View source for L-08-212, Reply to Request for Additional Information for the Review of the License Renewal Application

{{Adams
| number = ML082060074
| issue date = 07/21/2008
| title = Reply to Request for Additional Information for the Review of the License Renewal Application
| author name = Sena P
| author affiliation = FirstEnergy Nuclear Generation Corp
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000334, 05000412
| license number = DPR-066, NPF-073
| contact person = 
| case reference number = L-08-212, TAC MD6593, TAC MD6594
| document type = Letter type:L
| page count = 113
| project = TAC:MD6593, TAC:MD6594
| stage = Response to RAI
}}

=Text=
{{#Wiki_filter:FENOC, FirstEnergyNuclear OperatingCompany PeterP. Sena III                                                                                     724-682-5234 Site Vice President                                                                             Fax: 724-643-8069 July 21, 2008 L-08-212                                                     10 CFR 54 ATTN: Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555-0001

==SUBJECT:==

Beaver Valley Power Station, Unit Nos. 1 and 2 BV-1 Docket No. 50-334, License No. DPR-66 BV-2 Docket No. 50-412, License No. NPF-73 Reply to Request for Additional Information for the Review of the Beaver Valley Power Station, Units 1 and 2. License Renewal Application (TAC Nos. MD6593 and MD6594),
and License Renewal Application Amendment No. 17 Reference 1 provided the FirstEnergy Nuclear Operating Company (FENOC) License Renewal Application (LRA) for the Beaver Valley Power Station (BVPS). Reference 2 requested additional information from FENOC regarding the BVPS license renewal integrated plant assessment in Sections 3.1.2.2, 3.2.2.2.3, 3.3.2.1 .X, 3.3.2.2, 3.3.2.3, 3.3.2.3-X, 3.4.2.2, 3.4.2.3, B.2, B.2.28, B.2.33, B.2.40, and B.2.41 of the BVPS LRA.
The Attachment provides the FENOC reply to the U.S. Nuclear Regulatory Commission request for additional information. The Enclosure provides Amendment No. 17 to the BVPS License Renewal Application.
There are no regulatory commitments contained in this letter. If there are any questions or if additional information is required, please contact Mr. Clifford I. Custer, Fleet License Renewal Project Manager, at 724-682-7139.
I declare under penalty of perjury that the foregoing is true and correct. Executed on July;_ ,2008.
Sincerely, Peter P. Sena III

Beaver Valley Power Station, Unit Nos. I and 2 L-08-212 Page 2

==References:==
: 1. FENOC Letter L-07-113, "License Renewal Application," August 27, 2007.
: 2. NRC Letter, "Request for Additional Information for the Review of the Beaver Valley Power Station, Units 1 and 2, License Renewal Application (TAC Nos.
MD6593 and MD6594)," June 5, 2008.

==Attachment:==

Reply to Request for Additional Information Regarding Beaver Valley Power Station, Units 1 and 2, License Renewal Application, Sections 3.1.2.2, 3.2.2.2.3, 3.3.2.1.X, 3.3.2.2, 3.3.2.3, 3.3.2.3-X, 3.4.2.2, 3.4.2.3, B.2, B.2.28, B.2.33, B.2.40, and B.2.41

==Enclosure:==

Amendment No. 17 to the BVPS License Renewal Application cc:  Mr. K. L. Howard, NRC DLR Project Manager Mr. S. J. Collins, NRC Region I Administrator cc:  w/o Attachment or Enclosure Mr. B. E. Holian, NRC DLR Director Mr. D. L. Werkheiser, NRC Senior Resident Inspector Ms. N. S. Morgan, NRC DORL Project Manager Mr. D. J. Allard, PA BRP/DEP Director Mr. L. E. Ryan, PA BRP/DEP

ATTACHMENT L-08-212 Reply to Request for Additional Information Regarding Beaver Valley Power Station, Units 1 and 2, License Renewal Application, Sections 3.1.2.2, 3.2.2.2.3, 3.3.2.1.X, 3.3.2.2, 3.3.2.3, 3.3.2.3-X, 3.4.2.2, 3.4.2.3, B.2, B.2.28, B.2.33, B.2.40, and B.2.41 Page 1 of 46 Section 3.1.2.2 Question RAI 3.1.2.2.7.1-1 The staff has determined that the applicant has credited: (1) the Water Chemistry Program to manage cracking due to stress corrosion cracking (SCC) in the bottom mounted instrumentation (BMI) guide tubes as a result of exposure to the components to the reactor coolant, and (2) the One-Time Inspection Program to verify the effectiveness of a Water Chemistry Program in precluding or mitigating cracking due to SCC in these components. The staff has also noted that, in the BVPS LRA, the applicant credits a combination of the Water Chemistry Program and the ASME Section XI Inservice Inspection, Subsection IWB, IWC, and IWD Program to manage cracking due to SCC on other stainless steel (including CASS) ASME Code Class 1 components that are exposed to the reactor coolant.
These BMI guide tubes are ASME Code Class 1 reactor coolant pressure boundary (RCPB) components. The staff requests that the applicant provide the following information with respect to the program that are credited for management of cracking in the BMI guide tubes. Part 1: Identify whether there is any applicable BPVS-specific in industry generic operating experience on cracking due to SCC of stainless steel PWR BMI guide tubes. Part 2: Provide your basis why a One-Time Inspection Program is justified to manage cracking due to SCC in the stainless steel BMI guide tubes in lieu of crediting a periodic condition monitoring program, such as the ASME Section XI, Subsections IWB, IWC, and IWD Program, particularly when the BMI guide tubes are categorized as an ASME Code Class 1 RCPB components.
RESPONSE RAI 3.1.2.2.7.1-1 FENOC has determined that the Beaver Valley Power Station (BVPS) ASME Section XI Inservice Inspection Subsections IWB, IWC, and IWD Program is applicable to the bottom-mounted instrumentation guide tubes. The BVPS License Renewal Application, (LRA), Table 3.1.2-1 is revised to replace row 2, which assigns the One-Time Inspection Program to manage cracking of the bottom-mounted guide tubes, with a row that assigns the ASME Section XI Inservice Inspection Subsections IWB, IWC, and IWD Program to manage cracking of the bottom-mounted guide tubes. Based on this change, LRA Table 3.1.1, row 23 and LRA Further Evaluation Section 3.1.2.2.7.1 are revised to identify the assignment of the ASME Section XI Inservice Inspection

Attachment L-08-212 Page 2 of 46 Subsections IWB, IWC, and IWD Program instead of the One-Time Inspection Program to manage cracking of the bottom-mounted guide tubes. Also, LRA Section 3.1.2.1.1, list of assigned programs, is revised to remove the One-Time Inspection Program from the list of aging management programs for the Reactor Vessel System, because there are no other component types in the system that credit the One-Time Inspection Program.
Part 1:
FENOC has not identified any plant-specific operating experience regarding cracking of the bottom-mounted instrument guide tubes. A search of the Institute for Nuclear Power Operations (INPO) Operating Experience database identified a 1989 event at Turkey Point in which transgranular stress corrosion cracking (TGSCC) was identified in several bottom-mounted instrument guide tubes. The cracking occurred above the seal table due to chloride contamination and intermittent wetting. Additionally, NRC Information Notice 2003-11, "Leakage Found on Bottom-Mounted Instrumentation Nozzles," describes axially-oriented cracks that were identified in two bottom-mounted instrumentation penetration nozzles at South Texas Project Unit 1. The utility concluded that the most likely root cause explanation for the degradation was
''manufacturing (welding) flaws resulting in excessive stress in the nozzle/weld material leading to crack initiation with low cycle fatigue/primary water stress corrosion cracking then supporting crack propagation."
Part 2:
FENOC is crediting the BVPS ASME Section XI Inservice Inspection Subsections IWB, IWC, and IWD Program as a periodic condition monitoring program for the bottom-mounted instrumentation guide tubes.
See the Enclosure to this letter for the revision to the BVPS LRA.
Question RAI 3.1.2.2.13-1 GALL AMR IV.C2-21 provides the staff's AMR recommendations for managing cracking due to pressurized water stress corrosion cracking pressurizer instrumentation penetrations, heater sheaths and sleeves, heater bundle diaphragm plate, and manways and flanges that are fabricated from Nickel-alloy materials or are designed with internal Nickel-alloy cladding. In WCAP-14574-A, "License Renewal Evaluation: Aging Management Evaluation for Pressurizers" (ADAMS ML010660292), as approved in the staff's safety evaluation of October 26, 2000 (ADAMS ML003763768), Westinghouse Electric Corporation (WEC) provides a generic design basis for Westinghouse-designed pressurizers.
In this report WEC identifies that the Nickel-alloy locations in Westinghouse-designed pressurizers are those for the safe end welds for the pressurizer safety,

Attachment L-08-212 Page 3 of 46 relief, spray and surge nozzles. In order to assist the staff in verifying whether or not GALL AMR IV.C2-21 is applicable to the BVPS LRA and to confirm the applicability of the generic conclusions in WCAP-1 5474-NP-A, clarify whether or not the BPVS design includes pressurizer instrumentation penetrations, heater sheaths and sleeves, heater bundle diaphragm plate, and manways and flanges that are made from Nickel-alloy materials or are designed with internal Nickel-alloy cladding. NOTE TO FENOC: The NRC reviewer did find some entries in the LRA that may correspondto some of these component commodity groups but the names did not match up exactly to the GALL names.
RESPONSE RAI 3.1.2.2.13-1 The only nickel alloy locations (materials or cladding) associated with the BVPS pressurizer components are the spray nozzle safe end welds (both units), the surge nozzle safe-end weld (Unit 2 only), and the safety and relief nozzle safe-end welds (both units). Aging management for these components are compared to NUREG-1801, "Generic Aging Lessons Learned (GALL) Report," row IV.C2-24, for cracking in LRA Table 3.1.2-3, rows 111, 112 and 113.
Question RAI 3.1.2.2.16.2-1 SRP-LR Section 3.1.2.2.16.2, in part, makes the following recommendation for pressurizer spray heads that are fabricated with Nickel-alloy structural/pressure retaining materials:
        "Fornickel alloy welded spray heads, the GALL Report recommends no further aging management review if the applicantcomplies with applicableNRC Orders and provide a commitment in the FSAR supplement to implement applicable(1) Bulletins and Generic Letters and (2) staff-accepted industry guidelines."
Clarify whether or not the CASS pressurizer spray heads are secured to the pressurizer upper head using a Nickel-alloy weld material. If Nickel-alloy welds are used as the basis for securing the CASS pressurizer spray heads to the upper pressurizer heads, provide your basis why the commitment mentioned SRP-LR Section 3.1.2.2.16.2 and in GALL AMR item IV.C2-17 has not been credited for aging management of cracking due to SCC and/or PWSCC in the pressurizer spray heads at BVPS.

Attachment L-08-212 Page 4 of 46 RESPONSE RAI 3.1.2.2.16.2-1 There are no nickel alloy components or weld material associated with the pressurizer spray heads within the pressurizers. The spray heads at both units are fabricated of cast austenitic stainless steel and are secured by threading to spray head couplings (pipes) and locking bars, which are fabricated of stainless steel. These components are compared to NUREG-1 801, row IV.C2-17, for management of cracking in LRA Table 3.1.2-3, rows 126 and 127. See also LRA Table 3.1.1, Item Number 3.1.1-36, and Further Evaluation Section 3.1.2.2.16.2.
However, the pressurizer spray nozzle safe end welds (external to the pressurizer upper head) at both units are nickel alloy, and are compared to NUREG-1801, row IV.C2-24, for management of cracking in LRA Table 3.1.2-3, items 111, 112, and 113. See also LRA Table 3.1.1, Item Number 3.1.1-31, and Further Evaluation Section 3.1.2.2.13.
FENOC provided commitments for the nickel-alloy components and nickel-alloy clad components in LRA Table A.4-1, "Unit 1 License Renewal Commitments," Item Number 15, and Table A.5-1, "Unit 2 License Renewal Commitments," Item Number 17, to develop a plant-specific aging management program that will implement applicable (1) NRC Orders, Bulletins and Generic Letters, and (2) staff-accepted industry guidelines.
Section 3.2.2.2.3 Question RAI 3.2.2.2.3.1-1 In LRA Section 3.2.2.2.3.1, FENOC indicates that the AMRs on loss of material due to pitting and crevice corrosion of stainless steel containment isolation piping components under exposure to a treated water environment would be handled by the Type "2" AMR tables for their parent system. However, the staff has noted that the AMRs on loss of material in LRA Tables 3.2.2-1 though 3.2.2-3, LRA Tables 3.3.2-1 through 3.3.2-32, and LRA Tables 3.4.2-1 through 3.4.2-10 do not specifically identify which of the AMR items in the tables, if any, cover management of loss of material in these containment isolation components.
Identify all plant systems that contain containment isolation system components that are within the scope of LRA Section 3.2.2.2.3.1 and which of the specific AMR items in LRA Tables 3.1.2-1 through 3.1.2-3, LRA Tables 3.2.2-1 though 3.2.2-3, LRA Tables 3.3.2-1 through 3.3.2-32, and LRA Tables 3.4.2-1 through 3.4.2-10, if any, cover the scope of the stainless steel containment isolation components that are addressed in LRA Section 3.2.2.2.3.1. Clarify which AMPs are credited to manage loss of material due to pitting and crevice corrosion in the containment isolation component surfaces that are exposed to treated water.

Attachment L-08-212 Page 5 of 46 RESPONSE RAI 3.2.2.2.3.1-1 LRA Section 3.2.2.2.3.1 and Table 3.2.1, Item 3.2.1-03, address loss of material for stainless steel containment isolation piping and components internal surfaces that are exposed to treated water. The only NUREG-1801 Volume 2 row that aligns to NUREG-1801, Volume 1, Table 2, Item 3, and to Further Evaluation 3.2.2.2.3.1, is row V.C-4. This NUREG-1801 row recommends management of loss of material by the NUREG-1801, Section XI.M2, "Water Chemistry," program, augmented by verification of effectiveness with the Section XI.M32, "One-Time Inspection," program.
BVPS does not have one single system that consolidates containment isolation components. Additionally, NUREG-1801, Section V.C, does not address some materials, environments, and aging effects associated with containment penetrations (NUREG-1801, Section V.C, does not address materials such as copper, used in compressed air systems, does not address environments such as raw water other than open-cycle cooling water, gas environments such as nitrogen or dried air, and treated borated water, and does not address aging effects such as cracking of stainless steel in any environment other than "Closed cycle cooling water"). Therefore, FENOC did not consider NUREG-1801, Section V.C, as a comprehensive reference section for aging evaluation comparisons, and used other NUREG-1 801 Chapters for aging comparisons of piping elements.
In addition to row V.C-4, NUREG-1801 contains 18 other rows in Sections IV,V, VII and VIII that address loss of material for stainless steel components in treated water. In each case, NUREG-1801 recommends the Section XI.M2, "Water Chemistry," and XI.M32, "One-Time Inspection," programs. For each instance of a stainless steel component in the "Treated water," "Treated water >600C (>140F),"' or "Treated water
>2500C (>4820 F)" environments in LRA Sections 3.1, 3.2, 3.3, and 3.4, FENOC credited the BVPS Water Chemistry and One-Time Inspection Programs with management of loss of material. Therefore, the containment penetration components in various systems that would have been compared to NUREG-1 801, row V.C-4, (and for which Further Evaluation Section 3.2.2.2.3.1 would have applied) for consistency with material, environment and aging effect, are consistent with the recommendations of NUREG-1801 row V.C-4 and NUREG-1 800, Section 3.2.2.2.3.1, for the assigned aging management programs.
Question RAI 3.2.2.2.3.3-1 In LRA Section 3.2.2.2.3.3, FENOC states that, while the recommendations in SRP-LR Section 3.2.2.2.3.3 are applicable only to the evaluation of loss of material in aluminum or stainless steel BWR emergency safety feature (ESF) piping, piping components, and piping elements that are exposed treated water, FENOC conservatively decided to use this SRP-LR section to further evaluate the

Attachment L-08-212 Page 6 of 46 potential for loss of material to occur in the BVPS stainless steel emergency safety feature (ESF) components that are exposed to a treated NaOH-based water environment (i.e., a hydroxide-based alkaline water environment). The staff noted that consistent with this SRP-LR guidance, FENOC credits its Water Chemistry Program to manage loss of material due to pitting and crevice corrosion in the BVPS chemical injection/addition pumps that are exposed to a treated NaOH-based water environment and its One-Time Inspection Program to verify the effectiveness of the Water Chemistry Program in managing this aging effect.
Part 1: Clarify why the NaOH-based treated water environment discussed in LRA Section 3.2.2.3.3 is considered to be the equivalent of the BWR treated water environment addressed in SRP-LR Section 3.2.2.2.3.3. Part 2: Clarify why the AMR for managing loss of material due to pitting and crevice corrosion is limited only to the stainless steel ESF systems that are exposed to the NaOH-based treated water, and of these systems, only to the surfaces of chemical injection or addition pumps that are exposed to the NaOH-treated water environment.
RESPONSE RAI 3.2.2.2.3.3-1 Part 1:
NUREG-1801, Section IX.D, "Selected Definitions and Use of Terms for Describing and Standardizing Environments," describes "Treated water" as demineralized water, which is the base water for all clean systems in BWRs and PWRs. The Electric Power Research Institute (EPRI) document EPRI-1010639 "Non-Class 1 Mechanical Implementation Guideline and Mechanical Tools," (EPRI Mechanical Tools) indicates that the common alkalis, such as caustic soda (sodium hydroxide - NaOH), are not particularly corrosive. Aging effects of components exposed to sodium hydroxide solutions used at nuclear power plants for pH control are no different than those for other water treatments except for the potential for caustic corrosion, and caustic cracking. The potential for caustic corrosion and caustic cracking is dependent upon both temperature and concentration of the NaOH. Austenitic stainless steels are very resistant to caustic corrosion in NaOH concentrations up to 50%. Austenitic stainless steels are susceptible to caustic cracking when NaOH concentrations exceed 25% and temperatures are above 212'F. NaOH concentrations do not exceed 25% in the BVPS Containment Depressurization System, and operating temperatures of the tanks do not exceed 125&deg;F. Therefore, neither caustic corrosion nor caustic cracking are aging effects requiring management for the components exposed to NaOH, and the aging effects for components exposed to the solution are equivalent to those for other treated water environments. Since the aging effects for the selected components exposed to the NaOH solution are equivalent to those for other treated water environments, then the comparison to the BWR treated water environment is considered to be acceptable.

Attachment L-08-212 Page 7 of 46 The applicable aging effects of loss of material due to pitting and crevice corrosion were identified for each of the components for which loss of material was compared to NUREG-1801, row V.D2-28. NUREG-1801, row V.D2-28, is the only row used in the BVPS LRA that links to Table 3.2.1-5, and to Further Evaluation Section 3.2.2.2.3.3.
Part 2:
The AMR results in LRA Table 3.2.2-1 that link to Section 3.2.2.2.3.3 through Table 3.2.1-5 are not limited only to stainless steel chemical injection or addition pumps that are exposed to NaOH-treated water. The first paragraph of LRA Section 3.2.2.2.3.3 was intended to address all treated water environments that are compared to NUREG-1 801, row V.D2-28, and which link to LRA Section 3.2.2.2.3.3 via Table 3.2.1-5, not just the NaOH-treated water environment. The first sentence of the second paragraph was intended to provide clarification for what a reviewer might consider to be an unusual match (i.e., the NaOH environment), and does not list all component types exposed to the NaOH-treated water environment. Piping, valve body and tank components in the Chemical Addition / Chemical Injection subsystem are also exposed to NaOH treated water. The text of LRA Section 3.2.2.2.3.3 is revised to include a discussion regarding the use of NaOH-treated water and the components that are exposed to the NaOH solution.
See the Enclosure to this letter for the revision to the BVPS LRA.
Question RAI 3.2.2.2.3.6-1 In LRA Section 3.2.2.2.3.6, FENOC credits its Internal Surfaces of Miscellaneous Piping and Ducting Program (LRA AMP B.2.28) to manage loss of material due to pitting and crevice corrosion in internal stainless steel tank surfaces of the emergency safety feature systems (i.e., in the containment depressurization systems and safety injection systems) as a result of exposure to condensation.
FENOC categorizes its Internal Surfaces of Miscellaneous Piping and Ducting Program as a new AMP that is entirely consistent with the program elements in GALL AMP XI.M38, "Inspection of Internal Surfaces of Miscellaneous Piping and Ducting," without exception or the need for enhancement. The staff has noted that the scope of GALL AMP XI.M38 is limited to visual inspections of the internal surfaces of steel (including carbon steel, alloy steel and cast irons) piping, piping elements, ducting, and components that are not addressed in other aging management programs, and that the scope of GALL AMP XIM38 does not include the internal surfaces of stainless steel components. Part 1: Identify which specific tank in the safety injection system is exposed internally to the condensation environment. Part 2:, Justify and provide your basis why the scope of the Inspection of Internal Surfaces of Miscellaneous Piping and Ducting Program is considered to be acceptable for managing the loss of material due to

Attachment L-08-212 Page 8 of 46 pitting and crevice corrosion in the stainless steel emergency safety feature (ESF) tank surfaces (including those in the RWSTs, chemical addition tanks, and the miscellaneous tank grouping in the SI system) under exposure to an internal condensation environment.
RESPONSE RAI 3.2.2.2.3.6-1 Part 1:
The specific tank in the safety injection system for which "Loss of material" is compared to NUREG-1801, row V.D1-29, and which is linked to LRA Section 3.2.2.2.3.6 via LRA Table 3.2.1-8, is the Unit I Boron Injection Surge Tank (1SI-TK-2, shown on LR Drawing 1-11-1, grid B-2, colored blue for the 10 CFR 54.4(a)(2) function).
Part 2:
The BVPS Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program is used to manage the internal surfaces of the tank at and above the normal waterline. While the NUREG-1801, Section XI.M38, "Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components," program description does not identify applicability to materials other than steel, similar inspections are capable of detecting loss of material from stainless steel surfaces prior to loss of the component intended function. Loss of material at or above the normal waterline is expected to result in surface irregularities of sufficient size as to be identified visually prior to loss of component function.
Section 3.3.2.2 Question RAI 3.3.2.2.6-1 LRA Section 3.3.2.2.6 provides your AMR further evaluation assessment for the boral and boraflex materials used in the BVPS spent fuel pool storage rack designs. In this section, FENOC states that reduction of neutron absorption capability is not an aging effect requiring management for the Boral coupons used in the BPVS Unit 1 spent fuel storage rack design. The staff has verified that, in AMR item 3.3-13 of LRA Table 3.3.1, the applicant identifies that loss of material is an applicable aging effect requiring management (AERM) for boral coupons used in the design of the BVPS Unit 1 spent fuel storage racks. The staff is of the opinion that loss of material in the Boral materials may impact the neutron absorption capability of the Boral coupons used in the spent fuel storage rack designs. Part 1. Justify why reduction of neutron absorption capability has not been identified as an AERM for the Boral materials used in the design of the BVPS Unit 1 spent fuel pool storage racks, particularly when loss of material has

