ML101340182

Response to Request for Additional Information Related to the Review of the License Renewal Application

ML101340182
Person / Time
Site:	Kewaunee
Issue date:	05/13/2010
From:	Hartz L Dominion Energy Kewaunee
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
10-286
Download: ML101340182 (18)

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10lHiilion H

Energy Kewaunee, Inc.

i ). 'minion Boulevard, Clen Allen, VI " ", DOlllinion' May 13, 2010 United States Nuclear Regulatory Commission Serial No.: 10-286 Attention: Document Control Desk LR/MWH RO Washington, DC 20555-0001 Docket No.: 50-305 License No.: DPR-43 DOMINION ENERGY KEWAUNEE, INC.

KEWAUNEE POWER STATION RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION RELATED TO THE REVIEW OF THE KEWAUNEE POWER STATION LICENSE RENEWAL APPLICATION By letter dated April 14, 2010 (reference 1), the NRC provided a request for additional Information regarding the aging management review results included in the license renewal application (LRA) for Kewaunee Power Station (KPS) (reference 2). The NRC staff indicated that a response to this request for additional information (RAI) is needed to complete the review of the KPS LRA. Attachment 1 to this letter provides the Dominion Energy Kewaunee, Inc. (DEK) response to the RAI submitted by the NRC staff in reference 1.

In a letter dated March 26, 2010 (reference 3), DEK committed to provide a response to RAI 3.1.2.2.13-01 within 60 days of the date of that letter. The NRC concern identified In RAI 3.1.2.2.13-01 is currently being considered for review and resolution on an Industry basis and a ~}eneric industry position will not be developed within the 60-day schedule identified in our March 26, 2010 letter. Therefore, DEK is revising the proposed commitment schedule A response to this RAI will be provided after further Industry review of the NRC concern.

Serial No.10-286 Docket No. 50-305 Page 2 of 4 Should you have any questions regarding this submittal, please contact Mr. Paul C.

Aitken at (804) 273-2818.

Very truly yours,

-~J-fco--

Leslie N. Hartz Vice President - Nuclear Support Services COMMONWEALTH OF VIRGINIA 31.2014 COUNTY OF HENRICO The foregoing document was acknowledged before me, in and for the County and State aforesaid, today by Leslie N. Hartz, who is Vice President - Nuclear Support Services of Dominion Energy Kewaunee, Inc.

She has affirmed before me that she is duly authorized to execute and file the foregoing document in behalf of that Company, and that the statements in the document are true to the best of her knowledge and belief.

Acknowledged before me this /3 ~ay of ~, 2~1 o..

My Commission Expires: .il1Ay 31, ZQIl/: /It cJ.,. i.~

Notary Public

Attachment:

1. Response to RAJ 82.1.32-5

References:

1. Letter from John Daily (NRC) to David A. Heacock (DEK), "Request for Additional Information for the Review of the Kewaunee Power Station License Renewal Application (TAC No. MD9408)," dated April 14, 2010. [ADAMS Accession No.

ML082341020]

2. Letter from D. A Christian (DEK) to NRC, "Kewaunee Power Station Application for Renewed Operating License," dated August 12, 2008. [ADAMS Accession No.

ML082341020]

3. Letter from L. N. Hartz (DEK) to NRC, "Response to Request for Additional Information Associated with the Review of the Kewaunee Power Station License Renewal Application," dated March 26, 2010. [ADAMS Accession No.

ML100890229]

Serial No.10-286 Docket No. 50-305 Page 3 of 4 Commitments made in this letter:

1. License Renewal Commitment 47 will be added to LRA Table A6.0-1, consistent with the response to RAI 82.1.32-5. The new commitment is proposed to support approval of the renewed operating license, and may change during the NRC review period.

2. In a letter dated March 26, 2010 (reference 3), DEK committed to provide a response to RAI 3.1.2.2.13-01 within 60 days of the date of that letter. The NRC concern identified in RAI 3.1.2.2.13-01 is currently being considered for review and resolution on an industry basis and a generic industry position will not be developed within the 60-day schedule identified in our March 26, 2010 letter.

