zones meet the requirements of NRC Branch Technical Position MEB 3-1. As described in FSAR-SP Section 3.6.2.1.1, the maximum stress in the no break zones does not exceed 1.8 Sh per equation (9), Subarticle NC-3652 of ASME Section III when subjected to the combined loadings of internal pressure, deadweight, and postulated pipe break beyond the no break zone. Thus, a postulated pipe break beyond the no break zone does not prevent the components within the no break zone from performing their intended functions. For the main steam and main feedwater systems, the piping in the auxiliary building is safety related, and within the no break zone. The connected piping in the turbine building is non-safety related.
The connected, non-safety related piping in the turbine building is not within the scope of license renewal because a pipe break in this area will not prevent the connected safety related components from performing their intended function.
Guidance provided in NEI 95-10, Appendix F, requires that non-safety related components directly connected to safety related components up to and including the first equivalent anchor beyond the safety/non-safety interface be included within the scope of license renewal. The above argument for excluding attached piping from the scope of license renewal is not included in NEI 95-10, Appendix F, guidance. Thus, LRA Section 2.1.2.2 has been revised as shown on Amendment 19 in Enclosure 2, to state that an exception to NEI 95-10, Appendix F, is taken for main steam and main feedwater piping based on the no break zones described above.
For the main feedwater system, non-safety related piping in the turbine building connected to the safety related piping in the auxiliary building was originally included within the scope of license renewal. For consistency with the main steam system, the non-safety related main feedwater system piping in the turbine building has been removed from the scope of license renewal. LRA Section 2.3.4.3 and Table 3.4.2-3 have been revised as shown on Amendment 19 in Enclosure 2, to remove the non-safety related main feedwater system components in the turbine building from the scope of license renewal. In addition, license renewal boundary drawing LR-CW-AE-M-22AE01, which includes only non-safety related components in the turbine building, has been deleted, and license renewal boundary drawing LR-CW-AE-M-22AE02 has been revised to show that the non-safety related main feedwater piping in the turbine building connected to the safety related piping in the auxiliary building is not within the scope of license renewal.
ULNRC-05946 January 10, 2013 Page 7 of 7 The use of no break zones for the steam generator blowdown system is similar to the main steam and main feedwater systems, but the no break zones for the steam generator blowdown system end in the auxiliary building. The steam generator blowdown system includes safety related piping downstream of the no break zones, extending to the auxiliary building-turbine building wall. Therefore, it is necessary to include the connected non-safety related steam generator blowdown piping in the turbine building within the scope of license renewal. Although no changes to the LRA are required for the steam generator blowdown system, license renewal boundary drawing LR-CW-BM-M-22BM01 has been revised to clarify the location of the interface between the safety related and non-safety related piping.
Since it is assumed during the initial scoping and screening that a component with a Y flag in the Q-QUAL field of the CEL has a safety-related function, all components with a Y flag were reviewed. Thus, this methodology did not preclude the identification of safety-related SSCs that should have been included within the scope of license renewal. No additional scoping evaluations were required. No SSCs were added to the scope of license renewal, and no additional AMRs were performed.
Corresponding Amendment Changes No changes to the License Renewal Application (LRA) are needed as a result of this response.
License Renewal Application changes are made as a result of the response to RAI 2.3.4.2-1a.
Refer to the Enclosure 2 Summary Table "Amendment 19, LRA Changes from RAI Response, for a description of LRA changes.
ULNRC-05946 January 10, 2013 Page 1 of 9 Amendment 19, LRA Changes from RAI Response Summary Table Affected LRA Section LRA Page Section 2.1.2.2 2.1-6 through 2.1-8 Section 2.3.4.3 2.3-91 through 2.3-93 (Encl 2, page 5 and 6 of 9)
Table 3.4.2-3 3.4-41 through 3.4-43 (Encl 2, page 7 and 8 of 9)
Table A4-1 item 39 A-49
ULNRC-05946 January 10, 2013 Page 2 of 9 Callaway Plant Unit 1 License Renewal Application Callaway Plant License Renewal Application Amendment 19 Revision to Section 2.1.2.2 to add a discussion of nonsafety-related piping connected to safety-related piping in the main steam and main feedwater systems.
Section 2.1.2.2 (page 2.1-6 through 2.1-8) is revised as follows (new text shown underlined) 2.1.2.2 10 CFR 54.4(a)(2) - Nonsafety-Related Affecting Safety-Related 10 CFR 54.4(a)(2) requires that plant SSCs within the scope of license renewal include all nonsafety-related SSCs whose failure could prevent satisfactory accomplishment of any of the safety-related functions identified for safety-related SSCs. The guidance provided in NEI 95-10, Appendix F was used to develop the methodology for scoping to the criterion of 10 CFR 54.4(a)(2).