Attachment L-08-212 Page 9 of 46 been identified as an AERM for this material. Part 2. Justify why a one-time inspection of the Boral coupons has not been credited and coupled to the Water Chemistry Program, in order to confirm that the Water Chemistry Program is effective in managing potential loss of material, and possibly reduction of neutron absorption capability, in the Boral coupons.
RESPONSE RAI 3.3.2.2.6-1 Part 1:
The loss of material aging effect for Boral identified by FENOC is associated with the aluminum cladding, not with the boron carbide neutron absorber material sandwiched within the cladding.
Boral in the Unit 1 spent fuel pool rack walls is credited with maintaining sub-criticality with keff < 0.95 for stored fuel. Boral is a neutron absorbing material of a uniformly dispersed mixture of boron carbide and aluminum powders, clad in aluminum sheets, and hot-rolled to produce an integral three-layer panel. No aging effects have been identified in the industry that affect the boron carbide's neutron absorption function.
FENOC used the EPRI Mechanical Tools to determine that the aluminum cladding of Boral may be susceptible to pitting and/or crevice corrosion in treated water.
Aluminum develops a strongly-bonded oxide film, which gives it excellent corrosion resistance in many environments. This film is quite stable in neutral and many acidic solutions, but is attacked by alkalis. Aluminum alloys exhibit negligible action in boric acid solutions. The normal environment of the Unit 1 spent fuel pool is borated water.
FENOC credits the Water Chemistry Program to manage loss of material by maintaining chemistry parameters within the normal range in which aging effects are negligible.
NRC Mermo, "Resolving Spent Fuel Storage Pool Action Plan Issues" (July 26, 1996; Attachment, Section 3.3.1), concludes that degradation of neutron absorption performance has not been observed in materials other than Boraflex for any operating reactors in the United States. Potential aging effects resulting from sustained irradiation of Boral were previously evaluated by the NRC (BNL-NUREG-25582, dated January 1979) and determined to be insignificant. Therefore, reduction of neutron absorption is not an aging effect requiring management for Boral in a treated water environment.
Part 2:
FENOC credited only the Water Chemistry Program to manage loss of material of Boral aluminum cladding because the EPRI Mechanical Tools indicate that aluminum alloys exhibit negligible corrosion in boric acid solutions. NUREG-1801 does not address aluminum in treated borated water, so FENOC considered stainless steel in treated borated water to be an analogous combination for NUREG-1801 comparison of aging management for this issue. NUREG-1801, rows V.A-27 and V.D1-30,

Attachment L-08-212 Page 10 of 46 recommend management of loss of material due to pitting and crevice corrosion for some stainless steel components in treated borated water environments (including components with low or stagnant flow, such as tanks) with the Water Chemistry Program, and without verification by a One-time Inspection Program. Therefore, FENOC considered the assignment of the Water Chemistry Program without the additional assignment of a One-Time Inspection Program to have precedent in NUREG-1801 for management of loss of material in treated borated water.
As described in Part 1 of this response, industry operating experience has not identified degradation of neutron absorption performance for Boral', and the BVPS aging management reviews did not identify reduction of neutron absorption as an aging effect requiring management. Since reduction of neutron absorption was not identified as an aging effect requiring management, FENOC did not assign a program to manage the effect. However, the 1993 Safety Evaluation Report for BVPS Unit 1 License Amendment 178 that supported the Unit 1 fuel pool rerack (and installation of Boral) includes a commitment for a Boral Surveillance Program that will characterize the performance of the Boral panels during the remaining life time of the plant. The surveillance program calls for removing and testing one coupon from the mounting jacket at the following intervals relative to the installation of the racks: 1st cycle, 2nd cycle, 4th cycle, 7th cycle, 10th cycle, 20th cycle, 30th cycle, and 40th cycle. Each coupon, upon its removal from the mounting jacket, is required to be analyzed according to the following tests:
     " Visual Observation and Photography
     " Neutron Attenuation
     " Dimensional Measurements (length, width, and thickness)
     " Weight and Specific Gravity The neutron attenuation and the dimensional measurements are used to determine whether or not the coupons are exhibiting any signs of boron loss or structural deformation, respectively. The gravimetric analyses are performed to augment the results of the neutron attenuation studies should boron loss be indicated.
The BVPS operating experience from this program includes identification of coupon blistering, as well as oxidation that did not appear to be progressing. The evaluation of these results considered the potential for these effects to have an impact on the neutron absorption properties, and concluded that the results of the tests were indicative of satisfactory material performance. No changes to the current surveillance interval are planned. The next set of coupons are scheduled to be removed, inspected and tested in 2011, and are required to be compared to previous test results and other available industry OE at that time. While this program is not credited for License Renewal, the commitment for the program under the current licensing basis will remain in effect. Since the 40th cycle after installation occurs

Attachment L-08-212 Page 11 of 46 roughly 60 years after installation of the Boral, the planned program duration exceeds the end of the period of extended operation.
Question RAI 3.3.2.2.13-1 Part 1. Provide your technical basis why the internal and external surfaces of elastomeric seals or components in the control area and plant area ventilations systems would not be subject to the mechanical aging mechanism of wear or abrasion. Part 2. Using the information in Part I of this question and any other relevant information, provide your basis on whether or not GALL AMR items VII.F1 -5 and VII.F1 -6 (as applicable to the management of loss of materiallwear in external and internal elastomeric seal or component surfaces of control room area ventilation systems under exposure to indoor air) are applicable to the BPVS LRA and whether or not GALL AMR items VII.F2-5, VII.F2-6, VII.F3-5, VII.F2-6, VII.F4-4, and VII.F4-5 (as applicable to the management of loss of material/wear in external and internal elastomeric seal or component surfaces of the plant area ventilation systems]) are applicable to the BVPS LRA.
RESPONSE RAI 3.3.2.2.13-1 Part 1:
FENOC used the EPRI Mechanical Tools and EPRI-1002950, "Aging Effects for Structures and Structural Components (Structural Tools)," supplemented by operating experience reviews, to identify potential aging effects for material-environment combinations. In the EPRI Mechanical and Structural Tools, "wear" is evaluated as a design consideration, rather than an aging effect. Instances of significant wear or fretting are not related to normal aging, and are expected to manifest well before the period of extended operation and be corrected. As such, it is expected that loss of material due to wear or fretting from normal plant operations is insufficient to result in loss of component function during the period of extended operation. The EPRI Tools do not specifically consider loss of material due to wear or abrasion to be applicable aging mechanisms for internal or external surfaces of elastomers, but recommends plant-specific consideration for the potential that loss of material due to wear may occur.
FENOC's review of plant-specific operating experience did not identify any elastomeric components for which loss of material due to wear was determined to be an additional aging effect that required management.
Part 2:
As described in Part 1 of this response, FENOC did not identify loss of material due to wear to be an applicable aging effect requiring management for elastomeric components. As a result, NUREG-1801, rows VII.F1-5, VII.F1-6, VII.F2-5, VII.F2-6,

Attachment L-08-212 Page 12 of 46 VII.F3-5, VII.F3-6, VII.F4-4 and VII.F4-5, which all address loss of material due to wear for elastomers, are not applicable to the BVPS LRA. It should be noted, however, that the aging effects of "Cracking" and "Hardening and loss of strength" were identified as aging effects requiring management for the external surfaces of elastomeric flexible ventilation connections that are subject to aging management review. As identified in the FENOC response to RAI-3.3.2.3-1 / 3.4.2.3-1, other elastomeric components in LRA Sections 3.1, 3.2, 3.3, and 3.4 will be addressed by repetitive maintenance tasks such that they are classified as "short-lived" and not subject to aging management review per 10 CFR 54.21 (a)(1)(ii).
Question RAI 3.3.2.2.5.1-1/3.4.2.3-lA The staff has noted that FENOC is crediting its External Surfaces Monitoring Program to manage hardening and loss of strength in: (1) the elastomeric auxiliary system components that are exposed, either internally or externally, to uncontrolled indoor air or to dry air, and (2) the elastomeric flexible hoses in the auxiliary feedwater system (a steam and power conversion system) that are exposed externally to uncontrolled indoor air. GALL AMP XI.M36, "External Surfaces Monitoring," pertains to the external surfaces of steel components in systems that are within the scope of license renewal and are subject to AMRs for loss of material and leakage. The GALL program does not apply to elastomeric components or to the management of material property changes (including hardening or loss of strength) in elastomeric components. Justify your basis for crediting the External Surfaces Monitoring Program to manage hardening and loss of strength in: (1) the elastomeric auxiliary system seals or components that are exposed, either internally or externally, to uncontrolled indoor air or to dry air, and (2) the elastomeric flexible hoses in auxiliary feedwater system that are exposed externally to uncontrolled indoor air. Using a technical basis, clarify how a visual examination is considered to be capable of demonstrating that a change in a elastomeric material property is occurring, including a potential change in the hardness property or strength property of each elastomeric material that are used in the fabrication of these components.
RESPONSE RAI 3.3.2.2.5.1-1/3.4.2.3-1A Part 1:
The BVPS External Surfaces Monitoring Program implements aging management elements described in the NUREG-1801, XI.M36, "External Surfaces Monitoring,"
program. Additionally, the BVPS External Surfaces Monitoring Program contains increased scope beyond the NUREG-1801 program to include aging management of elastomeric ventilation flexible connections. This increased scope includes new inspection activities in addition to the visual inspections, such as physical manipulation

Attachment L-08-212 Page 13 of 46 of elastomeric components, to identify aging effects that are unique to elastomers. A visual examination alone is insufficient to identify hardening and loss of strength, and may not be sufficient to identify cracking. FENOC did not originally identify the elastomer increased scope nor include an evaluation of the 10 program elements related to the increased scope in the External Surfaces Monitoring Program discussion in Appendix B of the LRA.
LRA Section B.2.15 is revised to include the following 10-element summary description for the aging management of elastomeric components by the BVPS External Surfaces Monitoring Program:
* Scope of Program In addition to the program scope describedin NUREG-1801, Section XLM36, the External Surfaces Monitoring program will require monitoring of the external surfaces of flexible elastomeric connections in ventilation systems for cracking and for hardening and loss of strength. The program is also credited with managing these aging effects for the internalsurfaces of these components, in which both the internaland external surface environments are ambient or dry air.
" Preventive Actions The External Surfaces Monitoring Programis a monitoring program that does not include preventive actions.
" ParametersMonitored or Inspected In addition to the parametersspecified by the NUREG-1801, Section XI.M36 program, the External Surfaces Monitoring program will require the use of periodic plant system inspections and walkdowns to monitor for materialdegradationof elastomeric flexible connections in ventilation systems. These inspections include a visual inspection coupled with physical manipulation of elastomeric components to identify aging parameterssuch as cracks, hardeningand loss of strength.
" Detection of Aging Effects In addition to the detection methods specified by the NUREG-1801, Section XI.M36 program, the External Surfaces Monitoring program will require a periodic visual inspection, coupled with physical manipulationof in-scope elastomeric ventilation components, to identify cracking, hardeningand loss of strength.
Physical manipulation of elastomeric components, such as by pinching or prodding flexible connections in ventilation systems, will aid in identification of elastomer aging effects. Cracking of elastomeric components becomes evident at the outside radius of elastomer deformations as the cracks open. Changes in materialproperties,such as hardeningand loss of strength, can be detected during manipulationof elastomeric components by the relative inflexibility of the component, or by the

Attachment L-08-212 Page 14 of 46 failure of the component to return to its previous shape or configuration.
Additionally, since the external environment of ventilation systems is similarto the internalenvironment, the condition of the external surface is expected to be representative of the internalsurface condition.
Monitoring and Trending In addition to the monitoring and trending specified by the NUREG-1801 Section XI.M36 program, the External Surfaces Monitoringprogram will require a periodic visual inspection, coupled with physical manipulation of in-scope elastomeric components to identify cracking, hardeningand loss of strength. The program provides qualification requirementsfor personnel associatedwith visual inspection and physical manipulation of elastomers in accordance with FENOC procedures and processes.
* Acceptance Criteria In addition to the acceptance criteria specified by the NUREG-1801, Section XI.M36 program, the External Surfaces Monitoringprogram will provide acceptance criteria for elastomer inspections. The proposed program defines acceptance criteria as no unacceptable visual or tactile indication of leakage, hardening,loss of strength, or cracking that would lead to loss of intended function during the period of extended operation. Visual or tactile indications with respect to system design standards, proceduralrequirements, currentlicensing basis, industry codes or standards,and engineeringevaluations shall be evaluated by assignedengineeringpersonnel.
Evaluation of visual and tactile indications will determine whether the results are acceptable or if corrective action is required.
"  Corrective Actions This element is discussed further in LRA Section B. 1.3.
" Confirmation Process This element is discussed further in LRA Section B. 1.3.
" Administrative Controls This element is discussed further in LRA Section B. 1.3.
" Operating Experience BVPS has experienced leakage from flexible elastomeric hoses in the cooling water environment associatedwith diesel engines (both diesel generatorsand the diesel-driven air compressor), and in the lubricatingoil environment associatedwith the turbine oil purifier. Corrective actions for these conditions included hose replacementand administrative changes to ensure leakage does not result in inoperabilityof important equipment.

Attachment L-08-212 Page 15 of 46 BVPS has also identified a tear in an elastomeric ventilation flexible connection between a control room emergency fan and associatedductwork. The cause of the tear could not be identified. The tearmay have been caused by maintenance activities, aging, or it may have been present during initial installation. An evaluation of the consequences of the 3/8-inch by 1/8-inch slit determined that the consequences to system operation were insignificant.
The available operatingexperience relative to elastomers provides reasonable assurancethat visual inspection, coupled with physical manipulation, is sufficient to identify aging effects in elastomeric components priorto loss of function.
Part 2:
As identified in the FENOC response to RAI-3.3.2.3-03 / 3.4.2.3-3, (with the exception of elastomeric flexible ventilation connections), FENOC will perform repetitive maintenance tasks prior to the period of extended operation, to replace the elastomeric components identified in LRA sections 3.1, 3.2, 3.3, and 3.4 such that those components are classified as "short-lived" and not subject to aging management per 10 CFR 54.21 (a)(1)(ii). The frequency of the repetitive tasks will be determined based upon manufacturer recommendations and operating experience. The flexible hoses in the auxiliary feedwater system are, therefore, classified as short-lived and excluded from aging management review.
See the Enclosure to this letter for the revision to the BVPS LRA.
Section 3.3.2.3/3.4.2.3 Question RAI 3.3.2.3-1/3.4.2.3-1 GALL Volume 2 Table IX.F, "Selected Definitions and Use of Terms for Describing and Standardizing - Aging Mechanisms," states that the scope of elastomeric degradation covers:
        "Degradationmay include cracking,crazing, fatigue breakdown, abrasion,chemical attacks, and weathering. [20, 21] Elastomer hardeningrefers to the degradationin elastic properties of the elastomer."
Justify your basis for concluding that loss of material due to wear (including wear induced by abrasion), chemical reaction/decomposition (including that induced by chemical attacks) or weathering are not aging effects requiring management (AERMs) for: (1) each elastomeric auxiliary system component that is exposed, either internally or externally, to uncontrolled indoor air or to dry air, and (2) the flexible hoses in the auxiliary feedwater system (a steam and power conversion

Attachment L-08-212 Page 16 of 46 system) that are exposed externally to uncontrolled indoor air. If any of these aging effects are determined be AERMs, clarify which AMP will be credited to manage the aging effect or effects in the elastomeric components that are exposed to these environments and justify why the AMP or AMPs credited for aging management is (are) considered to be valid for aging management.
NOTE: the issue on whether loss of materialdue to wear is an AERM for elastomeric components in the controlarea and plant area ventilation systems under exposure to uncontrolled indoorair has been addressedin RAI # 3.3.2.2.13-1; however, this question pertains,in part, to the management of wear in other auxiliarysystem elastomeric components that are exposed to this environment or to management of wear in elastomeric auxiliarysystem components exposed to dry air.
RESPONSE RAI 3.3.2.3-1/3.4.2.3-1 The potential for chemical degradation of elastomers (other than by exposure to oxygen or ozone) is limited to applications in which the component contains a liquid or gas other than air. As identified in the response to RAI-3.3.2.3-3 / 3.4.2.3-3, (with the exception of elastomeric flexible ventilation connections), FENOC will perform repetitive maintenance tasks prior to the period of extended operation, to replace the elastomeric components identified in LRA Sections 3.1, 3.2, 3.3, and 3.4 such that those components are classified as "short-lived" and not subject to aging management per 10 CFR 54.21 (a)(1)(ii). The frequency of the repetitive tasks will be determined based upon manufacturer recommendations and operating experience. The flexible hoses in the auxiliary feedwater system are, therefore, classified as short-lived and excluded from aging management review. The remainder of this response is applicable to elastomeric flexible ventilation connections.
FENOC used the EPRI Mechanical Tools and Structural Tools, supplemented by operating experience reviews, as the primary references to identify potential aging effects for material-environment combinations. In the EPRI Tools, "wear" is evaluated as a design consideration, rather than an aging effect. Instances of significant wear or fretting are not related to normal aging, and are expected to manifest well before the period of extended operation and be corrected. As such, it is expected that loss of material due to wear or fretting from normal plant operations is insufficient to result in loss of component function during the period of extended operation. The EPRI Tools do not specifically consider loss of material due to wear or abrasion to be applicable aging mechanisms for internal or external surfaces of elastomers. The EPRI Tools do, however, recommend plant-specific consideration for the potential that loss of material due to wear may occur. FENOC's review of plant-specific operating experience did not identify any elastomeric components for which loss of material due to wear was determined to be an additional aging effect that required management.

Attachment L-08-212 Page 17 of 46 Weathering of elastomers is addressed in the EPRI Structural Tools as an aging mechanism encompassed within the aging effect of "Change in material properties."
NUREG-1801, Section IX.F, "Selected Definitions and Use of Terms for Describing and Standardizing Aging Mechanisms," defines aging mechanisms that cause the aging effects. NUREG-1801, Section IX.F, groups "weathering" under "Elastomer degradation." NUREG-1801, IX.F, defines "weathering" as "Degradation of external surfaces of materials when exposed to outside environment." The BVPS LRA, Sections 3.1, 3.2, 3.3 and 3.4, do not contain elastomers in an air-outdoor environment.
Therefore, weathering is not applicable to the BVPS elastomeric components in mechanical systems that are subject to aging management review.
Question RAI 3.3.2.3-2/3.4.2.3-2 The staff has noted that FENOC is crediting its External Surfaces Monitoring Program to manage cracking in: (1) the elastomeric auxiliary system components that are exposed, either internally or externally, to uncontrolled indoor air or to dry air, and (2) the elastomeric flexible hoses in the auxiliary feedwater systems (i.e., subsystems of the steam and power conversion system grouping) that are exposed externally to uncontrolled indoor air. GALL AMP XI.M36, "External Surfaces Monitoring," pertains to the external surfaces of steel components in systems that are within the scope of license renewal and are subject to AMRs on loss of material and leakage. The GALL program does not apply to elastomeric components or to the management of cracking in elastomeric components.
Part 1: Justify your basis for crediting the External Surfaces Monitoring Program to manage cracking in: (1) the elastomeric auxiliary system components that are exposed, either internally or externally, to uncontrolled indoor air or to dry air, and (2) the flexible hoses in the auxiliary feedwater systems that are exposed externally to uncontrolled indoor air. Part 2: The FENOC External Surfaces Monitoring credits only visual examinations of the external seal surfaces to manage cracking in the elastomeric surfaces that are exposed, either internally or externally, to uncontrolled indoor air or dry air. Visual examination techniques in ASME Code Section XI, Article IWA-2000 credit only VT-1 visual examination techniques as being acceptable inspection techniques for managing cracking.
The FENOC program does not: (1) specify whether the visual examination techniques for cracking would be enhanced VT-1 techniques, or (2) explain how a visual examination of the external surface could be capable of detecting a subsurface crack or a crack that only penetrated the internal surface of the component. Thus, in your response to Part 1, include a technical basis on: (1) the specific visual examination technique that FENOC is crediting to manage cracking in these elastomeric components, and (2) on how the specific visual examination technique selected is capable of detecting a crack that may have initiated in these materials, particularly if the crack is categorized only as a subsurface flaw or an internal surface penetrating flaw.