Therefore, DEK is revising the proposed commitment schedule. A response to this RAI will be provided after further industry review of the NRC concern.

Serial No.10-286 Docket No. 50-305 Page 4 of 4 cc: U.S. Nuclear Regulatory Commission Regional Administrator, Region III 2443 Warrenville Road Suite 210 Lisle, IL 60532-4532 Mr. P. S. Tam, Senior Project Manager U.S. Nuclear Regulatory Commission One White Flint, Mail Stop 08-H4A 11555 Rockville Pike Rockville, MD 20852-2738 Mr. Daniel Doyle Environmental Project Manager U.S. Nuclear Regulatory Commission Mail Stop 0-11 F1 Washington, DC 20555-0001 Mr. John Daily License Renewal Project Manager U.S. Nuclear Regulatory Commission Mail Stop 0-11 F1 Washington, DC 20555-0001 NRC Senior Resident Inspector Kewaunee Power Station N490 Highway 42 Kewaunee, WI 54216 Public Service Commission of Wisconsin Electric Division P.O. Box 7854 Madison, WI 53707 David Hardtke Chairman - Town of Carlton E2334 Lakeshore Road Kewaunee, WI 54216

Serial No.10-286 Docket No. 50-305 ATTACHMENT 1 RESPONSE TO RAI 82.1.32-5 KEWAUNEE POWER STATION DOMINION ENERGY KEWAUNEE, INC.

Serial No.10-286 Docket No. 50-305 Attachment 1/Page 1 of 13 I. NRC ISSUES AND REQUESTS In a letter from NRC to DEK dated April 14, 2010, the following Request for Additional Information was submitted.

"RAI B2.1.32-5, Review of the Work Control Process, Kewaunee License Renewal Application

Background:

In the Dominion Energy Kewaunee (Dominion) Letter No.09-597 dated September 25, 2009 (Agencywide Documents Access and Management System (ADAMS) Accession Number ML092710045), Dominion amended the Work Control Process (WCP) aging management program (AMP) and identified that the WCP is a new AMP that when enhanced will be consistent with the program elements recommended in: (a) Generic Aging Lessons Learned (GALL) AMP XI.M32, "One-Time Inspection," when implemented as a one-time inspection program for those components that are managed on a preventative or mitigative monitoring basis (i.e., through implementation of either license renewal application (LRA) AMP 82.1.24, "Primary Water Chemistry Program;"

AMP 82.128, "Secondary Water Chemistry Program;" AMP 82.1.8, "Closed-Cycle Cooling Water Program;" AMP 82.1.14, "Fuel Oil Program;" or AMP 82.1.17, "Lubricating Oil Analysis Program"), and (b) GALL AMP XI.M38, "Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components," when applied as a periodic condition monitoring program and subject to the exceptions that were taken to GALL AMP XI.M38 in the letter of September 25, 2009. On December 3, the staff issued requests for additional information (RAls) 82.1.32-1, -2, -3, and -4 with respect to the revised program element criteria for the WCP and on some of exceptions that were taken to GALL AMP XI.M38. Dominion responded to these RAls in the Dominion Letter No.09-777, dated January 21, 20[10] (ADAMS Accession No. ML100220066). The staff has reviewed the information in the letters of September 25, 2009 and January 21, 2010, and has the following issues that require resolution.

Issue 1 (Part 1 of the RAI - In regard to the information that has been submitted for the WCP in the letter of September 25. 2009. as supplemented bv the response to RAI 82.1.32-1 in the letter of January [271. 2010):

The staff has noted that the applicant is crediting methodology in EPRI TR 107514 as the basis for selecting the sample sizes for the material-environment-aging effect combinations that will be managed by the WCP on a one-time inspection basis, and that this report states that the sample sizes should achieve a desired confidence level.