The methodology includes identification of nonsafety-related SSCs that are connected to safety-related SSCs and nonsafety-related SSCs that could spatially interact with safety-related SSCs. Determination and identification of any other SSCs satisfying criterion 10 CFR 54.4(a)(2) was completed as described below based on review of applicable CLB documents, plant specific and industry operating experience, and by system and structure functional evaluations.
Nonsafety-Related SSCs Performing Safety-Related 10 CFR 54.4(a)(1) Functions The FSAR and other current licensing basis documents were reviewed for nonsafety-related plant systems or structures, to determine whether nonsafety-related systems or structures were credited with performing a safety-related function. Callaway does not have nonsafety-related systems or structures credited in CLB documents that perform a safety-related function.
Nonsafety-Related SSCs Directly Connected to Safety-Related SSCs Nonsafety-related SSCs that are directly connected to safety-related SSCs were included within the scope of license renewal to ensure structural integrity of the safety-related SSC up to the first seismic anchor or equivalent anchor past the safety/nonsafety interface.
Seismic anchors and equivalent anchors were identified following the guidance of NEI 95-10, Appendix F as discussed below:
x A seismic anchor that ensures that forces and moments are restrained in three orthogonal directions
ULNRC-05946 January 10, 2013 Page 3 of 9 Callaway Plant Unit 1 License Renewal Application x
An equivalent anchor that is defined in the CLB.
x An equivalent anchor that consists of a large piece of plant equipment or a series of supports that are part of a plant-specific piping design analysis. The large piece of equipment that serves as the anchor is in the scope of license renewal or the nonsafety-related piping up to the last orthogonal support is in the scope of license renewal.
x An equivalent anchor that is composed of a combination of restraints or supports attached to the nonsafety-related piping that encompasses at least two supports in each of the three orthogonal directions. The nonsafety-related piping up to the last orthogonal support is in the scope of license renewal.
In cases where seismic or equivalent anchors were not available to serve as the license renewal boundary, the following methods as provided for in NEI 95-10, Appendix F, were utilized to establish the license renewal boundary:
x A base-mounted component (e.g., pump, heat exchanger, tank, etc.) that is a rugged component and is designed not to impose loads on connecting piping was included in scope as it has a support function for the safety-related piping. The base-mounted equipment that serves as the equivalent anchor is in the scope of license renewal.
x A flexible connection that was considered a pipe stress analysis model end point, when the flexible connection effectively decouples the piping system (i.e., does not support loads or transfer loads across it to connected piping).
x A free end of nonsafety-related piping, such as a drain pipe that ends at an open floor drain.
x Nonsafety-related piping runs that are connected at both ends to safety-related piping. The entire run of nonsafety-related piping between the safety-related piping is in the scope of license renewal if no seismic anchors or equivalent anchors are available.
x A point where buried piping exits the ground. The buried portion of the piping is included in the scope of license renewal.
x A smaller branch line where the moment of inertia ratio of the larger piping to the smaller piping is such that the smaller branch line does not impose loads on the larger piping and does not support the larger piping.
An exception to NEI 95-10, Appendix F, was taken for the main steam and main feedwater piping. The main steam and main feedwater lines have an anchor in the reactor building-auxiliary building wall, and a torsional restraint in the auxiliary building-turbine building wall.
As discussed in Callaway FSAR-SP Section 3.6.2.1.1, the portion of the piping extending from the anchor to outside of the torsional restraint is defined as a "no break zone" (NBZ).
ULNRC-05946 January 10, 2013 Page 4 of 9 Callaway Plant Unit 1 License Renewal Application Breaks were not postulated in the NBZ because the maximum stress will not exceed 1.8 Sh per equation (9), Subarticle NC-3652 of ASME Section III when subjected to the combined loadings of internal pressure, deadweight, and postulated pipe break beyond the NBZ. For this piping, a break on the turbine building side of the torsional restraints will not prevent the piping on the auxiliary building side of the torsional restraints from accomplishing its intended function. Therefore, the piping in the turbine building connected to the main steam and main feedwater lines was not included within the scope of license renewal.
Nonsafety-Related SSCs Not Directly Connected to Safety-Related SSCs In accordance with NEI 95-10, Appendix F, Callaway applied the preventive option for 10 CFR 54.4(a)(2) scoping. The preventive option is based on scoping nonsafety-related SSCs not directly connected to safety-related SSCs within the scope of license renewal, which could lead to an interaction with safety-related SSCs. Mechanical nonsafety-related interactions with safety-related SSCs include high, moderate, and low energy fluid/steam spatial interaction and potential flooding of safety-related SSCs. Jet impingement, pipe whip, flood barriers, curbing, and pipe supports to prevent falling pipe are structural SSCs and are managed in the structural area.