Attachment L-08-212 Page 18 of 46 RESPONSE RAI 3.3.2.3-2/3.4.2.3-2 The responses to Parts 1 and 2 of the RAI are provided together, below.
As identified in the response to RAI-3.3.2.3-3 / 3.4.2.3-3, (with the exception of elastomeric flexible ventilation connections), FENOC will perform repetitive maintenance tasks prior to the period of extended operation, to replace the elastomeric components identified in LRA Sections 3.1, 3.2, 3.3, and 3.4 such that those components are classified as "short-lived" and not subject to aging management per 10 CFR 54.21 (a)(1)(ii). The frequency of the repetitive tasks will be determined based upon manufacturer recommendations and operating experience. The flexible hoses in the auxiliary feedwater system are, therefore, classified as short-lived and excluded from aging management review. The remainder of this response addresses aging management of elastomeric flexible connections in ventilation systems, which are the only remaining elastomeric components subject to aging management.
The FENOC External Surfaces Monitoring Program implements aging management elements described in the NUREG-1801, XI.M36 program. Additionally, the BVPS External Surfaces Monitoring Program contains increased scope beyond the NUREG-1801 program to include aging management of elastomeric ventilation flexible connections. This increased scope includes new inspection activities in addition to the visual inspections, such as physical manipulation of elastomeric components, to identify aging effects that are unique to elastomers. A visual examination alone is insufficient to identify hardening and loss of strength, and may not be sufficient to identify cracking.
FENOC did not originally identify the elastomer increased scope nor include an evaluation of the 10 program elements related to the increased scope in the External Surfaces Monitoring Program discussion in Appendix B of the LRA. A 10 element summary of the increased scope to address elastomers is provided in the FENOC response to RAI 3.3.2.2.5.1-1 / 3.4.2.3-1A.
Physical manipulation of elastomeric components will deform the material. Flexible ventilation connections can be pinched or pushed to create a bend. If cracks are present in elastomeric flexible ventilation connections, they will open on the outer radius of the bend and become more visible as the outer surface stretches to accommodate the bend. Cracks may not be apparent visually if the elastomer surface is not placed under tensile loading.
Aging of the internal surfaces of elastomers in ventilation systems is similar to that of the external surfaces. The environmental conditions that result in elastomer aging effects are related to temperature, ozone, and ultraviolet or ionizing radiation exposure.
External surfaces are more likely to be exposed to ultraviolet radiation than internal surfaces, and equally likely to be exposed to oxygen, and ozone. Temperature and ionizing radiation will affect the internal and external surfaces similarly. Therefore, the condition of the external surfaces of elastomers is expected to be representative of the internal surfaces. The External Surfaces Monitoring Program provides reasonable

Attachment L-08-212 Page 19 of 46 assurance that aging effects of elastomeric components will be identified by visual inspection of the external surfaces of elastomeric components, enhanced by physical manipulation, prior to loss of ventilation system function.
Question RAI 3.3.2.3-3/3.4.2.3-3 The staff has noted that FENOC includes the following plant-specific AMRs (i.e.
LRA Type "2" AMRs associated with Footnotes G) for the following elastomeric auxiliary system components or elastomeric steam and power conversion system (i.e., auxiliary feedwater system) components that are either exposed externally to air with borated water leakage, or to fuel oil, lubricating oil, or close-cycle cooling water:
Area Flexible         Pressure                   Air with borated Ventilation -                                     Elastomers Connection        Boundary                  water leakage - EXT Control Area Area Ventilation         Flexible        Pressure                    Air with borated Elastomers
        - Other         Connection        Boundary                  water leakage - EXT Auxiliary                           Pressure Flexible Hose                  Elastomers       Lubricating oil Feedwater                           Boundary Auxiliary                           Pressure                   Air with borated Flexible Hose                  Elastomers Feedwater                           Boundary                  water leakage - EXT Leakage Chemical and                                                       Air with borated Sight glass       Boundary    Elastomers Volume Control                                                    water leakage - EXT (spatial)
Pressure                Closed cycle cooling Compressed Air       Flexible Hose                  Elastomers Boundary                          water Pressure Compressed Air       Flexible Hose                  Elastomers           Fuel oil Boundary Pressure Compressed Air        Flexible Hose                  Elastomers       Lubricating oil Boundary

Attachment L-08-212 Page 20 of 46 Emergency Diesel                   Pressure Boundary Elastomers Flexible Hose Boundary                     Fuel oil Generators &
Support Emergency Diesel                   Pressure Flexible Hose            Elastomers    Lubricating oil Generators &                 Boundary Support Emergency Leakage Diesel Flexible Hose Boundary Elastomers      Lubricating oil Generators &
(spatial)
Support Emergency Diesel                   Pressure              Closed cycle cooling Flexible Hose            Elastomers Generators &                 Boundary                      water Support Security Diesel               Pressure              Closed cycle cooling Flexible Hose            Elastomers Generator                  Boundary                      water Security Diesel               Pressure Flexible Hose            Elastomers        Fuel oil Generator                  Boundary Security Diesel               Pressure Flexible Hose            Elastomers    Lubricating oil Generator                  Boundary Leakage Solid Waste                                         Air with borated Flexible Hose Boundary   Elastomers Disposal                                        water leakage - EXT (spatial)
Supplementary Leak Collection    Flexible   Pressure                Air with borated water leakage - EXT and Release    Connection   Boundary System

Attachment L-08-212 Page 21 of 46 In these AMRs, the applicant identifies that there are not any aging effects requiring management (AERMs) for the surfaces that are either exposed externally to air with borated water leakage, or to fuel oil, lubricating oil, or close-cycle cooling water. The fabrication method used to fabricate a particular elastomer (a type of polymetric material) is polymer-material specific. Examples include radiation induced polymerization, cationic or anionic polymerization (induced by acids or bases), or free-radical induced polymerization. These types of environments can also degrade, decompose, or change the material properties of a polymetric material, depending on the specific material composition of the polymer in question. The staff is concerned that the specific elastomeric materials used in fabrication of these auxiliary system components or steam and power conversion system components could be subject to aging, particularly if the specific environment could induce reactive conditions, such as those induced by acids (including boric acid), bases (lyes), radiation, free radicals, or heat. The staff seeks additional information regarding these AMRs.
Part 1: For those plant-specific Type "2" AMR items that do not specifically identify the specific elastomeric material of fabrication identify the specific elastomeric material (including polymer repeating chemical composition) used in the fabrication of the component listed in the AMR item.
Part 2: For each specific elastomeric material used in the fabrication of the elastomeric components, identify all environmental conditions (e.g., radiation, acidic conditions, basic [lye-based] conditions, exposure to organic fluids or solvents, free-radical conditions, etc.) that could potentially result in age-related degradation (e.g. cracking, etc.), in a change in a specific material property (e.g.,
hardening, reduction in elastic strength, loss of fracture toughness due to thermal aging embrittlement or radiation embrittlement, etc.), or chemical reaction/chemical decomposition of the specific elastomeric material.
Part 3: For each specific elastomer material-environment used in the particular AMR, discuss whether the particular environment to which the specific elastomeric material is exposed to can result in the environmental conditions and AERMs that have been addressed in your response to Part 2 of this question.
Provide specific technical details to support your determination of whether or not there are any AERMs for the specific component-elastomer material-environment combinations in these AMRs. If additional AERMs are applicable, clarify which AMP is credited for aging management and justify (using a technical basis) why the AMP or AMPs selected is (are) valid for the management of the applicable AERM or AERMs.

Attachment L-08-212 Page 22 of 46 RESPONSE RAI 3.3.2.3-3/3.4.2.3-3 The BVPS LRA is revised to include a new License Renewal Future Commitment to address elastomeric components. With the exception of ventilation flexible connections, FENOC will perform repetitive maintenance tasks prior to the period of extended operation, to replace the elastomeric components identified in LRA Sections 3.1, 3.2, 3.3, and 3.4 such that those components are classified as "short-lived" and not subject to aging management per 10 CFR 54.21(a)(1)(ii). The frequency of the repetitive tasks will be determined based upon manufacturer recommendations and operating experience. Therefore, elastomeric flexible hoses and sight glasses associated with fuel oil, lubricating oil, and closed cycle cooling water will be included within preventive
,maintenance activities such that they are short-lived components and excluded from aging management. Elastomeric flexible connections in ventilation systems are long-lived and remain subject to aging management review.
The LRA is further revised to delete, as appropriate, the elastomeric component types, materials and aging effects from the LRA Table 2s and the summary lists of materials and environments in LRA Sections 3.1, 3.2, 3.3 and 3.4.
See the Enclosure to this letter for the revision to the BVPS LRA.
Part 1:
Elastomeric flexible connections within ventilation systems are fabricated of fiberglass, double coated with neoprene (polychloroprene).
Part 2:
EPRI Structural Tools, Section 7.1.1 , documents that, "Neopreneis chemically and structurallysimilarto natural rubber,and its mechanicalpropertiesare also similar. Its resistance to oils, chemicals, sunlight, weathering, aging and ozone is outstanding. It retainsits properties at temperatures up to 250&deg;F."
The EPRI Structural Tools identifies various changes in elastomer properties that FENOC corresponded to the aging effects identified as "cracking" and as "hardening and loss of strength" in NUREG-1801. The environmental conditions that result in elastomer aging effects are related to temperature, ozone, and ultraviolet or ionizing radiation exposure.
Part 3:
Neoprene is relatively insensitive to temperature, ozone, and ultraviolet and ionizing radiation exposure, but FENOC did not exclude the potential for the NUREG-1 801 aging effects of "cracking" and "hardening and loss of strength" for neoprene in aging

Attachment L-08-212 Page 23 of 46 evaluations. The presence of boric acid leakage does not result in additional aging effects for elastomers in general or neoprene specifically.
FENOC assigned both "Air-indoor uncontrolled" and "Air with borated water leakage" environments to in-scope components in areas containing borated water systems.
Where the external environment of "Air with borated water leakage" exists, the environment of "Air-indoor uncontrolled" is also evaluated. The elastomeric components identified in this RAI have aging effects of "Cracking," and "Hardening and loss of strength" identified in the "Air-indoor uncontrolled" environment. No additional aging effects were identified that are associated specifically with the Air with borated water leakage environment. No additional aging effects requiring management were identified in response to this RAI beyond those listed in the LRA in the Air-indoor uncontrolled environment.
Question RAI 3.3.2.3-4 In the LRA, FENOC includes the following plant-specific AMRs (i.e. LRA Type "2" AMRs associated with either Footnotes F, G, H, I, or J) for polymetric components in the auxiliary systems:
LRA LRA Table        LRA System                       Component         Material     Function Item Pressure 3.3.2-16         EDG Water Cooling          45    Piping            Polymer      Boundary Pressure 3.3.2-16         EDG Water Cooling          46    Piping            Polymer      Boundary 54   Sight Glass       Polymer      Pressure Boundary 3.3.2-16         EDG Water Cooling Pressure 3.3.2-16         EDG Water Coaling           55   Sight Glass       Polymer      Boundary Pressure 3.3.2-16         EDG Water Cooling           56   Sight Glass       Polymer      Boundary Emerg. Response                                                 Pressure 3.3.2-17                                     75   Piping            Polymer      Boundary Substation Emerg. Response                                                 Pressure 3.3.2-17                                     76   Piping            Polymer      Boundary Substation

Attachment L-08-212 Page 24 of 46 Emerg. Response                           Pressure 3.3.2-17                      77  Piping        Polymer Boundary Substation Pressure 3.3.2-18      Fire Protection  16 Flexible Hose Polymer Boundary Pressure 3.3.2-18      Fire Protection  17 Flexible Hose Polymer Boundary Leakage Reactor Plant 3.3.2-26                       10 Demineralizer Polymer Boundary Sampling Sys.
(Spatial)
Leakage Reactor Plant 3.3.2-26                       11 Demineralizer Polymer Boundary Sampling Sys.
(Spatial)
Leakage Reactor Plant 3.3.2-26                       12 Demineralizer Polymer Boundary Sampling Sys.
(Spatial)
Leakage Reactor Plant 3.3.2-26                      100 Tank          Polymer Boundary Sampling Sys.
(Spatial)
Leakage Reactor Plant 3.3.2-26                      101 Tank          Polymer Boundary Sampling Sys.
(Spatial)
Leakage Reactor Plant 3.3.2-26                      102 Tank          Polymer Boundary Sampling Sys.
(Spatial)
Leakage Reactor Plant 3.3.2-26                      110 Tubing        Polymer Boundary Sampling Sys.
(Spatial)
Security Diesel                           Pressure 3.3.2-29                      69  Piping        Polymer Boundary Generator Security Diesel                           Pressure 3.3.2-29                       70 Piping        Polymer Boundary Generator Security Diesel                           Pressure 3.3.2-29                       71 Piping        Polymer Boundary Generator

Attachment L-08-212 Page 25 of 46 Leakage 3.3.2-31        Solid Waste             51   Tank               Polymer     Boundary Disposal Sys.                                               (Spatial)
Solid Waste                                                 Leakage 3.3.2-31        Disposal Sys.           52   Tank               Polymer     Boundary (Spatial)
Solid Waste                                                 Leakage 3.3.2-31        Disposal Sys.           53   Tank               Polymer     Boundary (Spatial)
For these plant-specific AMRs, FENOC has identified that there are not any aging effects requiring management (AERMs). The fabrication method used to fabricate a particular polymetric material is polymer-material specific. Examples include radiation induced polymerization, cationic or anionic polymerization (induced by acids or bases), or free-radical induced polymerization. These types of environments can also degrade, decompose, or change the material properties of a polymetric material, depending on the specific material composition of the polymer in question. The staff is concerned that the specific polymetric materials used in fabrication of these auxiliary system components could be subject to aging, particularly if the specific environment could induce reactive conditions, such as those induced by acids (including boric acid), bases, radiation, free radicals, or heat. The staff seeks additional information regarding those AMRs for auxiliary system polymer components in which the applicant has not identified any AERMs.
Part 1: For those plant-specific Type "2" AMR items that do not specifically identify the particular polymetric material used in the fabrication of the component (e.g. halon, etc.), identify the polymetric material used to fabricate the polymer material for the component listed in the AMR item.
Part 2: For each specific polymetric material used in the particular AMR item, clarify whether the specific material is a elastomeric, thermoplastic, or thermoset material and identify all environmental conditions (e.g., radiation, acidic conditions, basic [lye-based] conditions, exposure to organic fluids or solvents, free-radical conditions, etc.) that could potentially result in age-related degradation (e.g. cracking, etc.), in a change in a specific material property (e.g.,
hardening, reduction in elastic strength, loss of fracture toughness due to thermal aging embrittlement or radiation embrittlement, etc.), or chemical reaction/chemical decomposition of the specific polymetric material.

Attachment L-08-212 Page 26 of 46 Part 3: For each specific polymer material-environment used in the particular AMR, discuss whether the particular environment to which the specific polymer material is exposed to can result in the environmental conditions and AERMs addressed in your response to Part 2 of this question. Provide specific technical details to support your determination of whether or not there are any AERMs for the specific component-polymer material-environment combinations in these AMRs.
RESPONSE RAI 3.3.2.3-4 FENOC has reviewed details associated with the various polymer components addressed in the LRA. Polymer hoses in the Halon fire protection subsystems are periodically tested and replaced on condition, and, therefore, are considered consumables as described in LRA Section 2.1.2.4.3.
The BVPS LRA is revised to include a new License Renewal Future Commitment to address the remaining polymer components. Specifically, with the exception noted in this response, FENOC will perform repetitive maintenance tasks prior to the period of extended operation, to periodically replace, or to periodically test and replace on condition, polymer components identified in LRA Sections 3.1, 3.2, 3.3 and 3.4 such that those components are classified as "short-lived" and not subject to aging management, per 10 CFR 54.21 (a)(1)(ii). The frequency of the repetitive tasks will be determined based upon manufacturer recommendations and operating experience.
The exception to testing/replacement of polymers by preventive maintenance is Geoflex-D piping used as the buried fuel oil piping in the Security Diesel Generator System and the Emergency Response Facility Substation System diesel generator fuel oil systems.
The LRA is further revised to delete, as appropriate, the polymer component types, materials and aging effects from the LRA Table 2s and the summary lists of materials and environments in LRA Sections 3.1, 3.2, 3.3 and 3.4.
See the Enclosure to this letter for the revision to the BVPS LRA.
Part 1:
The Geoflex-D piping is a double-walled, flexible piping system designed for direct burial. GeoFlex pipe is a totally-bonded, multi-layer composite construction with braided fiber reinforcement. The inner-most Kynar (polyvinylidene fluoride) barrier layer is impermeable to diesel fuel. The exterior has a nylon barrier layer to protect the outer wall from chemical and microbial attack. Additional intermediate layers are made of polyethylene and nylon.

Attachment L-08-212 Page 27 of 46 Part 2:
Kynar, nylon and polyethylene are thermoplastics. FENOC used the EPRI Mechanical Tools to determine that polymers, such as those used in Geoflex piping, are either completely resistant to the fluid environment, or they deteriorate. Unlike metals, plastics do not display corrosion rates. Rather than depending upon an oxide layer for protection, plastics depend upon chemical resistance to the environment to which they are exposed. Acceptability for the use of plastics within a given environment is a design-driven criterion; once the appropriate material is chosen, the system will have no aging effects due to exposure to the contained fluid. Chemical decomposition due to exposure to ozone and ultraviolet or ionizing radiation is a potential aging effect for some polymers.
Part 3:
The materials of construction of GeoFlex piping were specifically chosen for use in transporting fuel oils and for direct burial. The product is Underwriters Laboratories (UL) listed for this application. The soil environment precludes exposure to ozone and to ultraviolet and ionizing radiation. An April 22, 1997, U.S. Environmental Protection Agency Memo (from Anna Hopkins Virbick, Director, Office of Underground Storage Tanks, to Environmental Protection Agency UST/LUST Regional Program Managers and State UST Program Managers - 

==Subject:==
Transmittal of Survey of Flexible Piping Systems) transmitted the results of a survey of flexible piping used in underground fuel oil delivery systems, and included evaluation of GeoFlex operating experience. The survey concluded that problems with the systems have been infrequent, and the performance of the technology has been excellent. Based on this review of industry operating experience and the use of proper design and application of the material, GeoFlexu piping materials with internal fuel oil and external buried (soil) environments do not exhibit aging effects requiring management.
Section 3.4.2.2 Question RAI 3.4.2.2.6-1 In the BVPS LRA, the Type "2" AMRs aligning to AMR item 14 in Table 4 of the GALL Report, Volume 1: (1) do not differentiate between which of the AMRs for stainless steel or Nickel-alloy steam and power conversion system components are exposed the treated water (greater than 60 &deg;C [140 OF]) environment and which are exposed to the steam environment, and (2) do not include any AMRs aligning to AMR items VIII.C-2, VIII.E-30, VIII.E-38, or VIII.F-3 in the GALL Report, Volume 2.
Part 1: Identify which of the AMRs in LRA Tables 3.4.2-1 through -10 (as a collective Table grouping) aligning to AMR item 14 in Table 4 of the GALL Report, Volume 1, are for components that are exposed to the treated water (greater than 60 0C [140 &deg;F]) environment and which of these AMRs are for the components

Attachment L-08-212 Page 28 of 46 that are exposed to the steam environment. Part 2: Provide your basis why the Type "2" AMRs in LRA Tables 3.4.2-1 through -10 (as a collective Table grouping) do not include any AMR items that align to AMR items VIII.C-2, VIII.E-30, VIII.E-38, VIII.F-3, or VIII.G-33 in the GALL Report, Volume 2.
RESPONSE RAI 3.4.2.2.6-1 Part 1:
In License Renewal documentation, FENOC did not distinguish between components that contain treated water in the vapor phase and those that contain treated water in the liquid phase. FENOC used the "Treated water" environment to encompass the "Steam" environment. For stainless steel in which the temperature was above the threshold for cracking (whether liquid or vapor phase), FENOC used the environment name "Treated water >60 0 C (>140 0 F)." For cast austenitic stainless steel (CASS) in environments that exceed the threshold temperature for thermal embrittlement of CASS (whether liquid or vapor phase), FENOC used the environment name "Treated water >25000 (>4820 F)."
The environment names with temperature distinction were only applied to stainless steel to provide better consistency with NUREG-1801 (there are no NUREG-1801 rows for other materials in these environments). Aging effects associated with the lower temperature environments were considered matches to the higher temperature environments during NUREG-1801 comparisons (e.g., the aging effect "Loss of material" is applicable to Treated water >60TC (>140 0 F), although NUREG-1801 identifies "Loss of material" for Treated water, but Treated water >60 0C (>1400F) in NUREG-1801 is only associated with cracking). These environment names were chosen because they correspond to actual aging effect thresholds, and because they correspond exactly to the majority of NUREG-1 801 rows that could be used for aging evaluation comparison.
The FENOC aging evaluation method used the EPRI Mechanical Tools as the primary aging evaluation reference. In the EPRI Mechanical Tools, the "Treated water" environment definition includes (encompasses) the "Steam" environment. The material / aging effects / recommended program assignments in NUREG-1801, Chapter VIII, "Steam and Power Conversion System," for rows with "Steam" identified as the environment, include the following:
* Steel / Loss of material / Water Chemistry Program (PWR / BWR)
* Steel / Loss of material / Water Chemistry Program and One-Time Inspection Program (PWR / BWR)
    " Steel / Cumulative fatigue damage / TLAA
    " Steel / Wall thinning (loss of material in BVPS LRA) / Flow-Acceleration Corrosion Program
    " Nickel-based alloys / Loss of material / Water Chemistry Program (PWR)

Attachment L-08-212 Page 29 of 46
    " Stainless steel / Loss of material / Water Chemistry Program (PWR / BWR)
* Stainless steel / Cracking / Water Chemistry Program (PWR)
* Stainless steel / Cracking / Water Chemistry Program and One-Time Inspection Program (BWR)
Each of these rows has a corresponding NUREG-1801, Chapter VIII row for Treated water (or Treated water >60'C (>140'F) in the case of cracking), with the exception that NUREG-1801 rows for Treated water in Chapter VIII do not recommend the Water Chemistry Program without augmentation by verification with the One-Time Inspection Program. Therefore, the only difference in aging comparisons to NUREG-1801 by using "Treated water" terminology instead of "Steam", is that the One-Time Inspection Program is recommended by NUREG-1801 for comparisons to rows citing the Treated water environment, where that program might not be recommended if the rows cite the Steam environment.
Part 2:
FENOC did not align to the NUREG-1801 rows cited in the question for aging management comparisons because they are not applicable to BVPS. The material /
environment / aging effect / program combination, if present in the BVPS LRA, was also present in another NUREG-1801 section that was more appropriate. The bases for not selecting the questioned NUREG-1801 rows are:
    " VIII.C-2 applies to the Extraction Steam System, which is not within the scope of License Renewal at BVPS.
* VIII.E-30 and VIII.E-38 apply to stainless steel components in Treated water
        >60 0C (>140 0 F) in the Condensate system. No components that are subject to aging management within the BVPS Condensate system are exposed to an environment that exceeds 60'C (140'F).
    " VIII.F-3 applies to Steam Generator Blowdown System stainless steel heat exchanger components in an environment that is >60&deg;C (>140 0 F). There are no stainless steel heat exchanger components subject to aging management in the BVPS Steam Generator Blowdown System that are exposed to an environment that exceeds 600C (140 0 F).
    " VIII.G-33 applies to stainless steel components in the Auxiliary Feedwater System in Treated water >60 0 C (>140 0 F). BVPS does not have stainless steel components subject to aging management in the Auxiliary Feedwater system that are exposed to an environment that exceeds 60 0C (140 0 F) (piping connected to the Main Feedwater System exceeds that temperature, but it is made of steel, not stainless steel).

Attachment L-08-212 Page 30 of 46 Question RAI 3.4.2.2.7.1-1 In the BVPS LRA, the Type "2" AMRs aligning to AMR items 15 and 16 in Table 4 of the GALL Report, Volume 1, do not include any AMRs aligning to AMR items VIII.C-1, VIII.D1-1, VIII.E-4, VIII.F-12, VIII.F-27, or VIII.G17 in the GALL Report, Volume 2. Provide your basis why the Type "2" AMRs in LRA Tables 3.4.2-1 through -10 (as a collective Table grouping) do not include any AMR items that align to AMR items VIII.C-1, VIII.D1 -1, VIII.E-4, VIII.F-12, VIII.F-27, or VIII.G17 in the GALL Report, Volume 2.
RESPONSE RAI 3.4.2.2.7.1-1 FENOC did not align to the NUREG-1801 rows cited in the question for aging management comparisons because they are not applicable to BVPS. The material /
environment / aging effect / program combination, if present in the BVPS LRA, was also present in another NUREG-1 801 section that was more appropriate. The bases for not selecting the questioned NUREG-1801 rows are:
    " VIII.C-1 applies to the Extraction Steam System, which is not within the scope of License Renewal at BVPS.
    " VIII.D1-1 applies to aluminum Feedwater System components in a treated water environment. There are no aluminum components subject to aging management review in the BVPS Main Feedwater System.
    " VIII.E-4 applies to Condensate System heat exchangers. There are no heat exchangers in the BVPS Condensate System that are subject to aging management review.
* VIII.F-12 applies to aluminum components in the Steam Generator Blowdown System. There are no aluminum components subject to aging management review in the BVPS Steam Generator Blowdown System.
    " VIII.F-27 applies to Steam Generator Blowdown System stainless steel heat exchanger components. There are no stainless steel heat exchanger components subject to aging management in the BVPS Steam Generator Blowdown System.
    " VIII.G-17 applies to aluminum components in the Auxiliary Feedwater system.
There are no aluminum components subject to aging management review in the BVPS Auxiliary Feedwater System.