However, the applicant's basis continues to leave some uncertainty with respect to establishing the sample size for the material-environment-aging effect-based populations being managed on a one time inspection basis because the applicant did not exactly specify or provide a justification for the minimum sample sizes that would be

Serial No.10-286 Docket No. 50-305 Attachment 1/Page 2 of 13 needed for these one-time inspections of these populations, or establish a limit, with justification, on when these one-time examinations would need to be completed to ensure appropriate and timely verification of preventative or mitigative program effectiveness. In addition, the staff's position on use of GALL AMP XI.M32 has been that one-time inspections of components that are managed on a one-time condition monitoring basis will need to be completed by a specified time agreed upon time (usually prior to entering the period of extended operation or within several years of entering the period of extended operation).

Request 1:

Regarding the information that was submitted on use of EPRI Report No. TR-107514, specify and justify the minimum percentage of components that will be used to establish the sample sizes for the one-time examinations of the stated component populations. In addition, identify and justify when the one-time inspections for the WCP will be completed."

"Issue 2 (Part 2 of the RAI - In regard to the information that has been submitted for the WCP in the letter of September 25, 2009, as supplemented by the response to RAI 82.1.32-3 in the letter of January [271, 2010):

The staff has noted that under the applicant's amended WCP basis, as given in the applicant's letter of September 25, 2009, and supplemented with information in the letter of January 21, 2010, the WCP lends itself to being a program that monitors for abnormal surface conditions such as rust, discoloration, deposits, scale or abnormal surface conditions, or for evidence of cracking or changes in the material properties for elastomeric components.' In RAI 82.1.32-3, the staff inquired as to the type of visual examination methods that would be used to detect indications/parameters associated with these aging effects (Le., specify VT-1, VT-3, etc.). In the response to RAI 82.1.32-3, the applicant stated that the 'non-defined' visual examination methods would be capable of detecting these aging effects and that personnel performing either the preventative maintenance activities or periodic surveillance activities would be trained to perform the inspection and would be generally qualified to detect the aging effects. The RAI response did not define the type of visual examination methods (in terms of ASME Code defined visual examination methods) that would be used to detect the parameters associated with these aging effects. The staff noted that the amended WCP basis only refers to EPRI Report No. TR-107514 as the basis for establishing the sample sizes of components that will be inspected under the program. The amended basis does not establish, define, or justify the minimum sample size that will need to be applied to the With the exception of the visual techniques that the applicant is crediting for detection of cracking in metallic components, which the applicant's letter of September 25, 2009 identifies will be EVT -I techniques or their equivalent.

Serial No.10-286 Docket No. 50-305 Attachment 1/Page 3 of 13 material-environment-aging effect populations being managed by the AMP on a periodic basis, or the minimum inspection frequency.

Request 2:

A. Specify and justify the minimum percentage of components that will be used to establish the sample sizes for the for the component populations that are associated with these material-aging effect combinations and that will be managed on a periodic WCP-inspection basis.

B. For these component populations, specify and justify the maximum frequency for the examinations."

"Issue 3 (Part 3 of the RAI - In regard to the operating experience information that has been submitted for the WCP in the letter of September 25,2009):

The staff has noted that, in regard to the operating experience (OE) examples that were provided for the WCP in the letter of September 25, 2009, the OE discussions create some uncertainties on whether the implementation of the WCP will be capable of detecting the aging effects for which it is credited prior to a loss of component intended tunction." In a conference call dated March 18, 2010, the applicant informed the staff that the WCP is a new program that, when implemented, will be consistent with the criteria in GALL AMP XI.M32, "One-Time Inspection," when performed on a one-time condition monitoring basis, and with the criteria in GALL AMP XI.M38, "Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components," with exceptions, when performed on a periodic condition monitoring basis. During the conference call, the applicant clarified that since the AMP is a new program, the OE discussions provided in the letter of September 25, 2009, were only provided as examples to indicate that the program had in the past detected relevant aging effects and that the examples were not used for the purpose of demonstrating the capability of AMP to detect aging. For new programs, Section A.1.2.3.10 in "Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants" (SRP-LR) Branch Position RLSB-1 (Appendix A.1 of NUREG-1800, Revision 1) states that:

"An applicant may have to commit to providing operating experience in the future for new programs to confirm their effectiveness."

