ML080140466

Q & a Database - Audit Team'S Evaluation

ML080140466
Person / Time
Site:	FitzPatrick
Issue date:	02/08/2008
From:	NRC/NRR/ADRO/DLR
To:
Mathew R
References
TAC MD2666
Download: ML080140466 (188)

Text

Question and Answer Database Audit and Review Related to the License Renewal Application for James A. Fitzpatrick Nuclear Power plant Applicant's No. Audit Questions Applicants Response Project Team's Evaluations Ref. No.

1 50 LRA Section B.1.1, "Program Description," This program is a new program that will be The project team finds the applicant's states that the program includes preventive consistent with GALL AMP XI.M34 including the use response acceptable because the measures to mitigate corrosion. Please discuss of preventive measures such as coatings. The applicant's preventive measures to mitigate the specific preventive measures used at preventive measures used at JAFNPP include corrosion are consistent with GALL AMP JAFNPP to mitigate corrosion of buried bituminous coatings such as coal tar epoxy or XI.M34 recommendations. This question is components, including the types of materials enamel that are applied in accordance with industry resolved.

used for any coatings, wrappings, or linings. standards and site specifications.

2 51 With regard to AMP B.1.1 described in LRA Buried components at JAFNPP are coated with The project team finds the applicant's Section B.1.1, please discuss a) the materials that were selected during original design response acceptable, because the aggressiveness of the soil at the JAFNPP site and construction to provide protection from the applicant's approach (i.e., use of as it relates to degradation of each of the potential adverse conditions of the soil (i.e., protective coating materials) is consistent material-environment combinations of the groundwater). The buried piping and tanks with GALL AMP XI.M34 buried components identified, b) how soil inspection program will perform inspections that will recommendations. Confirmation of aggressiveness is determined at JAFNPP, and confirm that the buried components and their effectiveness is the essence of this AMP.

c) the variation in soil aggressiveness at the coatings are adequate to ensure that the The applicant has committed to conduct different locations containing buried components are able to perform their intended the inspections recommended in GALL components on the JAFNPP site. functions for the period of extended operation. AMP XI.M34. This question is resolved.

For information concerning the aggressiveness of ground water, see the response to audit question 201.

3 52 LRA Section B.1.1, "Program Description," An inspection will be performed during the 10 year The project team finds the applicant's states that a focused inspection will be period immediately prior to the period of extended response acceptable because the performed within the first ten years of the operation. This point will be clarified by inserting applicant amended the LRA in a letter period of extended operation, unless an the following after the third sentence of Section dated February 01, 2007, to state that if opportunistic inspection occurs within this ten- 3.1.B.4.b of JAF-RPT-05-LRD02. an opportunistic inspection did not occur, year period. a focused inspection will be performed "If an inspection did not occur, a focused inspection prior to the period of extended operation in Please confirm that an inspection, either will be performed prior to the period of extended accordance with GALL Report focused or opportunistic, will also be performed operation." recommendations. This question is during the ten-year period immediately prior to resolved.

entering the period of extended operation, as The FSAR supplement for AMP 8.1.1 will be recommended in NUREG -1801. Also, please clarified to reflect this inspection.

revise the FSAR supplement for AMP B.1.1 to 1

Question and Answer Database Audit and Review Related to the License Renewal Application for James A. Fitzpatrick Nuclear Power plant Applicant's No. Audit Questions Applicants Response Project Team's Evaluations Ref. No.

reflect this inspection. This requires a LRA amendment.

4 54 With regard to AMP B.1.1 described in LRA As stated in section B.1.1 of the LRA this program is The project team finds the applicant's Section B.1.1, please confirm that any coating consistent with GALL. In addition, section 3.1.B.7.b response acceptable because coating and and wrapping degradations are reported and of JAF-RPT-05-LRD02 states that the site corrective wrapping degradations are reported and evaluated according to site corrective actions action program is in accordance with 10 CFR 50 evaluated in accordance with 10 CFR 50, procedures in accordance with 10 CFR 50, Appendix B such that any coating or wrapping Appendix B corrective action program .

Appendix B. degradations would be reported. This question is resolved.

5 55 LRA Section B.1.1, Exceptions to NUREG- The criteria will be that the inspection method The project team finds the applicant's 1801, states that methods that allow allows effective assessment of piping condition response acceptable, because any assessment of pipe condition without without the threat of damage to the coating that technique that is substituted for excavation may be substituted for inspections accompanies excavation. It is anticipated that such excavation/visual inspection will require requiring excavation solely for the purpose of methods will allow for assessment of more formal demonstration of the adequacy of inspection. Phased array UT technology is extensive portions of buried piping than the method the technique to detect and characterize provided as an example of such a method. If of excavating for visual inspections at a sampling degraded conditions, and must be phased array UT is used, please discuss the of locations. This exception was to allow the use of conducted by NDE inspectors qualified to following with regard to this exception: a) how more effective state-of-the-art inspection Level II in the specific technique will the method be qualified, b) what training will techniques, such as phased array UT, in lieu of employed.

inspectors be given, c) what criteria will be excavating piping which has the potential for used to determine if corrective actions are damaging the piping and its coating. Any technique The effectiveness of the method in needed, and d) what information will be used will be appropriately qualified for use and will determining the overall condition of the provided related to the condition of coatings, require the use of trained inspectors applying piping and its protective coating will be the linings, or wraps used on the buried appropriate acceptance criteria. The specific determining factor in the selection of components. acceptance criteria and the extent of information alternate methods, if any.

providing an indication of the condition of the coating will depend on the specific inspection This question is resolved.

method developed. The effectiveness of the method in determining the overall condition of the piping and its protective coating will be the determining factor in the selection of alternate methods, if any.

The following applies to the use of the phased array UT method of inspection for inspection of buried piping and tanks.

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Question and Answer Database Audit and Review Related to the License Renewal Application for James A. Fitzpatrick Nuclear Power plant Applicant's No. Audit Questions Applicants Response Project Team's Evaluations Ref. No.

A. How will the method be qualified? The method of qualification for a specific UT technique will be through demonstration. This will be completed utilizing the guide lines established in ASME Sec.

V and any additional industry guidance that has been established at the time of qualification.

B. What training will inspectors be given? The minimum training requirements for inspectors performing / interpreting examination results will be that of a Level II. This will be in accordance with Entergy Nuclear Northeasts nondestructive testing written practice.

C. What criteria will be used to determine if corrective actions are needed? The piping examined will be evaluated utilizing existing Engineering procedures and specifications.

Corrective actions will be through the normal JAFNPP correction action process.

D. What information will be provided related to the condition of coatings, linings, or wraps used on the buried components? The ability to determine the condition of an exterior coating, lining, or wrap will not be known until the technique has been demonstrated. If ascertaining the condition of this material is considered an essential variable of the examination, the use of multiple test methods may be necessary to obtain the required results.

6 57 The FSAR supplement for AMP B.1.1 In Section A.2.1 of the LRA states, All aging The project team finds the applicant's Section A.2.1 of the LRA does not include a management programs will be implemented prior to response acceptable because the discussion of the commitment to implement this entering the period of extended operation. For applicant amended Section A.2.1 of the new program prior to the period of extended additional clarification, LRA Appendix A will be LRA to include a discussion of the operation. Please revise the FSAR supplement revised as follows. commitment to implement this new to include this commitment. program prior to the period of extended 3

Question and Answer Database Audit and Review Related to the License Renewal Application for James A. Fitzpatrick Nuclear Power plant Applicant's No. Audit Questions Applicants Response Project Team's Evaluations Ref. No.

Section A.2.1.1, Buried Piping and Tanks operation. See amendment letter No. 5, Inspection Program, add This program will be dated February 01, 2007. This question is implemented prior to the period of extended resolved.

operation. This requires a LRA Amendment.

7 58 The "Program Description" for AMP B.1.9 The EDG fuel oil storage tanks are sampled every The project team finds the applicant's states that the program entails sampling to 31 days. The diesel fire pump fuel oil tanks are response acceptable because the fuel oil ensure that adequate diesel fuel quality is sampled every 92 days. sampling frequency is consistent with maintained to prevent corrosion of fuel GALL AMP XI.M30, industry standards, systems. Please provide the sampling Reference procedure SP-01.07, Diesel Fuel oil and the plant Technical Specifications.

frequency for each of the diesel fuel tanks in Sampling and Analysis, step 2.3.1: The staff confirmed that the EDG fuel oil the scope of license renewal. storage tanks are sampled every 31 days, and the diesel fire pump fuel oil tanks are sampled every 92 days, in accordance with procedure SP-01.07, Diesel Fuel Oil Sampling and Analysis, Revision 7. The staff also verified that these sampling frequencies are consistent with current industry standards, and are in accordance with the plant's Technical Specifications.

On this basis, the staff finds these sampling frequencies acceptable 8 61 With regard to AMP B.1.9, please confirm that As stated in LRA Section B.1.9 under The project team finds the applicant's accumulated water is periodically drained from Enhancements, the Diesel Fuel Monitoring response acceptable because the Diesel each of the diesel fuel tanks in the scope of Program will be enhanced to include periodic Fuel Monitoring Program will be enhanced license renewal and provide the frequency at draining. The diesel fuel oil tanks are sampled to include routine draining, cleaning, visual which this activity is performed. If it is not, monthly for water. If water is detected then it is inspections, and ultrasonic measurement please provide the technical justification for not drained. Site procedure reference is ST-9J. of the bottom surfaces of the diesel fuel draining accumulated water periodically from tanks. The frequency for draining, cleaning each tank. and inspecting the tanks will be based on past experience, which has been demonstrated to provide acceptable performance for the diesel fuel storage tanks. With this enhancement, the Diesel Fuel Monitoring Program will be consistent with GALL AMP XI.M30. This question is 4

Question and Answer Database Audit and Review Related to the License Renewal Application for James A. Fitzpatrick Nuclear Power plant Applicant's No. Audit Questions Applicants Response Project Team's Evaluations Ref. No.

resolved.

9 62 With regard to AMP B.1.9, please clarify Coatings are not used on the diesel fuel tanks in The project team finds the applicant's whether coatings are used on any of the diesel the scope of license renewal. response acceptable because the coating fuel tanks in the scope of license renewal. is not used on the diesel tanks and is not Please include the type of coating, if any, and credited for aging management. This the results of any recent inspections of the question is resolved.

coating.

10 63 With regard to AMP B.1.9, please confirm that JAFNPP performs periodic multilevel sampling to The project team finds the applicant's multi-level oil sampling and analysis are provide assurance that fuel oil contaminants are response acceptable because the performed for the diesel fuel oil storage tank in within acceptable limits. ASTM D4057, Standard applicants Diesel Fuel Monitoring accordance with ASTM Standard D 4057. If it is Practice for Manual Sampling of Petroleum and Program includes sampling and analysis not, please provide the technical justification for Petroleum Products, is used for guidance on oil activities that are in accordance with not performing multi-level sampling. sampling. The JAF procedure is SP-01.07. ASTM standard D4057 and is consistent with GALL AMP.XI.M30 recommendations. This question is resolved.

11 64 With regard to AMP B.1.9, please provide the The monitoring and trending attribute of NUREG- The project team finds the applicant's frequency at which water and biological activity 1801,Section XI.M30, Fuel Oil Chemistry Program response acceptable because the fuel oil or particulate contamination concentrations are states water and biological activity or particulate chemistry requirements are implemented monitored and trended for each of the diesel contamination concentrations are monitored and in accordance with plant Technical fuel tanks in the scope of license renewal. trended in accordance with the plants technical Requirements Manual(TRM) and technical specifications or at least quarterly. As indicated in specification (TS) 5.5.10 and because the the LRA, no exceptions are taken with respect to audit team determined that the fuel oil the monitoring and trending attribute of the program testing performed in accordance with the described in NUREG-1801,Section XI.M30. standards specified in TS 5.5.10 and the applicants TRM would be sufficient to test The EDG fuel oil storage tanks are sampled every the oil for water and sediment contents, 31 days. The diesel fire pump fuel oil tanks are particulate contents, oil flash point sampled every 92 days. These samples include a property, and oil kinematic viscosity Tech Spec required composite for particulates on property. Thus, the testing under TS the diesel fuel oil storage tanks. The samples also 5.5.10 and the TRM will accomplish the include a test for water and sediment required by type of diesel fuel oil testing the Technical Requirements Manual. recommended in GALL AMP XI.M30 for 5

Question and Answer Database Audit and Review Related to the License Renewal Application for James A. Fitzpatrick Nuclear Power plant Applicant's No. Audit Questions Applicants Response Project Team's Evaluations Ref. No.

implementation. This question is resolved.

12 65 The Operating Experience section for AMP The probable cause was listed as possible fuel oil The project team finds the applicant's B.1.9 states that in 2000, sample results for degradation. The extent affected tanks TK-6B and response acceptable because the extent EDG fuel oil storage tanks exceeded the TK-6D. Corrective actions included resampling tank and cause of the excursion and the industry acceptable limit for particulate TK-6B and draining and refilling tank TK-6D with corrective actions taken were found to be contamination. Please discuss the extent and fresh fuel oil. Resample results of TK-6B were fully documented in the applicants cause of this excursion and the corrective acceptable. Reference document, CR-JAF-2000- corrective action program. This question actions. 02022 and CR-JAF-2000-05845 is resolved.

13 66 The Operating Experience section for AMP The probable cause was listed as fuel oil The project team finds the applicant's B.1.9 states that in 2002, trending of bottom degradation. Corrective action was to drain 2000 response acceptable because the cause sample results for EDG fuel oil storage tank gallons of fuel oil from the bottom of the tank and of the excursion and the corrective actions 93TK-6C showed a particulate contamination refill the tank with fresh fuel oil Reference taken were found to be fully documented increase. Please discuss the extent and cause document, CR-JAF-2002-01207. in the applicants corrective action of this excursion. program. This question is resolved.

14 67 The Exception noted for AMP B.1.9 states that The NUREG-1801 Section XI.M30 Parameters The project team finds the applicant's the guidelines of ASTM D2276 are not used for Monitored/Inspected states, For determination of response acceptable because although determination of particulates; instead ASTM particulates, modified ASTM D 2276, Method A, is GALL AMP XI.M30 recommends use of D6217 is used. However, NUREG-1801, Rev. used.. The guidelines of ASTM D2276 are not the modified ASTM Standard D 2276 for 1, includes ASTM D6217 as an acceptable used for determination of particulates, so it was the measurement of particulates in diesel standard for the determination of particulates. necessary to identify this as an exception. fuel, Standard D6217 is more appropriate Please clarify why the use of ASTM D6217 was for middle distillate fuels used at JAFNPP.

identified as an exception. The project team verified that the use of ASTM standard D 6217 is consistent with the requirements in the plant technical specifications. This question is resolved.

15 68 The Enhancement noted for AMP B.1.9 states The emergency diesel underground fuel oil storage The project team finds the applicant's that the Diesel Fuel Monitoring Program will be tanks are cleaned and inspected on an eight year response acceptable because the enhanced to include periodic draining, cleaning, frequency. They were UT inspected in 1988. These frequency for draining, cleaning and visual inspections, and ultrasonic measurement inspections have not revealed any degradation in inspecting the tanks will be based on past of the bottom surfaces of the fire pump diesel the surface of the tank. As described in XI.M34 the experience, which has been demonstrated fuel oil tanks, EDG day tanks, and EDG fuel oil most susceptible area for corrosion is the bottom of to provide acceptable performance for the 6

Question and Answer Database Audit and Review Related to the License Renewal Application for James A. Fitzpatrick Nuclear Power plant Applicant's No. Audit Questions Applicants Response Project Team's Evaluations Ref. No.

storage tanks. Please provide a) the frequency the tanks where water and sediment can diesel fuel storage tanks. Ultrasonic for these activities for each diesel fuel tank in accumulate. JAFNPP plans to continue to inspect measurement of the tank bottoms will the scope of license renewal, b) the basis for these tanks on this eight year frequency based on provide objective evidence that each frequency, and c) how the locations for past inspection results and if any significant degradation of the tanks is not occurring.

UT measurements will be determined. corrosion is detected a UT of the corrosion site and With the enhancement, the Diesel Fuel adjacent areas of the tank bottom will be performed Monitoring Program will be consistent with using the appropriate grid size based on the size of GALL AMP XI.M30. This question is the tank. resolved.

The fire pump diesel fuel oil tanks and the EDG day tanks are not currently subjected to internal inspections. An inspection frequency cannot be firmly established until the internal condition of these tanks is baselined. JAFNPP therefore plans to inspect these tanks on an eight year frequency similar to the EDG underground storage tanks. This frequency is based on the past inspection results of the EDG underground fuel oil storage tanks which have not indicated significant degradation while exposed to the same internal fuel oil environment.

If initial inspections find unexpected conditions the frequency will be adjusted via the corrective action process.

16 69 Section B.1.9 of the LRA states two Section A.2.1 of the LRA states, All aging The project team finds the applicant's enhancements for AMP B.1.9; however, the management programs will be implemented prior to response acceptable because the FSAR supplement in Section A.2.1.9 of the entering the period of extended operation. This applicant committed to amend LRA LRA does not include a discussion of the includes enhancements to individual programs. For Section A.2.1 to clearly state that the commitment to enhance this program. Please additional clarification, LRA Appendix A will be program will be enhanced to include revise the FSAR supplement to include a revised as follows. periodic draining, cleaning, and ultrasonic discussion of the two enhancements for AMP measurement of the bottom surfaces of B.1.9 to be implemented prior to the period of Section A.2.1.9, Diesel Fuel Monitoring Program, the fire pump diesel fuel oil tanks, EDG extended operation. add day tanks, and EDG fuel oil storage tanks This program will be enhanced to include periodic and to specify acceptance criteria for UT draining, cleaning, and ultrasonic measurement of measurements of diesel fuel storage tanks the bottom surfaces of the fire pump diesel fuel oil included in this program. The project team tanks, EDG day tanks, and EDG fuel oil storage reviewed the applicants license renewal 7

Question and Answer Database Audit and Review Related to the License Renewal Application for James A. Fitzpatrick Nuclear Power plant Applicant's No. Audit Questions Applicants Response Project Team's Evaluations Ref. No.

tanks. Also, this program will be enhanced to commitment list in LRA Amendment 5, specify acceptance criteria for UT measurements Attachment 1, Revision 1, dated of diesel fuel storage tanks included in this February 1, 2007, and confirmed that program. These enhancements will be enhancements to this program are implemented prior to the period of extended identified as Commitment No. 3, to be operation. implemented before the period of extended operation. This question is This requires a LRA amendment. resolved.

17 70 With regard to AMP B.1.9, please clarify Flashpoint is not a required parameter for this The project team finds the applicant's whether flashpoint is measured as part of the AMP. NUREG-1801 Section XI.M30 does not response acceptable because although fuel oil analysis. If it is not measured, please specify flash point as a test for diesel fuel oil. NUREG-1801 Section XI.M30 does not provide the technical justification for not However, flash point is measured. Reference specify flash point as a required test measuring this parameter. procedure SP-01.07, Diesel Fuel oil Sampling and parameter for this AMP , the project team Analysis, step 3.1.2.A: confirmed that it is monitored under the Flash Point - °F 125 °F - min current fuel oil analysis program in accordance with procedure SP-01.07, Flash points are measured on both new and stored Diesel Fuel oil Sampling and Analysis.

diesel fuel oil. This question is resolved.

18 71 Clarify whether or not the inspections and/or The inspections and/or surveillance test The project team finds the applicant's surveillance tests requirements described in requirements described in this AMP are consistent response acceptable because the team this AMP are consistent with Technical with Technical Specifications (TS). confirmed that the inspection and Specifications (TS) Sections 3.0.2, 3.0.3, surveillance test requirements are 3.8.3.3 and 5.5.10. If not, provide a technical Reference procedure SP-01.07, Diesel Fuel oil consistent with the plant TS and GALL basis for its acceptability and your Sampling and Analysis, step 3.1.1. AMP XI.M30 recommendations. This commitments for revising the TS. question is resolved.

19 73 In LRA Section B.1.21, the Program JAFNPP meets the requirements of ASME Section The current NRC position in GALL for Description states that the one-time inspection XI with respect to the inspection of Class 1 small inservice inspection of small bore piping is activity for small bore piping in the reactor bore piping and socket welds through to perform volumetric examination of coolant system and associated systems that implementation of a risk-informed ISI program. welds at selected critical locations form the reactor coolant pressure boundary will During the period of extended operation, as susceptible to cracking, in addition to the also be comparable to the program described required by 10 CFR 50.55a, JAFNPP will meet the ASME Section XI requirements. For in NUREG-1801,Section XI.M35, One-Time requirements of ASME Section XI or implement an socket welds, the staff requires to meet 8

Question and Answer Database Audit and Review Related to the License Renewal Application for James A. Fitzpatrick Nuclear Power plant Applicant's No. Audit Questions Applicants Response Project Team's Evaluations Ref. No.

Inspection of ASME Code Class I Small-Bore approved alternative such as the existing risk- the ASME Section XI requirements.

Piping. Please clarify if JAFNPP meets the informed ISI Program. However, Subsection IWB Code requirements of ASME Section XI with respect requirements for both small bore welds to the inspection of Class 1 small bore piping The ISI program for small-bore piping at JAF uses and socket weld connections include and socket welds. nondestructive examination (NDE) techniques to surface examinations and VT-2 detect and characterize flaws. Three different types examinations for leakage during pressure of examinations are volumetric, surface, and visual. testing of the RCPB piping.

Examinations performed on pipe segments within the 3rd interval inspection program have included JAFNPP states in its response that during the examination of associated socket welds. The the period of extended operation, as pipe segments have been examined for FAC and required by 10 CFR 50.55a, JAFNPP will thermal fatigue by ultrasonics, radiography and meet the requirements of ASME Section surface examination (dependent upon flaw XI or implement an approved alternative mechanism) that captures the associated socket such as the existing risk-informed ISI welds verifying integrity. Program. In addition, the ISI program for Surface examinations, such as magnetic particle or small-bore piping at JAF uses dye penetrant testing, are used to locate surface nondestructive examination (NDE) flaws. techniques to detect and characterize flaws.

Three levels of visual examinations are specified.

VT-1 visual examination is conducted to assess the In LRA Section B.1.21, the Program condition of the surface of the part being examined, Description also states that the one-time looking for cracks and symptoms of wear, inspection activity for small bore piping in corrosion, erosion or physical damage. It can be the reactor coolant system and associated done with either direct visual observation or with systems that form the reactor coolant remote examination using various optical and video pressure boundary will also be devices. VT-2 visual examination is conducted comparable to the program described in specifically to locate evidence of leakage from NUREG-1801,Section XI.M35, One-Time pressure retaining components (periodic pressure Inspection of ASME Code Class I Small-tests). While the system is under pressure for a Bore Piping.

leakage test, visual examinations are conducted to detect direct or indirect indication of leakage. VT-3 The project team finds that the applicant's visual examination is conducted to determine response acceptable because the one general mechanical and structural condition of time inspection program for small bore components and supports and to detected piping will meet the current NRC positions discontinuities and therefore, adequately manage and imperfections. cracking during the period of extended operation. This question is resolved.

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Question and Answer Database Audit and Review Related to the License Renewal Application for James A. Fitzpatrick Nuclear Power plant Applicant's No. Audit Questions Applicants Response Project Team's Evaluations Ref. No.

A preliminary review of Class 1 piping was performed to derive an estimated number of Class 1 socket welds and/or piping segments in accordance with the Risk-Informed Inservice Inspection Program (RI-ISI). The estimated total of Class 1 socket welds and/or piping segments is eight piping segments that are inspected in each ISI interval out of the total segments identified in the ISI program and includes approximately 15 welds out of the total class I socket weld population.

The total number of inspections conducted during the 3rd ISI Interval estimated at approximately 5%

of the total segments and 1% of the total welds

.Examination Category B-F welds are scheduled and examined as part of the IGSCC Augmented Inspection Program. Extent and frequency of examinations are in accordance with the Risk-Informed ISI Program.

20 83 The FSAR supplement for AMP B.1.21 in Section A.2.1 of the LRA states, All aging The project team finds the applicant's Section A.2.1.23 of the LRA does not discuss management programs will be implemented prior to response acceptable because the the commitment to implement this new program entering the period of extended operation. This applicant amended LRA Section A.2.1.23 prior to the period of extended operation. includes the One-Time Inspection Program. For to include a discussion to implement this Please revise the FSAR supplement to discuss additional clarification, LRA Appendix A will be new program prior to the period of this commitment. revised as follows. extended operation. See amendment letter No. 5, dated February 01, 2007. This Section A.2.1.23, One-Time Inspection Program, question is resolved.

addThis program will be implemented within the 10 years prior to the period of extended operation.

This requires a LRA amendment.

21 86 In LRA Section B.1.22, the table in the Program Reactor building steel crane structural girders used The project team finds the applicant's Description states that this AMP will be used to in load handling are inspected under the Periodic response acceptable because the aging manage loss of material for carbon steel Surveillance and Preventive Maintenance Program management activities for crane rails and components on cranes, rails, and girders. (PSPM) identified in Section B.1.22 of the girders will involve visual examination 10

Question and Answer Database Audit and Review Related to the License Renewal Application for James A. Fitzpatrick Nuclear Power plant Applicant's No. Audit Questions Applicants Response Project Team's Evaluations Ref. No.

NUREG-1801 includes AMP XI.M23, Inspection application. Process facility crane rails and girders methods that will be consistent with the of Overhead Heavy Load and Light Load are inspected under the Structures Monitoring program elements in GALL AMP XI.M23.