Attachment L-08-212 Page 31 of 46 Section 3.3.2.1.X Question RAI 3.3.2.1.X-1 In LRA Table 3.3.2-5, 3.3.2-25, and 3.3.2-26, the applicant provide a number AMR line items that align to LRA AMR 3.3.1-38 and to AMR item 18 in Table 3 of the GALL Report, Volume 1, and AMR item VII.E4-15 in Table VII of the GALL Report, Volume. These AMR line items are applicable to the following systems and stainless steel components:
    " BVPS Unit 2 batch tank - jacket heat exchanger in the chemical and volume control system
    " heat exchanger shells /channels in the radiation monitoring system and the reactor plant sample system
* piping components and valve bodies in the radiation monitoring system and the reactor plant sample system In these AMRs, the applicant credits its Water Chemistry Program and One-Time Inspection Program to manage cracking due to SCC in the components surfaces that are exposed to treated water (greater than 60 &deg;C [140 OF]) environment. The staff has noted that the guidance in GALL AMR VII.E4-15 is applicable to stainless steel piping componentslelements in BWR shutdown cooling systems and recommends in part that the BWR Stress Corrosion Cracking Program to manage cracking in these BWR components. The staff's requests additional clarification why it is valid to credit the One-Time Inspection to manage cracking due to SCC in these components and how the One-Time Inspection would be used to monitor for cracking in the components.
Part 1: Justify why it is valid to credit the One-Time Inspection Program in lieu of a periodic condition monitoring program that incorporates program element criteria that are analogous to those in GALL AMP XI.M7, "BWR Stress Corrosion Cracking." Part 2: Identify the type of inspection technique(s) will be used to detect cracking in these components, the sample size that will be used for the one-time inspection of these components, the acceptance criteria that will be used to evaluate inspection results, and the corrective actions that will be implemented (including assessing the need for crediting a periodic monitoring program for aging management) if relevant indications are determined to be unacceptable when assessed against the acceptance criteria for the examinations.

Attachment L-08-212 Page 32 of 46 RESPONSE RAI 3.3.2.1.X-1 Part 1:
The One-Time Inspection Program is sufficient to confirm that "cracking" is being adequately managed by the Water Chemistry Program.
FENOC used the EPRI Mechanical Tools as the primary aging evaluation reference.
Cracking due to stress corrosion cracking (SCC) may occur to stainless steel components in treated water environments at temperatures above 140'F if oxygen or chlorides are present in concentrations above thresholds. The BVPS Water Chemistry Program manages cracking by control of these contaminants. Therefore, the Water Chemistry Program is expected to manage cracking such that the aging effect does not occur, or is occurring very slowly. Consistent with the NUREG-1801 description of the XI.M32, "One-Time Inspection," program, the BVPS One-Time Inspection Program will provide verification of the effectiveness of the Water Chemistry Program in managing cracking in these components.
The FENOC methodology invoked for NUREG-1801 row assignment precluded comparison to a NUREG-1 801 row outside the "parent" chapter of the system if that row specified that "Further Evaluation" was required. This convention was selected to assist in the review process by assuring that reviewers of a given LRA-NUREG-1 801 section would not need to reference Further Evaluation text in another section; however, the methodology led to less than optimum row assignments on occasion.
In this particular case, the best fit for NUREG-1 801 row assignments for the components in question would have been in Chapter VIII, "Steam and Power Conversion System," for cracking of stainless steel in treated water >60&deg;C (>1400 F) that specify the Water Chemistry and One-Time Inspection Programs (NUREG-1 801 rows VIII.B1-5, VIII.C-2, VIII.D1-5, VIII.E-30, VIII.F-24 and VIII.G-33). These rows are related to various PWR system environments similar to the Auxiliary System in question and they have identical material, environment and aging effect/mechanism combinations; they are all managed through the Water Chemistry and One Time Inspection Programs.
Based on this discussion, it is valid to credit the combination of Water Chemistry and One-Time Inspection Programs to provide reasonable assurance that "cracking" is being adequately managed in lieu of a periodic condition monitoring program analogous
,to NUREG-1801, Section XI.M7, "BWR Stress Corrosion Cracking."

Attachment L-08-212 Page 33 of 46 Part 2:
The One-Time Inspection Program is a new program that is consistent with the NUREG-1 801, XI.M32 program. The following additional detail from the program element evaluation text is provided from the BVPS License Renewal Project program supporting documents:
" Detection of Aging Effects The proposed program will require the use of established NDE techniques, including visual, ultrasonic,and surface techniques that are performed by qualified personnel following procedures consistent with the ASME Code and 10 CFR Part 50, Appendix B. The inspection techniques will be consistent with the NUREG-1801, table titled "Examplesof ParametersMonitored or Inspected And Aging Effect for Specific Structure or Component." The program owner will determine the inspection techniques as appropriate.
The proposed program requires representativesamples of system and component populationsto be selected by the Programowner. Where practical,inspections focus on the bounding or lead components most susceptible to aging due to time in service, severity of operatingconditions, and lowest design margin.
" Acceptance Criteria Inspection findings (indication or relevant conditions of degradation)shall be evaluated by assignedengineeringpersonnel and would include considerationof design standards,industry codes or standards,etc. Evaluation of inspection findings shall determine that the results are acceptable or that corrective action is required.
" Corrective Actions BVPS quality assurance (QA) procedures, review and approvalprocesses, and administrative controls are implemented in accordancewith the requirementsof 10 CFR Part50, Appendix B. One of the potential corrective actions to address adverse conditions is assessing the need for a periodic monitoringprogram.
Section 3.3.2.3-X Question RAI 3.3.2.3-X LRA Table 3.3.2-30 includes AMR #109 on management of loss of material in CASS service water valve bodies that are exposed on the external surfaces to an outdoor air environment. In this AMR, the applicant credits its External Surfaces Monitoring Program to manage loss of material that may occur in the external valve body surfaces under exposure to this environment. The BVPS External

Attachment L-08-212 Page 34 of 46 Surfaces Monitoring Program in given LRA Section B.2.15 and is identified as a new AMP that is entirely consistent with the recommended program element criteria in GALL AMP XI.M36, "External Surfaces Monitoring," without exception to GALL or the need for program enhancement. The scope of GALL AMP XI.M36, "External Surfaces Monitoring," is currently limited to the inspection of steel (i.e.,
carbon steel, alloy steel, or cast iron) components in order to manage: (1) loss of material that may occur in the steel components as a result of general corrosion, pitting corrosion, or crevice corrosion, or (2) cracking in the coatings that may be to line the external surfaces of these steel components. The scope of GALL AMP XI.M36, "External Surfaces Monitoring," does not currently apply to the management of loss of material in the external surfaces of stainless steel components. Justify your basis for crediting the External Surfaces Monitoring Program to manage loss of material in the external surfaces of these stainless steel valve body components and for extrapolating the scope of GALL AMP XI.M36, "External Surfaces Monitoring," to the management of loss of material in external stainless steel component surfaces.
RESPONSE RAI 3.3.2.3-X Loss of material from an external surface of stainless steel (or other metals) will be evident by surface irregularities or localized discoloration before loss of function occurs.
Although materials other than steel are not discussed in NUREG-1 801 for this program, identification of the "Loss of material" aging effect for other metals is amenable to the same types of visual inspections. Therefore, inclusion of other metals was not considered an exception or an enhancement to NUREG-1801. The proposed BVPS External Surfaces Monitoring Program includes the following inspection parameters:
    " corrosion and material wastage (loss of material);
* leakage from or onto external surfaces;
    " worn, flaking, or oxide-coated surfaces;
* corrosion stains on thermal insulation; and,
    " protective coating degradation (cracking and flaking).
The proposed program provides qualification requirements for personnel associated with visual inspection activities in accordance with site-controlled procedures and processes.
Therefore, the BVPS External Surfaces Monitoring Program is capable of managing loss of material for stainless steel.

Attachment L-08-212 Page 35 of 46 Based on this discussion, LRA Section B.2.15, "External Surfaces Monitoring," is revised for clarity regarding loss of material from stainless steel or other metals.
See the Enclosure to this letter for the revision to the BVPS LRA.
Section B.2 Question RAI B.2-2 The staff has determined that the BVPS Unit I is scheduled to enter its 4 th 10-Year ISI interval on April 1, 2008 and that BVPS Unit 2 is scheduled to enter its 3 rd 10-Year ISI interval on August 29, 2008. The applicant is required under 10 CFR 50.55a to use the 2001 Edition of the ASME Code Section XI Edition, inclusive of the 2003 Addenda, for these 10-Year ISI Intervals. Given the fact that the 10-Year ISI Intervals will change during the license renewal review process, clarify which Edition of the ASME Code Section XI will be credited for those AMPs that credit (all or in part) the ASME Code Section XI for aging management of ASME Code Class components, structures, or supports.
RESPONSE RAI B.2-2 As the staff has noted, the ASME Code, Section Xl edition that will be in effect for the 4th (Unit 1) and 3rd (Unit 2) BVPS 10-Year Inservice Inspection Intervals is the 2001 Edition including the 2002 and 2003 Addenda. The 2001 Edition of the ASME Code, Section Xl, including the 2002 and 2003 Addenda, therefore, will be credited for aging management of ASME Code Class components and supports for the 4th (Unit 1) and 3rd (Unit 2) 10-Year Inservice Inspection Intervals for the following BVPS aging management programs:
    " B.2.2 - ASME Section Xl, Inservice Inspection, Subsections IWB, IWC, and IWD
* B.2.4 - ASME Section XI, Subsection IWF
* B.2.34 - Reactor Head Closure Studs Further updates to the ASME Code edition used by these programs will be governed by 10 CFR 50.55a.
The following ASME Code aging management programs reference the 1992 Edition with the 1992 Addenda, and are not currently on the same intervals as the B.2.2, B.2.4, and B.2.34 AMPs:
* B.2.3 - ASME Section Xl, Subsection IWE 0 B.2.5 - ASME Section Xl, Subsection IWL

Attachment L-08-212 Page 36 of 46 The ASME Code edition that will be used when these two aging management programs are updated will be in accordance with 10 CFR 50.55a.
Section B.2.28 Question RAI B.2.28-1 The staff has noted that the applicant's Nickel-Alloy Nozzles and Penetration Program does not have a specific corresponding program in Chapter XI of the GALL Report, Volume 2. As such, staff is of the opinion that, if the applicant is tying its basis for managing primary water stress corrosion cracking of a particular Nickel-Alloy component to the Nickel-Alloy Nozzles and Penetrations Program, the AMP would need to be defined as a plant-specific AMP for the application. Justify why AMP B.2.28, Nickel-Alloy Nozzles and Penetration Program, had not been identified as a plant specific AMP for the BVPS LRA and the program elements for the AMP provided in the application, consistent with the recommended program element criteria in Branch Position RSLB-01 in NUREG-1800, Revision 1, Volume 2.
RESPONSE RAI B.2.28-1 The BVPS LRA, Appendix B, "Aging Management Programs," Section B.2.28, "Nickel-Alloy Nozzles and Penetrations," was not intended to be a defined aging management program with 10 elements. Section B.2.28 was intended to identify a commitment, as specified in NUREG-1801. The commitment wording was included in Appendix B as a pointer and for ease of review.
To clarify the issue, BVPS LRA, Appendix B, Section B.2.28, and Appendix A, "Updated Final Safety Analysis Report Supplement," Section A. 1.28, "Nickel-Alloy Nozzles and Penetrations Program," are revised to delete the text in these LRA sections. The LRA is further revised such that other sections of the LRA that referenced these sections, including Table 3.1.2-1 and Table 3.1.2-3 in LRA Section 3.1, are revised to delete references to the aging management program, and to include references to the commitments provided in LRA Appendix A, Table A.4-1 (Unit 1), Item 15, and Table A.5-1 (Unit 2), Item 17.
See the Enclosure to this letter for the revision to the BVPS LRA.

Attachment L-08-212 Page 37 of 46 Question RAI B.2.28-2 LRA Tables 3.1.2-1 and 3.1.2-3 collectively identify that AMP B.2.28, "Nickel Alloy Nozzles and Penetrations," will be used to manage following components/commodity groups:
* Core support pad and guide lug
    "   Nozzle (Unit 2 inlet/outlet safe end weld)
    "   Penetration (Bottom - instrument tube)
* Vessel shell (Flange leak detection tube)
    "   Flexible hose (Unit 2)
    "   Steam generator (Drain tube - Unit 2 only)
    "   Steam generator (Primary safe end weld)
* Steam generator (Tubesheet)
Clarify whether or not these are the commodity groups that are within the scope of LRA B.2.28, "Nickel Alloy Nozzles and Penetrations," LRA UFSAR Supplement Section, A.1.28, and the scope of LRA Commitment No. 15 for Unit 1 and Commitment No. 17 for Unit 2, as subject to the unit identification clarifications in the commodity group descriptions.
RESPONSE RAI B.2.28-2 In FENOC response to RAI-B.2.28-1, LRA Section B.2.28, and Appendix A, Section A.1.28, are revised to delete the text in these LRA sections. The LRA is further revised such that the component types / commodity groups listed by the NRC in this RAI and included in LRA Tables 3.1.2-1 and 3.1.2-3 are revised to delete references to the aging management program, and to include references to the commitments provided in LRA Appendix A, Table A.4-1 (Unit 1), Item 15, and Table A.5-1 (Unit 2), Item 17.
In addition to the components / commodity groups listed by the NRC in this RAI, the component type "Pressurizer (Safe end welds)" should be included in the list of components that will be managed by the Nickel Alloy Nozzles and Penetrations Program. The "Pressurizer (Safe end welds)" component type (LRA Table 3.1.2-3, Item No. 112) is included in the LRA revisions described above and in the FENOC response to RAI-B.2.28-1.
See the Enclosure to this letter for the revision to the BVPS LRA.

Attachment L-08-212 Page 38 of 46 Question RAI B.2.28-3 Part A: Clarify whether NRC Bulletin 2003-02, and NRC Bulletin 2004-01, the FENOC's letter replies made in response to these Bulletins, and any regulatory commitments contained in these Bulletin responses are within the scope of the applicant's Nickel-Alloy Nozzles and Penetrations Program and the particular license renewal commitment or commitments for this program (i.e., to either LRA Commitment No. 15 for BVPS Unit 1 and/or LRA Commitment No. 17 for BVPS Unit 2). Part B ; Clarify whether the FENOC letter of February 27, 2007 and any regulatory commitments or actions made in this letter, and staffs basis for approval in the NRC's Confirmatory Action Letter to FENOC of March 20, 2007, are within the scope of the applicant's Nickel-Alloy Nozzles and Penetrations Program and the applicable license renewal commitment or commitments for this program, as made relevant to BVPS in the March 20, 2007 response letter.
Part C: identify any additional NRC generic communications, and BVPS specific commitments made in response to these additional generic communications that are within the scope of the applicant's Nickel-Alloy Nozzles and Penetrations Program and the applicable license renewal commitments for this program (i.e.,
to Commitment No. 15 for BVPS and/or to Commitment No. 17 for BVPS Unit 2).
RESPONSE RAI B.2.28-3 The responses to Parts A, B, and C of the RAI are provided together, below.
In response to RAI-B.2.28-1, LRA Section B.2.28, and Appendix A, Section A.1.28, are revised to delete the text in these LRA sections. The LRA is further revised such that the applicable component types in LRA Tables 3.1.2-1 and 3.1.2-3 are revised to delete references to the aging management program, and to include references to the commitments provided in LRA Appendix A, Table A.4-1 (Unit 1), Item 15, and Table A.5-1 (Unit 2), Item 17.
See the Enclosure to this letter for the revision to the BVPS LRA.
The FENOC responses to NRC Bulletin 2003-02, "Leakage from Reactor Pressure Vessel Lower Head Penetrations and Reactor Coolant Pressure Boundary Integrity,"
NRC Bulletin 2004-01, "Inspection of Alloy 82/182/600 Materials Used in the Fabrication of Pressurizer Penetrations and Steam Space Piping Connections at Pressurized-Water Reactors," and other NRC letters and communications, and the Regulatory Commitments made by FENOC in these responses, are implemented at BVPS as part of the current licensing basis. Industry research associated with nickel alloy components and the recommended management techniques are still evolving. As such, FENOC has not submitted any corresponding aging management program for license renewal. Instead, as specified in NUREG-1801, FENOC included License Renewal Future Commitments in the BVPS LRA, Tables A.4-1, Item 15, and Table

Attachment L-08-212 Page 39 of 46 A.5-1, Item 17, for Unit 1 and Unit 2, respectively, to develop a plant-specific aging management program prior to the period of extended operation that will implement applicable NRC Orders, Bulletins and Generic Letters; and, staff-accepted industry guidelines.
Section B.2.33 Question RAI B.2.33-1 The staff noted that, in LRA Table 3.1.2-2, "Reactor Vessel Internals - Summary of Aging Management Review," the applicant credits its PWR Vessel Internals as the basis for managing applicable aging effects for a significant number of RV internal commodity groups at BVPS Units 1 and 2. The staff also noted that the applicant's PWR Vessel Internals Program for the BVPS application does not have a specific corresponding program in Chapter Xl of the GALL Report, Volume 2. As such, staff is of the opinion that, if the applicant is tying its basis for aging management to the applicant's PWR Vessel Internals Program, the AMP would need to be defined as a plant-specific AMP for the application. Provide your basis why the AMP B.2.33, PWR Vessel Internals Program, has not been identified as a plant specific AMP for the BVPS LRA and the program elements for the AMP provided for in the application, consistent with the recommended program element criteria in Branch Position RSLB-01 in NUREG-1800, Revision 1, Volume 2.
RESPONSE RAI B.2.33-1 BVPS LRA, Section B.2.33, "PWR Vessel Internals," was not intended to be a defined aging management program with 10 elements. Section B.2.33 was intended to identify a commitment, as specified in NUREG-1801. The commitment wording was included in Appendix B as a pointer and for ease of review.
To clarify the issue, BVPS LRA, Appendix B, Section B.2.33, and Appendix A, Section A.1.33, "PWR Vessel Internals Program," are revised to delete the text in these LRA sections. The LRA is further revised such that other sections of the LRA that referenced these sections are revised to delete references to the aging management program, and to include references to the commitments provided in LRA Appendix A, Table A.4-1 (Unit 1), Item 18, and Table A.5-1 (Unit 2), Item 20.
See the Enclosure to this letter for the revision to the BVPS LRA.

Attachment L-08-212 Page 40 of 46 Question RAI B.2.33-2 LRA Tables 3.1.2-2 identifies that AMP B.2.33, "PWR Vessel Internals," will be used for aging management of the following components/commodity groups:
Lower internals                                                         Lower        Upper Lower                        internals                   Lower assembly Lower internals                    Upper internals                  internals   internals internals      assembly        assembly (Unit 1       assembly                                                    assembly     assembly assembly        (Support           (Fuel lower     (Clevis insert  (Lower core                                  (Hold down      (Lower support          bolt)                         column)        alignment                core plate) plate)                                     spring) column                                                            pin) casting)
Upper                                                                                    Lower Lower    Upper internals        Lower       Upper     internals internals Lower internals       internals  assembly (Upper assembly                                                        internals    internals   assembly assembly        assembly core plate, upper assembly         assembly       (Lower (Support                          (Lower     support plate (Clevis insert                                 (Lower core     (Support     support column                         support      and support bolt)                                           plate)    column)      column mixer                    column bolt)      assembly) base)                                                                                    bolt)
Upper Lower                                                                     internals internals                                                          Lower    assembly assembly                           Lower    Upper  internals    internals                   RCCA Core                                                     (Upper core guide tube (Unit I                       internals assembly   (Upper   assembly baffle/former                                                plate, upper assembly lower                       assembly    support column        (Lower      support assembly (Bolt)  (Radial key)        bolt)          support                    (Bolt) support                                                                   plate and column                                                     column bolt)     support casting)                                                                   assembly)
Lower internals Upper                       assembly                                        Upper internals                     (Secondary                          Lower     internals  Core baffle/
Core                            Core assembly      baffle/former  core support, baffle/former        internals   assembly       former (Support                      head/vessel assembly (Bolt)     assembly        (Upper    assembly assembly column                        alignment                     (Radial key)    support       (Bolt)
(Plates) mixer                       pin, head                                  column bolt) base)                    cooling spray nozzle)

Attachment L-08-212 Page 41 of 46 Lower internals assembly (Secondary Lower         Core barrel       Lower Core            core         Core internals      (Shell, ring,    internals baffle/former     support,  baffle/former Core barrel assembly     flange, nozzle,   assembly                                                  assembly assembly     head/vessel    assembly (Clevis          thermal        (Unit 1                                                     (Bolt)
(Plates)      alignment        (Bolt) insert bolt      shield/pad)  diffuser plate                    pin, head cooling spray nozzle)
Lower Lower Lower                                        Core barrel                                internals RCCA guide                         internals       Core internals                                      (Shell, ring,                             assembly Core  barrel       tube                        assembly   baffle/former assembly                                     flange, nozzle,                                (Lower assembly (Bolt)    assembly                          (Unit 1    assembly (Clevis                                         thermal                                   support (Bolt)                         diffuser     (Plates) insert)                                       shield/pad)                                 column plate) bolt)
RCCA                                                                    Core barrel Instrumentation guide                      RCCA guide                      RCCA guide   (Shell, ring,      RCCA support                                                      flange,   guide tube tube                            tube        Core barrel         tube structure (Flux assembly                       assembly     assembly (Bolt)    assembly        nozzle,   assembly thimble guide (Support                     (Guide tube)                         (Bolt)      thermal        (Bolt) tube) pin)                                                                   shield/pad)
Lower                           Upper Instrumentation                 Instrumentation                                  Upper internals                       internals                    RCCA guide support                        support                  Core barrel internals assembly                       assembly                            tube     assembly structure                   structure (Flux                             assembly (Clevis                      (Core plate                      assembly (Thermocouple                   thimble guide                      (Bolt)  (Hold down insert                       alignment                     (Guide tube) conduit)                        tube)                                    spring) bolt)                            pin)
Lower internals       Upper Lower                           Upper                           Upper Lower internals                Instrumentation                 assembly      internals internals                       internals                       internals assembly (Core                      support                        (Core    assembly assembly                       assembly                        assembly       support       (Upper support forging                    structure     (Core plate (Clevis                           (Fuel                                  forging and      support and lower                  (Thermocouple insert                       alignment                       alignment        lower      column support column)                      conduit) bolt)                            pin)                            pin)                      bolt) support column)

Attachment L-08-212 Page 42 of 46 RCCA                              Upper      Lower internals      Upper      Lower guide guide     Lower internals       internals                       internals  internals assembly (Core         alseiblyras tube      assembly (Fuel       assembly     support forging       (Fuel      (Fuel assembly alignment pin)         (Hold down        and lower      algmnel (Support                           spring)    support column)    alignment  alignment pin)pin)                                                                     pin)
Clarify which of the reactor vessel (RV) internal component commodity groups within the scope of the LRA for BVPS Unit 1 and BVPS Unit 2 are within the scope of LRA B.2.33, "PWR Vessel Internals Program," LRA UFSAR Supplement Section, A.1.33, and the scope of LRA Commitment No. 18 for Unit I and Commitment No. 20 for Unit 2.
RESPONSE RAI B.2.33-2 In the FENOC response to RAI-B.2.33-1, LRA Appendix B, Section B.2.33, and Appendix A, Section A.1.33, are revised to delete the text in these LRA sections.
Applicable components in LRA Table 3.1.2-2 that previously referred to the PWR Vessel Internals Program are revised to delete references to the aging management program, and to include references to the commitments provided in LRA Appendix A, Table A.4-1, Item 18, and Table A.5-1, Item 20.
See the Enclosure to this letter for the revision to the BVPS LRA.
The component types / commodity groups that credit the License Renewal Future Commitments in LRA Appendix A, Table A.4-1, Item 18 for Unit 1, and Table A.5-1, Item 20 for Unit 2, are:
Component Types / Commodity Groups Core baffle/former assembly (Bolt)
Core baffle/former assembly (Plates)
Core barrel (Shell, ring, flange, nozzle, thermal shield/pad)
Core barrel assembly (Bolt)
Instrumentation support structure (Flux thimble guide tube)
Instrumentation support structure (Thermocouple conduit)
Lower internals assembly (Clevis insert bolt)
Lower internals assembly (Clevis insert)
Lower internals assembly (Core support forging and lower support column)
Lower internals assembly (Fuel alignment pin)
Lower internals assembly (Lower core plate)
Lower internals assembly (Lower support column bolt)
Lower internals assembly (Radial key)