The staff is concerned with Dominion's basis that the WCP is a new program and that OE discussions in the letter of September 25, 2009 are only to be used as examples of Refer to Attachment 1 to this RAJ letter for a summary of the staff's issues with the OE discussion that were provided in Dominion Serial Letter No.09-597, dated September 25, 2009 (ADAMS ML092710045).

Serial NO.1 0-286 Docket No. 50-305 Attachment 1/Page 4 of 13 relevant past OE. The staff generally assesses the OE examples and discussions and uses the OE discussions as a basis for assessing whether the discussed OE could create uncertainties on whether the WCP is capable of managing the aging effects for which it is credited.

Request 3:

Provide your basis why the staff should not use the OE examples provided in the Dominion Serial Letter No.09-597 to assess whether the WCP will be capable of managing the aging effects for which it is credited. In addition, since this AMP is being defined as a new AMP for the LRA, clarify whether Dominion will amend the LRA to provide the type of commitment recommended in Section A.1.2.3.1 0 in SRP-LR Branch Position RLSB-1 for future OE that is detected by the WCP, as relevant to Updated Safety Analysis Report (USAR) Supplement Section A2.1.32 for the WCP."

[From NRC Letter dated April 14, 2010] - Issues with Operating Experience Discussions that Were Provided in the Dominion Serial Letter No.09-597, Dated September 25,2009 "Operating Experience Example 1:

In regard operating experience (OE) discussion that has been cited for the occluded fire protection piping (located adjacent to the fire protection jockey pump discharge valve),

the DE discussion has created a consistency issue in the license renewal application (LRA) on whether loss of fire water flow (loss of raw water flow) induced by fouling (rust) should have been identified as an aging effect requiring management for the internal surfaces of fire protection system piping that is exposed to fire protection water (raw water), or if not, whether this event should have been cited as relevant OE for the Work Control Process (WCP). In particular, LRA Section 3.3.2.1.18, "Fire Protection System,"

and LRA Table 3.3.2-18, "Auxiliary Systems - Fire Protection - Aging Management Evaluation" does not identify loss of fire water flow as an aging effect requiring management (AERM) during the period of extended operation for fire protection system piping, piping components, or piping elements. If loss of fire water flow due to fouling is not an AERM for the fire protection system piping exposed to fire water (which is identified as raw water in the in LRA Table 3.3.2-18), this event should not have been identified as relevant OE for the WCP. In contrast, if loss of fire water flow induced by fouling is an AERM for fire protection system components that are exposed internally to fire water, the applicant should have included an applicable evaluation discussion for this aging effect in LRA Section 3.3.2.1.18 and an applicable aging management review (AMR) line item for the aging effect in LRA Table 3.3.2-18, with identification of the aging management program (AMP) that will be used to manage the aging effect during the period of extended operation. The letter of September 25, 2009 did not amend the WCP to credit the WCP for management of this aging effect in the fire protection system components. The staff also has observed that the implementation of the WCP did not

Serial No.10-286 Docket No. 50-305 Attachment 1/Page 5 of 13 detect the rust in the piping until it had occluded 90% of the cross section area available for fire water flow through the system, and that the applicant's OE discussion did not identify whether the piping would have met the system flow requirements and would have been capable of performing its intended fire protection function with only 10% of the inside pipe cross section area available for normal operating flow. Thus, if loss of fire water flow is an AERM for this piping, and if the WCP will be the AMP that is credited to manage this aging effect, the OE discussion does not provide any assurance that application of the WCP will be capable of detecting fouling-induced blockage in the fire protection piping, piping components, or piping elements before the extent of blockage would cause the system to fail to meet its system flow requirements (when required to be called upon for actuation). If (otherwise) component structural integrity is the only intended function of concern for this component, and loss of material/rusting is the only aging effect/mechanism of concern, the OE discussion fails to provide a basis on why the WCP was considered to be capable of detecting loss of material due to corrosion (rusting) in a timely fashion prior to a loss of intended function."