Handling Systems, which covers aging Program as identified in Section B.1.27. The Specifically, reactor building steel crane management of these components. Please Structures Monitoring Program will be enhanced, structural girders used in load handling are confirm that the activities in JAFNPP AMP as identified in Section B.1.27, to address crane inspected under the Periodic Surveillance B.1.22 are consistent with the rails and girders. These programs when enhanced and Preventive Maintenance Program recommendations in NUREG-1801 AMP will include visual inspections of the crane rails and (PSPM) identified in Section B.1.22 of the XI.M23 for managing aging of these girders consistent with XI.M23 to manage loss of application. Process facility crane rails components. Please provide the technical material. Therefore the aging management and girders are inspected under the justification for those activities that are not activities for crane rails and girders under the Structures Monitoring Program as consistent. above two programs will be consistent with the identified in Section B.1.27. The attributes described for the program in NUREG- Structures Monitoring Program will be 1801 XI.M23 during the period of extended enhanced, as identified in Section B.1.27, operation. to address crane rails and girders. These programs when enhanced will include visual inspections of the crane rails and girders consistent with XI.M23 to manage loss of material. Therefore the aging management activities for crane rails and girders under the above two programs will be consistent with the attributes described for the program in NUREG-1801 XI.M23 during the period of extended operation.

This question is resolved.

22 87 In LRA Section B.1.22, the table in the Program The XI.M38 program consists of visual inspections The project team finds the applicant's Description states that this AMP will be used to of the internal surfaces of steel piping, piping response acceptable because the manage loss of material for the internal components, ducting, and other components program includes periodic visual surfaces of various piping, valve, and flow exposed to environments such as condensation inspections to detect aging degradation, elements. NUREG-1801 includes AMP XI.M38, and uncontrolled indoor air that are not covered by that are consistent with GALL Inspection of Internal Surfaces in other aging management programs. Aging AMP XI.M38 (Inspection of Internal Miscellaneous Piping and Ducting management activities for internal steel piping, Surfaces in Miscellaneous Piping and Components, which covers aging management piping components, and ducting included in the Ducting Components) . As recommended of these components. Please confirm that the Periodic Surveillance and Preventive Maintenance in the GALL Report, these inspections are activities in JAFNPP AMP B.1.22 are program as shown in Attachment 3 of JAFRPT performed as part of routine surveillance consistent with the recommendations in LRD include periodic visual inspections and are tests or maintenance. This question is NUREG-1801 AMP XI.M38 for managing aging consistent with the attributes described for the resolved.

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Question and Answer Database Audit and Review Related to the License Renewal Application for James A. Fitzpatrick Nuclear Power plant Applicant's No. Audit Questions Applicants Response Project Team's Evaluations Ref. No.

of these components. Please provide the program in NUREG-1801 XI.M38 technical justification for those activities that are not consistent.

23 88 In LRA Section B.1.22, the table in the Program The intent of these statements was to explain that The project team finds the applicant's Description states that this AMP will be used to the core spray, HPCI and RCIC piping included in response acceptable because the Periodic monitor core spray piping per the existing this program are administratively controlled in the Surveillance and Preventive Maintenance augmented flow accelerated corrosion program. Flow Accelerated Corrosion program, but are program is adequate to manage the aging Similar statements are made for the HPCI inspected using the Periodic Surveillance and effect for these components due to erosion.

system and RCIC system piping. Please clarify Preventive Maintenance program. Because the This question is resolved.

the intent of these statements. Specifically, are aging effect for these components is loss of material these components in the scope of this AMP or due to erosion and not loss of material due to flow the flow accelerated corrosion AMP? accelerated corrosion it would not be appropriate to manage using the Flow Accelerated Corrosion program.

Therefore these components are managed by the Periodic Surveillance and Preventive Maintenance program.

Section A.2.1 of the LRA states, All aging management programs will be implemented prior to entering the period of extended operation. This includes enhancements to individual programs.

24 90 The FSAR supplement for AMP B.1.22 in For additional clarification, LRA Appendix A will be The project team finds the applicant's Section A.2.1.24 of the LRA does not discuss revised as follows. response acceptable because the the commitment to implement the enhancement applicant amended LRA Section A.2.1.24 to this program prior to the period of extended Section A.2.1.24, Periodic Surveillance and to discuss the enhancement to this operation. Please revise the FSAR supplement Preventative Maintenance Program, add This program prior to the period of extended to discuss this commitment. program will be enhanced as necessary to assure operation. See amendment letter No. 5, that the effects of aging will be managed such that dated February 01, 2007. This question is applicable components will continue to perform resolved.

their intended functions consistent with the current licensing basis. These enhancements will be implemented prior to the period of extended operation. This requires a LRA amendment.

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Question and Answer Database Audit and Review Related to the License Renewal Application for James A. Fitzpatrick Nuclear Power plant Applicant's No. Audit Questions Applicants Response Project Team's Evaluations Ref. No.

JAFNPP License Renewal Commitment 13 states, "Enhance the Periodic Surveillance and Preventive Maintenance Program as necessary to assure that the effects of aging will be managed as described in LRA Section B.1.22". The referenced LRA section identifies the specific PSPM activities credited for license renewal.

This assures that all of the credited activities are identified when implementing the commitment.

JAF-RPT-05-LRD02 identifies which of these specific activities are accomplished with existing procedures. JAF-RPT-05-LRD02 will be a reference employed when implementing the commitment.

25 91 The program description of the LRA states that a) UT data for CRDRL cut and cap (1983) was This question deals with a repair whose JAFNPP has cut and capped the CRD return provided. installation was implemented in the CLB in line (CRDRL) nozzle to mitigate cracking, and accordance with an NRC-approved Code continues ISI examinations to monitor the b) The CRDRL nozzle-to-cap and cap weld was Case and 10 CFR 50.55a. No issues were effects of crack initiation and growth of the inspected after the cap was installed and has been identified for the extended period of inspected in accordance with the IGSCC Inspection nozzle and cap. Please provide the following information: operation. This question is resolved.

Program as a Category E weld. In 2000 the a) Provide details about the cracking found and inspection results revealed an unacceptable flaw in the repairs made (i.e., cut and capped) to this weld and a repair was initiated to install a weld mitigate future cracking; overlay. (

Reference:

JAF Mod JD-00-010). Upon completion of the weld overlay Mod a UT b) Provide the ASME Section XI inspection examination for the inspection of overlays was results since the corrective actions to address performed with acceptable results.

cracking were implemented; and c) Copy of assessment was provided to the NRC c) Discuss the results of your 2004 self- auditor. LO-WPOLO-2004-00056.

assessment and the corrective actions taken.

26 92 The discussion of Exceptions to NUREG-1801 Technical justification to license renewal for This question deals with a repair whose for AMP B.1.2 in the LRA states that JAFNPP Applicability to Nickel-Based Austenitic Steel: installation was implemented in the CLB in 13

Question and Answer Database Audit and Review Related to the License Renewal Application for James A. Fitzpatrick Nuclear Power plant Applicant's No. Audit Questions Applicants Response Project Team's Evaluations Ref. No.

repaired the CRDRL nozzle by weld overlay accordance with an NRC-approved Code rather than removing the crack by grinding. This repair was prepared specifically for austenitic Case and 10 CFR 50.55a. No issues were ASME Code Case N-504-1 was the technical stainless steel material. An alternate application to identified for the PEO. This question is basis for using this alternate repair. It is also nickel-base austenitic materials (i.e., Alloy 52) was resolved.

stated that the staff has approved the use of used due to the specific configuration of the nickel-this Code Case in a letter dated October 26, based austenitic weldment. A nickel-based filler 2000. was required and Alloy 52 was selected in place of low carbon austenitic stainless steel. Delta ferrite a) Please provide the following information: measurements were not performed for this overlay.

Since code cases can not be used as the basis A system hydrostatic test of completed repairs has for justification to license renewal, please been performed.

provide the technical justification for this weld repair for the period of extended operation. A system leakage test of completed repairs with a four-hour hold time was used.

27 93 The discussion of Exceptions to NUREG-1801 The CRDRL is incorporated into the JAF IGSCC The project team finds the applicants for AMP B.1.2 in the LRA states that JAFNPP Inspection Program, implemented in accordance response to be acceptable because the repaired the CRDRL nozzle by weld overlay with the requirements of BWRVIP-75A, classified applicant has indicated that it will monitor rather than removing the crack by grinding. under Category E. The extent and frequency of the for cracking of the CRDRL nozzle weld ASME Code Case N-504-1 was the technical inspection are in accordance with the parameters overlay using the inspection and flaw basis for using this alternate repair. It is also specified under Category E weldments evaluation guidelines of BWRVIP-75-A.

stated that the staff has approved the use of The guidelines in BWRVIP-75-A were this Code Case in a letter dated October 26, endorsed by the NRC for implementation 2000. Please provide the following information: in a safety evaluation dated September 14

Question and Answer Database Audit and Review Related to the License Renewal Application for James A. Fitzpatrick Nuclear Power plant Applicant's No. Audit Questions Applicants Response Project Team's Evaluations Ref. No.

15, 2000. This safety evaluation includes b). Discuss how the CRDRL will be monitored the basis of NRCs endorsement of the for cracking during the period of extended BWRVIPs revised inspection criteria for operation weld overlay repairs. The BWRVIP-75A are implemented as part of the applicants BWR Stress Corrosion Cracking Program (AMP B.1.5). This question is resolved.

28 94 The discussion of Exceptions to NUREG-1801 The CRDRL nozzle blend radius has been added The project team finds the applicants for AMP B.1.2 in the LRA states that liquid to ISI Program and is examined in accordance with response to be acceptable because the penetrant testing (PT) of CRDRL nozzle blend the ASME Section XI Code requirements of IWB- applicant: (1) has modified the CRDRL radius, adjacent wall area and bore regions is 2500-1, code Category B-D, Item No. B3.100. nozzle with an end-cap, (2) implemented a not performed. Note 3 states that JAFNPP Reference ASME Section XI, Figure IWB-2500-7(a) weld overlay repair of the end-cap to performs EVT-1 visual examinations (1/2 mil through (d), Nozzle in Head or Shell CRDRL nozzle nozzle weld to address flaws detected in resolution) of the CRDRL nozzle blend radius Relief request RR-29, Request for Relief from the the original end-cap weld material, and (3) and adjacent wall area every 10 years in lieu of ASME Boiler and Pressure Vessel Code currently is inspecting the weld overlay on PT examinations. Note 3 further states that the Requirements (TAC No. MB5037). This relief the CRDRL end-cap weld by UT weld overlay installed over a crack in the allows the use of the PDI program in lieu of ASME inspection, as performed in accordance CRDRL nozzle-to-cap weld covers the nozzle, Section XI, 1995 Edition, 1996 Addenda. with the applicants IGSCC program and the nozzle-to-cap weld, and part of the cap. the recommendations of BWRVIP-75A, Since the weld overlay is examined using UT in As discussed with the NRC auditor, this activity is which was endorsed for implementation by accordance with GL 88-01 and BWRVIP 75-A, listed as an exception to NUREG-1801 since the NRC safety evaluation dated September the LRA concludes that examination of the dissimilar weld between the CRDRL nozzle and 15, 2000.

nozzle and original nozzle-to-cap weld is not end cap is inspected as part of the JAFNPP required. In NUREG-1801, AMP XI.M6 IGSCC program and not subject to ASME Section The applicant amended the LRA in letter recommends PT inspection of CRDRL nozzle XI Subsection IWB requirements. No. 5, dated February 01, 2007, to correct blend radius and bore regions, and the reactor an error regarding the reference to the vessel wall area beneath the nozzle. Please This is discussed in LRA B.1.2 Note 1. ASME Section XI category B-D items list.

provide a discussion, including drawings, to No issues were identified for the PEO.

clarify how UT inspection of the weld overlay is The CRD return line and nozzle, while outside pipe This question is resolved.

consistent with the recommendations in size requirement (less than 4), was originally NUREG-1801. Also, please discuss how these included in the IGSCC (NUREG 0313) program as regions will be monitored for cracking during an enhancement based on susceptible materials the period of extended operation. and temperature parameters. The line was cut and capped in 1985 and the nozzle to cap weld was overlaid in 2000. Current examination of the overlay weld is currently performed by ultrasonic 15

Question and Answer Database Audit and Review Related to the License Renewal Application for James A. Fitzpatrick Nuclear Power plant Applicant's No. Audit Questions Applicants Response Project Team's Evaluations Ref. No.

examination per IGSCC program requirements.

The CRD return line nozzle blend radius receives a periodic (once per interval) EVT-1 and ASME Section XI category B-D weld and inner radius ultrasonic examination. JAF-RPT-05-LRD02 will be revised to correct section 4.1.B.4.b to read Numerous UT examinations vice current language of Numerous PT examinations. The enhancement listed for B.1.2 BWR CRD Return Line Nozzle relates to the fact that this inspection was not part of the original schedule for the current third interval, although an inspection was performed. CR-JAF-2006-00581 describes this situation.

As discussed with the NRC auditor, this enhancement to B.1.2 contains an error which will be corrected. The category B-D items should be listed as B3.90 and B3.100 since JAF uses Program B in IWB-2500-1. This requires a LRA amendment.

29 95 The discussion of Exceptions to NUREG-1801 In NYPA letter JPN-83-64 dated July 7, 1983 there This question deals with an exemption for AMP B.1.2 in the LRA states that JAFNPP is a detailed discussion of the defect and the CRD that was granted by the NRC for the was granted an exemption from the return flow capacity test. NRC Letter dated current operating period. No issues were requirement to perform a CRD return flow 8/25/1983 indicates a regulatory acceptance of the identified for the PEO. This question is capacity test per NUREG-0619 through an NYPA technical position. Documentation is resolved.

NRC letter dated August 25, 1983, which was available onsite for review issued before the CRDRL modification was made. Please discuss the technical justifications for this exemption, and provide a copy of the NRC letter accepting them.

30 96 The discussion of Exceptions to NUREG-1801 As discussed with the NRC auditor, this activity is The project team finds the applicants for AMP B.1.2 in the LRA states that the listed as an exception to NUREG-1801 since the response to be acceptable because during dissimilar weld between the CRDRL nozzle and dissimilar weld between the CRDRL nozzle and the audit, the project team determined that the end cap is not subject to ISI per ASME end cap is inspected as part of the JAFNPP the flaws in end-cap weld were repaired 16

Question and Answer Database Audit and Review Related to the License Renewal Application for James A. Fitzpatrick Nuclear Power plant Applicant's No. Audit Questions Applicants Response Project Team's Evaluations Ref. No.

Section XI, Subsection IWB. Note 1 states that IGSCC program and not subject to ASME Section using a weld overlay in accordance with this weld is inspected by UT as part of the XI Subsection IWB requirements. This is discussed Code Case N-508-2 which has been JAFNPP IGSCC program. Please discuss the in LRA B.1.2 Note 1. endorsed by the NRC for use in technical justification for this exception and Regulatory Guide 1.147, Revision 14, as provide a copy of the SER written by the staff invoked for use 10 CFR 50.55a. These accepting this use of UT to inspect this weld. type of repairs leave the flaws in the original weld material intact and the subsequent UT inspections of the weld overlay materials are done in accordance with the approved Code Case and the applicants IGSCC program. No technical justification is necessary as the Code Case has been endorsed in Regulatory Guide 1.1.47, as invoked for use in 10 CFR 50.55a. This question is resolved.

31 97 The Program Description for AMP B.1.3 in the No indications were noted during the performance The project team finds the applicants LRA states that, under this program, JAFNPP of the FW Nozzle Mod for the removal of Cladding. response to be acceptable because the has removed all identified feedwater blend radii Change of the FW thermal sleeve was performed in applicant has clarified that it did not detect flaws. Please provide the following information: accordance with NUREG-0619. any flaw indications in the inner blend radius as a result of the post modification a) Discuss the nature of the flaws identified in The phrase "removed all identified feedwater blend repair inspections of the modified FW the feedwater blend radii. radii flaws" is standard terminology for the nozzle geometry. The applicant amended description of a repair of this nature. However, it the LRA in letter No. 5, dated February 01, will be removed to increase clarity of the LRA. This 2007, to reflect this information. This requires an amendment to the LRA. question is resolved.

32 98 The Program Description for AMP B.1.3 in the No flaws were identified during the implementation The project team finds the applicants LRA states that, under this program, JAFNPP of this modification. response to be acceptable because the has removed all identified feedwater blend radii applicant has clarified that it did not detect flaws. Please provide the following information: The phrase "removed all identified feedwater blend any flaws indications in the inner blend radii flaws" is standard terminology for the radius as a result of the post modification b) Provide details on the size and location of description of a repair of this nature. However, it repair inspections of the modified FW any cracks found in the feedwater nozzles, will be removed to increase clarity of the LRA. This nozzle geometry. The applicant amended along with their repairs. Include a discussion of requires an amendment to the LRA. the LRA in letter # 5, dated February 01, any cracking found after the removal of 2007, to reflect this information. This cladding. question is resolved.

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Question and Answer Database Audit and Review Related to the License Renewal Application for James A. Fitzpatrick Nuclear Power plant Applicant's No. Audit Questions Applicants Response Project Team's Evaluations Ref. No.

33 99 The Program Description for AMP B.1.3 in the The third interval feedwater nozzle inner radius The project team finds the applicants LRA states that this program implements examinations were completed with phased array response to be acceptable because the enhanced inservice inspection (ISI) of the automated techniques (Wesdyne) based on EPRI applicant has clarified that it is using feedwater nozzles in accordance with the modeling meeting ASME Section XI, NUREG-0619 phased-array UT techniques to inspect the requirements of ASME Section XI, Subsection and NE-523-A71-0594 Rev.1 requirements. No feedwater nozzles, and that these IWB and the recommendations of General recordable indications were identified in the area of inspections are included as part of the Electric (GE) NE-523-A71-0594 to monitor the interest. Subsequent examinations will be applicants inspections for conforming with effects of cracking on the intended function of performed per ASME Section XI as modified by the the NRCs recommendations in NUREG-the feedwater nozzles. Please provide the fourth interval ISI program. 0619. The results of these inspections following information: revealed no relevant and/or reportable In 1983 the FW nozzle modification (removing indications. This question is resolved.

a) Discuss the methodology used in performing stainless steel cladding from the FW nozzle; the enhanced ASME Inservice Inspections (ISI) installing the triple thermal sleeve, double piston-of the feedwater nozzles, and the results of the ring seal spargers; and cutting & capping the CRD most recently completed ISI inspections. return line) was implemented. Inspections of the FW nozzle blend radius area have been performed every inspection interval in accordance with NUREG 0619 and/or the alternative requirements of GE document NE-523-A71-0594 Rev 0 and Rev

1. The results of these inspections revealed no relevant and/or reportable indications.

The most recently completed ISI inspections performed on the FW nozzle blend radius were conducted in 2002 using GE document NE-523-A71-0594 Rev 1, meeting Table 6-1, Method 4, Note 2 and 3, Triple sleeve, double piston ring, unclad. In accordance with this criterion JAF meets the requirement to extend the inspection interval to 10 years.

34 100 The Program Description for AMP B.1.3 in the The enhanced ASME Inservice Inspections (ISI) of The project team finds the applicants LRA states that this program implements the feedwater nozzles per NUREG-0619 and NE- response to be acceptable because the enhanced inservice inspection (ISI) of the 523-A71-0594 expand the inner radius examination applicant has: (1) clarified how the FW feedwater nozzles in accordance with the volume identified by ASME Section XI to the nozzle nozzle welds are inspected, (2) specified requirements of ASME Section XI, Subsection OD taper. which version of GE-NE-523-A71-0594 is IWB and the recommendations of General currently being used for these 18

Question and Answer Database Audit and Review Related to the License Renewal Application for James A. Fitzpatrick Nuclear Power plant Applicant's No. Audit Questions Applicants Response Project Team's Evaluations Ref. No.

Electric (GE) NE-523-A71-0594 to monitor the Feedwater nozzle inner radius examinations were examinations, (3) performs UT effects of cracking on the intended function of completed in 2002 using phased array automated examinations of the FW nozzle in the feedwater nozzles. Please provide the techniques (Wesdyne) based on procedure GFITI- accordance with the NRCs following information: ISI-210AD that references NE-523-A71-0594 recommendations in NUREG-0619, and revision 1. (4) since the results of these inspections b) Provide additional details on the revealed no relevant and/or reportable recommendations in GE report NE-523-A71- indications. This question is resolved.

0594 that JAFNPP has implemented in this AMP. Please specify the revision of the GE report that was used.

35 101 The discussion of the Exception for AMP B.1.3 In 1983 the FW nozzle modification (removing The project teams basis for Item 34 in the LRA states that NRC noted that the stainless steel cladding from the FW nozzle; above applies. This question is resolved intent of the requirements of NUREG-0619 and installing the triple thermal sleeve, double piston- since the results of the applicant's NEDO-21821-A had been satisfied with the ring seal spargers; and cutting & capping the CRD inspections revealed no relevant and/or JAFNPP modifications. Please clarify how the return line) was implemented. Repairs meet the reportable indications.

intent of the requirements of NUREG-0619 and requirements and guidelines of NUREG NEDO-21821-A were satisfied with the steps 0619/NEDO-21821-01. Inspections of the FW taken to address feedwater cracking. Also, nozzle blend radius area have been performed please provide a copy of NEDO-21821-A. every inspection interval in accordance with and/or the alternative requirements of GE document NE-523-A71-0594 Rev 0 and Rev 1. The results of these inspections revealed no relevant and/or reportable indications.

36 102 With regard to AMP B.1.3, please discuss how JAFNPP submitted letter JPN-99-003, dated The implementation of the applicants JAFNPP will monitor the bypass flow (if any) February 18, 1999, Commitment Change Feedwater NUREG-0619 inspections are performed as around the feedwater nozzle thermal sleeve to Nozzle Leakage Monitoring System, detailing JAFs a basis for eliminating the need for bypass detect leakage due to degraded thermal sleeve basis and position for discontinuing the use of the flow examinations.

seals and welds during the period of extended FW Leakage Monitoring System (LMS) to detect operation. Feedwater bypass flow at JAF. JAF has adopted the The UT examinations performed under the recommendations of NUREG-0619 by implementing applicants NUREG-0619 program and the following: BWR Stress Corrosion Cracking Program are sufficient to manage aging-related

• Removing stainless steel cladding from the cracking and fatigue-induced aging in the Feedwater nozzles FW nozzles.

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Question and Answer Database Audit and Review Related to the License Renewal Application for James A. Fitzpatrick Nuclear Power plant Applicant's No. Audit Questions Applicants Response Project Team's Evaluations Ref. No.

• Installing triple thermal sleeve, double pistion-ring This question is resolved.

seal spargers

• Cutting and capping the Control Rod Drive (CRD) return line

• Changing the internal valve trim in the low flow Feedwater control valve, and

• Implementing an augmented inspection program This commitment change was evaluated using the Nuclear Energy Institutes (NEI) guidelines on commitment management (NEI Guideline for managing NRC Commitments, Nuclear Energy Institute, Rev. 2, December 19, 1995.

37 104 In NUREG-1801, the discussion in the Scope of The BWR Penetrations Program scope of program The project team finds the applicants Program element for AMP XI.M8 notes that is consistent with NUREG-1801 XI.M8, BWR Penetrations.response to be acceptable because the guidelines for repair design criteria are provided The BWR Penetrations Program follows the applicant has clarified that it: (1) uses the in BWRVIP-57 for instrumentation penetrations, guidelines of BWRVIP 53-A and 57-A for repairs NRC-endorsed guidelines in BWRIVP-49 and BWRVIP-53 for the SLC line. Please and BWRVIP-49-A and 27-A for inspection and and BWRVIP-27A for inspections of the confirm that JAFNPP AMP B.1.4 follows the evaluation of applicable penetrations. All BWRVIP reactor vessel penetrations at JAFNPP, guidelines provided in BWRVIP 53 and 57 for guidelines are followed by JAFNPP as described in (2) uses BWRVIP-53A and BWRVIP-57A repairs, along with the inspection and EN-DC-135, JAF-RPT-NBS-01848, JAF-RPT-NBS- for the repairs of the of reactor vessel evaluation guidelines of BWRVIP-49 and 27. 04394, and ER-JAF-06-25191. JAF is committed to penetrations at JAFNPP, and (3) clarified apply BWRVIP documents per BWRVIP letter to that the these reports are within the scope NRC BWR Utility Commitments to the BWRVIP of the BWR Penetrations Program. The dated May 30, 1997, and BWRVIP letter to NRC NRC endorsed these BWRVIP reports for BWR Utility Commitments to the BWRVIP dated use in the following safety evaluations October 30, 1997. (SEs):

BWRVIP-27A: SE dated 12/20/99 BWRVIP-49A: SE dated 03/13/02 BWRVIP-53A: SE dated 05/07/02 BWRVIP-57A: SE dated 10/26/00.

This question is resolved.

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Question and Answer Database Audit and Review Related to the License Renewal Application for James A. Fitzpatrick Nuclear Power plant Applicant's No. Audit Questions Applicants Response Project Team's Evaluations Ref. No.