Nonsafety-related SSCs that contain fluid or steam, and are located in the same room or area that contain safety-related SSCs are included in scope for leakage boundary (spatial) interaction under criterion 10 CFR 54.4(a)(2). The rooms and areas of concern for potential leakage boundary (spatial) interaction were identified based on a review of the CLB and design drawings and considered for potential communication with other rooms that may contain 10 CFR 54.4(a)(1) components. Plant walk downs were performed as necessary to confirm the spatial interaction boundaries.
The potential effects of flooding as a consequence of a pipe break or critical crack were reviewed to ensure that the intended function of safety-related equipment would not be impaired. Floor drains required for water removal from safety-related rooms and areas are within the scope of license renewal based on 10 CFR 54.4(a)(2).
Piping that contains air and gas (non-liquid) is not a hazard to other plant equipment, and has been determined not to have spatial interactions with safety-related SSCs. SSCs containing air or gas cannot adversely affect safety-related SSCs due to leakage or spray, since gas systems contain no fluids that could spray or leak onto safety-related systems causing shorts or other malfunctions and is not in-scope for spatial interaction. Callaway and industry operating experience has not identified failures due to aging that have adversely affected the accomplishment of a safety function. Gas systems do not contain sufficient energy to cause pipe whip or jet impingement. The nonsafety-related piping containing air or gas that are attached to safety-related SSCs are in scope for structural integrity (attached) consistent with NEI 95-10, Appendix F guidance.
ULNRC-05946 January 10, 2013 Page 5 of 9 Callaway Plant Unit 1 License Renewal Application Callaway Plant License Renewal Application Amendment 19 Revision to Section 2.3.4.3 and Table 2.3.4-3 to remove license renewal boundary drawing LR-CW-AE-M-22AE01 and to delete component types flow orifice, heat exchanger (feedwater heater), and pump in the main feedwater system.
Section 2.3.4.3 and Table 2.3.4-3 (page 2.3-91 through 2.3-93) are revised as follows (deleted text shown in strikethrough):
2.3.4.3 Main Feedwater System
System Description
The purpose of the main feedwater system is to receive condensate from the condensate system and deliver feedwater at required pressure, temperature, and flowrate to the four steam generators.
The main feedwater system consists of two turbine-driven feedwater pumps, a motor-driven start-up feedwater pump, high pressure feedwater heaters, feedwater control valves, system-medium regulated feedwater isolation valves, feedwater flow elements, and associated piping, valves and instrumentation.
System Intended Functions The main feedwater system provides containment isolation, feedwater isolation for reactivity control during accident conditions, and a flow path for auxiliary feedwater for decay heat removal. Therefore, the main feedwater system is within the scope of license renewal based on the criteria of 10 CFR 54.4(a)(1).
Portions of the main feedwater system are within the scope of license renewal as nonsafety-related affecting safety-related components based on the criterion of 10 CFR 54.4(a)(2) for spatial interaction and structural integrity.
Portions of the main feedwater system are within the scope of license renewal to support fire protection, environmental qualification, ATWS and station blackout requirements based on the criteria of 10 CFR 54.4(a)(3).
Callaway FSAR References Additional details of the main feedwater system are included in FSAR Section 10.4.7 SP.
ULNRC-05946 January 10, 2013 Page 6 of 9 Callaway Plant Unit 1 License Renewal Application License Renewal Boundary Drawings The license renewal boundary drawings for the main feedwater system are listed below:
LR-CW-AE-M-22AE01 LR-CW-AE-M-22AE02 Component-Function Relationship Table The component types subject to aging management review are indicated in Table 2.3.4 Main Feedwater System.
Table 2.3.4-3 Main Feedwater System Component Type Intended Function Closure Bolting Leakage Boundary (spatial)
Pressure Boundary Structural Integrity (attached)
Flow Element Pressure Boundary Flow Orifice Structural Integrity (attached)
Heat Exchanger (Feedwater Heater)
Structural Integrity (attached)
Insulation Insulate (Mechanical)
Piping Leakage Boundary (spatial)
Pressure Boundary Structural Integrity (attached)
Pump Structural Integrity (attached)
Solenoid Valve Pressure Boundary Tubing Pressure Boundary Valve Pressure Boundary Structural Integrity (attached)
The AMR results for these component types are provided in Table 3.4.2-3, Steam and Power Conversion Systems - Summary of Aging Management Evaluation - Main Feedwater System.
ULNRC-05946 January 10, 2013 Page 7 of 9 Callaway Plant Unit 1 License Renewal Application Callaway Plant License Renewal Application Amendment 19 Deleted flow orifice, heat exchanger (feedwater heater), and pump components. No new Plant Notes are added.