"Operating Experience Example 2:

In regard to the OE discussion that has been cited for the service water valve disc seat, the OE example indicates that the valve was observed to weep (leak) in 2006 and that a work order was issued in 2006 on this event calling for an inspection of the valve seating. The OE discussion also indicates that the inspections on the valve seat were performed in 2008, and that when implemented, the inspections of the valve seat had indicated the presence of erosion in the valve seat, prompting a replacement of the valve. The staff has concerns that performance of the inspection of the valve seat and correction of the weeping condition found in the component was not completed until two years after issuing the work order. This creates some uncertainty on whether appropriate monitoring and trending activities for the WCP will be initiated on a timely fashion for noted conditions, and whether prompt corrective actions would be applied under implementation of the WCP due to delays in performing appropriate monitoring and trending activities."

"Operating Experience Example 3:

In regard to the OE discussion that has been cited on the loss of material occurring in the 'B' component cooling water pump casing, the OE discussion establishes that loss of material was detected in the 'B' component cooling water pump casing in April 2008.

The OE discussion does not specify which age-related degradation mechanism induced the loss of material in the 'B' train component cooling water pump casing. The OE discussion also appears to indicate that the applicant only performed a review of past operating history as its sole basis for confirming that the OE was not applicable to the

'A' component cooling water pump casing; however, the OE discussion does not specify whether the applicant opened up the corresponding 'A' train pump casing in order to verify that this type of condition was not occurring in the 'A' train pump casing, or whether the 'B' train component cooling water pump casing was considered to be operable with noted degradation left in the uncorrected condition. Thus, the OE

Serial No.10-286 Docket No. 50-305 Attachment 1/Page 6 of 13 discussion does not currently support the conclusion that implementation of the WCP would be capable of initiating those appropriate "monitoring and trending" activities or "corrective action" activities for detected component conditions, including the need to assess whether applicable sample expansion criteria should be applied when adverse material conditions are detected in the components."

"Issue 4 (Part 4 of the RAI - In regard to the enhancement of the WCP, USAR Supplement Section A2.1.32, and Commitment No. 25. as defined in the letter of September 25. 2009):

SRP-LR Section 3.0 defines AMP enhancements as follows:

"In some cases, an applicant may choose an existing plant program that does not currently meet all the program elements defined in the GALL Report AMP. If this is the situation, the applicant may make a commitment to augment the existing program to satisfy the GALL Report AMP element prior to the period of extended operation. This commitment is an AMP enhancement.

Enhancements are revisions or additions to existing aging management programs that the applicant commits to implement prior to the period of extended operation. Enhancements include, but are not limited to, those activities needed to ensure consistency with the GALL Report recommendations. Enhancements may expand, but not reduce, the scope of an AMP."

The SRP-LR guidance does not state that enhancements are applicable to new AMPs.

In the enhancement of the WCP (as given in Dominion Serial Letter No.09-597; ADAMS ML092710045), the applicant only indicates that the program is a new program that "will be consistent with the recommendations in NUREG-1801,Section XI.M32,

'One Time Inspection,' and NUREG-1801,Section XI.M38, 'Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components,'" and that this commitment is reflected in Commitment 25, which was placed on USAR Supplement Table A6.0-1.

In contrast, the staff noted that, in LRA Commitment No. 25, the applicant only indicated that the WCP, as a new AMP, will be implemented during the period of extended operation.' Thus, it is not clear whether commitment No. 25 is being placed on the

Specifically, Commitment No. 25 reads as follows

"Commitment: The Work Control Process will be established. The program will perform one-time inspections as a verification of the effectiveness of chemistry control programs. The program will also perform visual inspections of component internal surfaces, and external surfaces of selected components, to manage the effects of aging when the surfaces are made available for examination through surveillance and maintenance activities. Source: Work Control Process. Schedule: Prior to the Period of Extended Operation."