38 106 In NUREG-1801, the discussion in the A discussion of NDE techniques used for The project team finds the applicants Detection of Aging Effects element for AMP inspection of BWR penetrations is provided in response to be acceptable because the XI.M8 notes that the NDE techniques section 4.3 of JAF-RPT-05-LRD02, which was applicant has clarified that: (1) it uses the appropriate for inspection of BWR vessel available for review on site. NRC-endorsed guidelines in BWRIVP-49 internals, including the uncertainties, are and BWRVIP-27A for inspections of the included in BWRVIP-03. Please discuss the Section 11 of BWRVIP-03 describes NDE reactor vessel penetrations at JAFNPP, NDE techniques in BWRVIP-03 that are used in techniques outlined in BWRVIP-27-A for inspection and (2) the these reports are within the the JAFNPP inservice inspection program as of SLC/P nozzles. As described in section 4.3 of scope of the BWR Penetrations Program.

part of AMP B.1.4. JAF-RPT-05-LRD02, JAFNPP performs an The NRC endorsed these BWRVIP enhanced visual leakage inspection (with direct reports for use in the following safety view of component during pressure test) every evaluations (SEs):

outage and a surface examination every 10 years until such time as a volumetric inspection BWRVIP-27A: SE dated 12/20/99 technique is developed. Once an acceptable BWRVIP-49A: SE dated 03/13/02 volumetric examination is developed, it will be BWRVIP-53A: SE dated 05/07/02 performed each 10 year ISI interval in conjunction BWRVIP-57A: SE dated 10/26/00 with continued visual inspections each outage.

The inspections of the BWR internals at Section 14 of BWRVIP-03 endorses the inspection JAFNPP are within the scope to the guidelines of BWRVIP-49-A for inspection of applicants BWR Vessel Internals instrumentation penetrations. As described in Program, which is discussed in AMP B.1.7 section 4.3 of JAF-RPT-05-LRD02, JAFNPP in the LRA.

performs visual inspections of penetrations and nozzle-to-extension welds during pressure testing This question is resolved.

(VT-2).

Both the SLC/P nozzles and instrumentation penetrations are inspected by the ISI program which is consistent with the guidance of BWRVIP-03.

All BWRVIP guidelines are followed by JAFNPP as described in EN-DC-135, JAF-RPT-NBS-01848, JAF-RPT-NBS-04394, and ER-JAF-06-25191.

JAF is committed to apply BWRVIP documents per BWRVIP letter to NRC BWR Utility Commitments to the BWRVIP dated May 30, 1997, and BWRVIP letter to NRC BWR Utility Commitments to the BWRVIP dated October 30, 1997.

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Question and Answer Database Audit and Review Related to the License Renewal Application for James A. Fitzpatrick Nuclear Power plant Applicant's No. Audit Questions Applicants Response Project Team's Evaluations Ref. No.

39 107 In NUREG-1801, the discussion in the The BWR Penetrations Program does not The project team finds the applicants Acceptance Criteria element for AMP XI.M8 specifically use the guidelines for flaw growth response to be acceptable because: (1) notes that BWRVIP-14, 59, and 60 provide evaluation as specified in BWRVIP-14, 59, 60. the applicant has clarified that it is guidelines for the evaluation of crack growth for Flaws found during inspections are evaluated per applying the applicable flaw evaluation stainless steel, nickel alloys and low alloy applicable section of ASME Section XI. The ISI criteria of ASME Section XI for evaluating steels, respectively. program procedures, [[::JAF-ISI-0002|JAF-ISI-0002]] and JAF-ISI- any flaws that are detected in the SLC/

0003, were available for review on site. Core P nozzles and reactor vessel Please confirm that these recommended instrumentation nozzles at JAFNPP, as guidelines are included in AMP B.1.4, and NUREG-1801 Section XI.M8 states: invoked by 10 CFR 50.55a, and (2) any make the JAFNPP procedures that implement repair methods discussed in BWRVIP-14, these recommended guidelines available for Any indication detected is evaluated in accordance BWRVIP-59, and BWRVIP-60 that go staff review. with ASME Section XI or other acceptable flaw beyond or differ from ASME Section XI evaluation criteria, such as the staff-approved repair requirements do not constitute BWRVIP-49 or BWRVIP-27 guidelines. Applicable mandatory repair methods for JAFNPP.

and approved BWRVIP 14, BWRVIP-59, and This question is resolved.

BWRVIP-60 documents provide guidelines for evaluation of crack growth in stainless steels (SSs), nickel alloys, and low-alloy steels, respectively.

For this attribute of this AMP at JAF, flaw growth evaluation is performed using ASME Section XI criteria as allowed by GALL. In this case, the BWRVIP-14, 59, 60 guidance is not needed All BWRVIP guidelines are followed by JAFNPP as described in EN-DC-135, JAF-RPT-NBS-01848, JAF-RPT-NBS-04394, and ER-JAF-06-25191. JAF is committed to apply BWRVIP documents per BWRVIP letter to NRC BWR Utility Commitments to the BWRVIP dated May 30, 1997, and BWRVIP letter to NRC BWR Utility Commitments to the BWRVIP dated October 30, 1997.

40 108 In NUREG-1801, AMP XI.M8, eleven BWRVIP Responses to BWRVIP action items are provided The project team finds the applicants reports are referenced as guidance documents in LRA Appendix C. response to be acceptable, as the to manage aging effects of BWR penetrations. response clarifies that the Appendix C 22

Question and Answer Database Audit and Review Related to the License Renewal Application for James A. Fitzpatrick Nuclear Power plant Applicant's No. Audit Questions Applicants Response Project Team's Evaluations Ref. No.

Appendix C of this LRA addresses the A copy of all SE reports for all BWRVIP documents provides the responses to the applicant applicant action items associated with only of was provided to the staff at JAFNPP. The complete action items on BWRVIP-18-A, 25, 26-A, these reports - BWRVIP-27. Please provide the list of BWRVIP documents with license renewal 27-A, 38, 41, 47-A, 48-A, 49-A, and 74-A; responses to the applicant action items applicant action items is: 18-A, 25, 26-A, 27-A, 38, not just on BWRVIP-27. This question is applicable to JAFNPP for each of the remaining 41, 47-A, 48-A, 49-A, 74-A. None of the SE reports resolved.

10 BWRVIP reports cited in NUREG-1801. for other BWRVIP documents contain such action items.

41 109 The discussion of Operating Experience for Section 4.6 and 4.10.7 of assessment report JAF- The project team finds the applicants AMP B.1.4 in the LRA states that self- RPT-NBS-04394, Assessment of Vessel Internals response to be acceptable because the assessments in 2004 and 2005 revealed no Health, evaluates the effectiveness of inspections applicant has clarified: (1) which document issues or findings that could impact of BWR vessel penetrations and documents provides the self assessment of the effectiveness of the program. Please provide acceptable tests. Copies of these reports were inspections performed in the reactor the details of the findings resulted from these provided to the NRC auditor. Details of a 2004 ISI vessel instrument nozzles, (2) and self-assessments applicable to this AMP. self assessment and 2005 BWRVIP self provided this report to the audit team Address any issues related to penetrations that assessment identified no relevant findings related during the AMP audit of the JAFNPP LRA.

have been determined to be sensitized. to penetration inspections. The project team's review confirmed that no issues exist with the program. This question is resolved.

42 110 The Program Description for AMP B.1.5 in the Core Spray from RPV Nozzle on B loop to first This question deals with repairs on the LRA states that JAFNPP has taken actions to isolation valve was replaced with 347NG in 1992 core spray nozzle that were implemented prevent IGSCC and will continue to use and Core Spray A loop was replaced from the Safe for the current operating period in materials resistant to IGSCC for component End to the Isolation Valve with 316L. accordance with the recommendations in replacements and repairs following the NRC-approved documents, including recommendations delineated in NUREG-0313, All other IGSCC repairs have been by Weld NUREG-0313. The project team finds the Generic Letter 88-01, and the staff-approved Overlay. applicant response to be acceptable BWRVIP-75-A report. Please provide the JAF Pipe Specification Class 1504 restricts Carbon because the applicant has clarified how following information: Content to .035% max and requires solution the different weld repairs or components annealing. were implemented in accordance with the a) Discuss the details of any weld repairs and NRCs NUREG-0313 recommendations.

material replacement of components at A) The following is the IGSCC Program and welds JAFNPP to implement the NUREG-0313, GL by Category: The recommendations in NUREG-0313 for 88-01 and BWRVIP-75A recommendations. Class 1 nozzle safe ends have currently IGSCC Examination Category A been updated in topical report BWRVIP-75, which the NRC approved for Category A - Identifies welds, which are fabricated implementation in an safety evaluation 23

Question and Answer Database Audit and Review Related to the License Renewal Application for James A. Fitzpatrick Nuclear Power plant Applicant's No. Audit Questions Applicants Response Project Team's Evaluations Ref. No.

from resistant materials. dated September 15, 2000 (ADAMS (Total Population = 24) the increase in population is Accession number ML003751105). The due to the installation of RWCU MOD No. JD project team also verified that the 134 applicants program also incorporates the Category A Identifies longitudinal seam welds. updated augmented recommendations in (Total Population = 163) BWRVIP-75.

Category A* - Identifies sweep-o-let welds that have been solution annealed. This question is resolved.

IGSCC Examination Category D Category D - NWC=100% every 6 years; HWC/NMCA =100% every 10 years (at least 50%

in 1st 6 years)

• as supplemented by Notes: 1, 2,and 3(b)

Included in this category are all bimetallic nozzle weldments made with non-resistant material and 182 inconel weld butter.

(Total Population = 27)

The decrease in population is due to an overlay being applied to N-9-C1 IGSCC Examination Category E Category E - All welds included in this category are weld overlays.

(Total Population = 24)

The increase in population is due to an overlay being applied to N-9-C1 IGSCC Examination Category F There are no welds in this category.

IGSCC Examination Category G There are no welds in this category b) Induction Heat Stress Improvement and/or 24

Question and Answer Database Audit and Review Related to the License Renewal Application for James A. Fitzpatrick Nuclear Power plant Applicant's No. Audit Questions Applicants Response Project Team's Evaluations Ref. No.

Resistance Heat Stress Improvement has been employed on all recirculation system piping welds with the exception of safe-ends to nozzle welds and the Tee to RHR SDC weld.

(Total Population = 8)

NOTE: Long seam welds within the IGSCC Inspection Program are housed solely in the longitudinal seam weld spreadsheet database and were previously categorized as Category A-1. The ISI Program at James A. FitzPatrick has been updated to reflect the requirements of 10CFR50.55a. The longitudinal seam weld spreadsheet shall be maintained for the purposes of location and identification only, and will no longer be updated except when these two parameters are affected.

IGSCC Examination Category B Category B are those welds not made of resistant materials that have had a Stress Improvement (SI) process performed either before service or within two years of operation.

Category B - There are no welds in this category.

IGSCC EXAMINATION CATEGORY C Category C are those welds not made of resistant materials that have been given an SI process after more than two years of operation. NUREG 0313 Frequency and Extent Inspection requirements = All Every 10 Years.

ENN has further defined those welds in Category C by using the following suffixes:

Category C Identifies welds given a SI process 25

Question and Answer Database Audit and Review Related to the License Renewal Application for James A. Fitzpatrick Nuclear Power plant Applicant's No. Audit Questions Applicants Response Project Team's Evaluations Ref. No.

after more than two years of operation.

(Total Population = 59)

Category C* - Identifies welds treated with a Resistance Heating Stress Improvement (RHSI) process after more than two years of operation.

(Total Population = 2)

Category C Identifies welds given an SI process after more than two years of operation and have a service stress over 1.0 SM. Reference NuReg 0313, Rev. 2, Section 4.5.

(Total Population = 3) 43 111 The Program Description for AMP B.1.5 in the JAF action items for BWRVIP reports are listed in The project team finds the applicants LRA sates that JAFNPP has taken actions to Appendix C of the LRA. response to be acceptable since the prevent IGSCC and will continue to use staffs safety evaluation on BWRVIP-75 materials resistant to IGSCC for component A copy of all SE reports for all BWRVIP documents (dated May 14, 2002) did not include the replacements and repairs following the was provided to the staff upon arrival at JAFNPP. issuance of any license renewal applicant recommendations delineated in NUREG-0313, The complete list of BWRVIP documents with action items on the BWRVIP report. This Generic Letter 88-01, and the staff-approved license renewal applicant action items is: 18-A, 25, question is resolved.

BWRVIP-75-A report. Please provide the 26-A, 27-A, 38, 41, 47-A, 48-A, 49-A, 74-A. None following information: of the SE reports for other BWRVIP documents, including BWRVIP-75-A, contain such action items.

b) Provide the response to applicant action items (if any) associated with BWRVIP-75-A.

44 112 The Program Description for AMP B.1.5 in the To date JAF has detected indications via UT The project team finds the applicants LRA sates that JAFNPP has taken actions to examination and repaired the following with Weld response to be acceptable because the prevent IGSCC and will continue to use Overlays applicant: (1) clarified which Class 1 materials resistant to IGSCC for component Recirculation System component weld locations were replacements and repairs following the 12-02-2-1 28-02-2-53 determined to contain relevant flaw recommendations delineated in NUREG-0313, 12-02-2-8 22-02-2-63 indications as a result of implementing the Generic Letter 88-01, and the staff-approved 12-02-2-12 12-02-2-64 applicants IGSCC/ NUREG-0313 BWRVIP-75-A report. Please provide the 12-02-2-15 12-02-2-65 inspection program, (2) clarified how the following information: 12-02-2-18 12-02-2-69 applicant repaired the effected welds, and 12-02-2-19 12-02-2-70 (3) clarified that the inspections of the c) Discuss any detected flaw indications or 22-02-2-22 12-02-2-76 weld overlay repair did not indicate the cracks, along with their evaluations/repairs, 12-02-2-23 28-02-2-92 presence of any reportable indication in 26

Question and Answer Database Audit and Review Related to the License Renewal Application for James A. Fitzpatrick Nuclear Power plant Applicant's No. Audit Questions Applicants Response Project Team's Evaluations Ref. No.

subsequent to implementing the NUREG-0313 28-02-2-33 28-02-2-113 the weld overlay materials. The recommendations. 28-02-2-48 28-02-2-116 inspections of the weld overlays are 28-02-2-52 currently inspected in accordance with Jet Pump Instrumentation inspection criteria specified in BWRVIP-N8A-SE-2 4-02-2-118 75A, which was endorsed for Control Rod Drive implementation by safety evaluation dated N-9-C1 March 14, 2002. No issues were identified.

c) The post weld overlay exams performed on This question is resolved.

these welds reveal no reportable and/or unacceptable conditions.

45 113 AMP B.1.5-2 BWR Stress Corrosion Cracking The BWR Stress Corrosion Cracking Program The project team finds the applicants In NUREG-1801, the discussion of Acceptance acceptance criteria are consistent with NUREG- response acceptable because the Criteria for AMP XI.M7 notes that applicable 1801 XI.M7, BWR Stress Corrosion Cracking with applicant confirmed that the applicable and approved BWRVIP-14, 59, 60, 61 and 62 the exception of a different ASME Section XI code responses to the staffs applicant action documents provide guidelines for evaluation of edition. items are provided in Appendix C of the crack growth. Please clarify whether any of LRA. These responses to the applicant these BWRVIP reports are used in JAFNPP Responses to BWRVIP action items are listed in action items are on BWRVIP Report AMP B.1.5, and discuss the scope of their use. LRA Appendix C. BWRVIP-18-A, 25, 26-A, 27-A, 38, 41, 47-For each BWRVIP report used, provide the A, 48-A, 49-A, and 74-A. This question is response to applicant action items (if any) A copy of all SE reports for all BWRVIP documents resolved.

associated with the BWRVIP report. was provided to the staff upon arrival at JAFNPP.

The complete list of BWRVIP documents with license renewal applicant action items is: 18-A, 25, 26-A, 27-A, 38, 41, 47-A, 48-A, 49-A, 74-A. None of the SE reports for other BWRVIP documents contain such action items.

46 114 The discussion of Exceptions to NUREG-1801 a) JAF current interval 3rd uses IWA-4000. In the JAFNPP entered its Fourth 10-Year for AMP B.1.5 in the LRA states that the 1989 future, JAF is committed to the ASME 2001/2003 Inservice Inspection (ISI) Interval in edition of ASME Section XI is used for flaw Addenda, which requires the use of IWA-4000. January of 2007, and was required by 10 evaluation, while NUERG-1801 specifies the CFR 50.55a to update its ASME Section 1986 edition. Since the 1986 Subsections XI code of record to the 2001 Edition of IWB/C/D-4000 and -7000 are replaced by ASME Section XI, inclusive of the 2003 Subsection IWA-4000 in the later editions of the Addenda. Hence the project team finds Code, please clarify whether JAFNPP will use the applicants response to be acceptable 27

Question and Answer Database Audit and Review Related to the License Renewal Application for James A. Fitzpatrick Nuclear Power plant Applicant's No. Audit Questions Applicants Response Project Team's Evaluations Ref. No.

the guidelines in Subsection IWA-4000 for as the commitment to use the 2001 repairs and replacements. Edition of ASME Section XI, inclusive of the 2003 Addenda, complies with the ASME Section XI updating requirement in 10 CFR 50.55a. This question is resolved.

47 115 The discussion of Operating Experience for RO15 (2002) examinations included UT The performance demonstration initiative AMP B.1.5 in the LRA states that UT examinations of four recirculation nozzle safe-end (PDI) requirements for volumetric UT examinations of four recirculation nozzle safe- welds, one jet pump instrumentation nozzle safe- examinations are specified in 10 CFR end welds, three jet pump instrumentation end weld and two piping welds (Note N8-SE-1 and 50.55a and it discusses the use of weld nozzle safe-end welds, seven recirculation N8-SE-3 are piping welds despite the mockups to qualify inspectors and system piping welds, and three RHR system nomenclature), seven recirculation system piping procedures for UT inspection techniques.

piping welds during RO15 (2002) resulted in six welds, and five RHR system piping welds. The project team finds the applicants recordable indications, attributed to geometric response to be acceptable because the conditions and not cracks. Please provide Performance demonstration Initiative (PDI) applicant has: (1) identified that it adopted additional details to explain the geometric personnel performed the examinations per the NRCs PDI requirements in 10 CFR conditions observed and how they resulted in Washington group procedure JAF-UT-89-1 which 50.55a, (2) identified which weld recordable indications. Please include a adopted the Performance demonstration initiative geometries in the welds could result in UT discussion, including test data, to demonstrate requirements of PDI-UT-2 as required per 10CFR- indications during the implementation of how these geometric conditions are 50.55a for piping welds at the time. The examination, and (3) clarified how the distinguished from cracks when performing UT examinations performed identified geometry applicants implementation of the PDI examinations. requiring recording per JAF-UT-89-1 requirements. project was capable of qualifying UT The root and counterbore geometry identified was examiners to evaluate indications resulting recorded and evaluated by the examiner per from UT examinations of Class 1 procedure requirements and techniques developed components.

during the performance demonstration Initiative.

The applicant also amended the LRA in Performance demonstration Initiative (PDI) amendment letter No. 5, dated February procedures provide guidance for the evaluation of 01, 2007, and incorporated the indications observed during examinations. The amendment of the LRA as stated in the evaluation criterion is applied by PDI qualified response to the project team's question.

examiners as necessary for indication evaluation This question is resolved.

and varies dependent on the examination and circumstances encountered. Reference current PDI procedures for additional information. This clarification of the operating experience with N8-SE-1 and N8-SE-3 welds, and five RHR system 28

Question and Answer Database Audit and Review Related to the License Renewal Application for James A. Fitzpatrick Nuclear Power plant Applicant's No. Audit Questions Applicants Response Project Team's Evaluations Ref. No.

piping welds versus three RHR system piping welds as originally described, requires an LRA amendment.

48 116 Since NUREG-0313 was implemented at A discussion of repair and replacement corrective The project team finds the applicants JAFNPP, all replacement components for actions under the BWR Stress Corrosion Cracking response to be acceptable because the degraded items must be procured with IGSCC- Program is provided in section 4.4 of JAF-RPT applicant has: (1) clarified which resistant materials. Please discuss, and LRD02. Applicable procedures supporting specification provides the applicants provide copies for review of the plant procurement of IGSCC-resistant material were criteria for selecting IGSCC-resistant weld procedures and/or plans that are used to available for review on site. JAF Piping materials, ensure that replacement components at Specification Class 1504 restricts carbon content of JAFNPP are being procured with IGSCC- stainless steel to .035% max and requires solution (2) clarified which material properties or resistant components. annealing. Both these requirements provide IGSCC processes are used to ensure use of resistance. IGSCC-resistant weld filler materials, and Copies of procurement information for stock codes (3) clarified that it provided the J0700166, J0700167, J0700183, J0700184 procurement documents for stainless steel (ER308L/E308L) containing technical requirements (ER308L/E308L) weld filler metals to the indicating delta ferrite exceeded NUREG NRC auditors during the AMP audit for requirements of 8% Fe (Iron) were provided to the JAFNPP. This question is resolved.

NRC auditor.

49 117 The Program Description for AMP B.1.29.2 in BWRVIP-29 was implemented into JAF chemistry The project team finds the applicant's the LRA states that the program relies on procedures in approximately 1999. response acceptable because the monitoring and control of water chemistry BWRVIP-79 was implemented into JAF chemistry applicant provided a discussion on based on EPRI Report 1008192 (BWRVIP- procedures in February 2003. differences between the 1996 and 2000 130). NUREG-1801 recommends BWRVIP-29 BWRVIP-130 was implemented into JAF chemistry versions of the EPRI guidelines. Based (1996) or later revisions, which includes procedures in June 2005. on this, the project team determined that BWRVIP-79 and BWRVIP-130. Please provide the use of the 2000 revision of the EPRI the following information related to this AMP. BWR water chemistry guidelines provided at the time an acceptable method of

a. Discuss the history of the water chemistry controlling water chemistry that is program at JAFNPP including the periods when consistent with the GALL BWRVIP-29 and BWRVIP-79 were used, and recommendations. Therefore, the project when use of BWRVIP-130 was initiated. team finds this acceptable. This question is resolved.

29

Question and Answer Database Audit and Review Related to the License Renewal Application for James A. Fitzpatrick Nuclear Power plant Applicant's No. Audit Questions Applicants Response Project Team's Evaluations Ref. No.

50 118 The Program Description for AMP B.1.29.2 in BWRVIP-79 updated the BWR Water Chemistry The project team finds the applicant's the LRA states that the program relies on Guidelines - 1996 (BWRVIP-29) to provide response acceptable because the monitoring and control of water chemistry updated methodology for establishing site-specific applicant provided a discussion on based on EPRI Report 1008192 (BWRVIP- BWR water chemistry control programs. differences between the 2000 and 2004 130). NUREG-1801 recommends BWRVIP-29 versions of the EPRI guidelines and the (1996) or later revisions, which includes Section 1 Management Responsibilities current plant activities based on BWRVIP-BWRVIP-79 and BWRVIP-130. Please provide discusses the importance of good water chemistry 130. Based on this, the project team the following information related to this AMP. control in obtaining inspection relief from NRC. determined that the use of the 2004 revision of the EPRI BWR water chemistry

b. Discuss the specific differences between The committee reformatted Section 2 to be guidelines provides an acceptable method BWRVIP-29 and BWRVIP-79 and any consistent with the equivalent section in BWRVIP- of controlling water chemistry that is corrective actions added to the water chemistry 62 on inspection relief for core internals. The consistent with the GALL program at the time BWRVIP-79 was discussion provides the basis for the HWC recommendations, although there exists implemented. Provide the technical basis for recommendation, and the role of impurities on some insignificant differences in certain the disposition of each difference. IGSCC in the water chemistry limits included in GALL program elements per BWRVIP-29 Section 4. and the JAFNPP program elements per BWRVIP-130. Based on this, the project Section 3 covers other factors, besides IGSCC, team finds this acceptable. This question that are influenced by water chemistry. It includes a is resolved.

discussion of the effect of HWC and zinc injection on radiation fields, updated with the most recent plant data, and a strengthened discussion of feedwater iron control. The discussion of water chemistry effects on fuel integrity includes information on recent fuel failures. The committee reduced the Action Level 1 limit for feedwater copper from 0.5 to 0.2 ppb, and added diagnostic parameters for feedwater and reactor water iron.

Recent plant data on the effect of oxygen on flow accelerated corrosion (FAC) resulted in the committee raising the Action Level 1 limit for dissolved oxygen in the feedwater from a minimum of 15ppb to 30ppb. The recommendations for water chemistry control and diagnostic parameters in Section 4 now include separate tables for normal water chemistry and hydrogen water chemistry (including NMCA). It is possible to relax the limits for chloride and sulfate in the HWC cases. The 30

Question and Answer Database Audit and Review Related to the License Renewal Application for James A. Fitzpatrick Nuclear Power plant Applicant's No. Audit Questions Applicants Response Project Team's Evaluations Ref. No.

committee reviewed and reduced recommended chemistry surveillance, wherever appropriate, in support of the utility drive to reduce O&M costs (Section 5).

A new appendix on the effects of impurity transients on crack growth rates is included, with examples of decision trees for evaluating actions to minimize the detrimental effects on stress corrosion cracking.