Attachment L-08-212 Page 43 of 46 Component Types / Commodity Groups Lower internals assembly (Secondary core support, head/vessel alignment pin, head cooling spray nozzle)
Lower internals assembly (Unit 1 diffuser plate)
Lower internals assembly (Unit 1 lower support column casting)
RCCA guide tube assembly (Bolt)
RCCA guide tube assembly (Guide tube)
RCCA guide tube assembly (Support pin)
Upper internals assembly (Core plate alignment pin)
Upper internals assembly (Fuel alignment pin)
Upper internals assembly (Hold-down spring)
Upper internals assembly (Support column mixer base)
Upper internals assembly (Support column)
Upper internals assembly (Upper core plate, upper support plate and support assembly)
Upper internals assembly (Upper support column bolt)
Question RAI B.2.33-3 Clarify whether or not the examination requirements in ASME Code Section XI, Table IWB-2500-1, Examination Categories B-N-I, B-N-2, or B-N-3 are applicable to the RV internal components at BVPS Units 1 and 2, and if so, whether the applicant is crediting the applicable examination category requirements for aging management either under the applicant's ASME Section XI, Subsection IWB, IWB, and IWD Program or the applicant's PWR Vessel Internals Program.
RESPONSE RAI B.2.33-3 Examinations of the:
* interior of the Unit 1 and Unit 2 Reactor Vessels (Category B-N-I),
    " integrally welded core support structures and interior attachments to the Reactor Vessels (B-N-2), and
* removable core support structures (B-N-3),
are scheduled and performed in accordance with the ASME Boiler and Pressure Vessel Code, Section Xl, Table IWB-2500-1, under the BVPS ASME Section XI, Inservice Inspection Program, subject to the limitations and modifications of 10 CFR 50.55a.
However, for license renewal, consistent with the recommendations of NUREG-1 801, rows IV.B2-26 and IV.B2-34, only three line items from the Reactor Vessel Internals System credit the ASME Section Xl, Inservice Inspection, Subsections IWB, IWC, and

Attachment L-08-212 Page 44 of 46 IWD Program (LRA Section B.2.2) for aging management. The component types in these three line items are:
    " Lower internals assembly (Clevis insert);
* Lower internals assembly (Radial key); and,
    "   Upper internals assembly (Core plate alignment pin).
For the Reactor Vessel Internals component types listed in the FENOC response to RAI-B.2.33-2, FENOC provided License Renewal Future Commitments in LRA Appendix A, Table A.4-1, Item 18 for Unit 1, and Table A.5-1, Item 20 for Unit 2, to:
: 1. Participate in the industry programs applicable to BVPS for investigating and managing aging effects on reactor internals;
: 2. Evaluate and implement the results of the industry programs as applicable to the BVPS reactor internals; and,
: 3. Upon completion of these programs, but not less than 24 months before entering the period of extended operations, submit an inspection plan for the BVPS reactor internals to the NRC for review and approval.
No ASME examination categories are specified or credited in these License Renewal Future Commitments.
In the FENOC response to RAI-B.2.33-1, LRA Appendix B, Section B.2.33, and Appendix A, Section A.1.33, are revised to delete the text in these LRA sections.
Applicable components in LRA Table 3.1.2-2 that previously referred to the PWR Vessel Internals Program are revised to delete references to the aging management program, and to include references to the commitments provided in LRA Appendix A, Table A.4-1, Item 18, and Table A.5-1, Item 20.
See the Enclosure to this letter for the revision to the BVPS LRA.
Section B.2.40/B.2.41 Question RAI B.2.40-1/B.2.41-1 In FENOC's Program Evaluation Document for AMP B.2.40, Thermal Aging and Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel (CASS), the applicant indicates that the inspections of the CASS reactor vessel internal components will be done using ultrasonic testing (UT) techniques. The staff is of the opinion that the current state-of-the-art UT inspection methods may not be capable of detecting the presence of cracks (i.e., have not been adequately qualified) for CASS materials. Identify the UT inspection techniques that are

Attachment L-08-212 Page 45 of 46 credited for the examinations of the CASS RVI components, and clarify whether or not the state-of-the art technology for these techniques are capable of detecting surface penetrating and subsurface cracks in the CASS materials.
Clarify whether Performance Demonstration Initiative (PDI) will be used to qualify the UT techniques for CASS materials. If it is determined that the state-of-art-technology UT technology is not capable of detecting the presence of cracks in CASS components, identify the alternative inspection techniques or analyses will be credited to manage reduction of fracture toughness in the CASS RVI components as a result of thermal aging or neutron irradiation embrittlement and provide your basis why these alternative techniques are acceptable for management of this aging effect.
RESPONSE RAI B.2.40-1/B.2.41-1 In the FENOC response to RAI-B.2.40-2, LRA Appendix B, Section B.2.40, "Thermal Aging and Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel (CASS),"
and Appendix A, Section A.1.40, "Thermal Aging and Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel (CASS) Program," are revised to delete the text in these sections. The applicable components in LRA Table 3.1.2-2 that previously referred to the Thermal Aging and Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel (CASS) Program are revised to delete references to the aging management program, and to include references to the commitments provided in LRA Appendix A, Table A.4-1, Item 18, and Table A.5-1, Item 20, which, following revision as identified in the Enclosure to this letter, reads as follows:
       "Regardingactivities for managing the aging of Reactor Vessel internal components and structures, BVPS commits to:
: 1. Participatein the industry programsapplicable to BVPS for investigatingand managing aging effects on reactorinternals;
: 2. Evaluate and implement the results of the industry programs as applicableto the BVPS reactorinternals;and,
: 3. Upon completion of these programs, but not less than 24 months before entering the period of extended operation, submit an inspection plan for the BVPS reactorinternals to the NRC for review and approval."

Attachment L-08-212 Page 46 of 46 Question RAI B.2.40-2 In FENOC's Program Evaluation Document for AMP B.2.40, Thermal Aging and Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel (CASS), the applicant indicates that it may use the industry initiatives of the EPRI MRP Integrated Task Group of reactor vessel internal (RVI) components as an alternative basis to implementing the program elements of Thermal Aging and Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel (CASS)
Program. The applicant's basis for using the EPRI MRP's flaw evaluation and inspection guidelines is currently provided through implementation of AMP B.2.33, PWR Vessel Internals Program, which includes Commitment #18 for BVPS Unit 1, as provided in UFSAR Supplement Table A.2-4 and Commitment #20 for BVPS Unit 2, as provided in UFSAR Supplement Table A.2-5. The staff requests, if FENOC seeks to use the industry initiatives of the EPRI MPR as an alternative for managing reduction of fracture toughness (resulting from either thermal aging or neutron irradiation embrittlement) in the CASS RVI components, that AMP B.2.40, Thermal Aging and Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel (CASS), and the associated UFSAR supplement in LRA Section A.1.40, be amended to identify this as an exception to the "scope of program" program element in GALL XI.M13 and state that management of reduction of fracture toughness will be managed through the applicant's PWR Vessel Internals Program and the specific provisions in LRA Commitment #18 for BVPS Unit I and Commitment #20 for BVPS Unit 2.
RESPONSE RAI B.2.40-2 The BVPS LRA is revised to delete the "Thermal Aging and Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel (CASS) Program," described in Sections B.2.40 and A.1.40. The applicable sections of the LRA that previously referred to the Thermal Aging and Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel (CASS) Program are revised to delete references to the aging management program, and to include references to the commitments provided in LRA Appendix A, Table A.4-1, Item 18, and Table A.5-1, Item 20.
The LRA revision to delete the Thermal Aging and Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel (CASS) Program allows FENOC to use the industry initiatives of the EPRI Material Reliability Project as an alternative for managing reduction of fracture toughness.
See the Enclosure to this letter for the revision to the BVPS LRA.

ENCLOSURE Beaver Valley Power Station (BVPS), Unit Nos. 1 and 2 Letter L-08-212 Amendment No. 17 to the BVPS License Renewal Application Page 1 of 65 License Renewal Application Sections Affected Table 2.3.3-13         Table 3.1.2-1 Table 2.3.3-14         Table 3.1.2-2 Table 2.3.3-16         Table 3.1.2-3 Table 2.3.3-26         Section 3.2.2.2.3.3 Table 2.3.3-31         Section 3.3.2.1.1 Section 3.1.2.1.1      Section 3.3.2.1.5 Section 3.1.2.1.2      Section 3.3.2.1.7 Section 3.1.2.1.3      Section 3.3.2.1.11 Section 3.1.2.2.6      Section 3.3.2.1.12 Section 3.1.2.2.7.1    Section 3.3.2.1.13 Section 3.1.2.2.9      Section 3.3.2.1.14 Section 3.1.2.2.12     Section 3.3.2.1.15 Section 3.1.2.2.13     Section 3.3.2.1.16 Section 3.1.2.2.15     Section 3.3.2.1.17 Section 3.1.2.2.17     Section 3.3.2.1.18 Table 3.1.1            Section 3.3.2.1.26

Enclosure L-08-212 Page 2 of 65 License Renewal Application Sections Affected, cont.
Section 3.3.2.1.29    Table 3.3.2-31 Section 3.3.2.1.31    Section 3.4.2.1.1 Table 3.3.2-1         Table 3.4.2-1 Table 3.3.2-5         Section A. 1.28 Table 3.3.2-7         Section A.1.33 Table 3.3.2-11        Section A.1.40 Table 3.3.2-12        Table A.4-1 Table 3.3.2-13        Table A.5-1 Table 3.3.2-14        Table B.1-1 Table 3.3.2-15        Table B.1-2 Table 3.3.2-16        Table B.11-3 Table 3.3.2-17        Section B.2.15 Table 3.3.2-18        Section B.2.28 Table 3.3.2-26        Section B.2.33 Table 3.3.2-29        Section B.2.40 The Enclosure identifies the revision by Affected License Renewal Application (LRA)
Section, LRA Page No., and Affected Paragraph and Sentence. The count for the affected paragraph, sentence, bullet, etc. starts at the beginning of the affected Section or at the top of the affected page, as appropriate. Below each section the reason for the change is identified, and the sentence affected is printed in italics with deleted text lined-ou and added text underlined.

Enclosure L-08-212 Page 3 of 65 Affected Paragraph Affected LRA Section          LRA Page No.        and Sentence Table 2.3.3-13                Page 2.3-75         3 rd Row LRA Table 2.3.3-13, "Emergency Diesel Generators-Crankcase Vacuum System Components Subject to Aging Management Review," 3 rd row, requires revision to delete the Component Type "Flexible hose," because FENOC plans to periodically replace elastomeric components in mechanical systems (with the exception of ventilation flexible connections) such that these components are short-lived and not subject to aging management review. LRA Table 2.3.3-13, 3 rd row is revised to read:
Component Type                           Intended Function Flexible-Hose                           Leakge beundar-y (spatial Table 2.3.3-14                Page 2.3-77         4 th Row LRA Table 2.3.3-14, "Emergency Diesel Generators-Fuel Oil System Components Subject to Aging Management Review," 4 th row, requires revision to delete the Component Type "Flexible hose (Unit 2 only)," because FENOC plans to periodically replace elastomeric components in mechanical systems (with the exception of ventilation flexible connections) such that these components are short-lived and not subject to aging management review. LRA Table 2.3.3-14, 4 th row is revised to read:
Component Type                           Intended Function Flaxibic Hose (Unit 2 -Only)            P-Fesure boundar

Enclosure L-08-212 Page 4 of 65 Affected Paragraph Affected LRA Section          LRA Page No.         and Sentence Table 2.3.3-16                Page 2.3-82          8 th Row LRA Table 2.3.3-16, "Emergency Diesel Generators-Water Cooling System Components Subject to Aging Management Review," 8 th row, requires revision to delete the Component Type "Sight glass," because FENOC plans to periodically replace, or periodically test and replace on condition, polymer components in mechanical systems (with the exception of Geoflex-D piping) such that these components are short-lived and not subject to aging management review. LRA Table 2.3.3-16, 8 th row is revised to read:
Component Type                            Intended Function Sight-glass9                             Pressuro boundWr Table 2.3.3-26                Page 2.3-111         2 nd Row LRA Table 2.3.3-26, "Reactor Plant Sample System Components Subject to Aging Management Review," 2 nd row, requires revision to delete the Component Type "Demineralizer," because FENOC plans to periodically replace, or periodically test and replace on condition, polymer components in mechanical systems (with the exception of Geoflex-D piping) such that these components are short-lived and not subject to aging management review. LRA Table 2.3.3-26, 2 nd row is revised to read:
ILeakage____
Component Type                            Intended Function Demincraizo

Enclosure L-08-212 Page 5 of 65 Affected Paragraph Affected LRA Section          LRA Page No.         and Sentence Table 2.3.3-31                Page 2.3-126         3 rd Row LRA Table 2.3.3-31, "Solid Waste Disposal System Components Subject to Aging Management Review," 3 rd row, requires revision to delete the Component Type "Flexible hose," because FENOC plans to periodically replace elastomeric components in mechanical systems (with the exception of ventilation flexible connections) such that these components are short-lived and not subject to aging management review. LRA Table 2.3.3-31, 3 rd row is revised to read:
Component Type                              Intended Function Flexible Hos                               Leakage boundar-y (spatiaIg Table 3.1.2.1.1               Page 3.1-3           Aging Management Programs, 6 th Bullet LRA Section 3.1.2.1.1, "Reactor Vessel," Subsection "Aging Management Programs," 6 th bullet, requires revision to delete reference to the "One-Time Inspection," program item because FENOC is crediting the ASME Section Xl Inservice Inspection Subsections IWB, IWC, and IWD Program to manage cracking of the bottom-mounted instrument guide tubes instead of the One-Time Inspection Program. LRA Section 3.1.2.1.1, Subsection "Aging Management Programs," 6 th bullet, is revised to read:
       "Aging Management Programs 0One Timec Inspection (Sectibn 8.2.30)-"

Enclosure L-08-212 Page 6 of 65 Affected Paragraph Affected LRA Section          LRA Page No.         and Sentence Table 3.1.2.1.1               Page 3.1-3           Aging Management Programs, 4 th Bullet LRA Section 3.1.2.1.1, "Reactor Vessel," Subsection "Aging Management Programs," 4 th bullet, requires revision to delete reference to the "Nickel-Alloy Nozzles and Penetrations," program item. FENOC has committed in the LRA, Appendix A, to develop a plant-specific program for managing the aging of nickel-alloy components and nickel-alloy clad components susceptible to primary water stress corrosion cracking - PWSCC (other than upper reactor vessel closure head nozzles and penetrations). Therefore, the Nickel-Alloy Nozzles and Penetrations Program is replaced with a reference to the commitment location (Appendix A). LRA Section 3.1.2.1.1, Subsection "Aging Management Programs," 4 th bullet, is revised to read:
       "Aging Management Programs A.lly Nez-*zes and ,enetrations
                  ,Nickel                                Commitments Provided in Appendix A, Table A.4-1, Item 15, and Table A.5-1, Item 17" Table 3.1.2.1.2               Page 3.1-4           Aging Management Programs, 2 nd Bullet LRA Section 3.1.2.1.2, "Reactor Vessel Internals," Subsection "Aging Management Programs," 2 nd bullet, requires revision to delete reference to the "PWR Vessel Internals," program item. FENOC has committed in the LRA, Appendix A, to develop and implement a plant-specific program for managing the aging of Reactor Vessel internal components and structures. Therefore, the PWR Vessel Internals Program is replaced with a reference to the commitment location (Appendix A). LRA Section 3.1.2.1.2, Subsection "Aging Management Programs," 4 th bullet, is revised to read:
       "Aging Management Programs
* PWR Vessel Internals Commitments provided in Appendix A, Table A.4-1, Item 18, and Table A.5-1, Item 20"

Enclosure L-08-212 Page 7 of 65 Affected Paragraph Affected LRA Section          LRA Page No.         and Sentence Table 3.1.2.1.2               Page 3.1-4           Aging Management Programs, 3 rd Bullet LRA Section 3.1.2.1.2, "Reactor Vessel Internals," Subsection "Aging Management Programs," 3 rd bullet, requires revision to delete reference to the "Thermal Aging and Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel (CASS)," program item. FENOC has committed in the LRA, Appendix A, to develop and implement a plant-specific program for managing the aging of Reactor Vessel internal components and structures. Therefore, the Thermal Aging and Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel (CASS) Program is replaced with a reference to the commitment location (Appendix A). LRA Section 3.1.2.1.2, Subsection "Aging Management Programs," 3 rd bullet, is revised to read:
      "Aging Management Programs Thermal Aging and Neutron Irradiation Embrittement of Cast Austcniti Stainless Steel (GASS Commitments provided in Appendix A. Table A.4-1, Item 18, and Table A.5-1, Item 20" Table 3.1.2.1.3               Page 3.1-5           Aging Management Programs, 6 th Bullet LRA Section 3.1.2.1.3, "Reactor Coolant System," Subsection "Aging Management Programs," 6 th bullet, requires revision to delete reference to the "Nickel-Alloy Nozzles and Penetrations," program item. FENOC has committed in the LRA, Appendix A, to develop a plant-specific program for managing the aging of nickel-alloy components and nickel-alloy clad components susceptible to primary water stress corrosion cracking - PWSCC (other than upper reactor vessel closure head nozzles and penetrations). Therefore, the Nickel-Alloy Nozzles and Penetrations Program is replaced with a reference to the commitment location (Appendix A). LRA Section 3.1.2.1.3, Subsection "Aging Management Programs," 6 th bullet, is revised to read:
       "Aging Management Programs ke.
                 .i4     .. Nozzles Alley and PenetFations*.Commitments provided in Appendix A, Table A.4-1, Item 15, and Table A.5-1, Item 17"

Enclosure L-08-212 Page 8 of 65 Affected Paragraph Affected LRA Section          LRA Page No.        and Sentence Table 3.1.2.2.6               Page 3.1-9          2 nd and 3 rd Paragraphs LRA Section 3.1.2.2.6, "Loss of Fracture Toughness Due to Neutron Irradiation Embrittlement and Void Swelling," 2 nd and 3 rd paragraphs, require revision to delete references to the "PWR Vessel Internals Program." FENOC has committed in the LRA, Appendix A, to develop and implement a plant-specific program for managing the aging of Reactor Vessel internal components and structures. Therefore, the PWR Vessel Internals Program is replaced with a reference to the commitment location (Appendix A). LRA Section 3.1.2.2.6, 2 nd and 3 rd paragraphs, are revised to read:
       "BVPSprovides in the UFSAR Supplement (Seion-A.-.3) a commitment to..."
       "This commitment is identified in the UFSAR Supplement (Appendix A) PWR Table 3.1.2.2.7.1             Pages 3.1-9 & 10 2 nd and 3 rd Paragraphs LRA Section 3.1.2.2.7.1, "PWR Vessel Bottom-Mounted Instrument Guide Tubes," 2 nd and 3 rd paragraphs, require revision to delete reference to the "One-Time Inspection Program," because FENOC is crediting the ASME Section X1 Inservice Inspection, Subsections IWB, IWC, and IWD Program to manage cracking of the bottom-mounted instrument guide tubes instead of the One-Time Inspection Program. LRA Section 3.1.2.2.7.1, 2 nd and 3 rd paragraphs, are revised to read:
       "BVPS manages cracking from SCC of these lines by a combinationof the Water Chemistry Programand the ASME Section Xl Inservice Inspection, Subsections lWB, IWC, lWD One Time hnetiY-.         Program.
The Water Chemistry Programprovides for monitoring and controlling of water chemistry using site procedures and processes for the prevention or mitigation of the cracking aging effect. The ASME Section X1 Inservice Inspection, Subsections IWB, IWC, and IWD Programhas been shown to be effective in managing aging effects in Class 1, 2 or 3 components and their integral attachments in light-watercooled power plants. The One Time Inspection Program provides an inspcctin that either-verifies that unacceptable degradato
: i. nOt occurring or trggers additinal actios that assur-e the intended fUnctin Of affected components will be main tained durig the period ol0f ikexteded operato"

Enclosure L-08-212 Page 9 of 65 Affected Paragraph Affected LRA Section          LRA Page No.         and Sentence Table 3.1.2.2.9               Pages 3.1-10 & 11 1 st and 2 nd Paragraphs LRA Section 3.1.2.2.9, "Loss of Preload Due to Stress Relaxation," 1 st and 2 nd paragraphs, require revision to delete references to the "PWR Vessel Internals Program." FENOC has committed in the LRA, Appendix A, to develop and implement a plant-specific program for managing the aging of Reactor Vessel internal components and structures. Therefore, the PWR Vessel Internals Program is replaced with a reference to the commitment location (Appendix A).
LRA Section 3.1.2.2.9, 1 st and 2 nd paragraphs, are revised to read:
       "BVPS provides in the UFSAR Supplement (Seen,,           A. "3) a commitment to..."
       "This commitment is identified in the UFSAR Supplement (Appendix A) PWR Table 3.1.2.2.12             Page 3.1-11           2 nd and 3 rd Paragraphs LRA Section 3.1.2.2.12, "Cracking Due to Stress Corrosion Cracking and Irradiation-Assisted Stress Corrosion Cracking (IASCC)," 2 nd and 3r paragraphs, require revision to delete references to the "PWR Vessel Internals Program."
FENOC has committed in the LRA, Appendix A, to develop and implement a plant-specific program for managing the aging of Reactor Vessel internal components and structures. Therefore, the PWR Vessel Internals Program is replaced with a reference to the commitment location (Appendix A). LRA Section 3.1.2.2.12, 2 nd and 3 rd paragraphs, are revised to read:
       "BVPS manages the ReactorVessel Internals components exposed to reactor coolant with the Water Chemistry Program (Section B.2.42) and a P"-Ves~sel int*na.. PFogrm (Scet.on B.2.33) commitment, provided in the UFSAR Supplement (Appendix A)."
       "....In  addition, BVPS provides in the UFSAR Supplement (Sectien A *A--'3    a commitment to..."