Serial No.10-286 Docket No. 50-305 Attachment 1/Page 7 of 13 USAR supplement for the LRA to reflect a simple need for implementing the WCP during the period of extended operation without any need for enhancing the program, or whether the commitment is being placed on the USAR supplement to reflect that particular program element criteria for the WCP would need to be enhanced to make them consistent with either GALL AMP XI.M32 (when applied on a one-time condition monitoring basis) or GALL AMP XI.M38 (when applied on a periodic condition monitoring basis), or with the stated definition for AMP enhancements in Section 3.0 of the SRP-LR.

In addition, the staff has also observed that there are inconsistencies between the information provided in the letter of September 25, 2009 on AMP 82.1.32, the enhancement of the WCP, USAR Supplement Section A2.1.32, and Commitment No.

25. In particular, the updated enhancement and USAR supplement summary description for the WCP, reflect that the AMP would be implemented consistent with the recommended program element criteria in GALL AMP XI.M32 when applied on a one-time inspection basis, and with those in GALL AMP XI.M38, "Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components," when applied as a periodic condition monitoring program. However, the revised AMP 82.13.2 basis for the WCP, as proposed in the letter of September 25, 2009, indicates that the AMP would be implemented consistently with the guidance in GALL AMP XI.M38 when applied as a periodic condition monitoring program, but also when subjected to four specifically defined exceptions that the applicant has taken to the program elements in GALL AMP XI.M38.

These apparent inconsistencies need to be resolved.

Reguest4:

Review the information that has been supplied for the WCP (LRA AMP 82.1.32), the enhancement for the WCP, USAR Supplement Section A.2.1.32, and Commitment No.

25 in the September 25, 2009 letter (as supplemented by the letter of January 21, 2009), for consistency against each other. Clarify whether Commitment No. 25 on USAR Supplement Table A6.0-1 is either: (1) simply being placed on the LRA for the purpose of indicating that the WCP, as a new AMP, will be implemented during the period of extended operation, without any need for enhancing (i.e., revising or adding to) defined program elements of the AMP prior to implementation of the program, or (2) whether Commitment No. 25 is being placed on the LRA to reflect that particular program elements for the WCP will need to be enhanced to make the particular program element criteria for the WCP either (1) consistent with GALL or (2) consistent with GALL as subjected to particular exceptions, prior to implementation of the program.

If it is the former case, amend the LRA to remove the enhancement of the program leaving the current version of Commitment No. 25 in place. If it is the latter case, clarify why such enhancements of the WCP should be permitted when Section 3.0 of the SRP-LR does not apply enhancements to new programs, and provide the following additional clarifications and amendments of the LRA: (1) for implementation of the program on a

Serial No.10-286 Docket No. 50-305 Attachment 1/Page 8 of 13 one-time inspection basis, clarify which program elements in GALL AMP XI.M32, or procedures associated with these program elements, will need to be enhanced to make the program elements of the AMP consistent with GALL AMP XI.M32, (2) for implementation of the program on a periodic inspection basis, clarify which program elements in GALL AMP XI.M38, or procedures associated with these program elements, will need to be enhanced to make the program elements of the AMP consistent with GALL AMP XI.M38 (as subject to and with the exception of the four specific exceptions that had been identified and taken on GALL AMP XI.M38 in the letter of September 25, 2009), and (3) amend the existing enhancement of AMP and LRA Commitment No. 25 to reflect this information."

Serial No.10-286 Docket No. 50-305 Attachment 1/Page 9 of 13 II. DEK RESPONSE:

Request 1:

As discussed in the response to RAI 82.1.32-1 provided in DEK letter 09-777 dated January 21, 2010 [ADAMS ML100220066], a sample size will be established for each material, based on the total population which is consistent with the methodology discussed in Section 4, "Sampling Program Description" of EPRI TR-107514, Age-Related Degradation Inspection Method and Demonstration In Behalf of Calvert Cliffs Nuclear Power Plant License Renewal Application. Utilizing this sampling methodology, the sample size will be sufficient to achieve a 90 percent confidence level that 90 percent of the population is not experiencing the applicable aging effects. The use of the 90/90 confidence level is justified since one-time inspections are being performed for components that are within the scope of water quality control programs. These one-time inspections will provide additional assurance that unexpected aging degradation is not occurring.