This document, which replaces the 1996 revision (BWRVIP-29), provides water chemistry recommendations for BWRs during all modes of operation. It summarizes the technical bases for all water chemistry alternatives and provides guidance on the development of plant-specific chemistry programs. The guidelines recommend tightening some limits, relaxing others, and implementing more cost-effective monitoring. This will improve protection against materials and fuel problems, and reduce the risks of loss of output from chemistry transients 51 119 The Program Description for AMP B.1.29.2 in BWRVIP-130 updated the BWR Water Chemistry The project team finds the applicant's the LRA states that the program relies on Guidelines - 2000 (BWRVIP-79), providing an response acceptable because the project monitoring and control of water chemistry enhanced methodology for establishing site- team reviewed the water chemistry based on EPRI Report 1008192 (BWRVIP- specific BWR water chemistry control programs. guidelines given in BWRVIP-130 (EPRI 130). NUREG-1801 recommends BWRVIP-29 TR-1008192) and noted that the new (1996) or later revisions, which includes Section 1 addresses a recent policy of the U.S. section 7 in BWRVIP-130 contains goals BWRVIP-79 and BWRVIP-130. Please provide nuclear industry, which commits each nuclear utility for water chemistry optimization. These the following information related to this AMP. to adopt the responsibilities and processes on the are good practice recommended targets management of materials aging issues. It specifies that plants may use in optimizing water

c. Discuss the specific differences between which portions of the document are Mandatory, chemistry in order to balance the BWRVIP-29 and BWRVIP-130, or between Needed, or Good Practices, using the conflicting requirements of materials, fuel BWRVIP-79 and BWRVIP-130 and any classification in NEI 03-08: Guideline for the and radiation control. The project team corrective actions added to the water chemistry Management of Materials Issues. also noted that all other changes between 31

Question and Answer Database Audit and Review Related to the License Renewal Application for James A. Fitzpatrick Nuclear Power plant Applicant's No. Audit Questions Applicants Response Project Team's Evaluations Ref. No.

program at the time BWRVIP-130 was BWRVIP-29 and BWRVIP-130 do not implemented. Provide the technical basis for Section 2 discusses the technical basis for water change the original intent of the guidelines the disposition of each difference, including the chemistry control of IGSCC. The committee in BWRVIP-29. Based on this, the project good practice recommendations in BWRVIP- updated this Section with the latest information on team finds it acceptable. This question is 130, including NEI 03-08, for optimizing the the effects of impurities such as copper, sulfate resolved.

water chemistry. and chloride. It also discusses the overall goal of demonstrating the effectiveness of mitigating IGSCC of piping and reactor internals using HWC and NMCA.

Section 3 covers radiation field effects of water chemistry. The guidelines update the discussion of the effects of NMCA and zinc injection on radiation fields with the most recent plant data, and strengthen the discussion on control of feedwater iron with the recognition that iron increases fuel crud formation and decreases the efficiency of zinc.

Section 4 covers Flow Accelerated Corrosion (FAC) and now includes the effects of NMCA.

Section 5 discusses water chemistry impacts on fuel integrity, including corrosion-related fuel failures and the need for control of feedwater zinc, iron and copper. The guidelines recommend quarterly average maxima for feedwater zinc of 0.6 ppb for HWC plants and 0.4 ppb for NMCA plants based on fuel integrity issues.

Section 6 comprises the recommendations for water chemistry control and diagnostic parameters, which now include separate tables for hydrogen water chemistry, HWC/NMCA and normal water chemistry.

The Action Level tables now address the possibility that continued operation may reduce IGSCC if utilities exceed the Action Levels.

32

Question and Answer Database Audit and Review Related to the License Renewal Application for James A. Fitzpatrick Nuclear Power plant Applicant's No. Audit Questions Applicants Response Project Team's Evaluations Ref. No.

Section 7 is a new section containing recommended goals for water chemistry optimization. These are good practice recommendations for targets that plants may use in optimizing water chemistry to balance the conflicting requirements of materials, fuel and radiation control.

Section 8 discusses recommended chemistry surveillance. The guidelines reduce recommended surveillance and monitoring frequencies in order to reduce O&M costs, as long as there is no significant adverse impact on plant chemistry.

Appendices discuss the effects of impurity transients on crack growth rates, auxiliary systems, conductivity corrections for the presence of ionic species that are benign toward system integrity, ultrasonic fuel cleaning and the BWRVIP radiolysis model.

This document, which replaces the 2000 revision (BWRVIP-79), provides proactive water chemistry recommendations for BWRs during all modes of operation. It summarizes the technical bases for all water chemistry alternatives and provides guidance on the development of plant-specific chemistry programs. The guidelines recommend tightening some limits, relaxing others, and implementing more cost-effective monitoring, which will improve protection against materials and fuel problems and also reduce the risks of loss of output from chemistry transients.

52 120 The Program Description for AMP B.1.29.2 in JAFNPP instituted hydrogen water chemistry The project team finds the applicants the LRA states that the program relies on (HWC) in 1988 to mitigate cracking in recirculation response to be acceptable because the monitoring and control of water chemistry piping. There have been no new IGSCC indications applicant has: (1) clarified that it 33

Question and Answer Database Audit and Review Related to the License Renewal Application for James A. Fitzpatrick Nuclear Power plant Applicant's No. Audit Questions Applicants Response Project Team's Evaluations Ref. No.

based on EPRI Report 1008192 (BWRVIP- in the recirculation system piping after HWC implemented hydrogen water chemistry 130). NUREG-1801 recommends BWRVIP-29 implementation. Due to dose rate issues JAF could (HWC) at JAFNPP in 1999, (2) clarified (1996) or later revisions, which includes not add sufficient hydrogen to mitigate cracking of that it implemented noble metal chemical BWRVIP-79 and BWRVIP-130. Please provide reactor internals so they implemented noble metal addition (NMCA) in addition to HWC in the following information related to this AMP. chemical addition (NMCA) in 1999 and reapplied in 1999, and (3) since the implementation of 2004 for that reason. Zinc addition was instituted in NMCA at JAFNPP, the applicant has not

d. Describe the current status of the JAFNPP 1989 for dose rate reduction and has no impact on identified any new relevant IGSCC Water Chemistry Control Program with respect material degradation. indications in the Class 1 stainless steel to Hydrogen Water Chemistry (HWC), Noble piping welds. This question is resolved.

Metal Chemical Application (NMCA), and Zinc Injection. Specifically, identify when these programs started, and their impact on the operation of plant systems and the degradation of component materials.

53 121 BWRVIP-62, Technical Basis for Inspection Engineering report JAF-RPT-05-LRD-02, Aging The project team finds the applicants Relief for BWR Internal Components with Management Program Evaluation Report, response to be acceptable because the Hydrogen Injection, and BWRVIP-75, (AMPER) was available for onsite review. As noted applicant has clarified that it has not used Technical Basis for Revisions to Generic in AMPER sections 4.3, 4.5, and 4.6, JAFNPP has its implementation of noble metal Letter 88-01 Inspection Schedules identify not sought inspection relief for reactor vessel chemistry addition as a basis for circumstances and conditions for which relief internals based on the use of hydrogen water requesting ISI inspection relief, although it may be granted by the staff. Please describe all chemistry or the use of Noble Metal Chemical has taken credit for NMCA for reducing relief that has been granted by the staff for Application. If inspection relief is sought in the the inspections for its GL 88-01 inspection JAFNPP, based on these documents. future, the guidelines of BWRVIP-62 will be program. This is in accordance with the followed. revision to GL 88-01 inspections proposed in BWRVIP-75A and approved for JAFNPP has taken credit for NMCA to reduce the implementation in the staffs SE on inspections in the 88-01 program for welds that are BWRVIP-75A dated March 14, 2002. This mitigated by noble metals. Details were available question is resolved.

for onsite review.

54 122 GALL recommends that hydrogen peroxide be Engineering report JAF-RPT-05-LRD-02, Aging As indicated and discussed n the monitored to mitigate degradation in structural Management Program Evaluation Report, BWRVIPs response to NRC open issues material. GALL also notes that the rapid (AMPER) was available for onsite review. As on BWRVIP-62, dated August 1, 2001, the decomposition of hydrogen peroxide makes described in AMPER section 4.22.2.B.3.b, JAFNPP applicant is referring to measuring the reliable data exceptionally difficult to obtain, does not monitor ECP directly due to its status as a molar ratios of hydrogen to oxygen in the and BWRVIP-130 Section 6.3.3, "Water Category 3b plant as described in Table 2-6 of reactor coolant system coolant and RCS 34

Question and Answer Database Audit and Review Related to the License Renewal Application for James A. Fitzpatrick Nuclear Power plant Applicant's No. Audit Questions Applicants Response Project Team's Evaluations Ref. No.

Chemistry Guidelines for Power Operation," BWRVIP-130. water being processed by the reactor does not address monitoring for hydrogen water cleanup system. The project team peroxide. The staff notes that the JAFNPP follows BWRVIP-62 criteria for Category finds the applicants response to be Electrochemical Corrosion Potential (ECP) 3b plants and measures the reactor water and acceptable because the applicant has quantifies the oxidizing power of a solution in RWCU molar ratio. When this ratio is > 2:1 the clarified how monitoring of the hydrogen to contact with a specific metal surface. The ECP ECP is effectively < -230 mV SHE and in reality oxygen molar ratio will be capable of of different reactor internals component closer to -400 mV SHE. JAFNPP operates with a achieving an electrochemiical potential materials is very sensitive to the concentration measured molar ratio significantly > 2:1 with a goal (ECP) < -230 mV, and because this is of oxygen, hydrogen, and hydrogen peroxide of > 4:1. confirmed in the BWRVIPs response and therefore is different at different locations letter of August 1, 2001, which clarifies within the BWR reactor system. Section 8.3 of why molar ratio monitoring is an BWRVIP-130 (Figure 8- 11) discusses the acceptable basis for establishing the ECP potential locations suitable for measuring the of the reactor coolant. This question is ECP. Please provide the following information resolved.

related to this AMP.

a. Clarify whether ECP is monitored at the reactor locations recommended in BWRVIP-130 at JAFNPP. Discuss the methods used and their frequency.

55 123 GALL recommends that hydrogen peroxide be Based on the BWRVIP radiolysis model, a As indicated and discussed n the monitored to mitigate degradation in structural measured molar ratio in the reactor water of > 2:1 BWRVIPs response to NRC open issues material. GALL also notes that the rapid demonstrates the molar ratio is > 2:1 everywhere in on BWRVIP-62, dated August 1, 2001, the decomposition of hydrogen peroxide makes the reactor vessel at or below the normal water applicant is referring to measuring the reliable data exceptionally difficult to obtain, level which is where all the wetted components molar ratios of hydrogen to oxygen in the and BWRVIP-130 Section 6.3.3, "Water were treated with noble metals. JAFNPP adds reactor coolant system coolant and RCS Chemistry Guidelines for Power Operation," sufficient feedwater hydrogen to operate with a water being processed by the reactor does not address monitoring for hydrogen measured molar ratio > 4:1. In accordance with the water cleanup system. The project team peroxide. The staff notes that the model, it demonstrates at least a molar ratio of 3:1 finds the applicants response to be Electrochemical Corrosion Potential (ECP) at the upper portion of the shroud OD. Components acceptable because the applicant has quantifies the oxidizing power of a solution in above this level cannot be mitigated with HWC or clarified how monitoring of the hydrogen to contact with a specific metal surface. The ECP NMCA. When molar ratio is > 2:1 the equivalent of oxygen molar ration will be capable of of different reactor internals component ECP according to the model is < -400 mV SHE. achieving an electrochemiical potential materials is very sensitive to the concentration Data from other stations that measured ECP with (ECP) < -230 mV, and because this is of oxygen, hydrogen, and hydrogen peroxide noble metals validates the model results for the confirmed in the BWRVIPs response and therefore is different at different locations category 3B plants. letter of August 1, 2001, which clarifies 35

Question and Answer Database Audit and Review Related to the License Renewal Application for James A. Fitzpatrick Nuclear Power plant Applicant's No. Audit Questions Applicants Response Project Team's Evaluations Ref. No.

within the BWR reactor system. Section 8.3 of why molar ratio monitoring is an BWRVIP-130 (Figure 8-11) discusses the acceptable basis for establishing the ECP potential locations suitable for measuring the of the reactor coolant. This question is ECP. Please provide the following information resolved.

related to this AMP.

b. If ECP is not monitored periodically, discuss how JAFNPP ensures that hydrogen addition alone will maintain the ECP at an acceptable level within the reactor system.

56 124 GALL recommends that dissolved oxygen be As described in LRA Section B.1.29.2, the Water The project team finds the applicant's monitored as part of the water chemistry Chemistry Control - BWR Program is consistent response acceptable because in Section program. Please identify the systems in which with NUREG-1801. Engineering report JAF-RPT- 4.22.2 of the program basis document, dissolved oxygen is monitored at JAFNPP, and 05-LRD-02, Aging Management Program JAF-RPT-05-LRD02, the applicant stated discuss the methods used to monitor this Evaluation Report, (AMPER) was available for that dissolved oxygen is monitored parameter. Also, provide examples of recent onsite review. AMPER section 4.22.2.B.3.b routinely for the reactor water, feedwater, data from these systems. indicates that the Water Chemistry Control - BWR condensate and CRD water systems, as Program periodically monitors the concentration of recommended in BWRVIP-130. On this dissolved oxygen in reactor water, feedwater, basis, the project team finds this condensate, and control rod drive water and keeps acceptable. This question is resolved.

it within the BWRVIP-130 recommended range to mitigate corrosion.

Examples of recent dissolved oxygen data from the reactor water, feedwater, condensate, and control rod drive water systems were available for onsite review.

57 125 GALL recommends that the water quality (i.e., Engineering report JAF-RPT-05-LRD-02, Aging The project team finds this response to be pH and conductivity) be maintained in Management Program Evaluation Report, acceptable because the applicant has accordance with EPRI Guidelines by periodic (AMPER) was available for onsite review. As clarified in Engineering report LRD-02 that sampling to determine the concentration of described in AMPER section 4.22.2.B.3.b, the water quality requirements are in chemical species. BWRVIP-130, Section torus/pressure suppression chamber, condensate accordance with EPRI guidelines and 8.2.1.11, indicates that pH measurement storage tank, and demineralized water storage tank GALL report recommendations. This accuracy in most BWR streams is generally conductivity, chloride, sulfate and total organic question is resolved.

suspect because of the dependence of the compound levels are monitored and kept below 36

Question and Answer Database Audit and Review Related to the License Renewal Application for James A. Fitzpatrick Nuclear Power plant Applicant's No. Audit Questions Applicants Response Project Team's Evaluations Ref. No.

instrument reading on ionic strength of the BWRVIP-130 recommended levels to mitigate SCC sample solution. In addition, the monitoring of and corrosion. Operating experience shows that pH is not discussed in BWRVIP-130, Appendix this program has been effective in managing aging B for condensate storage tank, demineralized effects. Therefore, continued implementation of the water storage tank, or torus water. Please program provides reasonable assurance that explain what methods are used to monitor the effects of aging will be managed so that water quality of these systems and components crediting this program can perform components, and the technical basis for their intended function consistent with the current concluding that they are effective. licensing basis during the period of extended operation. In addition, as described in LRA Section B.1.21, prior to the period of extended operation, a one-time inspection activity will verify the effectiveness of the water chemistry control aging management programs by confirming that unacceptable cracking, loss of material, and fouling is not occurring.

58 126 Flow accelerated corrosion (FAC) in carbon The Water Chemistry Control - BWR Program is The project team finds the applicant's and low alloy steel components is affected by not credited to manage loss of material due to response acceptable because AMPER dissolved oxygen concentration, among other FAC. Consistent with NUREG-1801, loss of section 4.22.2.B.3.b indicates that the factors. Section 4.2.1 of BWRVIP-130 states material due to FAC is managed by the Flow- Water Chemistry Control - BWR Program that the rate of FAC increases dramatically if Accelerated Corrosion Program described in LRA periodically monitors the concentration of oxygen concentration is less than about 25 Section B.1.14. As stated in NUREG-1801, Section dissolved oxygen in reactor water, ppb. Please describe the procedures used at XI.M17, the FAC program is an analysis, feedwater, condensate, and control rod JAFNPP to maintain appropriate oxygen levels inspection, and verification program; thus, there is drive water and keeps it within the in water in the various plant systems for which no preventive action. As described in LRA Section BWRVIP-130 recommended range. Since this AMP is credited to mitigate loss of material B.1.29.2, the Water Chemistry Control - BWR BWRVIP-130 provides protection against due to FAC (i.e., erosion/corrosion, steam Program is consistent with NUREG-1801. FAC in various reactor components by cutting, etc.). maintaining appropriate oxygen level, the Engineering report JAF-RPT-05-LRD-02, Aging project team finds this acceptable. This Management Program Evaluation Report, question is resolved.

(AMPER) was available for onsite review. AMPER section 4.22.2.B.3.b indicates that the Water Chemistry Control - BWR Program periodically monitors the concentration of dissolved oxygen in reactor water, feedwater, condensate, and control rod drive water and keeps it within the BWRVIP-37

Question and Answer Database Audit and Review Related to the License Renewal Application for James A. Fitzpatrick Nuclear Power plant Applicant's No. Audit Questions Applicants Response Project Team's Evaluations Ref. No.

130 recommended range.

59 127 BWRVIP-130 recommends that reactor water Reactor water iron level is monitored as a The project team finds this response to be iron level be monitored as a diagnostic diagnostic acceptable because the applicant has parameter, and that feedwater copper level be parameter. As described in LRA Section B.1.29.2, clarified that these parameters are monitored as one of the control parameters. the Water Chemistry Control - BWR Program is periodically monitored through Please confirm that the JAFNPP water consistent with NUREG-1801. Engineering report implementation of the applicants Water chemistry program includes monitoring of these JAF-RPT-05-LRD-02, Aging Management Program Chemistry Program and the monitoring parameters. Evaluation Report, (AMPER) was available for requirements are in accordance with onsite review. As described in AMPER Section applicable plant procedures, as referenced 4.22.2.B.3.b, feedwater iron and copper in JAFNPP Report JAF-RPT-05-LRD-02.

concentrations are periodically monitored and kept This question is resolved.

below recommended levels. Thus, feedwater copper is monitored as a control parameter.

60 128 Aging of Standby Liquid Control (SBLC) system LRA Table 3.3.2-1, Standby Liquid Control System The project team finds this response to be components not in the reactor coolant pressure Summary of Aging Management Evaluation, shows acceptable because the applicant has boundary section of SBLC system relies on that stainless steel accumulators, orifices, piping, clarified that it will perform a one-time monitoring and control of SBLC makeup water pump casings, tank, thermowells, tubing, and valve examination of SBLC system orifices, chemistry. The effectiveness of the water bodies containing sodium pentaborate solution piping, accumulators, tanks, pump casing, chemistry program will be verified by a one- credit the Water Chemistry Control - BWR and valve bodies to verify the time inspection of the SBLC system. Please Program for aging management. Note 315 for each effectiveness of the Water Chemistry confirm that the One-Time Inspection program of these line items indicates that the One-Time Program to mitigate loss of material in the will include the SBLC pump casing, and the Inspection Program is applicable. Therefore, the system components. Also, in Section associated tank discharge piping and valve One-Time Inspection Program will include the 4.22.2 of the program basis document, bodies in addition to the SBLC tank. SBLC pump casing, and the associated tank JAF-RPT-05-LRD02, and Footnote 315 in discharge piping and valve bodies in addition to the LRA Section 3.3.2-1 verifies that a one-SBLC tank. time inspection is credited for these components. This question is resolved.

61 129 The discussion of operating experience for As discussed in LRA Section B.1.29.2, the 2001 The project team finds the applicants AMP B.1.29.2 in the LRA indicates that a self- self-assessment revealed that sample system flow response to be acceptable because the assessment of the water chemistry program rates for the corrosion product metal samplers for applicant has clarified what type of 38

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was conducted in 2001. Please discuss any feedwater and condensate may not be high enough corrective actions were implemented at abnormalities identified and corrective actions to adequately give a representative sample. The JAFNPP to address the self-assessments taken as a result of this self-assessment, and sample lines were replaced with sample lines that recommendation for sample system flow provide a copy of the most recently completed deliver greater than or equal to 6 linear ft/sec rates. No issues were identified that would self-assessment related to the water chemistry during 1st quarter 2004. impact the program. This question is program at JAFNPP. resolved.

A copy of the most recently completed self-assessment related to the water chemistry program was available for onsite review.

62 130 The Program Description for AMP B.1.26 in the JAFNPP has implemented long term commitments The project team finds the applicant's LRA states that Service Water Integrity provided in response to GL 89-13 response acceptable based on its review Program relies on implementation of the recommendations that include heat transfer testing, of JAF-RPT-MULTI-01267, JAF Raw recommendations of GL 89-13 to ensure that inspections and maintenance, and biofouling Water Systems Program Plan, Revision the effects of aging on the service water control. The one-time actions for walkdowns and 3, which identifies the various program systems (SWS) will be managed for the period review of maintenance, operating, and training activities conducted on the applicants raw of extended operation. Please confirm that all practices and procedures have also been water and service water systems of the recommendations in GL 89-13 have completed. associated with the implementation of the been implemented at JAFNPP, including a) applicants Generic Letter 89-13 surveillance and control of biofouling, b) a test commitments to the NRC. Ongoing program to verify heat transfer capabilities, c) programmatic activities implementing the routine inspection and maintenance, d) system applicants GL 89-13 commitments walkdowns, and e) review of maintenance, include: biofouling controls, such as, operating, and training practices and monitoring and inspections, chlorine procedures. Provide the technical basis for any injection, chemical treatments to control recommendations that have not been Microbiologically Influenced Corrosion implemented. Also, please make the JAFNPP (MIC), a Zebra Mussel Control Program, responses to GL 89-13 available for staff and molluscide treatments; a heat review at the onsite audit. exchanger testing program; and an inspection and maintenance program.

The project team staff finds that the applicants GL 89-13 implementation program and activities are in accordance with GL 89-13, and are consistent with GALL AMP XI.M20. This question is resolved.

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Question and Answer Database Audit and Review Related to the License Renewal Application for James A. Fitzpatrick Nuclear Power plant Applicant's No. Audit Questions Applicants Response Project Team's Evaluations Ref. No.

63 131 The Program Description for AMP B.1.26 in the As stated in JAF-RPT-05-LRD02 section 4.20 and The project team finds the applicant's LRA states that the service water systems section B.1.26 the service water systems of normal response acceptable because it confirmed include the normal service water (NSW), service water (NSW), emergency service water that normal service water (NSW),

emergency service water (ESW), and residual (ESW), and residual heat removal service water emergency service water (ESW), and heat removal service water (RHRSW). Please (RHRSW) are the raw water systems included in residual heat removal service water confirm that these are the only systems at the scope of this AMP. These are the only systems (RHRSW) are the only systems at JAFNPP that transfer heat from safety-related at JAFNPP that transfer heat from safety-related JAFNPP that transfer heat from safety-systems, structures, and components to the systems, structures, and components to the related systems, structures, and ultimate heat sink, and, therefore, are the only ultimate heat sink. components to the ultimate heat sink. This systems in the scope of this AMP. is consistent with GALL AMP XI.M20. This question is resolved.

64 132 The Program Description for AMP B.1.26 in the As described in JAF-RPT-05-LRD02 section 4.20 The project team finds the applicant's LRA states that the program includes the service water integrity program includes visual response acceptable because it confirmed component inspections for erosion, corrosion, inspections and non destructive testing methods that the service water integrity program and blockage. In NUREG-1801, AMP XI.M20 including ultrasonic testing and eddy current testing includes visual inspections and non notes that visual inspections are typically of heat exchanger tubes. These methods are destructive testing methods including performed; however, nondestructive testing applied to in-scope service water cooled ultrasonic testing and eddy current testing such as ultrasonic testing and eddy current components. This is documented in site of heat exchanger tubes. Specifically, testing, are effective methods to measure procedures AP-19.12 and AP-19.14 which provide components in the scope of this program surface condition and the extent of wall information on the scope and frequency of the are inspected for erosion, corrosion, and thinning, when determined necessary. Please inspections. blockage. Performance testing of heat discuss the inspection methods included in exchangers in the scope of this program is AMP B.1.26, including the type of inspections performed to verify acceptable used, the scope of the inspections, and the performance. In addition, chemical frequency of the inspections. treatment with biocides and chlorine is performed, along with periodic cleaning and flushing of redundant or infrequently used loops, to control or prevent fouling within the heat exchangers and loss of material in service water components.

These activities are consistent with the recommendations in GALL AMP XI.M20.

This question is resolved.

65 133 The discussion of Exceptions to NUREG-1801 Coatings and linings are not credited to prevent or The project team finds the applicant's for AMP B.1.26 in the LRA states that minimize aging effects on components and as such response acceptable because it confirmed 40

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components are lined or coated only where the aging management review did not identify that there are no linings or coatings used necessary to protect the underlying metal components that are lined or coated. There are no within the service water piping.

surfaces. Please provide the following linings or coatings used within the service water Unlined/uncoated components in the information: piping. service water system are inspected using visual inspections and non-destructive a) Identify the components that are lined or testing methods to ensure that aging coated in the JAFNPP service water systems effects do not affect their ability to perform their intended functions. These activities are consistent with the recommendations in GALL AMP XI.M20. This question is resolved.

66 134 The discussion of Exceptions to NUREG-1801 Because linings and coatings are not credited to The project team finds the applicant's for AMP B.1.26 in the LRA states that prevent or minimize aging effects no specific response acceptable because the components are lined or coated only where inspections are needed. However, AMP B.1.26 applicant does not credit linings or necessary to protect the underlying metal includes the inspections of various service water coatings to manage the aging effects that surfaces. Please provide the following information: components which would detect any degradation of are applicable to the service water piping lined or coated components. at JAFNPP. The service water integrity b) Confirm that AMP B.1.26 includes aging management program includes inspections to detect degraded protective visual inspections and non-destructive linings or coatings. testing methods, including ultrasonic testing and eddy current testing of heat exchanger tubes. These tests would detect any degradation of lined or coated components. This question is resolved.