Enclosure L-08-212 Page 10 of 65 Affected Paragraph Affected LRA Section          LRA Page No.         and Sentence Table 3.1.2.2.13              Page 3.1-12          4 th Paragraph LRA Section 3.1.2.2.13, "Cracking Due to Primary Water Stress Corrosion Cracking (PWSCC)," 4th paragraph, requires revision to delete reference to the "Nickel-Alloy Nozzles and Penetrations Program." FENOC has committed in the LRA, Appendix A, to develop a plant-specific program for managing the aging of nickel-alloy components and nickel-alloy clad components susceptible to primary water stress corrosion cracking - PWSCC (other than upper reactor vessel closure head nozzles and penetrations). Therefore, the Nickel-Alloy Nozzles and Penetrations Program is deleted from the section. LRA Section 3.1.2.2.13, 4 th paragraph, is revised to read:
       "In addition, for nickel alloy, within the M,,el Afloy Nez-z-"  and
                                                                         ,    -en&#xf7;t,,,en.
Proegrm (Section B.2.28)~ description in the UFSAR Supplemgent (Sectio A. 1.28),. BVPS provided a commitment to develop a plant-specific aging management program that will implement applicable (1) NRC Orders, Bulletins and Generic Letters, and (2) staff-accepted industry guidelines."
Table 3.1.2.2.15              Page 3.1-13          2 nd and 3 rd Paragraphs LRA Section 3.1.2.2.15, "Changes in Dimensions Due to Void Swelling," 2 nd and 3 rd paragraphs, require revision to delete references to the "PWR Vessel Internals Program." FENOC has committed in the LRA, Appendix A, to develop and implement a plant-specific program for managing the aging of Reactor Vessel internal components and structures. Therefore, the PWR Vessel Internals Program is replaced with a reference to the commitment location (Appendix A). LRA Section 3.1.2.2.15, 2 nd and 3 rd paragraphs, are revised to read:
       "BVPSprovides in the UFSAR Supplement (Seeten A-."&#xf7;-             a commitment to..."
       "This commitment is contained within the UFSAR Supplement (Appendix A) desc~ription of the PWR Vesse! Internals P~rogrm (S-ection B.2.33)."

Enclosure L-08-212 Page 11 of 65 Affected Paragraph Affected LRA Section           LRA Page No.         and Sentence Table 3.1.2.2.17               Page 3.1-15          2 nd, 3 rd and 4 th Paragraphs LRA Section 3.1.2.2.17, "Cracking Due to Stress Corrosion Cracking, Primary Water Stress Corrosion Cracking, and Irradiation-Assisted Stress Corrosion Cracking," 2 nd, 3 rd and 4 th paragraphs, require revision to delete references to the "PWR Vessel Internals Program." FENOC has committed in the LRA, Appendix A, to develop and implement a plant-specific program for managing the aging of Reactor Vessel internal components and structures. Therefore, the PWR Vessel Internals Program is replaced with a reference to the commitment location (Appendix A). LRA Section 3.1.2.2.17, 2 nd, 3 rd and 4 th paragraphs, are revised to read:
       "BVPS manages cracking due to SCC of the PWR stainless steel and nickel alloy Reactor Vessel Internals components with the Water Chemistry Program (Section B.2.42) and a PWR Vessel*ne.rnals Program (Se,.,ion B.2.33) commitment, provided in the UFSAR Supplement (Appendix A)."
       "In addition, BVPS provides in the UFSAR Supplement (-Se-,en-4*A.         ".3 a commitment to..."
       "This commitment is identified in the UFSAR Supplement (Appendix A) PWR

Enclosure L-08-212 Page 12 of 65 Affected Paragraph Affected LRA Section           LRA Page No.           and Sentence Table 3.1.1                    Page 3.1-26            Item 3.1.1-23, Discussion column, 2 nd Paragraph LRA Table 3.1.1, "Summary of Aging Management Evaluations in Chapter IV of NUREG-1 801 for the Reactor Vessel, Vessel Internals, and Reactor Coolant System," row 3.1.1-23, requires revision to delete reference to the "One-Time Inspection Program," because FENOC is crediting the ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD Program to manage cracking of the bottom-mounted instrument guide tubes instead of the One-Time Inspection Program. LRA Table 3.1.1, row 3.1.1 Discussion column only, 2 nd paragraph, is revised to read:
Item                             Discussion Number 3.1.1-23  B VPS manages the stainlesssteel bottom-mounted guide tubes with the Water Chemistry (B.2.42) and ASME Section X1 Inservice Inspection, Subsections IWB, IWC. and IWD (B.2.2)
One T7rn lnpoctien (B.2.30) Programs.

Enclosure L-08-212 Page 13 of 65 Affected Paragraph Affected LRA Section           LRA Page No.          and Sentence Table 3.1.1                    Page 3.1-29           Item 3.1.1-31, Discussion column, 3 rd Paragraph Page 3.1-31           Item 3.1.1-34, Discussion column, 3 rd Paragraph LRA Table 3.1.1, "Summary of Aging Management Evaluations in Chapter IV of NUREG-1801 for the Reactor Vessel, Vessel Internals, and Reactor Coolant System," rows 3.1.1-31 and 3.1.1-34 require revision to delete reference to the "Nickel-Alloy Nozzles and Penetrations," program item. FENOC has committed in the LRA, Appendix A, to develop a plant-specific program for managing the aging of nickel-alloy components and nickel-alloy clad components susceptible to primary water stress corrosion cracking - PWSCC (other than upper reactor vessel closure head nozzles and penetrations). Therefore, the Nickel-Alloy Nozzles and Penetrations Program is replaced with a reference to the commitment location (Appendix A). LRA Table 3.1.1, rows 3.1.1-31 and 3.1.1-34
      - Discussion column only, 3 rd paragraph of each row, is revised to read:
Item Number                           Discussion 3.1.1-31  The BVPS commitment is described in Appendix A -within-th Ni.kel Alloy Nzzles and Penetrations Program (A.1.2 )*
3.1.1-34  desefipe.

Enclosure L-08-212 Page 14 of 65 Affected Paragraph Affected LRA Section           LRA Page No.          and Sentence Table 3.1.1                    Page 3.1-25           Item 3.1.1-22, Discussion column,;
2 nd Paragraph Page 3.1-27           Item 3.1.1-27, Discussion column, 2 nd Paragraph Page 3.1-28           Item 3.1.1-30, Discussion column, 3 rd Paragraph Page 3.1-30           Item 3.1.1-33, Discussion column, 2 nd Paragraph Page 3.1-34           Item 3.1.1-37, Discussion column, 2 nd and 3 rd Paragraphs LRA Table 3.1.1, "Summary of Aging Management Evaluations in Chapter IVof NUREG-1801 for the Reactor Vessel, Vessel Internals, and Reactor Coolant System," rows 3.1.1-22. -27. -30, -33, and 37 require revision to delete references to the "PWR Vessel Internals Program." FENOC has committed in the LRA, Appendix A, to develop and implement a plant-specific program for managing the aging of Reactor Vessel internal components and structures.
Therefore, the PWR Vessel Internals Program is replaced with a reference to the commitment location (Appendix A). LRA Table 3.1.1, rows 3.1.1-22. -27. -30, -
33, and 37 - Discussion column only (paragraphs as identified above), is revised to read:
Item                              Discussion Number 3.1.1-22, The BVPS commitment is described in Appendix A-within-the 3.1.1-27, PWR Ve.se Intvrna s Program (A.4.33) de".ription.
3.1.1-30
           &
3.1.1-33 3.1.1-37  BVPS manages the aging effect with the Water Chemistry (B.2.42) Programand a commitment for the PWR Vesse/
Inter-nals (8.2.33) Pmogram.
The BVPS commitment is described in Appendix A -withinthe P/R VesseIl Int**ral's PFgam (A.4.33) dscription.

Enclosure L-08-212 Page 15 of 65 Affected Paragraph Affected LRA Section         LRA Page No.             and Sentence Table 3.1.1                  Page 3.1-48              Item 3.1.1-80, Discussion column LRA Table 3.1.1, "Summary of Aging Management Evaluations in Chapter IVof NUREG-1801 for the Reactor Vessel, Vessel Internals, and Reactor Coolant System," row 3.1.1-80, requires revision to delete reference to the "Thermal Aging and Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel (CASS) Program." FENOC has committed in the LRA, Appendix A, to develop and implement a plant-specific program for managing the aging of Reactor Vessel internal components and structures. Therefore, the Thermal Aging and Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel (CASS)
Program is replaced with a reference to the commitment location (Appendix A).
LRA Table 3.1.1, row 3.1.1 Discussion column only, is revised to read:
Item                             Discussion Number 3.1.1-80  Consistent with NUREG-1801, with a different program assigned. The aging effect will be managed through the commitments provided in Appendix A. Table A.4-1. Item 18, and Table A. 5-1. Item 20.
BNPSrnanIges tho aging offoct with thaThermal Aging and Neutron !rradiation Embgfiftement of Cast AustenitiG Stainess Steel (GASS) (B.2.40) Programn.

Enclosure L-08-212 Page 16 of 65 Affected Paragraph Affected LRA Section         LRA Page No.         and Sentence Table 3.1.2-1               ,Page 3.1-51          Row No. 2, Aging Management Program column LRA Table 3.1.2-1, "Reactor Vessel, Vessel Internals, and Reactor Coolant System - Reactor Vessel - Summary of Aging Management Evaluation," row 2 requires revision to delete reference to the "One-Time Inspection Program,"
because FENOC is crediting the ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD Program to manage cracking of the bottom-mounted instrument guide tubes instead of the One-Time Inspection Program.
LRA Table 3.1.2-1, row 2 - Aging Management Program column only, is revised to read:
Row                 Aging Management Program No.
2    ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD (B.2.2)
One Tinge kn~ectien ('B. 2.30)

Enclosure L-08-212 Page 17 of 65 Affected Paragraph Affected LRA Section            LRA Page No.           and Sentence Table 3.1.2-1                   Page 3.1-58            Row No. 36, Aging Management Program column Page 3.1-69            Row No. 86, Aging Management Program column Page 3.1-71            Row No. 100, Aging Management Program column Page 3.1-75            Row No. 123, Aging Management Program column LRA Table 3.1.2-1, "Reactor Vessel, Vessel Internals, and Reactor Coolant System - Reactor Vessel - Summary of Aging Management Evaluation," row numbers 36, 86, 100, and 123 require revision to delete reference to the "Nickel-Alloy Nozzles and Penetrations," program item. FENOC has committed in the LRA, Appendix A, to develop a plant-specific program for managing the aging of nickel-alloy components and nickel-alloy clad components susceptible to primary water stress corrosion cracking - PWSCC (other than upper reactor vessel closure head nozzles and penetrations). Therefore, the Nickel-Alloy Nozzles and Penetrations Program is replaced with a reference to the commitment location (Appendix A). LRA Table 3.1.2-1, row numbers 36, 86, 100, and 123 - Aging Management Program column only, is revised to read:
Row                      Aging Management Program Nos.
36,    Commitments provided in Appendix A. Table A.4-1. Item 15, 86,    and Table A.5-1, Item 17 100    Ni.ko*! A,..,y, zz ... and
                                       . Penotraties.(B.2-.28)
         &
123

Enclosure L-08-212 Page 18 of 65 Affected Paragraph Affected LRA Section         LRA Page No.           and Sentence Table 3.1.2-2                Page 3.1          Row Nos. [See list below],
All pages       Aging Management Program column In LRA Table 3.1.2-2, "Reactor Vessel, Vessel Internals, and Reactor Coolant System - Reactor Vessel Internals - Summary of Aging Management Evaluation," multiple row numbers require revision to delete references to the "PWR Vessel Internals," program item. FENOC has committed in the LRA, Appendix A, to develop and implement a plant-specific program for managing the aging of Reactor Vessel internal components and structures. Therefore, the PWR Vessel Internals Program is replaced with a reference to the commitment location (Appendix A). LRA Table 3.1.2-2, row numbers as listed in the table shown below - Aging Management Program column only, is revised to read:
Row Aging Management Program Nos.
1, 2, 5,7,8,9,12,14,  Commitments provided in Appendix A. Table 15,18,20,21,24,26,    A.4-1. Item 18, and Table A.5-1. Item 20 B....
27,28,32,33,37,39,     !-VlR   nc   itrQi     b 2  d 41,43,44,46,50, 51, 54,56,58,60,62,63, 66,68,69,72,74,75, 76,81,82,86,87,91, 92,97,98,101,102, 103,104,108,109, 113,115,119,120, 124,125,129,130; 132,136,137,141, 142, 146, 147 & 151

Enclosure L-08-212 Page 19 of 65 Affected Paragraph Affected LRA Section         LRA Page No.             and Sentence Table 3.1.2-2                Pages 3.1-100 &          Row Nos. 95 and 134 3.1-106         Aging Management Program column and Notes column LRA Table 3.1.2-2, "Reactor Vessel, Vessel Internals, and Reactor Coolant System - Reactor Vessel Internals - Summary of Aging Management Evaluation," row numbers 95 and 134, requires revision to delete reference to the "Thermal Aging and Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel (CASS) Program." FENOC has committed in the LRA, Appendix A, to develop and implement a plant-specific program for managing the aging of Reactor Vessel internal components and structures. Therefore, the Thermal Aging and Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel (CASS) Program is replaced with a reference to the commitment location (Appendix A). LRA Table 3.1.2-2, row numbers 95 and 134 - Aging Management Program and Notes columns only, is revised to read:
Row Nos.              Aging Management Program                Notes 95     Commitments provided in Appendix A. Table           E
          &      A.4-1, Item 18, and Table A.5-1. Item 20           -A 134     Thermal Aging and Neutron Irradiation Em~brittoment of Cast Austeniti Staknlesa Stool
_(GASS)-(B.2-40)_

Enclosure L-08-212 Page 20 of 65 Affected Paragraph Affected LRA Section          LRA Page No.           and Sentence Table 3.1.2-3                 Page 3.1-113           Row No. 15 Aging Management Program column Page 3.1-129           Row No. 112, Aging Management Program column Page 3.1-139           Row No. 171, Aging Management Program column Page 3.1-144           Row No. 200, Aging Management Program column Page 3.1-149           Row No. 234, Aging Management Program column LRA Table 3.1.2-3, "Reactor Vessel, Vessel Internals, and Reactor Coolant System - Reactor Coolant System - Summary of Aging Management Evaluation," row numbers 15, 112, 171,200, and 234, requires revision to delete reference to the "Nickel-Alloy Nozzles and Penetrations," program item. FENOC has committed in the LRA, Appendix A, to develop a plant-specific program for managing the aging of nickel-alloy components and nickel-alloy clad components susceptible to primary water stress corrosion cracking - PWSCC (other than upper reactor vessel closure head nozzles and penetrations). Therefore, the Nickel-Alloy Nozzles and Penetrations Program is replaced with a reference to the commitment location (Appendix A). LRA Table 3.1.2-3, row numbers 15, 112, 171, 200, and 234 - Aging Management Program column only, is revised to read:
Row Nos.                    Aging Management Program 15,    Commitments provided in Appendix A. Table A.4-1. Item 15, 112,    and Table A.5-1. Item 17 171,    Ni.k.l Alloy ,.ozzl, and Penotrations(9.2.2 8) 200
            &
234

Enclosure L-08-212 Page 21 of 65 Affected Paragraph Affected LRA Section       LRA Page No.           and Sentence Section 3.2.2.2.3.3        Page 3.2-7              1 st and 2 nd Paragraphs LRA Section 3.2.2.2.3.3, "BVR Stainless Steel and Aluminum Piping," 1st two paragraphs, requires revision for clarity to include discussion of sodium hydroxide (NaOH) solution and the component types that are exposed to the NaOH solution. LRA Section 3.2.2.2.3.3, 1 st two paragraphs, is revised to read:
       "Loss of materialfrom pitting and crevice corrosion could occur for BWR stainless steel and aluminum piping, piping components, and piping elements exposed to treated water. Forthe purpose of NUREG-1801 comparison, loss of materialfor BWR stainless steel piping components was determined to be applicable to PWR systems with treated (unborated)water, and to treated (unborated)water containingsodium hydroxide (NaOH) solution. This NUREG-1801 environment and was used for comparison because no correspondingNUREG-1801 row existed for PWRs.
BVPS Unit I and Unit 2 Chemical Addition Subsystems (includingpiping, pump casing, tank, and valve body component types) ,hemical injcction pumps and Unt I ,and 2 c-hmi.al addition pumps have an internalfluid of NaOH solution.
The BVPS position is that this environment is equivalent to the NUREG-1801 "Treated water"environment for aging comparisons. Nickel alloy in this environment was determined to be equivalent to stainless steel for aging comparisons. BVPS manages the aging effects by a combination of the Water Chemistry Program(Section B.2.42) in combination with the One-Time Inspection Program(Section B. 2.30)."

Enclosure L-08-212 Page 22 of 65 Affected Paragraph Affected LRA Section        LRA Page No.       and Sentence Section  3.3.2.1.1          Page 3.3-5         Materials, 7 th Bullet Section  3.3.2.1.12         Page 3.3-19        Materials, 5 th Bullet Section  3.3.2.1.16         Page 3.3-24        Materials, 6 th Bullet Section  3.3.2.1.18         Page 3.3-27        Materials, 8 th Bullet Section  3.3.2.1.26         Page 3.3-37        Materials, 6 th Bullet Section  3.3.2.1.31         Page 3.3-44        Materials, 5 th Bullet The LRA Sections and Subsections listed above require revision to delete the Material "Polymer." FENOC plans to periodically replace, or periodically test and replace on condition, polymer components in mechanical systems (with the exception of Geoflex-D piping) such that these components are short-lived and not subject to aging management review. These LRA Sections and Subsections are revised to read:
       "Materials

Enclosure L-08-212 Page 23 of 65 Affected Paragraph Affected LRA Section     LRA Page No. and Sentence Section 3.3.2.1.5        Page 3.3-10  Materials, 4 th Bullet, and Page 3.3-11  Aging Effects Requiring Management, 3 rd Bullet Section 3.3.2.1.7        Page 3.3-13  Materials, 5 th Bullet, and Page 3.3-14  Aging Effects Requiring Management, 3 rd Bullet Section 3.3.2.1.11       Page 3.3-18  Materials, 4 th Bullet, and Page 3.3-19  Aging Effects Requiring Management, 3 rd Bullet Section 3.3.2.1.12       Page 3.3-19  Materials, 4 th Bullet, and Page 3.3-20  Aging Effects Requiring Management, 3 rd Bullet Section 3.3.2.1.13       Page 3.3-19  Materials,    2 nd Bullet, and Page 3.3-20  Aging Effects Requiring Management, 1 st and 2 nd  Bullets Section 3.3.2.1.14       Page 3.3-22  Materials, 1st Bullet (at top of page), and Page 3.3-22  Aging Effects Requiring Management, 2 nd Bullet Section 3.3.2.1.15       Page 3.3-23  Materials,    3 rd Bullet, and Page 3.3-23  Aging Effects Requiring Management, 1 st and 2 nd  Bullets Section 3.3.2.1.16       Page 3.3-24  Materials, 4 th Bullet, and Page 3.3-25  Aging Effects Requiring Management, 1st Bullet (at top of page)
Section 3.3.2.1.17       Page 3.3-25  Materials, 3 rd Bullet, and Page 3.3-26  Aging Effects Requiring Management, 3 rd Bullet Section 3.3.2.1.29       Page 3.3-41  Materials,    3 rd Bullet, and Page 3.3-42  Aging Effects Requiring Management, 3 rd Bullet Continued on next page...

Enclosure L-08-212 Page 24 of 65 Continued from previous page...
Section 3.3.2.1.31          Page 3.3-44          Materials, 2 nd Bullet, and Page 3.3-44          Aging Effects Requiring Management, Ist and 2 nd Bullets Section 3.4.2.1.1           Page 3.4-3           Materials, 4 th Bullet, and Page 3.4-3           Aging Effects Requiring Management, 3 rd Bullet The LRA Sections and Subsections listed above require revision to delete the Material "Elastomers," and the Aging Effects Requiring Management "Cracking" (Sections 3.3.2.1.13, 3.3.2.1.15, and 3.3.2.1.31 only) and "Hardening and loss of strength." FENOC plans to periodically replace elastomeric components in mechanical systems (with the exception of ventilation flexible connections) such that these components are short-lived and not subject to aging management review. These LRA Sections and Subsections are revised to read:
       "Materials SOasteme" "Aging Effects Requiring Management
            -- Graoking (Sections 3.3.2.1.13, 3.3.2.1.15, and 3.3.2.1.31 only) 0Hardeningand less of -Stmngth"

Enclosure L-08-212 Page 25 of 65 Affected Paragraph Affected LRA Section          LRA Page No.         and Sentence Tables 3.3.2-X                [Listed below]       Rows [Listed below]
Table 3.4.2-1                 [Listed below]       Rows [Listed below]
The LRA Tables (listed below) in Section 3.3.2, "Auxiliary Systems - Summary of Aging Management Evaluation," and Table 3.4.2-1, "Steam and Power Conversion Systems - Auxiliary Feedwater System - Summary of Aging Management Evaluation," and the row numbers listed below, require revision to delete Component Types made of the Materials "Elastomer" or "Polymer."
FENOC plans to periodically replace [selected] elastomeric components in mechanical systems (with the exception of ventilation flexible connections), and to periodically replace, or periodically test and replace on condition, [selected]
polymer components in mechanical systems (with the exception of Geoflex-D piping), such that these components are short-lived and not subject to aging management review. Therefore, the affected LRA Tables, showing the rows selected for deletion, are revised to read:
Table 3.3.2-1           Page 3.3-104 Row            Component Type          Material No.
28     [Deleted/                    Pelymef Filter-heuing (bowl 29     f~eletedl                    Pelyer Fl/tr heusing (boiW)

Enclosure L-08-212 Page 26 of 65 Table 3.3.2-5            Page 3.3-231 Row              Component Type        Material No.
215       [Deleted                  Elastemes 216       [Deleted                  E-lastemee ISight         ,gla,,
217       [Deletedl                 E-asteme*
Isight glas-s 218       [Deletedi                 Oastemes 219       [Deleted/                 EBaeteme*
S;,g.h                          _-lo Table 3.3.2-7            Pages 3.3-266 & 267

Enclosure L-08-212 Page 27 of 65 Table 3.3.2-11     Pages 3.3-353 & 354 Row         Component Type       Material No.
5    [Deleted                E-asemers 6    [Deleted/               E!tetemere ExpansionjeWt 7    [Deletedi               Elastemers 8 xpaensin               !ein 8    [Deleted?               Eletenger Expansion jeWt Table 3.3.2-12      Pages 3.3-364 & 365

Enclosure L-08-212 Page 28 of 65 Table 3.3.2-13      Page 3.3-379 Row         Component Type        Material No.
7   [Deleted!                Eastene-s F-/ex-itl-hese 8   [Deleted[                E!astmrems F-leible-hese 9   [Deletedl                Elastemer Flexible hese Table 3.3.2-14      Page 3.3-385 Row         Component Type        Material No.
13   [Deleted[                Elasteme-s Flexble hose 14   [Deleted                 E-lastemes Fle[ible htose 15   (Deleted!                Oastoieme Flexible-hoee Table 3.3.2-15      Pages 3.3-401 & 402

Enclosure L-08-212 Page 29 of 65 Table 3.3.2-16         Pages 3.3-412, 418, 419 & 420 Row                                    Material No.            Component Type 3      [Deleted/                  Ostme-4      [Deletedl                   -asto eis 5      fDeleted/                   -astemer Fle*ible-hoee 45      [Deleted/                  P-eymer Piping 46      [Deletedl                  Poyme
__ipoing 54      [Deleted/                  Peyme s&tglgass 55      [Deleted/                  po;ymer Sighted                          _r 56      [Deletedl                  PelymeF
_;4gtgas~
Table 3.3.2-17         Page 3.3-423 Row            Component Type          Material No.
3      [Deletedi                  Eaetemer Expansion joint 4      [Deletedl                  Eastemers Expansion joint 5      [Deleted/                  Elastemer Expansion joint 6      [Deletedl                  E-astemer Expansi*n*j*int

Enclosure L-08-212 Page 30 of 65 Table 3.3.2-18      Page 3.3-444 Row          Component Type         Material No.
16   [Deletedl                  PGl-ymef Felxibll hose (halon) 17   [Deleted7                  Pgymer Flexbl, hos*. halon, Table 3.3.2-26      Pages 3.3-591, 592, 608, 609 & 610 Row                                  Material No.          Component Type 10   [Deletedl                  Pelymef Demineralize; 11   [Deletede Demninemfa#eF N           12   [Deleted[                  Pe~ym 100   [Deletedi                  P-elyme
                      -Tank 101   [Deletede Tank 102   [Deleted!                  Pelymef
                      .Tank 110   [Deletedi                  Peeymer Tubing 111   [Deleted                   POlYme
                      -Tubing 112   [Deleted                   Poelymer T1Dbin 113   rDeletedi                  Polyer Tubing_

Enclosure L-08-212 Page 31 of 65 Table 3.3.2-29 Page 3.3-677

Enclosure L-08-212 Page 32 of 65 Table 3.3.2-31 Pages 3.3-716, 717 & 724 Table 3.4.2-1  Page 3.4-39

Enclosure L-08-212 Page 33 of 65 Affected Paragraph Affected LRA Section         LRA Page No.         and Sentence Section A.1.28               Page A.1-12          Entire Section LRA Section A. 1.28, "Nickel-Alloy Nozzles and Penetrations Program," requires deletion. FENOC has committed in the LRA, Appendix A, to develop a plant-specific program for managing the aging of nickel-alloy components and nickel-alloy clad components susceptible to primary water stress corrosion cracking -
PWSCC (other than upper reactor vessel closure head nozzles and penetrations). Therefore, the Nickel-Alloy Nozzles and Penetrations Program text is deleted from the section. LRA Section A.1.28 is revised to read:
       "A.11.28   [Deleted NIKEL ALLOYhNO*ZZES AND PENETRATION. PROGA-*
managin thc aging of nickel alloy and nickel alloy elad components suscceptiblc to primar-y water stress corfosion cFacking PWSCC (other-than upper reactot vessel closure head nozzles and penetrations), BVPS commits to develop a plant spcific aging management program that wil inplemInt appIcVable:
: 1. NRC Orders*, Bulletins and Generic Letters, and,
: 2. staff ac~cepted indusftryguidehlncs."