Table 3.4.2-3, Main Feedwater System (Page 3.4-41 through 3.4-43) is revised as follows (deleted text shown in strikethrough):
Table 3.4.2-3 Steam and Power Conversion System - Summary of Aging Management Evaluation - Main Feedwater System Component Type Intended Function Material Environment Aging Effect Requiring Management Aging Management Program NUREG-1801 Item Table 1 Item Notes Flow Orifice SIA Carbon Steel Secondary Water (Ext)
Wall thinning Flow-Accelerated Corrosion (B2.1.7)
VIII.D1.S-16 3.4.1.005 A
Flow Orifice SIA Carbon Steel Secondary Water (Ext)
Loss of material Water Chemistry (B2.1.2) and One-Time Inspection (B2.1.18)
VIII.D1.SP-74 3.4.1.013 A
Flow Orifice SIA Carbon Steel Secondary Water (Int)
Wall thinning Flow-Accelerated Corrosion (B2.1.7)
VIII.D1.S-16 3.4.1.005 A
Flow Orifice SIA Carbon Steel Secondary Water (Int)
Loss of material Water Chemistry (B2.1.2) and One-Time Inspection (B2.1.18)
VIII.D1.SP-74 3.4.1.013 A
Heat Exchanger (Feedwater Heater)
SIA Carbon Steel Plant Indoor Air (Ext)
Loss of material External Surfaces Monitoring of Mechanical Components (B2.1.21)
VIII.H.S-29 3.4.1.034 A
Heat Exchanger (Feedwater Heater)
SIA Carbon Steel Secondary Water (Int)
Wall thinning Flow-Accelerated Corrosion (B2.1.7)
VIII.D1.S-16 3.4.1.005 C
ULNRC-05946 January 10, 2013 Page 8 of 9 Callaway Plant Unit 1 License Renewal Application Component Type Intended Function Material Environment Aging Effect Requiring Management Aging Management Program NUREG-1801 Item Table 1 Item Notes Heat Exchanger (Feedwater Heater)
SIA Carbon Steel Secondary Water (Int)
Loss of material Water Chemistry (B2.1.2) and One-Time Inspection (B2.1.18)
VIII.D1.SP-74 3.4.1.013 C
Pump SIA Carbon Steel Plant Indoor Air (Ext)
Loss of material External Surfaces Monitoring of Mechanical Components (B2.1.21)
VIII.H.S-29 3.4.1.034 A
Pump SIA Carbon Steel Secondary Water (Int)
Loss of material Water Chemistry (B2.1.2) and One-Time Inspection (B2.1.18)
VIII.D1.SP-74 3.4.1.013 A
Pump SIA Stainless Steel Cast Austenitic Plant Indoor Air (Ext)
None None VIII.I.SP-12 3.4.1.058 A
Pump SIA Stainless Steel Cast Austenitic Secondary Water (Int)
Loss of material Water Chemistry (B2.1.2) and One-Time Inspection (B2.1.18)
VIII.D1.SP-87 3.4.1.016 A
Pump SIA Stainless Steel Cast Austenitic Secondary Water (Int)
Cracking Water Chemistry (B2.1.2) and One-Time Inspection (B2.1.18)
VIII.D1.SP-88 3.4.1.011 A
ULNRC-05946 January 10, 2013 Page 9 of 9 Callaway Plant Unit 1 Page A-49 License Renewal Application Appendix A Final Safety Analysis Report Supplement Table A4-1 License Renewal Commitments Item #
Commitment LRA Section Implementation Schedule 39 NFPA 805 and LRA GAP analysis:
A gap analysis of LRA Tables 2.3.3-20 and 3.3.2-20 will be provided to identify differences between the existing and NFPA 805 post-transition changes. The results and the impacts of these gaps on the fire protection program described in LRA Tables 2.3.3-20 and 3.3.2-20 will be summarized, as the basis for transitioning to the NFPA 805 nuclear safety capabilities. The summary will also list the fire protection systems and components including structural fire barriers, (e.g., fire walls and slabs, fire doors, fire barrier penetration seals, fire dampers, fire barrier coatings/wraps, equipment/personnel hatchways and plugs, metal siding), that will be added or removed based on the NFPA 805 transition in the scope of license renewal in accordance with 10 CFR 54.4(a) and whether they are subject to an AMR in accordance with 10 CFR 54.21(a)(1).
B2.1.13 B2.1.14 Prior to January 11 March 25, 2013.
If the draft NFPA 805 Safety Evaluation Report is not available in the Fall of 2012 February 2013, Ameren will provide an alternate schedule to address this commitment.
(Revised Amendment 19)