67 135 The discussion of Exceptions to NUREG-1801 Unlined/uncoated components in the service water The project team finds the applicant's for AMP B.1.26 in the LRA states that systems are inspected as part of AMP B.1.26 to response acceptable because components are lined or coated only where ensure that aging effects do not affect their ability unlined/uncoated components in the necessary to protect the underlying metal to perform their intended functions. The use of service water system are inspected to surfaces. Please provide the following information: appropriate materials is controlled by design ensure that aging effects do not affect processes which consider the environment and their ability to perform their intended c) Discuss the preventive measures taken at operating experience to ensure appropriate functions. In addition, the use of JAFNPP to protect unlined/uncoated materials are selected. appropriate materials is controlled by components in the service water systems that design processes which consider the are exposed to aggressive cooling water environment and operating experience to 41

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environments, such as the use of appropriate ensure appropriate materials are selected.

materials These activities are consistent with GALL XI.M20 recommendations. This question is resolved.

68 136 The discussion of Operating Experience for All 4 original RHRSW pumps have been replaced: The project team finds the applicant's AMP B.1.26 in the LRA states that the results 10P-1A, 1B, 1C and 1D. response acceptable because the of SWS visual and other nondestructive applicant has clarified that all of the examinations (2000-2004) revealed areas of All of the EDG jacket water heat exchangers have degraded RHRSW pumps and EDG heat erosion and areas of corrosion on internal and been replaced. 93WE-1A - 12/05; 93WE-1B - exchangers were replaced. This question external surfaces. Corrective actions included 12/05; 93WE-1C - 6/05 and 93WE-1D - 2/04. is resolved.

replacement of RHRSW pumps, replacement of ESW and normal service water piping components, replacement of EDG jacket water heat exchangers, and close monitoring of RHRSW and ESW pump discharge strainer housings by ultrasonic inspections with repair as needed. Please provide the following information:

a) Identify the RHRSW pumps and EDG jacket heat exchangers that were replaced.

69 137 The discussion of Operating Experience for b) Approximately 1% of the ESW and NSW piping The project team finds the applicant's AMP B.1.26 in the LRA states that the results has been replaced due to visual and non- response acceptable because the of SWS visual and other nondestructive destructive examinations. The piping was replaced Operating Experience demonstrates that examinations (2000-2004) revealed areas of with carbon steel for the most part. Carbon steel the applicants service water integrity erosion and areas of corrosion on internal and has aged well at JAF as evidenced by the 30+ year program was capable of detecting the external surfaces. Corrective actions included service without the currently implemented controls. aging in the ESW and EDG jacket heat replacement of RHRSW pumps, replacement of Implementation of the current controls will only exchanger components, allowing for ESW and normal service water piping serve to extend the service life. These controls are proper corrective actions by the applicant components, replacement of EDG jacket water the visual and non-destructive examinations that (i.e., replacement of the impacted heat exchangers, and close monitoring of are currently conducted. The continuous components. Thus, the project team RHRSW and ESW pump discharge strainer chlorination performed for both the NSW and ESW concluded that the AMP is capable of housings by ultrasonic inspections with repair systems. The use of BULAB chemicals to assist detecting degradation of components prior 42

Question and Answer Database Audit and Review Related to the License Renewal Application for James A. Fitzpatrick Nuclear Power plant Applicant's No. Audit Questions Applicants Response Project Team's Evaluations Ref. No.

as needed. Please provide the following the chlorine in penetrating any buildup within the to a loss of intended function. Also, information: piping and to keep dissolved substances and silt in appropriate corrective actions are taken to suspension so as to exit the system piping. The prevent recurrence of the degradation of b) Provide the percentage of ESW and NSW PMs for examination and cleaning of piping and piping component failures. This question piping that was replaced, and the material used appurtenances on frequencies designed to is resolved.

for the replacement piping. minimize pipe wall thinning and maximize design functionality. The periodic flow testing via surveillance testing and flushing of stagnant system legs are some of the methodologies used at JAF to control system degradation.

The chemical cleaning processes, used in the ESW system, also ensures design functionality.

Stainless steel has been used in areas of erosion to extend the service life of the piping exposed to cavitation.

70 138 The discussion of Operating Experience for There are no other areas where erosion or The project team finds the applicant's AMP B.1.26 in the LRA states that the results corrosion have been found that need to be response acceptable because operating of SWS visual and other nondestructive addressed in the RHRSW system. experience during 2000-2004 period examinations (2000-2004) revealed areas of demonstrates that the service water erosion and areas of corrosion on internal and Within the ESW and NSW system there are integrity program is capable of detecting external surfaces. Corrective actions included sections of piping that have scheduled follow up the effects of aging and assuring that replacement of RHRSW pumps, replacement of non-destructive examinations with ample time appropriate corrective actions will be ESW and normal service water piping allotted for replacement as warranted. The unit implemented to prevent recurrence.

components, replacement of EDG jacket water cooler coils have been replaced in a number of Corrective actions taken in response to heat exchangers, and close monitoring of ESW unit coolers / heat exchangers. Replacement the 2000-2004 findings include:

RHRSW and ESW pump discharge strainer of additional unit cooler / heat exchanger coils has replacement of all four RHRSW pumps, housings by ultrasonic inspections with repair been included in the JAF long term plan. and all four EDG jacket water heat as needed. Please provide the following exchangers; ultrasonic inspections of information: RHRSW and ESW pump discharge strainer housings; and sections of the c) Aside from the components that were ESW and NSW piping were scheduled for replaced, discuss the other internal and followup non-destructive examinations. In external surfaces for which erosion and addition, replacement of additional unit corrosion were found, including the extent of cooler / heat exchanger coils has been the degradation and the corrective actions included in the JAF long term plan. This 43

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taken. Discuss your plans for replacing any question is resolved.

components or piping before the period of extended operation.

71 139 The discussion of Operating Experience for UT inspections of the RHRSW pump discharge and The project team finds the applicant's AMP B.1.26 in the LRA states that the results RHRSW system strainers have been ongoing since response acceptable because the of SWS visual and other nondestructive about 2001. Several below min. wall areas of the applicant has clarified the results of examinations (2000-2004) revealed areas of strainers have been repaired. No repairs were monitoring activities performed on the erosion and areas of corrosion on internal and necessary for the RHRSW pumps. All 4 pumps RHRSW and ESW pump discharge external surfaces. Corrective actions included have since been replaced. strainer housings. Specifically, UT replacement of RHRSW pumps, replacement of inspections of the RHRSW pump ESW and normal service water piping The ESW duplex strainers have experienced only a discharge and RHRSW system strainers components, replacement of EDG jacket water single repair for wall thinning on the four ESW have identified RHRSW system strainers heat exchangers, and close monitoring of strainer basket housings. A Top Ten team is with below minimum wall areas. The RHRSW and ESW pump discharge strainer discussing how to improve the service life of the ESW duplex strainers have experienced housings by ultrasonic inspections with repair strainer housings to preclude wall thinning. The only a single repair for wall thinning on the as needed. Please provide the following existing ESW strainer housings have lasted for 30+ four ESW strainer basket housings The information: years and are in no imminent danger of pinhole existing ESW strainer housings have leaks. lasted for 30+ years and are in no d) Discuss the results of the monitoring imminent danger of pinhole leaks. This activities for the RHRSW and ESW pump demonstrates that the applicants service discharge strainer housings. water integrity program is able to detect degradation of components and correct identified deficiencies prior to a loss of intended function.

72 140 The discussion of Operating Experience for The majority of issues centered on the The project team finds the applicant's AMP B.1.26 in the LRA states that a two-week implementation of Generic Letter 89-13. Since response acceptable because it confirmed ESW system assessment in February 2000 then, there have been several GL-89-13 that deficiencies identified during the revealed weaknesses in the Service Water inspections. Some inspections were in-house February 2000 self assessment were Integrity Program. Please discuss the (Corporate Inspections) and some were by outside primarily attributed to implementation of weaknesses identified and the significant agencies (NRC Ultimate Heat Sink and other the GL 89-13 program and appropriate improvements made to correct the inspections). All of the inspections since 2000 corrective actions have been weaknesses. indicated that GL-89-13 has been appropriately implemented to improve the program. All implemented. of the inspections performed since the 2000 assessment did not identify any Specifically, prior to 2000, lack of program significant deficiencies in the applicants 44

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ownership and weak program maintenance were implementation of its GL-89-13 program..

identified as improvements needed for appropriate This question is resolved.

implementation of GL-89-13.

The corrective actions taken essentially re-constituted the licensing commitments associated with Generic Letter 89-13, ensured that all related plant procedures were updated to reflect GL 89-13 licensing commitments.

There were two less prevalent issues identified in 2000 assessment. The Surveillance Test Program and the Corrective Action Program (CAP) were issues that resulted in effectiveness reviews being conducted for both programs. Corrective actions were initiated to correct and improve both programs. Several ESW Condition Reports issued prior to 2000 required adjustments in significant level and closure of corrective actions. All issues identified regarding the CAP have been addressed.

Additionally, all issues associated with the Surveillance Test Program have been addressed and included in the creation of a Surveillance Program Coordinator and a Surveillance Program Round Table.

Several NRC inspections confirm that the strength of the significant improvements made within the ESW system. Integrated Inspection Report 05000333/2003008 is one example. During the ESW and support systems review, the ESW system was heavily scrutinized. The inspection reviewed open work requests, temp mods, and operator workarounds to assess the collective impact on system operation. The inspection reviewed the condition report database to verify that equipment alignment problems were being identified and appropriately resolved. No findings of 45

Question and Answer Database Audit and Review Related to the License Renewal Application for James A. Fitzpatrick Nuclear Power plant Applicant's No. Audit Questions Applicants Response Project Team's Evaluations Ref. No.

significance were identified. Post work testing within the service water systems was reviewed.

Again, no findings of significance were identified.

Inspectors witnessed surveillance testing of service water systems and reviewed test data to assess whether the SSCs satisfied TS, UFSAR, Technical Requirements Manual, and Entergy procedural requirements. Again, no findings of significance were identified. Inspectors performed a detailed review of 69 corrective action program items assessing Entergy's threshold for problem identification, adequacy of cause analysis and extent of condition reviews, and timeliness of the corrective actions required. No findings of significance were identified.

Problem Identification and Resolution Inspection Report 05000333/2004006 is another example of the significant improvements made within the ESW system. The identification and resolution of problems was reviewed by the NRC. Their inspection team reviewed all aspects of the corrective action program (CAP). No findings of significance were identified. There were minor deficiencies noted. The team concluded that the plant staff identified deficiencies and entered them in the CAP, and at the appropriate threshold. The team also found that the self assessments and audits were sufficiently self-critical and provided relevant performance observations and insights.

The team found that with regard to prioritization and evaluation of issues including service water system erosion and/or corrosion, heat exchanger fouling that there were no findings of significance identified. There were some minor instances of documentation issues.

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Question and Answer Database Audit and Review Related to the License Renewal Application for James A. Fitzpatrick Nuclear Power plant Applicant's No. Audit Questions Applicants Response Project Team's Evaluations Ref. No.

73 141 The discussion of Operating Experience for Integrated Inspection Report 05000333/2005006 is The project team finds the applicant's AMP B.1.26 in the LRA states that during the the report referred to in the LRA section. During the response acceptable because the fall of 2005, NRC conducted an integrated inspection maintenance effectiveness was applicant clarified that no issues of inspection, which included an assessment of reviewed. The inspectors reviewed problems significance were identified during the maintenance effectiveness for the ESW involving selected in-scope SSCs to assess the NRC ESW system inspections. This system. Please discuss any weaknesses effectiveness of the maintenance program. The question is resolved.

identified in the NRC inspection, and the Emergency Service Water (ESW) system was one corrective actions taken. of the two sample systems selected. Reviews focused on proper Maintenance Rule scoping in accordance with 10CFR50.65; characterization of reliability issues; changing system and component unavailability; 10CFR50.65 (a)(1) and (a)(2) classifications; identifying and addressing common cause failures; trending key parameters and the appropriateness of performance criteria for SSCs classified (a)(2) as well as the adequacy of goals and corrective actions for SSCs classified (a)(1).

The inspectors reviewed system health reports, maintenance backlogs, and MR Basis documents.

No findings of significance were identified.

74 142 The Program Description for AMP B.1.29.1 in These are the only auxiliary systems with license The project team finds the applicant's the LRA states that the water chemistry control renewal intended functions utilizing cooling water response acceptable because the

- auxiliary systems includes the following: 1) as the heat transfer medium that are not included applicant has clarified that the auxiliary control room and relay room chilled water in another AMP. systems mentioned in the question are the system, 2) security generator jacket cooling only auxiliary systems that are within the water, 3) aux boiler heating water, 4) decay scope of AMP B.1.29.1, Water Chemistry heat removal cooling water, and 5) the stator Control - Auxiliary System Program. This cooling water system. Please confirm that question is resolved.

these are the only auxiliary systems at JAFNPP utilizing cooling water as the heat transfer medium that are not already included in another AMP. (e.g., jacket cooling water for an SBO diesel generator or a dedicated Appendix R diesel generator) 75 143 The Program Description for AMP B.1.29.1 in For stator cooling water and auxiliary boiler heating The project team finds the applicant's 47

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the LRA states that the program includes water, the parameters monitored, associated response acceptable because the sampling, analysis, and coolant replacement acceptance criteria, plans for inspection, and applicant amended the LRA to clarify that activities. Please discuss the sampling and administrative controls are described in LRA sampling and analysis methods will utilize analysis methods included in AMP B.1.29.1, section B.1.29.1. industry guidance, and one-time including the sampling procedures and Stator cooling water conductivity is monitored inspection results. The applicant controls, sampling and analysis frequency, weekly, while dissolved oxygen and soluble copper amended the LRA in amendment letter types of analyses performed, inspections used, are monitored monthly. The sampling and analysis No. 5, dated February 01, 2007, to reflect and criteria for coolant replacement for each of procedure was available for onsite review. JAF the information in the response and that a the systems covered in the program. has two on-line stator cooling water conductivity one-time inspection will be performed to monitors. Auxiliary boiler heating water verify that the water chemistry monitoring conductivity, pH, and dissolved oxygen are activities are achieving their mitigative monitored quarterly. The sampling and analysis function. This question is resolved.

procedure was available for onsite review.

For control room and relay room chilled water, decay heat removal cooling water, and security generator jacket cooling water, LRA section B.1.29.1 notes that the program will be enhanced prior to the period of extended operation to provide guidance for sampling and analysis. Industry recommendations and One-Time Inspection Program results will be considered in determining the parameters to be monitored, monitoring frequency, and associated acceptance criteria.

This requires a LRA amendment.

76 144 The Parameters Monitored/Inspected program The Auxiliary Systems Water Chemistry Control The project team finds the applicant's element for AMP B.1.29.1 in the LRA states that Program is based on equipment vendor response acceptable because the applicant the selection of parameters to be monitored/ specifications, chemical vendor recommendations, has identified the documents that are used inspected for the systems included in the technical manuals, industry standards, and as the basis for the industry program is in accordance with industry operating experience. Guidelines utilized include recommendations such as equipment recommendations. Please identify the EPRI guidelines, as well as vendor and other vendor specifications, chemical vendor documents that are used as the basis for the industry guidelines. recommendations, technical manuals, industry recommendations, and make these industry standards, and operating available for NRC review at the time of the Basis documents for stator cooling water monitoring experience. The project team finds the onsite audit. include EPRI Technical Report 1004004 and "parameters monitored/inspected program 48

Question and Answer Database Audit and Review Related to the License Renewal Application for James A. Fitzpatrick Nuclear Power plant Applicant's No. Audit Questions Applicants Response Project Team's Evaluations Ref. No.

General Electric Technical Information Letters and element meets the SRP-LR guidance. This Service Information Letters. Basis documents for question is resolved.

auxiliary boiler monitoring include the Cleaver Brooks manuals. These documents were available for onsite review.

77 145 The Detection of Aging Effects program As described in LRA section B.1.21, the One-Time The project team finds the applicant's element for AMP B.1.29.1 in the LRA states Inspection Program is a new program that will be response acceptable because the that the One-Time Inspection Program will applicant clarified that the specific consistent with NUREG-1801 XI.M32, One-Time Inspection.

verify effectiveness of water chemistry control Engineering report JAF-RPT-05-LRD-02, Aging inspection methods that will be used to program. Please identify the specific inspection Management Program Evaluation Report, verify the effectiveness of water chemistry methods that will be used in the One Time (AMPER) was available for onsite review. As control program will be consistent with Inspection Program for each of the auxiliary described in AMPER Appendix B, for the one-time GALL AMP XI.M32, One-Time Inspection .

systems in the scope of AMP B.1.29.1. inspection activity to verify effectiveness of water The applicant amended the LRA AMP chemistry control programs, combinations of B.1.29.1 to clarify that combinations of nondestructive examinations (including VT-1, nondestructive examinations (including ultrasonic, and surface techniques) will be VT-1, ultrasonic, and surface techniques) performed by qualified personnel following will be performed by qualified personnel procedures that are consistent with Section XI of following procedures that are consistent ASME B&PV Code and 10CFR50, Appendix B. with Section XI of ASME B&PV Code and This requires an LRA amendment. 10CFR50, Appendix B.. The applicant amended the LRA in amendment letter No. 5, dated February 01, 2007, to reflect the information in the response and that a one-time inspection will be performed to verify that the water chemistry monitoring activities are achieving their mitigative function. This question is resolved.

78 146 The Monitoring and Trending program The parameters monitored are archived for long The project team finds the applicant's element for AMP B.1.29.1 in the LRA states term trending and review. As stated under response acceptable because the that values from the analyses are archived for Parameters Monitored/Inspected of AMP B1.29.1, applicant amended the LRA to clarify that long term trending and review. Please provide stator cooling water conductivity, dissolved oxygen, industry recommendations and One-Time the following information: and soluble copper are monitored and auxiliary Inspection Program results will be boiler heating water conductivity, pH, and dissolved considered in determining the parameters a) Identify the parameters that are to be oxygen are monitored. to be monitored, monitoring frequency, 49

Question and Answer Database Audit and Review Related to the License Renewal Application for James A. Fitzpatrick Nuclear Power plant Applicant's No. Audit Questions Applicants Response Project Team's Evaluations Ref. No.

trended for each of the auxiliary systems in the and associated acceptance criteria. The scope of this AMP. For control room and relay room chilled water, applicant amended the LRA in decay heat removal cooling water, and security amendment letter No. 5, dated February generator jacket cooling water, LRA Section 01, 2007, to reflect the information in the B.1.29.1 notes that the program will be enhanced response and that a one-time inspection prior to the period of extended operation to provide will be performed to verify that the water guidance for sampling and analysis. Industry chemistry monitoring activities are recommendations and One-Time Inspection achieving their mitigative function. This Program results will be considered in determining question is resolved.

the parameters to be monitored, monitoring frequency, and associated acceptance criteria.

Parameters monitored for these systems will be archived for long term trending and review.

This requires a LRA amendment.

79 147 The Monitoring and Trending program In accordance with Entergy corporate procedure The project team finds the applicant's element for AMP B.1.29.1 in the LRA states EN-CY-101, Chemistry Activities, the chemistry response acceptable because Entergy that values from the analyses are archived for department trends chemistry and radiochemistry Corporate procedure EN-CY-101 provides long term trending and review. Please provide parameters to allow identification and correction of administrative controls and procedural the following information: adverse trends before limits are exceeded. Data is guidance for periodic review and trending reviewed as it is generated, and appropriate and because, upon its review of the b) Discuss the administrative controls and comments are made as necessary to document procedure, the project team determined procedures to be used to implement the reasons for adverse data indications. The site that Procedure EN-CY-101 included periodic review and trending. chemistry staff reviews the data trends to ensure acceptable limits and controls for adverse indications are noted and addressed in a monitoring the chemistry and radio timely manner. chemistry parameters for auxiliary systems and for taking appropriate In addition, site chemistry department group data corrective actions when chemistry test review sessions are performed at least quarterly to when these chemistry limits are exceeded.

share information on specific plant chemistry. A This question is resolved.

corporate chemist periodically participates in the data review sessions to provide an independent assessment. Chemistry trends, underlying causes of problems, and results of corrective actions are periodically reviewed with higher levels of line 50

Question and Answer Database Audit and Review Related to the License Renewal Application for James A. Fitzpatrick Nuclear Power plant Applicant's No. Audit Questions Applicants Response Project Team's Evaluations Ref. No.

management.

80 148 The Monitoring and Trending program As described in LRA section B.0.3, JAFNPP quality The project team finds the applicant's element for AMP B.1.29.1 in the LRA states assurance (QA) procedures, review and approval response acceptable because any that values from the analyses are archived for processes, and administrative controls are conditions adverse to quality, such as long term trending and review. Please provide implemented in accordance with the requirements failures, malfunctions, deviations, the following information: of 10 CFR Part 50, Appendix B. Conditions defective material and equipment, and adverse to quality, such as failures, malfunctions, nonconformances, are promptly identified c) Discuss the process to be used to determine deviations, defective material and equipment, and and corrected via the JAFNPP corrective whether corrective actions are required. nonconformances, are promptly identified and action process. This question is resolved.

corrected. In the case of significant conditions adverse to quality, measures are implemented to ensure that the cause of the nonconformance is determined and that corrective action is taken to preclude recurrence.

In addition, the root cause of the significant condition adverse to quality and the corrective action implemented are documented and reported to appropriate levels of management. The implementing procedure for the corrective action process was available for onsite review.

81 149 The Acceptance Criteria program element for The Auxiliary Systems Water Chemistry Control The project team finds the applicant's AMP B.1.29.1 in the LRA provides acceptance Program is based on equipment vendor response acceptable because the basis criteria for the stator cooling water system and specifications, chemical vendor recommendations, documents for the stator cooling water and the aux boiler heating water in accordance with technical manuals, industry standards, and auxiliary boiler heating water systems industry recommendations. Please provide the operating experience. Guidelines utilized include (i.e., EPRI Technical Report 1004004 and following information: EPRI guidelines, as well as vendor and other General Electric Technical Information industry guidelines. Letters, Service Information Letters, and a) Identify the industry documents that are Cleaver Brooks manuals) are consistent used as the basis for the industry Basis documents for stator cooling water with those used in the industry. For other recommendations, and make these available monitoring include EPRI Technical Report 1004004 auxiliary systems the project team for NRC review at the time of the onsite audit. and General Electric Technical Information Letters confirmed that, vendor recommendations, and Service Information Letters. Basis documents technical manuals, industry standards, for auxiliary boiler monitoring include the Cleaver and operating experience are used. This Brooks manuals. question is resolved.

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Question and Answer Database Audit and Review Related to the License Renewal Application for James A. Fitzpatrick Nuclear Power plant Applicant's No. Audit Questions Applicants Response Project Team's Evaluations Ref. No.

82 150 The Acceptance Criteria program element for For control room and relay room chilled water, The project team finds the applicant's AMP B.1.29.1 in the LRA provides acceptance decay heat removal cooling water, and security response acceptable because the criteria for the stator cooling water system and generator jacket cooling water, LRA Section applicant amended LRA Section B.1.29.1 the aux boiler heating water in accordance with B.1.29.1 notes that the program will be enhanced to clarify that industry recommendations industry recommendations. Please provide the prior to the period of extended operation to provide and One-Time Inspection Program results following guidance for sampling and analysis. Industry will be considered in determining the information: recommendations and One-Time Inspection parameters to be monitored, monitoring Program results will be considered in determining frequency, and associated acceptance b) Identify the acceptance criteria for the other the parameters to be monitored, monitoring criteria. In LRA Amendment No. 5, dated auxiliary systems in the scope of this AMP. frequency, and associated acceptance criteria. February 01, 2007, the applicant amended the LRA include Commitmtent No. 18, This requires a LRA amendment. which will require the applicant to enhance the Water Chemistry Control - Auxiliary Systems Program to include sampling and analysis guidance for chilled water, decay heat removal cooling water, and security generator jacket cooling water . This question is resolved.

83 151 The Acceptance Criteria program element for Acceptance criteria are determined by engineering The project team finds the applicant's AMP B.1.29.1 in the LRA provides acceptance evaluation of industry recommendation and response acceptable because the criteria for the stator cooling water system and experience. For instance, the stator cooling water acceptance criteria are determined by the aux boiler heating water in accordance with dissolved oxygen limits were changed in engineering evaluation of industry industry recommendations. Please provide the September 2005 to more conservative values from recommendation and experience.

following information: GE TIL-1098 following the determination that a trip Acceptance criteria are administratively at River Bend was due to having dissolved oxygen controlled via sampling and analysis c) Discuss how the acceptance criteria are limits at 1 ppm for an extended period of time. procedures. This question is resolved.

determined and how they are administratively controlled. Acceptance criteria are administratively controlled via sampling and analysis procedures, which were available for onsite review.

84 152 The Corrective Actions program element for As described in LRA section B.0.3, JAFNPP quality The project team finds the applicant's AMP B.1.29.1 in the LRA states that chemistry assurance (QA) procedures, review and approval response acceptable because it confirms parameters are adjusted as appropriate and processes, and administrative controls are that the applicant's procedures for 52

Question and Answer Database Audit and Review Related to the License Renewal Application for James A. Fitzpatrick Nuclear Power plant Applicant's No. Audit Questions Applicants Response Project Team's Evaluations Ref. No.

that additional sampling and verification are implemented in accordance with the requirements implementing the requirements of 10 CFR performed if necessary. Please discuss the of 10 CFR Part 50, Appendix B. Conditions 50 Appendix B require that any conditions administrative controls that are in place to adverse to quality, such as failures, malfunctions, adverse to quality, such as failures, determine the necessity for these additional deviations, defective material and equipment, and malfunctions, deviations, defective activities and to implement them. nonconformances, are promptly identified and material and equipment, and corrected. In the case of significant conditions nonconformances, be promptly identified adverse to quality, measures are implemented to and corrected via the JAFNPP corrective ensure that the cause of the nonconformance is action process. This question is resolved.

determined and that corrective action is taken to preclude recurrence.