The methodology in Section 4 of EPRI Report TR-107514 establishes that, for a population size greater than 200, the maximum required sample size is 25 samples.

The total component population and resulting inspection sample size, based on material group, is as follows:

Component Sample Material Group Population Size Copper Alloys -200 25 Stainless Steel >200 25 Steel >200 25 Aluminum 1 1 These one-time inspections will be completed prior to entering the period of extended operation consistent with License Renewal Commitment 25 for implementation of the Work Control Process program.

Request 2:

Part A Consistent with NUREG-1801, Generic Aging Lessons Learned (GALL) Report,Section XI.M38, "Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components," the Internals Surfaces Monitoring program inspections will be performed during scheduled surveillance and maintenance activities, as part of the Work Control

Serial No.10-286 Docket No. 50-305 Attachment 1/Page 10 of 13 Process program described in DEK letter 09-597 dated September 25, 2009 [ADAMS ML092710045]. Also consistent with NUREG-1801,Section XI.M38, the Internal Surfaces Monitoring program inspections are not based on a statistically-determined sample size or a specified confidence level approach. EPRI Report No. TR-107514 was not used as a basis for any aspect of the Internal Surfaces Monitoring program inspections.

Sufficient internal surfaces inspection opportunities have historically been available during surveillance and maintenance activities for the vast majority of material-environment combinations reflected in the license renewal application. A maintenance history review from 1991 to 2007 determined that scheduled surveillance and maintenance activities provided numerous opportunities to periodically inspect plant components and structural elements. The review of individual maintenance activities indicated a total of more than 7800 scheduled maintenance tasks with 907 of these activities determined to provide component inspection opportunities consistent with the internal surfaces monitoring portion of the Work Control Process program. Although these inspection opportunities are based on a historical review of plant maintenance activities, the surveillance and preventive maintenance programs continue to be performed such that it is reasonable to conclude that this level of activity is representative of plant operation during the period of extended operation. In addition, scheduled surveillance and preventive maintenance activities provide multiple opportunities for inspections due to their recurring nature.

A numerical count of the total population of components that will be managed for the effects of aging by the Internal Surfaces Monitoring activities was not determined since the methodology that was used during the Integrated Plant Assessment identified components that required further evaluation during the aging management reviews on a component type-basis (as described in LRA Section 2.1.5, Screening Methodology). As such, a percentage-based sample size cannot be provided.

As described in the response to RAI 82.1.32-2 in DEK letter 09-777 dated January 21, 2010 [ADAMS ML100220066], a review of the scheduled surveillance and maintenance activities will be performed to select activities that will provide a set of inspections that will be representative of the components in the program. This review will be conducted as part of the implementation of the Work Control Process program and will ensure that material - environment combinations that rely on the Internal Surfaces Monitoring activities to manage aging effects are adequately represented within the scope of the scheduled maintenance activities inspections. The program includes a requirement to schedule additional inspections for components within material - environment groups that are not adequately represented by scheduled surveillance and maintenance activities.

The initial review of inspection opportunities for material - environment groupings shows that numerous opportunities during scheduled surveillance or maintenance activities exist for such inspection except for a limited number of groups. In some cases, the

Serial No.10-286 Docket No. 50-305 Attachment 1/Page 11 of 13 number of components within a material - environment grouping is small, and each of the components is subject to scheduled maintenance such that 100% are inspected. In two cases, specifically elastomeric materials in raw water environments and non-metallics in raw water, no routine maintenance activities have been identified. In these cases, in accordance with program requirements, specific inspections would be required if scheduled maintenance activities are not identified for these material - environment combinations.