Enclosure L-08-212 Page 34 of 65 Affected Paragraph Affected LRA Section          LRA Page No.          and Sentence Section A.1.33                Page A.1-14           Entire Section LRA Section A. 1.33, "PWR Vessel Internals Program," requires deletion.
FENOC has committed in the LRA, Appendix A, to develop and implement a plant-specific program for managing the aging of Reactor Vessel internal components and structures. Therefore, the PWR Vessel Internals Program text is deleted from the section. LRA Section A.1.33 is revised to read:
       "A.1 .33 [Deletedl PWR VESSEL INTERNALS PRO,,AFW-Fer thc PAR Vessel InterFnals Program, regardingativitisfor mfo-     anagingth
          .agingOf R.eactor-Vessel intcrnal eomponcnts and struetures, 9 VP-S provided in Tablen A.. 4 (U'nit 4 only) and Tablc A.5 I (1Unit 2 ony conmmiments to:
: 1. P-adicatc in the industry programs applicable to BVPS for-investigating and managig agi'ngeffcts on .eactorinternals;
: 2. Evaluate and implement the results of the industry pro grams_ as appliabl to the BVPlS reactor internals; and-,
enterin th period of extended operation, submit an insection plan foe the BVP-S reactor. internals to the NRC f*o review and approvl.. "

Enclosure L-08-212 Page 35 of 65 Affected Paragraph Affected LRA Section          LRA Page No.         and Sentence Section A.1.40                Page A.1-17          Entire Section LRA Section A. 1.40, "Thermal Aging and Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel (CASS) Program," requires deletion. FENOC has committed in the LRA, Appendix A, to develop and implement a plant-specific program for managing the aging of Reactor Vessel internal components and structures. Therefore, the Thermal Aging and Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel (CASS) Program text is deleted from the section. LRA Section A.1.40 is revised to read:
       "A.1 .40   [Deleted              A,,.- AND NEum,-
THER.A*.AGI                         ,
IRRA,-AT,,N  E,-m-TT-LEmEN OF CAsT AUSTENITIC STAINLESS STEEL      (CASS)    PROGRAM The Thermal Aging and Neutron Irradiation Embrittlemcnt of Cast Austcnit"c Stainless Steel (CASS) Programinspects Reactor-Vessel Internali acorldance     .,th ASME Code Sction X4, SubseGcti        IIW43, Categoy B N 3. This-insection is augmented to detect the effects of loss of fracture toughness duct thermal aging and ncutron irradiation mb-rittlement of CASS compenents. The progam incudes identifiation of the limitng susceptiblenoponents from4 thc stadpontof thcrmal agn  *-    ceptibflt, neutron fluence, and cracking. Foe each -identifiedcomponet, aging m~anagement is accom~plished through either-a.
supplemgental examgination or-a component specific evaluation, including a mechanical loading assessmgent.
BVPS padticipates in the EP-RI Materials Reliability Project established to investigate the impacts of aging on P-WR vessel internal components. The results of this project provide add~itinal baises for the insections and evaluatin pedformed under-this program."

Enclosure L-08-212 Page 36 of 65 Affected Paragraph Affected LRA Section           LRA Page No.        and Sentence Table A.4-1                    Page A.4-6          Item Number 15 LRA Table A.4-1, "Unit 1 License Renewal Commitments," Item Number 15 regarding nickel-alloy components, requires clarification. The Nickel-Alloy Nozzles and Penetrations Program is not a defined program. Therefore, the commitment needs to be revised to remove the program title from the commitment. Item Number 15 in LRA Table A.4-1 is revised to read:
Item                   CImplementation                                              Related LRA No.                                                    Schedule       Source       Section No./
Comments 15   For-the Ni.kel
                   -      oy Nozz"les an,           January 29, 2016     LRA           None Penetrations Program, Regarding activities for managing the aging of nickel-alloy components and nickel-alloy clad components susceptible to primary water stress corrosioncracking - PWSCC (other than upper reactorvessel closure head nozzles and penetrations),BVPS commits to develop a plant-specific aging management program that will implement applicable:
: 1. NRC Orders, Bulletins and Generic Letters; and,
: 2. Staff-accepted industryguidelines.

Enclosure L-08-212 Page 37 of 65 Affected Paragraph Affected LRA Section            LRA Page No. and Sentence Table A.4-1                     Page A.4-7       Item Number 18 LRA Table A.4-1, "Unit 1 License Renewal Commitments," Item Number 18 regarding Reactor Vessel internal components and structures, requires clarification. The PWR Vessel Internals Program is not a defined program.
Therefore, the commitment needs to be revised to remove the program title from the commitment. Item Number 18 in LRA Table A.4-1 is revised to read:
Item No.                   Commitment                 Implementation Schedule       Source      Related Section LRA No./
Comments 18    ,F ,thecPWRVe.ssel  Int&#xf7;.. P. gra.. ,. January 29, 2014    LRA           None Regarding activities for managing the                                       A..3 aging of Reactor Vessel internal components and structures, BVPS commits to:
: 1. Participatein the industry programs applicable to BVPS Unit I for investigatingand managing aging effects on reactorinternals;
: 2. Evaluate and implement the results of the industry programs as applicable to the BVPS Unit 1 reactorinternals; and,
: 3. Upon completion of these programs, but not less than 24 months before entering the period of extended operation, submit an inspection plan for the BVPS Unit I reactorinternals to the NRC for review and approval.

Enclosure L-08-212 Page 38 of 65 Affected Paragraph Affected LRA Section             LRA Page No.         and Sentence Table A.4-1                      Page A.4-8           Item Number 21 LRA Table A.4-1, "Unit 1 License Renewal Commitments," Item Number 21 requires deletion. FENOC has committed in the LRA, Table A.4-1, Item Number 18, to develop and implement a plant-specific program for managing the aging of Reactor Vessel internal components and structures. Therefore, the Thermal Aging and Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel (CASS) Program commitment is not required and is deleted. Item Number 21 in LRA Table A.4-1 is revised to read:
Related LRA No.                   Commitment                    Implementation     Source   Section No./
Comments 21    [Deleted/                                    januaFy
                                                     .      2, 2,16      LRA       A1A4
      !rrad&#xfd;atie  Eimbhriflerngnt of Cast AUStoen&
des~ibedin LA S'ectien B.2.-40

Enclosure L-08-212 Page 39 of 65 Affected Paragraph Affected LRA Section           LRA Page No.         and Sentence Table A.4-1                   Page A.4-8            New Item Number 21 LRA Table A.4-1, "Unit 1 License Renewal Commitments," requires a new License Renewal Future Commitment related to elastomeric components.
FENOC plans to periodically replace elastomeric components in mechanical systems (with the exception of ventilation flexible connections) such that these components are short-lived and not subject to aging management review. A table that provides a list of elastomeric components that are the focus of this new commitment is included following the commitment. New Item Number 21 is created, and LRA Table A.4-1 is revised to read:
SCommitment                                     Implementation     Source      Section LRA e IRelated      No./
No.                                                    Shdl Comments 21    With the exception of flexible connections   January29, 2016     FENOC            None in ventilations systems, priorto the period                       Letter of extended operation, FENOC will                                L-08-212 perform repetitive maintenance tasks to replace mechanical system elastomeric components that would otherwise be subject to aging management review.
Subsequent frequencies of the repetitive replacements will be based on manufacturerrecommendations and applicable operating experience.
[Deleted]                                                                       _
[See "Elastomeric Components and Affected Systems" table on next page.]

Enclosure L-08-212 Page 40 of 65 Elastomeric Components and Affected Systems Component          ;System Name            Deleted from
_______ _______                      Sec~tion / Table Emergency Diesel Expansion joint           Generators &   2.3.3.11 / 3.3.2-11 Support Emergency Diesel Flexible hose            Generators &   2.3.3.12 / 3.3.2-12 Support Emergency Diesel Flexible hose            Generators &   2.3.3.13 / 3.3.2-13 Support Emergency Diesel Flexible hose            Generators &   2.3.3.14 / 3.3.2-14 Support Emergency Diesel Flexible hose            Generators &   2.3.3.15 / 3.3.2-15 Support Emergency Diesel Flexible hose            Generators &   2.3.3.16 / 3.3.2-16 Support Expansion joint            ERF Diesel    2.3.3.17 / 3.3.2-17 Generator Support  2.3.3.17_/_3.3.2-17 Flexible hose           Security Diesel 2.3.3.29 / 3.3.2-29 Generator Flexible hose             Solid Waste   2.3.3.31 / 3.3.2-31 Disposal Sight glass             Chemical and    2.3.3.5 / 3.3.2-5 Volume Control Flexible hose           Compressed Air    2.3.3.7 / 3.3.2-7 Flexible hose       Auxiliary Feedwater  2.3.4.1 / 3.4.2-1

Enclosure L-08-212 Page 41 of 65 Affected Paragraph Affected LRA Section           LRA Page No.         and Sentence Table A.4-1                    N/A                  New Item Number 28 LRA Table A.4-1, "Unit 1 License Renewal Commitments," requires a new License Renewal Future Commitment related to polymer components. FENOC plans to periodically replace, or to periodically test and replace on condition, polymer components in mechanical systems (with the exception of underground Geoflex-D piping), such that these components are short-lived and not subject to aging management review. A table that provides a list of polymer components that are the focus of this new commitment is included following the commitment.
New Item Number 28 is created, and LRA Table A.4-1 is revised to read:
Item No.                   Commitment                    Implementation Schedule           Source     Related Section LRA No./
Comments 28    With the exception of underground            January29, 2016       FENOC           None GeoFlexfuel oil piping, prior to the period                         Letter of extended operation, FENOC will                                  L-08-212 perform repetitive maintenance tasks to replace, or to test and replace on condition, mechanical system polymer components that would otherwise be subiect to aging management review.
Subsequent frequencies of the repetitive tests/replacementswill be based on manufacturerrecommendations and applicable operating experience.
[See "Polymer Components and Affected Systems" table on next page.]

Enclosure L-08-212 Page 42 of 65 Polymer Components and Affected Systems i-lter housing (1v&-  Area ventlation -      2.3.3.1 / 3.3.2-1 FL-47/48 bowl)       Control Area Emergency Diesel Flexible hose       Generators &       2.3.3.12 / 3.3.2-12 Support Emergency Diesel Piping         Generators &       2.3.3.16 / 3.3.2-16 Support Emergency Diesel Sight glass        Generators &       2.3.3.16 / 3.3.2-16 Support Flexible hose      Fire Protection     2.3.3.18 / 3.3.2-18 (Halon)_______                                      ___
Demineralizer       Reactor2.3.3.26 / 3.3.2-26 Sample Tank           Reactor Plant      2.3.3.26 / 3.3.2-26 Sample Tubing          Reactor Plant      2.3.3.26 / 3.3.2-26 Sample       _________
Tank            Solid Waste       2.3.3.31 / 3.3.2-31 Disposal

Enclosure L-08-212 Page 43 of 65 Affected Paragraph Affected LRA Section          LRA Page No.         and Sentence Table A.5-1                   Page A.5-6           Item Number 17 LRA Table A.5-1, "Unit 2 License Renewal Commitments," Item Number 17 regarding nickel-alloy components, requires clarification. The Nickel-Alloy Nozzles and Penetrations Program is not a defined program. Therefore, the commitment needs to be revised to remove the program title from the commitment. Item Number 17 in LRA Table A.5-1 is revised to read:
Item No.                   Commitment                   Implementation Schedule       Source       Related Section LRA No./
Comments 17    For-the Nickol Alloy N-zz... an               May 27, 2027       LRA            None PenetrationsP. ram, Regarding                                                   A.1.2 activities for managing the aging of nickel-alloy components and nickel-alloy clad components susceptible to primary water stress corrosion cracking - PWSCC (other than upper reactorvessel closure head nozzles and penetrations), BVPS commits to develop a plant-specific aging management program that will implement applicable:
: 1. NRC Orders, Bulletins and Generic Letters; and,
: 2. Staff-accepted industry guidelines.

Enclosure L-08-212 Page 44 of 65 Affected Paragraph Affected LRA Section          LRA Page No.       and Sentence Table A.5-1                   Page A.5-7         Item Number 20 LRA Table A.5-1, "Unit 2 License Renewal Commitments," Item Number 20 regarding Reactor Vessel internal components and structures, requires clarification. The PWR Vessel Internals Program is not a defined program.
Therefore, the commitment needs to be revised to remove the program title from the commitment. Item Number 20 in LRA Table A.5-1 is revised to read:
Item                                              Implementation                 Related LRA No.                   Commitment                     Schedule       Source      Section No./
Comments 20    Feo the PWR Vesscl Int ... s Pr*o g.m,      May 27, 2025        LRA          None Regarding activities for managing the                                        A.1.3 aging of Reactor Vessel internal                                             B.2.3 components and structures, BVPS commits to:
: 1. Participatein the industry programs applicableto BVPS Unit 2 for investigatingand managing aging effects on reactorinternals;
: 2. Evaluate and implement the results of the industry programs as applicable to the BVPS Unit 2 reactorinternals;and,
: 3. Upon completion of these programs,    -
but not less than 24 months before entering the period of extended operation, submit an inspection plan for the BVPS Unit 2 reactorinternals to the NRC for review and approval.

Enclosure L-08-212 Page 45 of 65 Affected Paragraph Affected LRA Section                   LRA Page No.                 and Sentence Table A.5-1                            Page A.5-8                   Item Number 23 LRA Table A.5-1, "Unit 2 License Renewal Commitments," Item Number 23 requires deletion. FENOC has committed in the LRA, Table A.4-1, Item Number 18, to develop and implement a plant-specific program for managing the aging of Reactor Vessel internal components and structures. Therefore, the Thermal Aging and Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel (CASS) Program commitment is not required and is deleted. Item Number 23 in LRA Table A.5-1 is revised to read:
Item No.                        Commitment                               Implementation Schedule       Source Related Section LRA No./
Comments 23    [Deletedi                                                      May.27,,2027       LRA     A. 1.4 itlssl     lf~s W,fs., ~l,#
                       *M   rh rr,-,sl~ A r,,vjnn.,n.#rI Air,, ,,IAL                                2-40 Irradiation ErnbrKf'oncent of Gast Austeniti desGribed in LRA Section B.240-.

Enclosure L-08-212 Page 46 of 65 Affected Paragraph Affected LRA Section           LRA Page No.         and Sentence Table A.5-1                    Page A.5-8           New Item Number 23 LRA Table A.5-1, "Unit 2 License Renewal Commitments," requires a new License Renewal Future Commitment related to elastomeric components.
FENOC plans to periodically replace elastomeric components in mechanical systems (with the exception of ventilation flexible connections) such that these components are short-lived and not subject to aging management review. A table that provides a list of elastomeric components that are the focus of this new commitment is included following the commitment. New Item Number 23 is created, and LRA Table A.5-1 is revised to read:
Item                                                 Implementation                 Related No.                   Commitment                       Schedule        Source      Section LRA.
No./
Comments 23    With the exception of flexible connections     May 27, 2027      FENOC            None in ventilations systems, prior to the period                      Letter of extended operation, FENOC will                                L-08-212 perform repetitive maintenance tasks to replace mechanical system elastomeric components that would otherwise be subject to aging management review.
Subsequent frequencies of the repetitive replacements will be based on manufacturerrecommendations and applicable operating experience.
LDe*e,*ej
[See "Elastomeric Components and Affected Systems" table on next page.]

Enclosure L-08-212 Page 47 of 65 Elastomeric Components and Affected Systems rnergency Diesel Expansion joint    Generators &     2.3.3.11 / 3.3.2-11 Support Emergency Diesel Flexible hose     Generators &     2.3.3.12 / 3.3.2-12 Support Emergency Diesel Flexible hose     Generators &     2.3.3.13 / 3.3.2-13 Support Emergency Diesel Flexible hose     Generators &     2.3.3.14 / 3.3.2-14 Support Emergency Diesel Flexible hose     Generators &     2.3.3.15 / 3.3.2-15 Support Emergency Diesel Flexible hose     Generators &     2.3.3.16 / 3.3.2-16 Support ERF Diesel Expansion joint Generator Support   2.3.3.17 / 3.3.2-17 Flexible hose    Security Diesel   2.3.3.29 / 3.3.2-29 Generator Flexible hose      Solid Waste     2.3.3.31 / 3.3.2-31 Disposal Chemical and Sight glass     Volume Control      2.3.3.5 I 3.3.2-5 Flexible hose    Compressed Air      2.3.3.7 / 3.3.2-7 Flexible hose  Auxiliary Feedwater   2.3.4.1 / 3.4.2-1

Enclosure L-08-212 Page 48 of 65 Affected Paragraph Affected LRA Section            LRA Page No.         and Sentence Table A.5-1                     N/A                  New Item Number 27 LRA Table A.5-1, "Unit 2 License Renewal Commitments," requires a new License Renewal Future Commitment related to polymer components. FENOC plans to periodically replace, or to periodically test and replace on condition, polymer components in mechanical systems (with the exception of underground Geoflex-D piping), such that these components are short-lived and not subject to aging management review. A table that provides a list of polymer components that are the focus of this new commitment is included following the commitment.
New Item Number 27 is created, and LRA Table A.5-1 is revised to read:
SItem No.                    Commitment                    Implementation Schedule           Source     Related Section LRA No./
Comments 27     With the exception of underground              May 27, 2027        FENOC           None GeoFlexfuel oil piping, prior to the period                         Letter of extended operation, FENOC will                                  L-08-212 perform repetitive maintenance tasks to replace, or to test and replace on condition, mechanical system elastomeric components that would otherwise be subject to aging management review.
Subsequent frequencies of the repetitive tests/replacements will be based on manufacturer recommendations and applicable operating experience.
[See "Elastomeric Components and Affected Systems" table on next page.]