In addition, the root cause of the significant condition adverse to quality and the corrective action implemented are documented and reported to appropriate levels of management. The implementing procedure for the corrective action process is available for onsite review.

85 153 The Operating Experience program element For control room and relay room chilled water, The project team finds the applicant's for AMP B.1.29.1 in the LRA describes decay heat removal cooling water, and security response acceptable because the operating experience for the stator cooling generator jacket cooling water, LRA Section applicant amended LRA Section B.1.29.1 water system conductivity, dissolved oxygen, B.1.29.1 notes that the program will be enhanced to clarify that industry recommendations and copper content and aux boiler heating prior to the period of extended operation to provide and One-Time Inspection Program results water conductivity and pH. These are the same guidance for sampling and analysis. Since these will be considered in determining the parameters and auxiliary systems described in systems are not currently monitored, operating sampling, analysis, and acceptance the Acceptance Criteria subsection of AMP experience providing objective evidence of program criteria. See amendment letter No. 5, B.1.29.1. Please provide the following information: effectiveness for these systems does not exist. dated February 01, 2007. A review of plant operating experience review reports and a) Discuss the operating experience that has This requires a LRA amendment. condition reports indicated that there were been gathered and reviewed for other auxiliary no aging effects identified that are not systems described in the scope of this AMP. bounded by industry operating experience.

This question is resolved.

86 154 The Operating Experience program element For control room and relay room chilled water, The project team finds the applicant's for AMP B.1.29.1 in the LRA describes decay heat removal cooling water, and security response acceptable because the operating experience for the stator cooling generator jacket cooling water, LRA Section applicant amended LRA Section B.1.29.1 water system conductivity, dissolved oxygen, B.1.29.1 notes that the program will be enhanced to clarify that industry recommendations and copper content and aux boiler heating prior to the period of extended operation to provide and One-Time Inspection Program results 53

Question and Answer Database Audit and Review Related to the License Renewal Application for James A. Fitzpatrick Nuclear Power plant Applicant's No. Audit Questions Applicants Response Project Team's Evaluations Ref. No.

water conductivity and pH. These are the same guidance for sampling and analysis. Industry will be considered in determining the parameters and auxiliary systems described in recommendations and One-Time Inspection acceptance criteria or performance the Acceptance Criteria subsection of AMP Program results will be considered in determining parameters. See amendment letter No. 5, B.1.29.1. Please provide the following information: the parameters to be monitored, monitoring dated February 01, 2007. This question is frequency, and associated acceptance criteria. resolved.

b) Discuss the acceptance criteria or This requires a LRA amendment.

performance parameters for other auxiliary systems described in this AMP, and how are they applied to the review of their operating experience.

87 156 The Operating Experience program element The stator cooling water system has continuous in- The project team finds the applicant's for AMP B.1.29.1 in the LRA describes line conductivity meters at the generator inlet and response acceptable because it clarified operating experience for the stator cooling outlet. Although these meters do not have alarms, that JAFNPP has two on-line stator water system conductivity, dissolved oxygen, data from these meters is recorded, trended, and cooling water conductivity monitors but the and copper content and aux boiler heating reviewed periodically. stator cooling water system does not have water conductivity and pH. These are the same continuous monitoring instrumentation or parameters and auxiliary systems described in The stator cooling water system does not have alarms for dissolved oxygen or soluble the Acceptance Criteria subsection of AMP continuous monitoring instrumentation or alarms for copper. The project team confirmed that B.1.29.1. Please provide the following dissolved oxygen or soluble copper. stator cooling water conductivity is information: monitored weekly, while the dissolved oxygen and soluble copper are monitored d) Clarify whether the stator cooling water monthly. This question is resolved.

system has continuous monitoring instrumentation or alarms for conductivity, dissolved oxygen, or other parameters, and whether these additional data are recorded, trended, and reviewed periodically.

88 157 The Program Description for AMP B.1.29.3 in With the exception of systems in the Water The project team finds the applicant's the LRA states that the water chemistry control Chemistry Control - Auxiliary Systems Program, response acceptable because the

- closed cooling water systems program there are no other closed cooling water systems applicant clarified that with the exception includes the following: 1) jacket cooling water with license renewal intended functions at JAFNPP of systems in the Water Chemistry Control subsystem for the emergency diesel generator, in which the water chemistry is controlled, that are - Auxiliary Systems Program, there are no

2) reactor building closed loop cooling, and 3) not subjected to significant sources of other closed cooling water systems with turbine building closed loop cooling. Please contamination, and in which heat is not directly license renewal intended functions at confirm that these are the only closed cooling rejected to a heat sink. JAFNPP. This question is resolved.

water systems at JAFNPP in which the water 54

Question and Answer Database Audit and Review Related to the License Renewal Application for James A. Fitzpatrick Nuclear Power plant Applicant's No. Audit Questions Applicants Response Project Team's Evaluations Ref. No.

chemistry is controlled, that are not subjected to significant sources of contamination, and in which heat is not directly rejected to a heat sink.

89 158 The Program Description for AMP B.1.29.3 in As noted in LRA section B.1.29.3, the JAFNPP The project team finds the applicant's the LRA states that the program includes Water Chemistry Control - Closed Cooling Water response acceptable because the preventive measures that manage loss of Program takes exception to the recommended applicant clarified that the program is material, cracking, and fouling for components performance and functional testing, with the based on EPRI Report TR-1007820 in closed cooling water systems. As described following justification. (Revision 1 to EPRI TR-107396). From a in NUREG-1801, Rev. 1,Section XI.M21, review of the EPRI report the project team CCCW system aging management programs While NUREG-1801,Section XI.M21, Closed-Cycle confirmed that the report does not monitor the effects of corrosion and SCC by Cooling Water System endorses EPRI report TR- recommend that performance and testing and inspection. Please describe the 107396 for performance and functional testing functional testing be part of the water testing and inspection activities utilized at guidance, EPRI report TR-107396 does not chemistry control program. The lack of JAFNPP to monitor the effects of corrosion and recommend that equipment performance and performance and functional testing, SCC on closed cooling water systems functional testing be part of a water chemistry however, is not consistent with GALL.

components. control program. This is appropriate since The applicant has taken an exception to monitoring pump performance parameters is of the GALL Report program elements little value in managing effects of aging on long- parameters monitored or inspected, and lived, passive CCW system components. Rather, detection of aging effects and has EPRI report TR-107396 states in section 5.7 provided an adequate technical basis to (Section 8.4 in EPRI report 1007820) that support this exception. This question is performance monitoring is typically part of an resolved.

engineering program, which would not be part of water chemistry. In most cases, functional and performance testing verifies that component active functions can be accomplished and as such would be governed by the maintenance rule (10 CFR 50.65). For example, loss of material cannot be detected by system performance testing. Passive intended functions of pumps, heat exchangers and other components will be adequately managed by the Closed Cooling Water Chemistry and One-Time Inspection programs through monitoring and control of water chemistry parameters and verification of the absence of aging effects.

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Question and Answer Database Audit and Review Related to the License Renewal Application for James A. Fitzpatrick Nuclear Power plant Applicant's No. Audit Questions Applicants Response Project Team's Evaluations Ref. No.

Corrosion coupons are used to monitor the effects of corrosion on the reactor building and turbine building closed loop cooling systems.

In addition, LRA section B.1.21, One-Time Inspection, describes inspections planned to verify effectiveness of the water chemistry control programs to ensure that significant degradation is not occurring and component intended function is maintained during the period of extended operation.

90 159 The Program Description for AMP B.1.29.3 in The EPRI document used as guidance is EPRI The EPRI Report 1007820 used as the LRA states that the activities for monitoring Report 1007820, Closed Cooling Water Chemistry guidance for this program is acceptable and controlling closed cooling water chemistry Guideline (TR-107396, Rev. 1). EPRI Report since the activities are consistent with using JAFNPP procedures and processes are 1007820, Closed Cooling Water Chemistry GALL AMP XI.M21. This question is based on EPRI guidance for closed cooling Guideline (TR-107396, Rev. 1) was available for resolved.

water chemistry. Please identify the EPRI onsite review.

documents used as guidance and make them available for NRC review at the time of the onsite audit.

91 160 With regard to AMP B.1.29.3, provide the As indicated in LRA section B.1.29.3, the Water The project team finds the applicant's following details of the JAFNPP closed cooling Chemistry Control - Closed Cooling Water response acceptable because the water aging management program: Program is consistent with the program described parameters monitored and frequencies are in NUREG-1801,Section XI.M21, Closed-Cycle consistent with those recommended in a) Identify the parameters monitored for each of Cooling Water System, with one exception related EPRI Report 1007820 and GALL AMP the closed cooling water systems in the to performance and functional testing. XI.M21 recommendations. This question program, the sampling and testing frequencies, is resolved.

and how these are determined. Sampling and testing frequencies are documented in Chemistry procedures SP-01.25, Reactor Building Closed Loop Cooling Sampling and Analysis, RT-01.15, Turbine Building Closed Loop Cooling Sampling and Analysis, and SP-01.23, Diesel Fire Pump Emergency Diesel Generator Coolant Corrosion Inhibitor Sampling and Analysis.

These procedures were available for onsite review.

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Question and Answer Database Audit and Review Related to the License Renewal Application for James A. Fitzpatrick Nuclear Power plant Applicant's No. Audit Questions Applicants Response Project Team's Evaluations Ref. No.

The parameters monitored and frequencies are those recommended in EPRI Report 1007820.

92 161 With regard to AMP B.1.29.3, provide the Acceptance criteria are identified in Chemistry The project team finds the applicant's following details of the JAFNPP closed cooling procedures SP-01.25, Reactor Building Closed response acceptable because the water aging management program: Loop Cooling Sampling and Analysis, RT-01.15, parameters monitored and frequencies are Turbine Building Closed Loop Cooling Sampling consistent with those recommended in b) Identify the acceptance criteria for the and Analysis, and SP-01.23, Diesel Fire Pump EPRI Report 1007820 and GALL AMP monitored parameters and how these are Emergency Diesel Generator Coolant Corrosion XI.M21 recommendations. This question determined. Inhibitor Sampling and Analysis. These procedures is resolved.

were available for onsite review. The acceptance criteria are those recommended in EPRI Report 1007820.

93 162 With regard to AMP B.1.29.3, provide the The parameters trended are those recommended The project team finds the applicant's following details of the JAFNPP closed cooling in EPRI Report 1007820. response acceptable because the water aging management program: parameters monitored and frequencies are See the response for item # 163 for additional consistent with those recommended in c) Describe which of the parameters are details. EPRI Report 1007820 and GALL AMP trended for each of the closed cooling water XI.M21 recommendations. This question systems in the program. is resolved.

94 163 With regard to AMP B.1.29.3, provide the In accordance with Entergy corporate procedure The project team finds the applicant's following details of the JAFNPP closed cooling EN-CY-101, Chemistry Activities, the chemistry response acceptable because Entergy water aging management program: department trends chemistry and radiochemistry Corporate procedure EN-CY-101 parameters to allow identification and correction of describes the administrative controls and d) Describe the administrative controls and adverse trends before limits are exceeded. Data is procedures used to implement periodic procedures used to implement periodic review reviewed as it is generated, and appropriate review and trending of water chemistry and trending of water chemistry parameters comments are made as necessary to document parameters and to determine what and to determination what corrective actions reasons for adverse data indications. The site corrective actions are required. This are required. chemistry staff reviews the data trends to ensure question is resolved.

adverse indications are noted and addressed in a timely manner. In addition, site chemistry department group data review sessions are performed at least quarterly to share information on specific plant chemistry. A corporate chemist periodically participates in the data review sessions 57

Question and Answer Database Audit and Review Related to the License Renewal Application for James A. Fitzpatrick Nuclear Power plant Applicant's No. Audit Questions Applicants Response Project Team's Evaluations Ref. No.

to provide an independent assessment. Chemistry trends, underlying causes of problems, and results of corrective actions are periodically reviewed with higher levels of line management.

95 164 With regard to AMP B.1.29.3, provide the Corrosion inhibitor concentrations outside allowable The project team finds the applicant's following details of the JAFNPP closed cooling limits are returned to acceptable range utilizing response acceptable because the water aging management program: chemical additions or feed and bleed. The TBCLC applicant has clarified that when and RBCLC systems have a demineralizer parameters are outside the allowable e) Describe the initiation and implementation of available, along with feed and bleed, to remove range, the problems are identified and the corrective action process for bringing water system contaminants. Both systems have an corrected in accordance with the chemistry parameters back within the limits of oxygen addition and oxygen removal skids applicant's corrective action program. This the acceptance criteria specified by the available to control levels of dissolved oxygen. question is resolved.

program. Corrective actions are taken in accordance with 10 CFR Part 50, Appendix B; EPRI Report 1007820 (TR-107396 Rev. 1); and the JAFNPP corrective action program.

96 165 The Exceptions to NUREG-1801' subsection The Water Chemistry Control-Closed Cooling The project team finds the applicants for AMP B.1.29.3 in the LRA states that the Water Program includes monitoring and control of response acceptable because it clarified JAFNPP water chemistry control - closed water chemistry to minimize exposure to that the closed cooling water chemistry cooling water program does not include aggressive environments and corrosion inhibitors AMP includes sufficient activities to performance and functional testing. As for the emergency diesel generator closed cooling monitor and control closed cooling water described in NUREG-1801, Rev. 1, Section water to manage general, crevice, and pitting chemistry and is adequate to manage the XI.M21, program element 3 for Parameters corrosion, as well as SCC. Corrosion coupons are aging effects for which it is credited.

Monitored/Inspected states that the aging used to monitor the effects of corrosion on the Monitoring and control of water chemistry management program monitors the effects of reactor building and turbine building closed loop parameters to minimize exposure to corrosion and SCC by testing and inspection to cooling systems. aggressive environments are controlled by evaluate system and component condition. plant-specific procedures and processes Further, element 4 for Detection of Aging As noted in LRA section B.1.29.3, the JAFNPP that are based on EPRI guidance for Effects states that control of chemistry does not Water Chemistry Control - Closed Cooling Water closed cooling water systems. In addition, preclude corrosion or SCC at locations of Program takes exception to the recommended LRA section B.1.21, One-Time Inspection, stagnant flow conditions or crevices and that performance and functional testing, with the describes inspections planned to verify the extent and schedule of inspections and following justification. effectiveness of the water chemistry testing should assure detection of corrosion or control programs to ensure that significant SCC before the loss of the intended function of While NUREG-1801,Section XI.M21, Closed-Cycle degradation is not occurring and the component. Please provide the technical Cooling Water System endorses EPRI report TR- component intended function is justification for concluding that water chemistry 107396 for performance and functional testing maintained during the period of extended 58

Question and Answer Database Audit and Review Related to the License Renewal Application for James A. Fitzpatrick Nuclear Power plant Applicant's No. Audit Questions Applicants Response Project Team's Evaluations Ref. No.

control alone is sufficient to assure detection of guidance, EPRI report TR-107396 does not operation. This question is resolved.

corrosion or SCC before the loss of the recommend that equipment performance and intended function of the component or system. functional testing be part of a water chemistry Also, please discuss the administrative controls control program. This is appropriate since or procedures that are in place to evaluate and monitoring pump performance parameters is of initiate corrective actions in the closed cooling little value in managing effects of aging on long-water chemistry aging management program lived, passive CCW system components. Rather, based on the results of inspections or other EPRI report TR-107396 states in section 5.7 means for the detection of aging resulting from (Section 8.4 in EPRI report 1007820) that corrosion and SCC. performance monitoring is typically part of an engineering program, which would not be part of water chemistry. In most cases, functional and performance testing verifies that component active functions can be accomplished and as such would be governed by the maintenance rule (10 CFR 50.65). For example, loss of material cannot be detected by system performance testing. Passive intended functions of pumps, heat exchangers and other components will be adequately managed by the Closed Cooling Water Chemistry and One-Time Inspection programs through monitoring and control of water chemistry parameters and verification of the absence of aging effects.

In addition, LRA section B.1.21, One-Time Inspection, describes inspections planned to verify effectiveness of the water chemistry control programs to ensure that significant degradation is not occurring and component intended function is maintained during the period of extended operation.

As described in LRA section B.0.3, JAFNPP quality assurance (QA) procedures, review and approval processes, and administrative controls are implemented in accordance with the requirements of 10 CFR Part 50, Appendix B. Conditions adverse to quality, such as failures, malfunctions, deviations, defective material and equipment, and 59

Question and Answer Database Audit and Review Related to the License Renewal Application for James A. Fitzpatrick Nuclear Power plant Applicant's No. Audit Questions Applicants Response Project Team's Evaluations Ref. No.

nonconformances, are promptly identified and corrected. In the case of significant conditions adverse to quality, measures are implemented to ensure that the cause of the nonconformance is determined and that corrective action is taken to preclude recurrence. In addition, the root cause of the significant condition adverse to quality and the corrective action implemented are documented and reported to appropriate levels of management.

The implementing procedure for the corrective action process are available for onsite review.

97 166 The Operating Experience subsection for AMP Loss of piping material was calculated from The project team finds the applicant's B.1.29.3 in the LRA describes operating corrosion studies on coupons of base metals that response acceptable because the experience for the RBCLC system where low were indicative of metals in the RBCLC system. applicant adequately described how a loss levels of dissolved oxygen in the piping caused The type of iron oxide found and the quantity of of material in system piping was attributed loss of material in system piping. An oxygen filterable iron in the RBCLC system indicated that to low levels of dissolved oxygen in the injection system was installed in August 2003 low oxygen levels in the system were contributing system water. This question is resolved.

to correct this problem. Please provide the to a magnetite iron oxide and not the protective following information: layer of iron oxide that was desirable.

a) Discuss how the loss of piping material was detected and how it was linked to the low levels of dissolved oxygen in the system water.

98 167 The Operating Experience subsection for AMP Administrative controls or procedures are in place The project team finds the applicant's B.1.29.3 in the LRA describes operating to correlate physical inspections and tests to water response acceptable because the experience for the RBCLC system where low chemistry on a periodic basis. Periodic chemistry applicant clarified the administrative levels of dissolved oxygen in the piping caused monitoring of corrosion coupons, dissolved oxygen controls or procedures that are in place to loss of material in system piping. An oxygen and iron concentration in the RBCLC water were correlate physical inspections and tests to injection system was installed in August 2003 particularly useful in this case. In accordance with water chemistry on a periodic basis.

to correct this problem. Please provide the Entergy corporate procedure EN-CY-101, Specifically, Entergy corporate procedure following information: Chemistry Activities, the chemistry department EN-CY-101, Chemistry Activities, requires periodically assesses corrosion/deposition the chemistry department to periodically b) Clarify whether this was a special inspection conditions in plant systems by direct inspections, assess corrosion/deposition conditions in or whether administrative controls or test coupons, microbiological sampling, computer plant systems by direct inspections, test procedures are in place to correlate physical modeling or other means. coupons, microbiological sampling, 60

Question and Answer Database Audit and Review Related to the License Renewal Application for James A. Fitzpatrick Nuclear Power plant Applicant's No. Audit Questions Applicants Response Project Team's Evaluations Ref. No.

inspections and tests to water chemistry on a computer modeling or other means. This periodic basis. question is resolved.

99 169 The Operating Experience subsection for AMP Corrosion coupons installed in the TBCLC water The project team finds the applicant's B.1.29.3 in the LRA describes operating during periods of high dissolved oxygen response acceptable because the experience for the TBCLC system where high concentration had pits on the surface. Unlike the applicant described how it detects pitting dissolved oxygen concentration in the piping corrosion coupons, the system piping has a corrosion in carbon steel material and its caused pitting corrosion in carbon steel. An protective iron oxide layer, and therefore may not link to the high concentrations of dissolved oxygen removal skid was installed and system have experienced pitting. oxygen in the system water. This question leaks were repaired to lower the dissolved is resolved.

oxygen concentration. Please provide the following information:

a) Discuss how the pitting corrosion in carbon steel material was detected and how it was linked to the high concentrations of dissolved oxygen in the system water.

100 170 The Operating Experience subsection for AMP Administrative controls or procedures are in place The project team finds the applicant's B.1.29.3 in the LRA describes operating to correlate physical inspections and tests to water response acceptable because the experience for the TBCLC system where high chemistry on a periodic basis. For additional details applicant clarified the administrative dissolved oxygen concentration in the piping see response to item # 99. controls or procedures that are in place to caused pitting corrosion in carbon steel. An correlate physical inspections and tests to oxygen removal skid was installed and system In accordance with Entergy corporate procedure water chemistry on a periodic basis.

leaks were repaired to lower the dissolved EN-CY-101, Chemistry Activities, the chemistry Specifically, Entergy corporate procedure oxygen concentration. Please provide the department periodically assesses EN-CY-101, Chemistry Activities, requires following information: corrosion/deposition conditions in plant systems by the chemistry department to periodically direct inspections, test coupons, microbiological assess corrosion/deposition conditions in b) Clarify whether this was the result of a sampling, computer modeling or other means. plant systems by direct inspections, test special inspection or whether administrative coupons, microbiological sampling, controls or procedures are in place to correlate computer modeling or other means. This physical inspections and tests to water question is resolved.

chemistry on a periodic basis.

101 172 With regard to AMP B.1.11, please discuss Surfaces that are not readily visible due to The project team finds the applicant's how surfaces that are not readily visible and radiological, safety, security or other considerations response acceptable because surfaces insulated will be handled under this program. are inspected when plant conditions permit such as that are not readily visible due to 61

Question and Answer Database Audit and Review Related to the License Renewal Application for James A. Fitzpatrick Nuclear Power plant Applicant's No. Audit Questions Applicants Response Project Team's Evaluations Ref. No.

refueling outages. Surfaces that are inaccessible or radiological, safety, security or other not readily visible during both plant operations and considerations are inspected when plant refueling outages are inspected at such intervals conditions permit such as refueling that would provide reasonable assurance that the outages and maintenance. Specifically, effects of aging will be managed such that the applicant states that surfaces that are applicable components will perform their intended inaccessible during plant operations are function during the period of extended operation. inspected during refueling outages.

Surfaces that are inaccessible or not Surfaces that are insulated are inspected when the readily visible during both plant operations external surface is exposed (i.e., maintenance) at and refueling outages are inspected at such intervals that would provide reasonable intervals which provide reasonable assurance that the effects of aging will be managed assurance that the effects of aging will be such that applicable components will perform their appropriately managed Surfaces that are intended function during the period of extended insulated are inspected when the external operation. surface is exposed (i.e., maintenance) at intervals that provide reasonable assurance that the effects of aging will be adequately managed. This question is resolved.

102 173 Please confirm that AMP B.1.11 includes Yes, the condition of coatings is inspected. During The project team finds the applicant's confirmation of the integrity of any paint or system inspections, visual inspections identify response acceptable because visual coatings that are used on the surface of items which could affect system performance, observations of coatings during periodic components. safety, or reliability as well as general system inspections and walkdowns are housekeeping, personnel safety hazards and governed by procedures which provide radiological concerns. Examples of parameters guidance for identifying indications of inspected are possible degradation which could affect

• condition and placement of coatings, system performance, safety, or reliability.

• evidence of corrosion, and This is consistent with GALL AMP XI.M38

• indications of leakage. recommendations. This question is This is discussed in Parameters resolved.

Monitored/Inspected in the NUREG-1801,Section XI.M38 program description. The JAF AMP is consistent with the NUREG-1801 AMP with no exceptions.

103 174 Please discuss the frequency of inspections for System inspections are conducted at least once per The project team finds the applicant's the various applications described in AMP refueling cycle and are normally performed more response acceptable because system 62

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B.1.11 and the basis for these frequencies. frequently. This frequency is acceptable since aging inspections are conducted at least once per effects are typically caused by long term refueling cycle and are normally performed degradation mechanisms such as corrosion. more frequently and inspections Surfaces that are inaccessible or not readily visible frequencies are adjusted as necessary during plant operations and refueling outages are based on plant-specific inspection results inspected at such intervals that would ensure the and industry experience. This is consistent components intended function is maintained. The with GALL AMP XI.M38 recommendations.

intervals of inspections may be adjusted as This question is resolved.

necessary based on plant-specific inspection results and industry experience. In addition, all plant personnel are required to identify adverse conditions via the corrective action process. Since adverse conditions include those which the system walkdowns are intended to manage, aging effects may be identified through routine operations and maintenance activities.

104 176 Please discuss the monitoring and trending This is discussed in Monitoring and Trending in The project team finds the applicant's activities to be implemented under AMP B.1.11 the AMPER LRD-02, Section 4.10. Acceptance response acceptable because the project including the acceptance criteria to be used for criteria are discussed under Acceptance Criteria team confirmed that visual inspection each component/aging effect to be managed by in the AMPER LRD-02, Section 4.10. activities are governed by site controlled AMP B.1.11. procedures and processes. Engineering Monitoring and Trending: evaluations of visual indications of leakage or loss of material consider Visual inspection activities are performed and procedural requirements, current licensing associated personnel are qualified in accordance basis, industry codes, and standards to with site controlled procedures and processes. The ensure that the need for corrective actions External Surfaces Monitoring Program uses is identified before loss of intended standardized monitoring and trending activities to functions. This is consistent with GALL track degradation. Deficiencies are documented so AMP XI.M38 recommendations. This that results can be trended. question is resolved.