Implementation of the Internal Surfaces Monitoring activities within the Work Control Process program will ensure that the effects of aging associated with the in-scope components will be adequately managed so there is reasonable assurance that their intended function will be maintained consistent with the current licensing basis throughout the period of extended operation.

Part B Typically, scheduled surveillance and maintenance activities will be repeated several times during the period of extended operation. The majority of material - environment groups are subject to scheduled surveillance and maintenance activities performed on a 12 month to 36 month basis. For the copper alloy material in a moist air environment combination, maintenance activities are scheduled to occur on a frequency of once per 120 months. The longer period between inspections is justified since very limited and slowly progressing aging is expected for this material - environment combination.

Overall, the scheduled surveillance and maintenance activities will result in inspection opportunities for the various material and environment combinations at a frequency that will provide reasonable assurance that aging will be detected before there is a loss of intended function.

Request 3:

For each of the operating experience examples related to the Work Control Process -

Internal Surfaces Monitoring program, provided in Attachment 2 to DEK letter 09-597 dated September 25, 2009 [ADAMS ML092710045], aging degradation was identified and corrective actions were taken, as necessary, prior to the loss of intended functions.

DEK agrees that the OE examples submitted do not substantiate the future effectiveness of the Work Control Process - Internal Surfaces Monitoring program in managing aging effects. Therefore, since the program is considered to be a new AMP for the LRA, the following is proposed:

1. DEK supplements the letter 09-597 submittal to withdraw the Work Control Process - Internal Surfaces Monitoring program operating experience examples because they do not directly substantiate the future effectiveness of the program in managing aging effects.

Serial No.10-286 Docket No. 50-305 Attachment 1/Page 12 of 13

2. Consistent with SRP-LR Branch Position RLSB-1, DEK is providing a commitment to provide relevant Work Control Process - Internal Surfaces Monitoring program operating experience for NRC review following implementation of the program.

The following commitment will be added to LRA Appendix A, USAR Supplement, Table A6.0-1:

Item Commitment Source Schedule 47 Submit three examples of Letter 10-286; Within 2 years operating experience associated Respbnseto following with the Work Control Process - RAI 82.1.32-5. implementation Internal Surfaces Monitoring of the Work program for NRC staff review in Control determining the effectiveness of Process aging the program to detect and correct management the effects of aging prior to the loss program.

of intended function.

Request 4:

The Work Control Process program is described in LRA Appendix 8, Section 82.1.32, Work Control Process, as supplemented by DEK letter 09-597, dated September 25, 2009 [ADAMS ML092710045]. As a result of the supplemental information submitted in letter 09-597, the Work Control Process program is a new program that will be implemented prior to the period of extended operation. The commitment to implement the program is documented in LRA Table A6.0-1, Commitment 25, as supplemented by DEK letter 09-597.

There are no enhancements proposed for the Work Control Process program.

Therefore, DEK proposes a revision to the description of the Work Control Process program provided in DEK letter 09-597. Specifically, in DEK letter 09-597, Attachment 2, page 12 of 38, strike the entire second paragraph under the heading Enhancements, as shown below.

Enhancements The Work Control Process program is a new program that will be consistent with the recommendations of NUREG-1801,Section XI.M32, "One-Time Inspection,"

and NUREG-1801,Section XI.M38, "Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components. "

This oommitment is identified in Appendh< A, Tab.'-e A6.0 1 Lioense Renewa,l Commitments, Item 25.

Serial No.10-286 Docket No. 50-305 Attachment 1/Page 13 of 13 The supplemental information submitted in DEK letter 09-597 included an amended description of the Work Control Process program and a revised implementation Commitment 25 in Attachment 2 (under the heading Part A: LRA Appendix A and B).

A review of the LRA determined that LRA Section A 1.1, Aging Management Programs, requires revision to provide consistency with the letter 09-597 submittal. Accordingly, LRA Appendix A, USAR Supplement, Section A 1.1.32 will be revised as follows:

32. Work Control Process [Section A2.1.32] [Existing Requires Enhancement To Be Developed]