Enclosure L-08-212 Page 49 of 65 Polymer Components and Affected Systems Filter housing (1VS-        Area Ventilation -
2.3.3.1 / 3.3.2-1 FL-47/48 bowl)             Control Area Emergency Diesel Flexible hose             Generators &     2.3.3.12 / 3.3.2-12 Support Emergency Diesel Piping               Generators &     2.3.3.16 / 3.3.2-16 Support Emergency Diesel Sight glass              Generators &     2.3.3.16 / 3.3.2-16 Support Flexible hose            Fire Protection   2.3.3.18 / 3.3.2-18 (Halon)
Demineralizer             Reactor Plant    2.3.3.26 / 3.3.2-26 Sample Tank                 Reactor  Plant   2.3.3.26 / 3.3.2-26 Sample Tubing                Reactor  Plant   2.3.3.26 / 3.3.2-26 Sample Tank                  Solid Waste     2.3.3.31 / 3.3.2-31 Tank______________      Disposal      2.3.3.31_/_3.3.2-31

Enclosure L-08-212 Page 50 of 65 Affected Paragraph Affected LRA Section              LRA Page No. and Sentence Table B.1-1                       Page B.1-6      1 5 th Row Page B.1-7      Ist and  8 th Rows LRA Table B.1-1, "BVPS Aging Management Programs," requires deletion of several rows based on the removal of the Nickel-Alloy Nozzles and Penetrations, the PWR Vessel Internals, and the Thermal Aging and Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel (CASS) Programs from Appendix B. These programs were not well-defined, and License Renewal Future Commitments are to be used to develop the programs that will manage the aging of the components that previously credited these programs. Therefore, the Table B.1-1 rows that correspond to these [deleted] programs are deleted.
LRA Table B.1-1 is revised to read:
Aging Management Program Title               LRA Section    Status Nickl,.l Alloy*     z4zles and Penet.rat;,'.                                 New PWR Vessel Internals                                            B.-23        New Thermal Aging and Neutron Irradiation Ebr-itterent e            B. 244       New Gast Austen&ti Stainless Steel (GASS)

Enclosure L-08-212 Page 51 of 65 Affected Paragraph Affected LRA Section          LRA Page No.        and Sentence Table B.1-2                   Page B.1-9          4 th, 7 th and 1 0 th Rows LRA Table B.1-2, "BVPS Aging Management Program Correlation to NUREG-1801 Aging Management Programs," requires deletion of BVPS-specific program information in several table cells based on the removal of the Nickel-Alloy Nozzles and Penetrations, the Thermal Aging and Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel (CASS), and the PWR Vessel Internals Programs from Appendix B. These programs were not well-defined, and License Renewal Future Commitments are to be used to develop the programs that will manage the aging of the components that previously credited these programs. Therefore, the BVPS-specific program information in Table B.1-2 table cells that corresponds to these [deleted] BVPS programs is deleted.
LRA Table B.1-2 is revised to read:
LRA Section NUREG-1801 Program                     BVPS Program Nickel-Alloy Nozzles and          NiGe! All.y. N-zzlcs and          B.--28 Penetrations                      Penetraiek*s Thermal Aging and Neutron         Therm.al Aging and N-utr, n         244 Irradiation Embrittlement of Cast Iradiation Embri,wrn nt of Gas.
Austenitic Stainless Steel (CASS) Aust.enit Stainless Steel (CASS)
PWR Vessel Internals              PWR Vessel Int,-a                 B...o

Enclosure L-08-212 Page 52 of 65 Affected Paragraph Affected LRA Section        LRA Page No.         and Sentence Table B.1-3                 Page B.1-15          9 th Row Page B.1-16          2 nd and 9 th Rows LRA Table B.1-3, "BVPS Aging Management Program Consistency with NUREG-1801 Aging Management Programs," requires deletion of table rows based on the removal of the Nickel-Alloy Nozzles and Penetrations, the PWR Vessel Internals, and the Thermal Aging and Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel (CASS) Programs from Appendix B. These programs were not well-defined, and License Renewal Future Commitments are to be used to develop the programs that will manage the aging of the components that previously credited these programs. Therefore, the Table B.1-3 rows that correspond to these [deleted] programs are deleted. LRA Table B.1-3 is revised to read:
NUREG-1801 Comparison Programs                         Programs with Plant-    Consistent       Programs with   Exception(s) to Program Name            Specific      with         Enhancement(s)      Expn 80 NUREG-                           NUREG-1801 1801 ick    Alloyl Nzz No     and       -          Yes P*enetatids Pesse, InterYes Thormel Aging and Neutron        -Yes Irradiationembitcct (CAS S)

Enclosure L-08-212 Page 53 of 65 Affected Paragraph Affected LRA Section         LRA Page No.         and Sentence Section B.2.15              Pages B.2-39          Multiple locations in Section through B.2-42 LRA Section B.2-15, "External Surfaces Monitoring," requires revision to address the increased scope to the NUREG-1801, Section XI.M36, "External Surfaces Monitoring," program that manages aging of elastomer ventilation flexible connections. Multiple subsections of the program are affected, so the entire External Surfaces Monitoring Program is reproduced for clarity. LRA Section B.2-15 is revised to read:
       "B.2-15    EXTERNAL SURFACES MONITORING ProgramDescription The External Surfaces Monitoring Programis a new program that BVPS will implement priorto the period of extended operation.
The External Surfaces Monitoring Programis based on system inspections and walkdowns. This program will consist of periodicinspections to monitor the external surfaces of in-scope steel components and other metal components for material degradationand leakage, and periodic inspection of in-scope elastomer components for hardening,loss of strength or cracking through physical manipulation. The program will also require inspection of radiators(fins and tubes) associatedwith diesel engines and diesel-driven equipment for build-up of dust, dirt and debris. Additionally, the program is credited with managing aging effects of internalsurfaces, for situations in which materialand environment combinations are the same for internaland external surfaces such that external surface condition is representativeof internalsurface condition.
Loss of materialdue to boric acid corrosion is managed by the Boric Acid Corrosion Program[Section B. 2.7].
NUREG-1801 Consistency The External Surfaces Monitoring Programis a new program that is consistent with NUREG-1801, Section XI.M36, External Surfaces Monitoring.
Exceptions to NUREG-1801 None Enhancements None

Enclosure L-08-212 Page 54 of 65 Aging Management ProgramElements The results of an evaluation of each of the 10 aging management program elements describedin NUREG-1801, Section XI.EI, are provided as follows:
* Scope of Program The program will require visual inspection of the external surfaces of in-scope components and monitoring of the external surfaces of steel components and other metal components within the scope of license renewal and subject to aging management review for loss of materialand leakage. The pro-gram will reguire monitoring of the external surfaces of flexible elastomeric connections in ventilation systems for cracking and for hardeningand loss of strength. The progmrm will require .,*e.*tin-e14,;
scope clastomcr components for-hardoning, loss of strength Or cracking.
The program will also require inspection of radiators(fins and tubes) associatedwith diesel engines and diesel-driven equipment for build-up of dust, dirt and debris.
Inspections shall include, but will not be limited to the following types of inspection:
o   Visual inspection for indications of general corrosion(appliabe steel components), pitting corrosion, and crevice corrosionof exposed metal surfaces. Forsteel components, general corrosion is expected to be present and detectable. If pitting and crevice corrosionshould exist, then general corrosion will manifest itself as visible rust or rust by-products (e.g., discolorationor coating degradation)and will be detectableprior to any loss of intended function. Loss of material from external surfaces of stainless steel (or other metals) will be evident by surface irregularitiesor localized discolorationbefore loss of function occurs. Although materials other than steel are not discussed in NUREG-1801 for this program,identification of the loss of materialaging effect for other metals is amenable to the same types of visual inspections.
o   In addition to the program scope described in NUREG-1801, Section XI.M36, the External Surfaces Monitoring program will require monitoring of the external surfaces of flexible elastomeric connections in ventilation systems for crackinq and for hardening and loss of strength. The program is also credited with managing these aging effects for the internal surfaces of these components, in which both the internaland external surface environments are ambient or dry air. Visual
                                             . 4.npetin of elast.mers 16F indication,
                                                                                      ,. s hardening, loss of strength and cracking. The inspectionIll include physial manipulation of elastomcrs to visually confr fexdbil#y,

Enclosure L-08-212 Page 55 of 65 o Visual inspection of radiators(fins and tubes) associatedwith diesel engines and diesel-driven equipment for build-up of dust, dirt and debris. The applicable aging effect is reduction of heat transferdue to build-up of dust, dirt and debris.
The E-xternal Surfaces Monitoring proegram is credited with managiny aging effects of internal surfac-es, for-situations in whic~h material and
                  .nvirnmonteombinations are the same for-internal and external sufaees,-
such that external isur-face conditon is relpresentative of internal surface
          " Preventive Actions The External Surfaces Monitoring Program is a visual monitoringprogram that does not include preventive actions.
* ParametersMonitored/ Inspected The program will require the use of periodicplant system inspections and walkdowns to monitor for material degradationand leakage. The program requires inspection of components such as piping, piping components, ducting and other components. The inspection parameterswill include the following:
o Corrosion and materialwastage (loss of material);
o Leakage from or onto external surfaces; o Worn, flaking, or oxide-coated surfaces; o Corrosion stains on thermal insulation;and, o Protective coating degradation (cracking and flaking).
In addition to the parametersspecified by the NUREG-1801, Section XI.M36 pro-gram, the External Surfaces Monitoring program will require the use of periodic plant system inspections and walkdowns to monitor for materialdegradationof elastomeric flexible connections in ventilation systems. These inspections include a visual inspection coupled with physical manipulation of elastomeric components to identify a-ging parameterssuch as cracks, hardening and loss of strength.
The program provides for inspection of bolting used in pressureretaining components (non-safety related)as requiredby the Bolting Integrity Program.

Enclosure L-08-212 Page 56 of 65 Detection of Aging Effects The program will require periodic visual inspection of in-scope steel components and other metal components to identify loss of material. -The pro gram will require periodic inspction of in scope elastomer comgponents for-har-denkg, loss Of Strength OF cracking. The program will also require inspection of radiators(fins and tubes) associatedwith diesel engines and diesel-driven equipment for build-up of dust, dirt and debris.
For metal surfaces that are painted or coated, the program will inspect these surfaces to confirm integrity of the paint or coating. If no degradationis indicated, then no additionalinspection of the subject surface will be required.
In addition to the detection methods specified by the NUREG-1801, Section XI.M36 pro-gram, the External Surfaces Monitoring program will require a periodic visual inspection, coupled with physical manipulation of in-scope elastomeric ventilation components, to identify cracking, hardeningand loss of strength.
Physicalmanipulation of elastomeric components, such as by pinching or prodding flexible connections in ventilation systems, will aid in identificationof elastomeraging effects. Cracking of elastomeric components becomes evident at the outside radius of elastomer deformations as the cracks open. Changes in materialproperties,such as hardeningand loss of strength, can be detected during manipulation of elastomericcomponents by the relative inflexibility of the component, or by the failure of the component to return to its previous shape or conf*guration. Additionally, since the external environment of ventilation systems is similarto the internalenvironment, the condition of the external surface is expected to be representativeof the internalsurface condition.
The program is credited with managing aging effects of internalsurfaces, for situationsin which material and environment combinations are the same for internaland external surfaces, such that external surface condition is representativeof internal surface condition.
The program will require a visual inspection to be conducted for in-scope component surfaces at least once per fuel cycle. This frequency allows inspections of components that may be in locations that are only accessible during outages. As such, component surfaces that are inaccessibleor not readily visible during plant operations are inspected during refueling outages.

Enclosure L-08-212 Page 57 of 65 Component surfaces that are inaccessibleor not readily visible during plant operationsand refueling outages will be inspected at such intervals that will provide reasonableassurance that the effects of aging will be managed such that applicable components will perform their intended function during the period of extended operation.
Component surfaces that are insulated will be inspected when the external surface is exposed (i.e., maintenance) at such intervals that will provide reasonableassurance that the effects of aging will be managed such that applicable components will perform their intended function during the period of extended operation.
The intervals of inspection may be adjusted as necessary based on BVPS inspection results and industry experience.
Monitoring and Trending The program provides qualificationrequirements for personnel associated with visual inspection activities in accordancewith site controlled procedures and processes.
In addition to the monitoring and trending specified by the NUREG-1801 Section XI.M36 program, the External Surfaces Monitoring program will require a periodic visual inspection, coupled with physical manipulation of in-scope elastomeric components to identify cracking, hardening and loss of strength. The programprovides qualification requirementsfor personnel associatedwith visual inspection and physical manipulationof elastomers in accordance with FENOC proceduresand processes.
Formaltrending will not be requiredby the program. However, inspection results will be maintainedin accordance with System Engineering Walkdown procedures and as such, the inspection results will be available for review and trending during subsequent walkdown inspections. Also, the program will require that deficiencies are documented in the BVPS Corrective Action Programand allow results to be trended.
Acceptance Criteria The program defines acceptance criteria as no unacceptable visual indication of leakage, loss of material,hardening and loss of strength or cracking, and reduction of heat transferthat would lead to loss of intended function during the period of extended operation. Visual indications with respect to system design standards,proceduralrequirements, current licensing basis, industry codes or standards,and engineering evaluations shall be evaluated by assigned engineeringpersonnel. Evaluation of

Enclosure L-08-212 Page 58 of 65 visual indicationswill determine if the results are acceptableor if corrective action is required.
In addition to the acceptance criteria specified by the NUREG-1801, Section XI.M36 program, the External Surfaces Monitoring program will provide acceptance criteria for elastomerinspections. The proposed program defines acceptance criteria as no unacceptable visual or tactile indication of leakage, hardening,loss of strength, or cracking that would lead to loss of intended function during the period of extended operation.
Visual or tactile indications with respect to system design standards, proceduralrequirements,currentlicensing basis, industry codes or standards,and engineering evaluations shall be evaluated by assigned engineeringpersonnel. Evaluation of visual and tactile indicationswill determine whether the results are acceptable or if corrective action is required.
CorrectiveActions This element is discussed further in Section B. 1.3.
ConfirmationProcess This element is discussed further in Section B. 1.3.
          " Administrative Controls This element is discussed further in Section B. 1.3.
          " Operating Experience The External Surfaces Monitoring Programis a new program;therefore, there is no plant-specific program operatingexperience for program effectiveness. Industry operating experience that forms the basis for the program is described in the operatingexperience element of the NUREG-1801 program description.
BVPS has experienced leakage from flexible elastomeric hoses in the cooling water environment associatedwith diesel engines (both diesel generatorsand the diesel driven air compressor), and in the lubricatingoil environment associatedwith the turbine oil purifier. Corrective actions for these conditions included hose replacement and administrative changes to ensure leakage does not result in inoperabilityof important eguipment.
BVPS has also identified a tearin an elastomeric ventilation flexible connection between a control room emergency fan and associated ductwork. The cause of the tear could not be identified. The tearmay have been caused by maintenance activities, aging, or it may have been

Enclosure L-08-212 Page 59 of 65 present during initialinstallation. An evaluation of the consequences of the 3/8-inch by 1/8-inch slit determined that the consequences to system operation were insignificant.
The availableoperating experience relative to elastomersprovides reasonableassurancethat visual inspection, coupled with physical manipulation,is sufficient to identify aging effects in elastomeric components prior to loss of function.
Industry and plant-specific operatingexperience will be evaluated in the development and implementation of this program. As additionaloperating experience is obtained,lessons learned will be appropriatelyincorporated into the program.
Conclusion The implementation of the External Surfaces Monitoring Programwill provide reasonableassurancethat the aging effects will be managed so that the systems and components within the scope of this Programwill continue to perform their intended functions consistent with the current licensing basis for the period of extended operation."

Enclosure L-08-212 Page 60 of 65 Affected Paragraph Affected LRA Section         LRA Page No.        and Sentence Section B.2.28               Page B.2-77         Entire Section LRA Section B.2.28, "Nickel-Alloy Nozzles and Penetrations," requires deletion.
FENOC has committed in the LRA, Appendix A, to develop a plant-specific program for managing the aging of nickel-alloy components and nickel-alloy clad components susceptible to primary water stress corrosion cracking - PWSCC (other than upper reactor vessel closure head nozzles and penetrations).
Therefore, the Nickel-Alloy Nozzles and Penetrations Program text is deleted from the section. LRA Section B.2.28 is revised to read:
       "B.2.28 [Delete       NICKEL.ALLOYN.Z..E. A ND P.ENETRAION.S r
Ferthe N^1kel Ag,, N^, -z.e and Penetratio;.-ns,P.-m..........       ;,;;*. ,..
For.
managing the aging of nickel alloy and ni.kel agly Glad components SUScept to primary' water-stress orso cracking PW-SCC (othier than upper-rcacte; vessel closure head noz-zlos and penetrations), BVPS has provided in Appendix A a Elomemitmcnt to develop a plant specific a*n           men pro gram that will irnplcmgent applicable:
: 1. NRC Orders, Bulletins and Con cric Letters, and-,
: 2. staff acceptod industry guidelines."

Enclosure L-08-212 Page 61 of 65 Affected Paragraph Affected LRA Section         LRA Page No.        and Sentence Section B.2.33               Page B.2-90         Entire Section               (
LRA Section B.2.33, "PWR Vessel Internals," requires deletion. FENOC has committed in the LRA, Appendix A, to develop and implement a plant-specific program for managing the aging of Reactor Vessel internal components and structures. Therefore, the PWR Vessel Internals Program text is deleted from the section. LRA Section B.2.33 is revised to read:
       "B.2.33 [Deleted] PWR VESSEL INTERNALS BVPS has prov..ided   in Appendix A (UFSAR   Supplemint),T-able A.4   (UnitI1
: 1. Pari*Gcpate in the industry prgrams applUicable to BVPS font           g
: 2. Evaluate and implement the results of the industry programns as applicable to the BVPS reactor, internals; and-,
: 3. Upon completion of these programns, but not less than 24 months befoee entering the period of extended operations, submit an inspectlon plan fo the BVPS reactor internals to the NRC fo revie. an approval."

Enclosure L-08-212 Page 62 of 65 Affected Paragraph Affected LRA Section           LRA Page No.            and Sentence Section B.2.40                 Pages B.2-110           Entire Section through B.2-113 LRA Section B.2.40, "Thermal Aging and Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel (CASS)," requires deletion. FENOC has committed in the LRA, Appendix A, to develop and implement a plant-specific program for managing the aging of Reactor Vessel internal components and structures. Therefore, the Thermal Aging and Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel (CASS) Program text is deleted from the section. LRA Section B.2.40 is revised to read:
      "B.2.40     [Deletedl THER*A; A*,IN         AND,EUTRON     IRRADATON EMBRITLEMENT OF CAsT-Au&;TENiTIC STAINLESS STEEL: (CASS)
Program Dcscription The Thermal Aging,,,and             ,-,. bae a....E              of Cast Austenii
                                                               .Mbitt.lement Stainess Steel (CASS) Program is a nwpogram that BVPS will implemcnt p.riorto thc period of cxtended operaton.,
Reaclto Vessel Internals wigl be          pt*,d in accordance with ASE= Code Scction Ml, Subsection IWB, Category B N 3. This insection will be augmcntc neutron irradiation embrittlom~ent of          -S compnents. The pormWil include identifiation of the limiting susceptible componenits froem the stndonto thermal aging susceptibiliy, neutron fluence, and cracking. Fr each identified component, aging management will be accomlplished thro-ugh either supplemgental examination or-a Ge~cpnt spcii evaluation, including a m~echanic-al loading assessment.
9V       w#. ad!ipatm. in the EP: Materials Refabt Piqeeo t estao:,shedo inve9stigate the impacts of aging on PWR vessel internal com~ponents. The result of this pr~oject will provide additional bases for the inspections and evaluations pogFfomed under this program.
NUREG-1801 Consistenc The Thermal Aging and Neutron Irradiation E-mbrittlement of Cast4AuSten.itic Stainless Steel (CA SS) P-rogram is a e ging managem~ent program that wl be consistent with NUREG 1 8014, Section Xk M 3, Thermal Aging and Neuto Irradiation E-mbrittlement of Cast Austenitic Stainless Steel (CA~SS)-.

Enclosure L-08-212 Page 63 of 65 E-xceptions to NUREG-1801 None, Enhancements None A    gna...gement Progra.           1.ements The reisults of an evalation of each of thc 10 aging management pro gram elements described in NUREG 1801, Section Xl.MI3, are provided as Agileos Scopc of Program be screcned for-potential susceptibIlity to thermal aging mbrilement.
The sre&#xfd;geFria is set fo.-h in thi let dated May 19, 2000, fro, Walters, Nclear E   .n.;erg Instiute, License P.ene.. Iu        No4.18 0/-030, Thermal Aging SE;brittlment of Cast Stainless Steel Components. The screeningcriteria is applicable to components constructed from SA 351 Grades CF,3, CF-3A, CF8, 0   CEB8A, 0  CFAM, CF3MA, CF8M,         ithA seic onditions above 250 C (482 F). In aplying the screening method, feri content is calculated by using Hulf eqivlent factors descriedi NUREGI/CR 4513, Rev. 1.
For-petentially suseeptible components, the program will requir evaluation of the synergistic loss of fractur-e toughness due to neutron emgbrittlement and thermal aging embriffement.
For-each such component, ag-'        manaement will be accomphished through either a suplm ena exaI'm.mination of the affected component a-s pait of a 10 year-inservwieInspection program during the license r-enewa termf, Or a comgponent spec~ifi evaluation to determine the component' susc~eptibilit to loss of fracture toughness.-
Prc*vcntivc 1          Actions The prga is a cnditin moenitorig proegram that detects degradationo componaents be-Mfor)e- loss of intended function. Thcrc fore, there are no wevntve er miigtig ttibbutes that are associated with these activites.
          " Paramcter-s Monitored / Inspcctcd The program wil identify the Reactor- Vessel Inernals cast austenti stainless steel materaias that have a projected 60 year-neutron fluence o gr-eater than 1.OE 17-n1'cm (E> 1.0 Me V) or are dotermned to be susceptible to thermal aging embrittement. For-such m~aterials, the

Enclosure L-08-212 Page 64 of 65 component or a component spec~ifi evalation to determineth component's susceptibiliy to loas of fracture toughness.
                -O     ea vios Vvesel. Intemas     Gasl*.
t    austenllSti   sti nle s tIe*SeS s.I*I  l Gempon*4en~VV
           *Detection of Aging Effect that have a projected 60 year-notron fluence of greateF than 1.OE+ 47 a*o&#xfd; (E>1.0 MeV) Or are dctcrmind to be susceptible to thermal em~brieet                  fh yoar inse.Mvie inspection program in effcct during 10 the r-enewal period wigl inlude supplemental inspe;tions covering p'eions standpoint of thermal aging SUSccptib#4lt                noutron fluen c, and cracking SUSepti#k#y, critical flaw size wtadqteari.The critical flaw size will be determined based on the service loading conditons and service degrade mater*al proper;ies. Exraminati;n merth-od*S that meet the criteria of the ASlE Code Section A-, Appendix Vill aroeaceptae As an altermate to sp plemental inspectiOns, a component specific evaluation may be pefFormedt,           including a mechanical loading assessment to determine the maximumg tensile loading on the com~ponent during ASM Code Service Level A, 8, C, and D conditions. if the loading is compressive or-low enough (45 ksio to preclude fracture, then supplemental insection of the com~ponent wigl not be required. Failure to meet this criterion will require continued use of the supplomenta insection proegram.
For each cast austenitic stainless steel com.ponent tat iS Pr....ted to have a neutron fluenhe of less than 4.1-E47 ncm-2 (IE>1.0MeV) andis susceptible to thermal aging, thesupplem     .tion                           prg applies.
For each cast austeniti stainless steel component thaispoetdo have a neutron fluonce of less than 4.0E+17 n/cm? "'E>1.0 AleV) and is not susceptible to thermal agingL, the existing ASME Code Sectione insection requirements are adequate.
           *Monitoring and Trending Inspection schedules wNllbe in accordance with ASME Section AI,

Enclosure L-08-212 Page 65 of 65 "Acccptance Criteria Flaws detected in cast austeniftic istainesissteel componentsar evaluated in accordance with the applicable pr-ocedures of ASME= Code SectiOn Al 1WB 3500. Flaw toleran"e ev..hation for   .omponents ,i;h ferrite content up to 25% will be pormed according to the prciple*         s associated with IW3 3640 procedures for-submerged arc welds (SA W)-,
disregarding the code restriction of 20% ferrite in IW3 364 1(b)(4). Flaw tolerance evaluations for comgponents with greater-than 250% ferrie will be pe~formcd on a ease by case basis using fracture toughness data provided in indus*ty lieratur
           " Corrcctive'Actions This element is discusscd in Section B.1.3.
           " Confirmation Procces Thi-s element i-s discusised in Section B.1.3.
           " Administrative Con"rl This element is discussed in Sedc:    ,. B.3.
           " Opcrating Expcricncc The Thermal Aging and Neutron Irradiation E-mbrittement of Cs Austenitic Stainless Steel (CA SS) Progrm isanwprogram; therefore, thmr is no plant specific program operating experienc for progm effedhveness. Industr-y operating experieZnz thaQt forms the basis for-the program is described in the operating exprec element of the NUREG-4801 program ..des....,.
Industry and plant specifie operating exprec wil be evaluated in the deeomn         an              tat           ;gg..m   A6 adeea     e.. ert
              ;'t&#xf7;the'- program7 C~c-noksion The implementation of the Thermal Aging and Neutron Irradiation Embrittlemn of Cast Austenii    Stainless Steel (CA SS) Rogram will provide easonabie*
assurance that the aging effect-s will be m~anaged so that the syste~ms, and components within the scope of this Program wigl continu~e to pe~ffrm thei intended functions consistent with the current licensing basis for the periodwo extended operation."}}