Acceptance Criteria:

Engineering evaluations of visual indications of leakage or loss of material consider procedural requirements, current licensing basis, industry 63

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codes, and standards to ensure that the need for corrective actions is identified before loss of intended functions.

105 177 With regard to the Enhancement for AMP a) The guidance documents were available on site The project team finds the applicant's B.1.11, please identify a) the guidance for review. b) As stated in the enhancement, response acceptable because the documents that will be enhanced, b) the Inspections shall include areas surrounding the enhancement will add a requirement to components that will be affected, and c) the subject systems to identify hazards to those the existing plant guidance documents to aging effects that will be addressed by the systems. Inspections of nearby systems that could include areas surrounding the subject enhancement. impact the subject systems will include SSCs that systems to identify hazards to those are in scope and subject to aging management systems. Adding a requirement to inspect review for license renewal in accordance with 10 surrounding areas will provide assurance CFR 54.4 (a)(2). c) The aging effect will be loss of that no hazards exist and will make the material. AMP consistent with the recommendations in the GALL Report.

This question is resolved.

106 178 The FSAR supplement for AMP B.1.11 in Section A.2.1 of the LRA states, All aging The project team finds the applicant's Section A.2.1.11 of the LRA does not discuss management programs will be implemented prior to response acceptable because the the commitment to implement the enhancement entering the period of extended operation. This applicant agreed to amend LRA Section includes enhancements to individual programs.

to this program prior to the period of extended operation. A.2.1.11 to provide a clearer description of the program enhancement and to include Please revise the FSAR supplement to discuss For additional clarification, LRA Appendix A will be a commitment to implement the this commitment. revised as follows: enhancement prior to the period of extended operation. The project team Section A.2.1.11, External Surfaces Monitoring, add reviewed the applicants proposed The program guidance documents will be clarification provided in its response and enhanced to include periodic inspections of determined that it is acceptable. This systems in scope and subject to aging question is resolved.

management review in accordance with 10 CFR 54.4(a)(1) and (a)(3). Inspections shall include areas surrounding the subject systems to identify hazards to those systems. Inspections of nearby systems that could impact the subject systems will include SSCs that are in scope and subject to aging management review in accordance with 10 CFR 54.4(a)(2). These enhancements will be implemented prior to the period of extended 64

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operation. This requires a LRA Amendment.

107 179 In LRA Section B.1.15, the Program Internal and external operating experience means The project team finds the applicant's Description states that representative tubes JAFNPP site and industry operating experience. response acceptable because the within the sample population of heat The following is an example of the steps which may inspection plan for heat exchangers will exchangers will be eddy current tested at a be used to develop the inspection plan: specify the inspection frequency based on frequency determined by internal and external 1. An initial visual inspection would be performed of baseline testing and plant-specific and operating experience. Please clarify what is the sample population of in scope heat industry operating experience. This meant by internal and external operating exchangers. This inspection would document the question is resolved.

experience. Also, please discuss a) the rational as-found conditions. Additional examination to be used in determining the inspection methods may be used if as-found conditions frequency using plant-specific and industry warrant, (i.e. ultrasonic thickness measurements or operating experience, and b) the anticipated radiography). The results of these inspections minimum inspection frequency to be imposed would be used to establish the frequency of future to ensure timely detection of aging effects. inspections.

2. Where physically accessible, baseline eddy current data would be obtained. The results of these tests would be used to determine the frequency of future inspections and the number of tubes to be sampled.

108 180 In LRA Section B.1.15, the discussion of (a) Practicality is dependant on physical location, The project team finds the applicant's Parameters Monitored program element physical size, orientation, physical dimensions, response acceptable because the states that, where practical, eddy current accessibility and disassembly of heat exchanger. applicant has clarified that eddy current inspections of shell-and-tube heat exchanger testing will be performed when practical as tubes will be performed to determine tube wall (b) If eddy current inspection is determined to be determined by the tubes physical location, thickness. Please discuss the criteria for impractical aging of tube is managed based on the physical size, orientation, physical determining practicality for eddy current results of: dimensions, accessibility and disassembly inspections. Also, please discuss how aging of of the heat exchangers. If eddy current tubes for heat exchangers in the scope of this 1. Visual inspection of the external portion of heat inspection is determined to be impractical, AMP will be managed when it is determined exchanger tubes is conducted during maintenance aging of the heat exchanger tubes will be that eddy current inspection is impractical. activities when eddy current inspections are not managed using visual inspection of the practical. This inspection is focused on detecting external portion of heat exchanger tubes, the extent of tube erosion, corrosion, fouling and which is conducted during maintenance scaling, and on the detection of corrosion at the activities and is focused on detecting the tube sheet and rolled tube joints. And/or extent of tube erosion, corrosion, fouling and scaling, and on the detection of

2. Pressure/Leak testing is another method that corrosion at the tubesheet and rolled tube 65

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can be used when eddy current is impractical. This joints. Visual inspections of heat task is focused on finding leaks in cracked tubes exchanger components with the same and in defects at the tube joints. material/ environment combination as the tubes will also provide information that can These defects may be caused by improper be used to determine if degradation is installation, abusive transients, by plugging of occurring, and whether further action is tubes, and also by improper cleaning in the case of needed to manage aging. This question is rolled tube joints. resolved.

109 181 In LRA Section B.1.15, the discussion of Visual inspections is focused on detecting the The project team finds the applicant's Parameters Monitored program element extent of tube erosion, corrosion, fouling and response acceptable because the heat states that visual inspections will be performed scaling, and on the detection of corrosion at the exchangers within the scope of this on heat exchanger heads, covers, and tube sheet and rolled tube joints. In some cases, program s have tubes constructed of tubesheets where accessible to monitor surface heat exchanger heads, partition plates, baffles, copper alloy that are exposed to lube oil or condition for indications of loss of material. covers, or tubesheets are of the same material treated water on the external surface. The Since this AMP is credited to manage loss of environment combination as tubes, which provides aging effect of concern for these material-wear on the external surface of heat additional data for determining inspection components is loss of material due to exchanger tubes, please clarify how the visual frequency and the presence of aging effects. wear. The applicant has clarified that eddy inspections described will help to manage the current testing will be performed when aging effects for which it is credited in the LRA. practical. For cases where eddy current inspection is determined to be impractical, aging of the heat exchanger tubes will be managed using visual inspection of the external portion of heat exchanger tubes.

Visual inspections are conducted during maintenance activities and are focused on detecting the presence and extent of a loss of material. Based on its review, the project team has determined that the applicants use of wall thickness via eddy current testing, or indications of loss of material via visual inspection as the parameters to be monitored will provide an effective method of detecting degradation of heat exchanger tubes. This question is resolved.

110 182 In LRA Section B.1.15, the discussion of (a) The sample population of heat exchangers will 66

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Detection of Aging Effects program element be determined based on the materials of The project team finds the applicant's states that representative tubes within the construction of the heat exchanger tubes and the response acceptable because at least one sample population of heat exchangers will be associated environments as well as the type of heat exchanger of each type, material, eddy current tested. Please discuss a) the heat exchanger (for example, shell and tube type). and environment combination will be rational to be used in determining the sample At least one heat exchanger of each type, material included in the sample population. This population, and b) the rational to be used for and environment combination will be included in ensures that potential impacts of different selecting representative tubes within the the sample population. This ensures that potential design, material and environment sample population. impacts of different design, material and combinations will be addressed.

environment combinations will be addressed. Representative tubes within the heat exchanger sample population will be (b) Representative tubes within the heat exchanger selected based on previous eddy current sample population will be selected based on inspections, work order history, such as previous eddy current inspections, WO history such corrective maintenance, tube plugging as corrective maintenance, tube plugging history, history, engineering evaluation, EPRI engineering evaluation, EPRI guidance and service guidance, and service conditions of the condition of the heat exchanger. The sample tubes heat exchanger. The applicants rational are considered on locations in the bundle most for sample selection provides assurance prone to discovering mechanistic failures such as that the leading indicators of degradation pitting, tube erosion, and lagging vibration wear/fret will be inspected. This question is damage. resolved.

111 183 In LRA Section B.1.15, the discussion of Eddy Current test inspections are done according The project team finds the applicant's Detection of Aging Effects program element to the code requirements of ASME Section V, response acceptable because eddy states that representative tubes within the Article 8, 1980 and 1989 editions. Vendor who current test inspections are done in sample population of heat exchangers will be provides services uses digital data acquisition with accordance with established industry eddy current tested. Please discuss the data offline analysis. standards (ASME Section V, Article 8, collection techniques that will be implemented 1980 and 1989 editions). This question is for this AMP. resolved.

112 185 In LRA Section B.1.15, the discussion of As stated in Section 3.2 of JAF-RPT-05-LRD02, The project team finds the applicant's Operating Experience program element states the Heat Exchanger Monitoring Program manages response acceptable because a review of that the Heat Exchanger Monitoring Program at loss of material for copper alloy heat exchanger plant-specific operating experience did not JAFNPP is a new program. Please discuss the tubes in the lube oil subsystems of the HPCI pump identify any failures or degradation of heat JAFNPP specific operating experience with the turbine and EDG engine. Of these components exchangers within the scope of this AMP.

heat exchangers for which this AMP is credited only the HPCI turbine lube oil cooler has been This performance history confirms that the to manage aging, including any degradation or inspected. These inspections occurred in 1998 and components within the scope of this failures that resulted in corrective actions. 2006 and detected no evidence of degradation. A program are not experiencing aging 67

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review of site condition reports and records did not effects not bounded by industry operating document any failures on these heat exchangers. experience. This question is resolved.

113 186 The FSAR supplement for AMP B.1.15 in Section A.2.1 of the LRA states, All aging The project team finds the applicant's Section A.2.1.16 of the LRA does not discuss management programs will be implemented prior to response acceptable because the the commitment to implement this new program entering the period of extended operation. This applicant has amended LRA Section prior to the period of extended operation. includes the Heat Exchanger Monitoring Program. A.2.1.16 to state that this program will be Please revise the FSAR supplement to discuss implemented prior to the period of this commitment. For additional clarification, LRA Appendix A will be extended operation.

revised as follows. Section A.2.1.16, Heat See amendment letter No. 5, dated Exchanger Monitoring Program, add February 01, 2007. This question is resolved.

This program will be implemented prior to the period of extended operation.

This requires a LRA amendment.

114 187 The description of AMP B.1.28 in the LRA As indicated in LRA Table 3.1.2-2, the CASS The project team finds the applicant's states that this is a new program and will be components in the scope of this program are: response acceptable because the fully implemented prior to the period of

• Control rod guide tubes (bases) exposed to an applicant has appropriately identified the extended operation. Please provide a list of environment of Treated water > 482 F and neutron RVI cast austenitic stainless steel (CASS)

CASS components in the primary pressure fluence. components that are within the scope of boundary and RVI that are in the scope of this

• Fuel support pieces (orificed supports) exposed this AMP and consistent with the line AMP, and the screening criteria that will be to an environment of Treated water > 482 F and items in the corresponding AMR Table.

used to determine the susceptibility of CASS neutron fluence. Therefore, the project team determined components exposed to thermal and neutron

• Jet pump castings (transition piece, inlet that the scope of this program is embrittlement. elbow/nozzle, mixer adapter, restrainer bracket, consistent with the GALL AMP XI.M13.

diffuser collar) exposed to an environment of This question is resolved.

Treated water > 482 F and neutron fluence.

As stated in LRA Section B.1.28, the Thermal Aging and Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel (CASS) Program at JAFNPP is a new program that will be consistent with the program described in NUREG-1801,Section XI.M13. As a program that is consistent with NUREG-1801, the screening criteria (casting 68

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method, molybdenum content, and ferrite content) given in Section XI.M13, Scope of the Program, apply to the JAFNPP program for determining susceptibility to thermal aging.

Components exposed to more that 1E17 n/cm2 (E>1MeV) over the life of the plant will be included in the program as susceptible to neutron irradiation embrittlement.

115 189 In NUREG-1801, the discussion in the Since the Thermal Aging and Neutron Irradiation The project team finds the applicants Detection of Aging Effects program element Embrittlement of Cast Austenitic Stainless Steel response to be acceptable because the for AMP XI.M13 notes that for reactor vessel (CASS) Program at JAFNPP is a new program, the applicant has clarified that:(1) this is a new internal CASS components that have a neutron list of components for which a supplemental AMP which will be implemented during the fluence of greater than 10E17 n/cm2 or are examination will be used has not yet been period of extended operation, as determined to be susceptible to thermal established. One example of a supplemental committed to in LRA Commitment No. 17, embrittlement, an applicant can implement examination for those components that require which was provided in amendment No. 9, either (a) a supplemental examination of the inspection is an enhanced visual examination dated 04/06/2007, (2) because this is a affected component as part of a 10-year ISI (EVT-1) capable of detecting 0.0005 inch new AMP, there are no CASS or high program during the license renewal period, or resolution. fluence RVI components that have been (b) a component specific evaluation to evaluated in accordance with a determine the components susceptibility to supplemental fracture toughness loss of fracture toughness. Please provide the assessment at this time, and (3) any following information: inspections of impacted CASS or high fluence RVI components would be done a) Identify any components for which a by an EVT-1 visual method capable of supplemental examination is used, and detecting a 0.0005 inch crack. This is describe what kind of supplemental inspection consistent with the criteria in GALL AMP will be used for detecting the critical flaw size XI.M13 and is acceptable. This question is with adequate margin resolved.

116 190 In NUREG-1801, the discussion in the Since the Thermal Aging and Neutron Irradiation The project team finds the applicants Detection of Aging Effects program element Embrittlement of Cast Austenitic Stainless Steel response to be acceptable because the for AMP XI.M13 notes that for reactor vessel (CASS) Program at JAFNPP is a new program, the applicant has clarified that:(1) this is a new internal CASS components that have a neutron list of components for which a component specific AMP which will be implemented during the fluence of greater than 10E17 n/cm2 or are evaluation will be used has not been developed. period of extended operation, as determined to be susceptible to thermal Component-specific evaluations will be in committed to in LRA Commitment No. 17, embrittlement, an applicant can implement accordance with guidance in NUREG-1801, which was provided in amendment No. 9, 69

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either (a) a supplemental examination of the Section XI.M13. dated 04/06/2007, (2) because this is a affected component as part of a 10-year ISI new AMP, there are no CASS or high program during the license renewal period, or fluence RVI components that have been (b) a component specific evaluation to evaluated in accordance with a determine the components susceptibility to supplemental fracture toughness loss of fracture toughness. Please provide assessment at this time, and (3) any the following information: subsequent supplemental component-specific fracture toughness assessments b) Identify any components for which a will be implemented in accordance with component specific evaluation is used, and the guidance in GALL AMP XI.M13.

discuss the methodology that will be used to demonstrate adequate toughness of the embrittled material. This is consistent with the criteria in GALL AMP XI.M13 and is acceptable. This question is resolved.

117 191 In NUREG-1801, the discussion in the Flaws found by supplemental inspections will be The project team finds the applicants Acceptance Criteria program element for AMP evaluated in accordance with the ASME Boiler and response to be acceptable because the XI.M13 notes that flaws detected in CASS Pressure Vessel Code, Section IWB-3500. Flaw applicant has clarified that the flaw components are evaluated in accordance with evaluation for CASS components with up to 25% evaluation procedure to be used for CASS the applicable procedures of IWB-3500/3600 or ferrite content will be in accordance with ASME components with detected flaws is IWC-3500/3600. Please confirm that the flaw Sections IWB-3640 and IWB-3641. Flaw evaluation consistent with the NUREG-1801 evaluation procedure to be used for CASS for CASS components with >25% ferrite content recommendations. This question is components with detected flaws is consistent will be developed on a case-by-case basis using resolved.

with the NUREG-1801 recommendations. fracture toughness data. This is consistent with NUREG-1801 recommendations.

118 194 With regard to AMP B.1.28, please discuss The CASS program comparable to NUREG-1801 The project team finds the applicants JAFNPP-specific operating experience with Section XI.M13 is applicable only to the reactor response to be acceptable because the CASS components in the scope of this AMP. vessel internals. The identified CASS components applicant has clarified that there are no of the internals (control rod guide tube, fuel support site-specific operating experience exists pieces, and pieces of the jet pump assemblies) are for the components in the scope of this not subject to ISI, so there are no ISI results to new program. This program will be date. No other JAFNPP site operating experience consistent with GALL AMP XI.M13 when exists for the components in the scope of this new developed and any future operating program. experience and lessons learned will be factored into this program through the applicant's corrective action process. This 70

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question is resolved.

119 198 The program description for AMP B.1.27.1 in In performing the IPA for license renewal, Entergy The project team finds the applicant's the JAFNPP LRA does not indicate that this compared the JAFNPP masonry wall program to response acceptable, because the program includes all of the guidance provided the acceptable masonry wall program described in applicants program is consistent with in I.E. Bulletin 80-11, Masonry Wall Design, NUREG-1801,. The program attributes were GALL AMP XI.S5 , as confirmed by the and Information Notice 87-67, Lessons learned specifically compared to the ten elements of the project teams review of Aging from Regional Inspections of Licensee Actions program described in NUREG-1801,Section XI.S5, Management Program Evaluation Report in Response to I.E. 80-11." Please describe Masonry Wall Program. As stated in the Abstract of LRD-02. This question is resolved.

how you incorporated these guidance in the NUREG-1801, an applicant may reference the program. Also, provide the visual examination GALL report in a license renewal application to frequency for the program and its technical demonstrate that the programs at the applicants basis. facility correspond to those reviewed and approved in the GALL report and that no further staff review is required. As indicated in Aging Management Program Evaluation Report LRD-02, Section 4.21.2, Operating experience shows that this program has been effective in managing aging effects. I.E. Bulletin 80-11 block walls within scope of JAFNPP maintenance rule are visually inspected at least once every 5 years to ensure there is no loss of intended function between inspections.

There are no inaccesible block walls. The absence of operating experience involving significantly degraded masonry walls indicates that this frequency is appropriate. (Ref.

JAFNPP procedure JAF-RPT-BYM-263, Section 4, and Aging Management Program Evaluation Report LRD 02, Section 4.21.2) 120 199 In the discussion of operating experience, four The Structural Maintenance Rule Monitoring is The project team finds the applicant's noteworthy incidences of degradation are performed in accordance with procedure DESO 12. response acceptable, because it noted: cracks, gaps, corrosion, and flaking of This document provides for inspection of reinforced demonstrates that the applicant has coating. For each of the first three incidences of concrete, structural steel, masonry, and formal procedures for documenting and degradation, please provide the plant architectural items. One or more inspection data correcting degraded concrete conditions.

documentation that describes the degradation, sheets (dependent on whether degradation is The project team reviewed several of the the assessment performed, the acceptance noted) are completed for each Structure that is referenced procedures and inspection criteria applied, future monitoring outlined in the Structural Maintenance Rule Basis reports, to confirm the applicants 71

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recommendations, and any corrective actions Document. Judgment of the engineering team (two response. This question is resolved.

taken. Also describe the monitoring activities minimum) is used to evaluate degradation and that are or will be conducted under the determine the course of action whether to restore Structures Monitoring Program. the condition of the structure or to adjust the monitoring frequency. The results of each subsequent monitoring inspection are recorded and evaluated to establish the time for the next inspection. The interval before the next inspection for a structure may decrease, increase, or remain the same based on the condition of the structure relative to the previous inspection. A Condition Report (CR) is issued for any structures that require immediate attention or a Work Order is initiated for minor degradation that requires attention. Inspection Checklist data sheets from the most recent inspections are available for review.

The following reinforced concrete and masonry degradations, including cracks and gaps, were reported during the 2005 SMP inspections:

The SMP inspection of the RWCU Heat Exchanger (Inspection # 05-RB-300-005-03) reinforced concrete pedestal foundation monitors a degraded concrete condition. The steel frame supporting each end of the three stacked RWCU heat exchangers rests on concrete pedestals. One of the concrete pedestals had degraded by the loss of concrete from top and side surfaces located adjacent to the bearing surface of the steel frame.

Past repairs were not effective in restoring the concrete due to the thermal expansion of the heat exchangers.

The most recent inspection in 2005 confirmed there was no change in the concrete condition from the previous inspection in 2003 (i.e., 2-year frequency).

The broken concrete condition exceeds the acceptance criteria of hairline cracks and therefore 72

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condition reports have been written to provide immediate management attention. As a result, an engineering change package has been designed and issued to restore the support structure and is scheduled for implementation. The monitoring frequency will remain at 2-years for this item.

The SMP inspection of the Emergency Diesel Generator Room (Inspection # 05-ED-272-002-03,

1. 05-ED-272-004-03) of masonry block walls identified separations between the reinforced concrete wall and the end of the adjoining masonry walls. The vertical joint between the walls has separated from the joint filler such that a small (cracklike) opening has formed at several locations along the joint. The joint filler serves to fill the gap between the two walls and does not contribute to the structural integrity of the walls Therefore, a work order has been issued to repair the filler material. The repair work has not been scheduled.

The monitoring frequency will remain at 2-years for these items.

No corrosion was reported during the 2005 inspections for reinforced concrete and masonry items.

121 200 Some BWR units have a history of problems The Dresden/Quad Cities License Renewal The project team finds the applicant's with containment penetration bellows, and the Application (LRA) and Safety Evaluation Report response acceptable, because the licensees have a long-term replacement (SER) provide a description of the Dresden/Quad environment conducive to SCC of the program that will continue into the LR period. Cities operating experience with stainless steel stainless steel, containment penetration The applicant is requested to address this bellows. The Dresden/Quad Cities review bellows does not exist at JAFNPP. This industry operating experience and submit a determined a total of 120 bellows were within the question is resolved.

specific technical basis why the JAFNPP scope of license renewal. Of these 120 bellows, 24 containment penetration bellows are not bellows were identified as being degraded. The subject to the aging effects and aging root cause was identified as stress corrosion mechanisms observed at these BWRs. cracking (SCC). From 1990 to 2003 Dresden/Quad Cities replaced or removed the degraded bellows from service. The SER states that several of the 73

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replaced bellows received metallurgical analysis.

Analysis results from a couple of examples determined the presence of corrosive products, such as magnesium salts, chlorides, fluorides, and sulfides. Also, these corrosive species are not typical of containment operating conditions. As a result, the SER concludes the corrosive species, leading to the site specific degradation of the bellows, were most probably introduced during plant construction. (Reference Dresden/Quad Cities SER pages 3-403 to 3-408)

Cracking due to SCC for the JAFNPP containment bellows is not an aging affect requiring management. There is no JAFNPP site-specific operating experience similar to that of Dresden/Quad Cities. In summary, the presence of corrosive contaminants is necessary for SCC to occur. The normal environment for the JAFNPP drywell is dry and there has been no indication of contamination of the bellows during construction. In addition, containment bellows for JAFNPP are not exposed to a corrosive environment. As such, SCC is not applicable to JAFNPP stainless steel bellows. (Ref. LRA paragraph 3.5.2.2.1.7)

There is nothing to indicate that the bellows have been or would be subjected to corrosive contaminants since the environment is dry and inerted. They are static devices designed for thermal expansion between the drywell and torus during a DBA, therefore they do not experience inservice stresses that would make them susceptible to SCC. The leak rate testing (ref. ST-39B-X201) performed to date provides reasonable assurance that the structural integrity of these expansion bellows remains intact.

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122 201 More information is needed about the aging JAFNPP has determined that groundwater is not The project team finds the applicant's management of inaccessible concrete areas. aggressive and sampling will be done in the future response acceptable. The applicant has The applicant is requested to submit the dates to verify this evaluation. Groundwater at JAFNPP is committed (Commitment No.16) to and complete results (at specific locations/not expected to be non-aggressive similar to Nine Mile enhance the Structures Monitoring averages or ranges) of all past groundwater which is non-aggressive as stated in the SER for Program to ensure that an engineering monitoring tests. Discuss why the groundwater License Renewal of Nine Mile Point Nuclear evaluation is made on a periodic basis (at is non-aggressive, and/or aggressive, if Station, Units 1 and 2. least once every five years) of applicable. Confirm that the JAFNPP SMP groundwater samples, to confirm that the credited for LR will continue to perform the Values for pH, chloride and sulfate are not groundwater remains non-aggressive to groundwater monitoring and inspect all available. Structures Monitoring Program (SMP) concrete during the period of extended inaccessible areas that may be exposed by will be enhanced to ensure an engineering operation.

excavation for any reason, whether the evaluation is made on a periodic basis (at least environment is considered aggressive or not, once every five years) of groundwater samples to Based on review of the SER for License and will also inspect any inaccessible area assess aggressiveness of groundwater to concrete. Renewal of Nine Mile Point Nuclear where observed conditions in accessible areas, For the SMP, JAFNPP will obtain samples from a Station, Units 1 and 2, the project team which are exposed to the same environment, well that is most representative of the ground water concluded that the site groundwater is not show that significant concrete degradation surrounding below-grade site structures. Samples currently aggressive.

occurred. will be monitored for sulfates, pH and chlorides.

Structures Monitoring Program will also inspect any This question is resolved.

inaccessible concrete areas that may be exposed by excavation for any reason, or any inaccessible area where observed conditions in accessible areas, which are exposed to the same environment, show that significant concrete degradation is occurring. This is license renewal commitment 16.

123 202 The applicant is requested to address and Monitoring report JAF-RPT-BYM-03399 Revision 2 The project team finds the applicant's discuss operating experience in detail for the documents the results of inspection performed response acceptable because the cracks identified in 2005, including the under the structures monitoring program. applicant has adequately addressed the acceptance criteria of concrete structures and Acceptance criteria are delineated in DESO 12. plant-specific operating experience components. Was any scope expansion The cracks identified did not deviate significantly identified in 2005 in accordance with plant required due to unacceptable conditions from the baseline inspection and were identified as corrective action process and the identified? Identify any additional inspections minor cracking. Follow-up actions, if required, are maintenance rule program requirements.

scheduled for the next inspection period. identified within the body of the report and were This question is resolved.

available for review during the site audit. As a result of the inspection no additional scope nor new inspections were added. The structural 75

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maintenance rule baseline (initial) inspections were performed in 1997 and future monitoring inspection frequencies were established based on the results of the baseline inspections. In cases where random cracks were identified in either reinforced concrete or masonry, a shorter monitoring interval of 2 years was established to confirm the condition was not a degrading condition (i.e., shrinkage cracks). For the majority of cases, the 2-year frequency has been continued until the present. As a result, the multiple inspections of these structures have confirmed the condition is not progressing and will not affect functional capabilities. No additional inspections are required during the next planned inspection for any items that have cracks identified.

As discussed in the Item #199 response, the only cracks of any significance that were reported during the 2005 inspection was associated with the RWCU Heat Exchanger concrete pedestal.

However, there were a number of reinforced concrete and masonry items that were inspected in 2005 that contain hairline cracks that were reported during previous inspections and continue to be monitored. Any hairline cracks that are identified and being monitored in reinforced concrete are reviewed by experienced structural engineers to confirm they are not associated with a structural loading condition. Likewise, most hairline cracks being monitored in masonry construction are located in joint lines and are attributed to shrinkage. Minor pre-existing masonry wall hairline crack in the block face in the Electric Bay (Inspection # 05-TB-272-002-03) and in the West Diesel Fire Pump Room (Inspection # 05-SW-255-006-03) are being monitored on 2-year frequencies.

A work order has been issued to repair the West Diesel Fire Pump Room hairline crack.

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Question and Answer Database Audit and Review Related to the License Renewal Application for James A. Fitzpatrick Nuclear Power plant Applicant's No. Audit Questions Applicants Response Project Team's Evaluations Ref. No.

124 203 Please address each the current status of the Approximately 7 years remain before JAFNPP The project team finds the applicant's enhancement to the existing Structures enters the period of extended operation, response acceptable, because Monitoring Program including results of any implementing procedures required for new AMPs, Commitment No.16, submitted in a letter enhanced inspections that have already been and procedure revisions for enhancements to dated February 01, 2007, describes the completed. existing AMPs have not yet been enhancements and the implementation developed. schedule for the Structures Monitoring Program. All enhancements will be Commitment #16 to implement the enhancements implemented prior to the period of to the Structures Monitoring Program are described extended operation. This question is in LRA Section B.1.27.2. resolved.

125 206 The scope of the enhancements listed for AMP The enhancements to the Structures Monitoring The project team finds the applicant's B.1.27.2 is quite significant, and it Program (SMP) are relatively minor items that are response acceptable because when encompasses several elements that would be not typically found in a maintenance rule structures Commitment No.16 is implemented, the expected to be part of an existing Structures monitoring program. The structures, structural applicant's Structures Monitoring Program Monitoring Program. Notable examples are the components and their aging effects requiring will be consistent with GALL AMP XI.S6.

inclusion of anchors and the addition of steel management under scope of SMP are included in This question is resolved.

components to the current inspection criteria. LRA Tables 3.5.2-1 through 3.5.2-6. Visual Consequently, the applicant is requested to: inspections of plant structures are performed at five-year intervals, except for the intake and (a) describe the scope of AMP B.1.27.2, discharge tunnel structures which are inspected at including the structures and components in the ten-year intervals. Visual inspections of buried scope of AMP B.1.27.2; the aging effects that plant structures are performed when opportunistic are monitored; the inspection methods excavation occurs. However, more frequent employed; and the inspection frequency; inspections may be performed based on past inspection results, industry experience, or exposure to a significant event (e.g. tornado, earthquake, fire, chemical spill). (Ref. Aging Management Program Evaluation Report LRD-02, section 4.21.1).

126 207 The scope of the enhancements listed for AMP Currently the aging management activities being The project team finds the applicant's B.1.27.2 is quite significant, and it implemented for structures and components that response acceptable because when encompasses several elements that would be will be added to the Structures Monitoring Program Commitment No.16 is implemented, the expected to be part of an existing Structures for license renewal are routine observations during applicant's Structures Monitoring Program Monitoring Program. normal plant operation and maintenance. This is will be consistent with GALL AMP XI.S6.

commitment #16. This question is resolved.

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Question and Answer Database Audit and Review Related to the License Renewal Application for James A. Fitzpatrick Nuclear Power plant Applicant's No. Audit Questions Applicants Response Project Team's Evaluations Ref. No.

Notable examples are the inclusion of anchors and the addition of steel components to the The corrective action program requires initiating current inspection criteria. Consequently, the condition reports for degraded conditions observed applicant is requested to: during routine operation and maintenance.

(b) for the structures and components that will be added to the Structures Monitoring Program scope for license renewal, describe the aging management activities that are currently being implemented.

127 208 The applicant has not addressed aging The seal between the concrete floor inside the management of the portion of the drywell shell drywell and the drywell shell is inspected under the This question is closed to RAI 3.5.2-2.

embedded in the drywell concrete floor. This SMP and was most recently inspected in October area is inaccessible for inspection, but is 2006 during the refueling outage. In response to RAI 3.5.2-2 requested additional potentially subject to wetting on both the inside NRC Generic Letter GL 87-05, the drywell sand information pertaining to aging and outside surfaces. Are there any inspections cushion drains were inspected to verify they were management of the drywell shell planned prior to the period of extended free from plugging. The JAF design includes drains embedded in the drywell concrete floor.

operation for this portion of the drywell shell? to capture refueling seal leakage and a seal over the sand cushion that precludes water intrusion The applicant provided its response to RAI that could affect the exterior surface of the 3.5.2-2 in LRA Amendment No. 6, dated embedded portion of the drywell shell. JAF February 12, 2007. The staffs basis for engineering will evaluate the need for any resolving RAI 3.5.2-2 is discussed in SER appropriate additional actions. Section 3.5.2.3.1.

See response to RAI 3.5.2-2.

128 209 Describe the "aggressive environment" and Aggressive environment is defined in NUREG-1801 The project team finds the applicant's "water-flowing" environments for Reinforced Chapter XI as it applies to steel in concrete as that response acceptable because the Concrete Foundation, Slabs, and Reinforced occurring when concrete pH <11.5 or chlorides concrete environment is not aggressive Concrete Walls. What is the plant-specific concentration >500 ppm. Concrete at JAFNPP is and the applicant is performing program to manage potential degradation? not susceptible to the aging effects caused by opportunistic inspections to monitor aggressive environment since it meets the aggressiveness of the concrete. This NUREG-1801 criteria provided in Item III.A6-1. question is resolved.

NUREG-1801is unclear with respect to this item as the Volume 2 T-18 item (III.A6-1) has an air environment and the associated T-18 Volume 1 item (Table 3.5-1, Item 34) discusses aging 78

Question and Answer Database Audit and Review Related to the License Renewal Application for James A. Fitzpatrick Nuclear Power plant Applicant's No. Audit Questions Applicants Response Project Team's Evaluations Ref. No.

management programs for water environments.

Water flowing is defined in NUREG-1801 as water that is refreshed, thus having larger impact on leaching; this can be rainwater, raw water, groundwater, or flowing water under a foundation.

For the purposes of the JAFNPP aging management review, water-flowing was considered flowing water at greater than 3 fps. (Ref. EPRI report 1002950 Aging Effects for Structures and Structural Components (Structural Tools), Section 3.3.1.4)

The potential aging effect resulting from flowing water is loss of material. For concrete, structures monitoring manages loss of material as identified in LRA Tables 3.5.2-1 through 3.5.2-4.

129 212 Please provide the following information related For JAFNPP no underwater supports are identified The project team finds the applicant's to inspection of underwater supports for loss of to be added to scope of this program for license response acceptable because the aging mechanical function: renewal period. effects of underwater supports are managed by the applicant's Structures (a) Identify the specific underwater supports No inspections are performed at JAFNPP using the Monitoring Program. This question is that will be added to the scope of the inspection GALL AMP XI.S7. The water control structures at resolved.

program for the license renewal period, JAFNPP are the intake and discharge structures.

including the system name and ASME Code Inspections of these structures are performed Class. under the Structures Monitoring Program AMP B.1.27.2. [Ref. Aging Management Program Evaluation Report LRD-02, section 4.21.1].

130 215 JAFNPP AMP B.1.16.1 identifies that the The Class MC supports that are currently in scope The project team finds the applicant's Containment Inservice Inspection (CII) program of containment inspection program at JAFNPP response acceptable because the is a plant-specific program encompassing the are16 torus saddle supports, 4 torus earthquake applicant has identified all Class MC requirements for the inspection of class MC. ties and 8 upper drywell stabilizers. supports within the scope of the CII Please provide the following information Program. This question is resolved.

related to:

(a) Identify the class MC supports that are currently included in the existing inspection program.

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131 216 JAFNPP AMP B.1.16.1 identifies that the (b) Torus supports and RPV stabilizer supports. The project team finds the applicant's Containment Inservice Inspection (CII) program The program document is JAF-RPT-PC-04088. response acceptable because the is a plant-specific program encompassing the All torus supports, earthquake ties and upper applicant has identified all Class MC requirements for the inspection of class MC. drywell stabilizer supports will be scheduled for supports within the scope of the CII Please provide the following information examination during the 4th ten-year inspection Program and clarified that no other related to: interval. The Code of Record for the 4th Interval supports to be added to this program. This (b) Identify the class MC supports that will be shall be ASME Section XI 2001 Edition /2003 question is resolved.

added to the scope of this inspection program Addenda. There are no other supports to add.

for the license renewal period.

132 217 JAFNPP AMP B.1.16.1 identifies that the (c) These are under the ASME Section XI program The project team finds the applicant's Containment Inservice Inspection (CII) program and require VT-3 inspection. The Class MC response acceptable because the is a plant-specific program encompassing the supports at JAF consist of 16 torus saddle applicant's program is consistent ASME requirements for the inspection of class MC. supports, 4 torus earthquake ties and 8 upper Section XI requirements. This question is Please provide the following information related drywell stabilizers. The original IWE program at resolved.

to: JAF was developed in accordance with the requirements ASME XI 1992 edition with 1992 (c) Specify the current inspection program and addenda after the IWE section of the code was describe the current inspection details for the mandated in 1996. This edition of the code did not MC supports that are identified in (b) above. require inspection of Class MC supports.

The current IWE Program at JAF was developed in accordance with the 1998 edition with 1998 addenda of ASME XI. This code edition requires that 100% of the Class MC supports be examined during the ten year interval. Accordingly, all torus supports, earthquake ties and upper drywell stabilizer supports are scheduled for examination during the JAF 4th ten-year inspection interval. The first examinations under the 4th interval IWE program will be performed either prior to or during RFO18 in 2008.

133 218 JAFNPP AMP B.1.16.1 identifies that the (d) These shall be included in the 4th interval ISI The project team finds the applicant's Containment Inservice Inspection (CII) program program which expires in October 17, 2014. The response acceptable because the is a plant-specific program encompassing the next interval will be updated and maintained as applicant confirmed that all torus supports, requirements for the inspection of class MC. required by 10 CFR 50.55(a) and ASME Section earthquake ties and upper drywell 80

Question and Answer Database Audit and Review Related to the License Renewal Application for James A. Fitzpatrick Nuclear Power plant Applicant's No. Audit Questions Applicants Response Project Team's Evaluations Ref. No.

Please provide the following information requirements. All torus supports, earthquake ties stabilizer supports continue to be related to: and upper drywell stabilizer supports continue to be examined in accordance with the JAF IWE examined in accordance with the JAF IWE Program during the PEO. This question is (d) Confirm that, all MC supports will be Program during the period of extended operation. resolved.

included in the scope of this inspection program for the period of extended operation.

134 219 The applicant is requested to identify the The IWE containment inspection program is The project team finds the applicant's inspection program and the Inspection currently performed in accordance with ASME response acceptable, because the frequency for the current license and for the section XI 1998, no addenda with repair / applicant identified the applicable Code extended period of operation. In the OE it said: replacement activities in accordance with ASME editions of record for the 3rd and 4th Results of the CII....during RF16 (2004) section XI 1992 including addenda. Going forward inspection intervals, and also provided the revealed no significant lost of material.. to the fourth ten-year ISI interval, inspection and inspection results in its letter dated Please, provide the inspection documentation repair / replacement will be performed in February 12, 2007. This question is of this inspection and the results. accordance with ASME section XI 2001 edition resolved.

including 2003 addenda.

Documentation available for review at the site.

135 220 The applicant is requested to address the With exception of the conditions identified in item This question is closed to RAI 3.5.2-2.

results of the CII general walkdown of primary 221 (B.1 16.1-4), the general walk down of primary containment during 2006 (RFO 17) including containment during 2006 (RFO 17) identified minor The specific details of RAI 3.5.2-2 pertain any corrective action, preventive action related surface rust/corrosion and areas of deteriorated to the programs and activities for to question 219 above. Are there any coatings evaluated by the responsible design managing the rust and deteriorated degradations found? If found, What are they? engineer as acceptable. No degradations were coatings of the drywell shell.

What were your corrective and preventive found.

actions? What were the results of your root The applicant provided its response to RAI cause analysis? Please discuss the 3.5.2-2 in LRA Amendment No. 6, dated acceptance criteria, qualification method used, February 12, 2007. The staffs basis for and/or any other means to support your resolving RAI 3.5.2-2 is discussed in SER conclusion? Section 3.5.2.3.1.

136 221 Please explain, Why the June 27, 2005, The JAF Torus Preservation verifies that sample This question is closed to RAI 3.5.2-5.

operating experience such as crack on the locations are tracked for wall thinning. The reports torus shell addressed in the LRA? Are there are in the NDE database and used to assure In RAI 3.5.2-5, the project team asked for any other similar situations identified? What are adequate wall thickness. IWE examinations are additional clarification on how the 81

Question and Answer Database Audit and Review Related to the License Renewal Application for James A. Fitzpatrick Nuclear Power plant Applicant's No. Audit Questions Applicants Response Project Team's Evaluations Ref. No.

the preventive and corrective actions taken for performed and any discrepancies noted in coatings applicant had addressed the cracks in the torus shell wall thinning? Please, provide are repaired using the CR system. All data is torus structure and how the applicant the results of the NDE examination including available on site. JPCE ISI engineer and IWE would manage cracking of the torus for the the acceptance criteria and qualification Structural engineer can supply documentation for period of extended operation.

method used and any pertaining documentation both the Torus Cracking and/or Torus Wall.

for the staff to review. The applicant provided its response toRAI The torus crack was discussed in LRA Section 3.5.2-5 in LRA Amendment No. 6, dated 3.5.2.2.1.8. The Torus was repaired in July 2005 February 12, 2007. The staffs basis for using a cap and removing the damaged section of resolving RAI 3.5.2-5 is discussed in SER shell. The RCA determined Condensation Section 3.5.2.3.1.

Oscillation from the HPCI Turbine Steam Discharge provided the energy that initiated the cracking. UT was subsequently performed at this location and at the RCIC discharge each time they were run. In RO17 a Visual examination was scheduled on the extent of condition and 2 cracks were noted near the HPCI discharge. These cracks were not through wall were removed and repaired by welding. To eliminate the cause the HPCI discharge line was modified with a sparger assembly which is designed to eliminate condensation oscillation.

JAF documentation can be found under the following:

CR-JAF-05-2593 WO- [[::JAF-05-24673|JAF-05-24673]] CR-JAF-06-4526 WO-JAF-06-28641.

Additional information will be addressed under RAI 3.5.2-5.

137 222 Explain how inspections are performed in the The interior torus suppression pool area above and The project team finds the applicant's torus suppression pool above and below the below the water line are inspected in accordance response acceptable, because periodic water line. Explain historically what inspection with the IWE program during refueling outages inspection is conducted consistent with findings have lead to the need for augmented (Code of Record ASME Section XI 1998 Edition). A ASME Section XI, IWE requirements.

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inspections. Explain if any augmented general visual examination is performed on the Augmented inspection, in accordance with inspections are currently being performed. area above the water line. Below the water line is IWE requirements, is also conducted.

normally inaccessible unless the torus water level is lowered or drained for a work activity, which is In addition, ultrasonic thickness required once per Interval in accordance with measurements are performed from the ASME Section XI, 1998 Edition. exterior surface of the Torus Shell. These examinations are being performed in The torus was last drained and cleaned in 1998 for support of the Torus Preservation the installation of the ECCS strainers. A general Program and are not required based on visual exam of the surface above and below the the IWE Containment Inspection Program.

water line was performed. The visual examination identified nine (9) of the most severe areas of This question is resolved.

pitting. The depths of the pits were measured at that time and a portion of those areas are monitored and measured by means of a UT from the outside of the torus shell every outage. Over a five year period, all nine of the pitted areas are examined by performing a UT.

Augmented containment inspections are conducted based on, Pre-existing component conditions which have been programmatically monitored and evaluated, that do not meet those conditions defined in IWE-1240 or IWE-3510.2 (i.e. pitting in the Torus).

The Augmented Containment Inspection Program for Examinations of other than those required by IWE-1241are conducted on the Torus in accordance with the ISI Program and is as follows:

• JAF has implemented a sub-tier Augmented inspection frequency, based on HPCI and/or RCIC actuation requiring Ultrasonic examination of the Torus from the exterior surface in the following areas.

A. Torus interior ring girder gussets

b. External support columns at the intersection of bay A and P (HPCI Exhaust)

c. External surfaces of bay N and O (RCIC Exhaust) 83

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• In addition, ultrasonic thickness measurements are performed from the exterior surface of the Torus Shell. These examinations are being performed in support of the Torus Preservation Program and are not required based on the IWE Containment Inspection Program.

138 223 Explain if water leakage has ever been There has been no observed leakage causing The applicant provided its response in discovered between the drywell and concrete moisture in the vicinity of the sand cushion at JAF staff's RAI 3.5.2-3 in a letter dated secondary shield wall or in the sand pocket and no moisture has been detected or suspected February 12, 2007. This question is closed area. Explain what JAFNPP does to inspect for on the inaccessible areas of the drywell shell. to RAI 3.5.2-3.

water leakage in these two areas or to verify that loss of material is not occurring on the Further, as discussed above, any potential leakage backside of the drywell. Provide the latest through the refueling bellows assembly is directed engineering system health report for the CII to a drain system. Therefore, no additional program. components have been identified that require aging management review as a source of moisture that might affect the drywell shell in the lower region. In 1988, JAF verified that the air gap through drain lines using fiber optic cable and did not find any evidence of moisture in the air gap or corrosion of the drywell shell. Additional information will be addressed under RAI 3.5.2-3.

139 224 The containment inservice inspection aging Two inspections were required per NRC Generic The applicant provided its response to RAI management program described in LRA Letter 87-05 prior to start-up from the 1988 Refuel 3.5.2-3 in a letter dated February 12, B.1.16.1 did not provide any information Outage. The first being inspection of the eight (8) 2007. This question is closed to RAI 3.5.2-regarding the applicants actions in response to 2 diameter sand cushion drain lines and the 3.

GL 87-05 and other industry operating second being inspection of the six (6) refueling experience including actions planned as a bellows leakage drain lines. The inspections using result of recent staff guidance (LR-ISG-2006- a flexible boroscope were to determine that the

01) to address the potential loss of material due lines were unplugged and functioning as designed.

to corrosion in inaccessible areas of the Mark 1 All eight sand cushion drain lines were inspected steel drywell shell for the period of extended and seven of the eight were found to be operable.

operation. Five of the six refueling bellows leakage drain lines were inspected and found to be operable.

Inspection ports were installed prior to the inspection in five of the six lines, an inspection port 84

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was not installed in the sixth line because of the lines inaccessibility.

The sand cushion for JAF is covered with stainless steel plates and an adhesive seal to prevent in-leakage. Drains are provided above these plates and also at the bottom of the sand cushion.

Because of this encasement type design arrangement, no ultrasonic (UT) thickness measurements are required for the drywell shell plates adjacent to the sand cushion. Additional information will be addressed under RAI 3.5.2-3.

140 225 The applicant is requested to address and As indicated in LRA section B.1.8, the Containment The project team finds the applicant's discuss the test option related to this program. Leak Rate Program is consistent with the NUREG- response acceptable because the What was the most significant operating 1801 Section XI.S4, 10 CFR Part 50, Appendix J, applicant's Containment Leak Rate experience related to this program? What were Option B program. As documented in the Program elements are consistent with your corrective and preventive actions? When Integrated Leakage Rate Test (ILRT) 5 year GALL AMP XI.S4 program elements. This does your next periodic intervalstart? extension request (Accession # ML032170128), question is resolved.

the previous 4 ILRTs, dating back to May 1985, showed consistent low leakage and validate the structural integrity of the primary containment.

Consistent with NUREG-1801,Section XI.S4, 10 CFR 50, Appendix J, the Containment Leak Rate Program is a monitoring program without preventive actions. Corrective actions are performed in accordance with 10 CFR Part 50, Appendix J, NEI 94-01, and 10CFR50 Appendix B.

Since the 5 year extension request was approved, the next ILRT is to be performed no later than March 7, 2010. Local leak rate tests have different intervals for individual components based on prior performance.

141 227 The [Scope of the Program] states that the ISI This item incorporates the following: Item 228, 229, The project team finds the applicants program manages cracking, loss of material, 230, 231, 234, 236, 237, 238 inclusively response acceptable because the and reduction of fracture toughness of the applicant has clarified the systems that reactor coolant system piping, components, a) The ISI Program at JAF includes both the are within the scope of the ISI Program 85

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and support. Reactor Coolant Pressure Boundary (RCPB) and and also confirmed that it is implementing piping systems that have been identified as ISI the proper ASME Section XI requirements A. Clarify what other plant systems the ISI Class 2 & 3. However, the LRA credits the ISI for ASME Code Class 1, 2, and 3 Program covers in addition to the reactor Program for aging management of the Class 1 systems. This question is resolved.

coolant system. If the scope of the ISI Program RCPB only. Therefore, no revision of the scope of covers other plant systems at JAFNPP under program attribute is required.

the requirements of 10CFR50.55a, identify and justify whether or not the [Scope of Program] b) The question in part B is confirmed.

program attribute needs to be revised. The list of systems in the JAFNPP ISI program includes:

B. Confirm that the ISI program includes Flow Diagram Reactor Building Service Water implementation of the general requirements of Cooling Control Room Area-Service and Chilled ASME Section XI, Subsection IWA for these Water systems, the specific requirements of ASME Reactor Building Cooling Water Section XI, Subsection IWB for portions of Reactor Building Cooling Water these systems that are part of the reactor Pass Cooling Water Supply coolant pressure boundary, the specific Fuel Pool Cooling (FPC) requirements of ASME Section XI, Subsection Core Spray (CS)

IWC for portions of these systems that are Standby Liquid Control categorized as ASME Code Class 2, Reactor Core Isolation Cooling (RCIC)

Subsection IWD for portions of these systems Reactor Water Cleanup (RWC) that are categorized as ASME Code Class 3, Residual Heat Removal (RHR) and Subsection IWF for ASME Code Class 1, Residual Heat Removal (RHR) 2, and 3 component supports High Pressure Coolant Injection (HPCI)

Reactor Water Recirculation (RC)

Control Rod Drive (CRD)

Feedwater (FW)

Service Water (SW)

Emergency Service Water (ESW)

Nuclear Boiler Vessel Instrumentation (NBVI)

Emergency Diesel Generator Fuel Oil and Combustion Air Systems Emergency Diesel Generator and Lubricating Systems Emergency Diesel Generator Air Start-up Lines 142 235 Program element "Detection of Aging Effects" - As stated in NUREG-1801 Volume 2 Rev 1 XI.M12, The project team finds the applicants It is not clear how the NDE methods described the ASME Section XI inspection requirements are response acceptable because the 86

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in ASME Section XI, Subsection IWA and sufficient for managing the effects of loss of applicant provides an acceptable basis invoked in accordance with specific inspection fracture toughness due to thermal aging that it is applying the NRC requirements in ASME Section XI, Subsection embrittlement of CASS pump casings and valve bodies.recommendations documented in the IWB, IWC, or IWD have the ability to monitor letter dated May 19, 2000, to manage for a drop in the fracture toughness property for For pump casings and valve bodies, based on the thermal aging in the CASS pump casings a given ASME Code Class 1, 2, or 3 assessment documented in the letter dated May and valves. The NRC-letter states and component. The project team requests that 19, 2000, from Christopher Grimes, Nuclear provides an acceptable basis for Entergy provide additional clarification on how Regulatory Commission (NRC), to Douglas concluding that the implementation of the ISI program for JAFNP will manage loss of Walters, Nuclear Energy Institute (NEI), screening Section XI requirements (including Code fracture toughness in the ASME Code 1, 2, and for susceptibility to thermal aging is not required. Case N-481) are sufficient to manage of 3 components for the facility, and in particular, The existing ASME Section XI inspection thermal aging embrittlement in CASS how the ISI program, when implemented, will requirements, including the alternative pump casings and valve bodies. Other ensure compliance with pertinent fracture requirements of ASME Code Case N-481 for pump than these CASS pump casings and valve toughness requirements in Section XI of the casings, are adequate for all pump casings and bodies, LRA Table 3.1.2-3 does not ASME Code and ensure system integrity if the valve bodies. In this way, the ISI program is used identify any other piping, piping elements fracture toughness for a particular components to manage the aging effect of loss of fracture or piping fitting commodity groups as material is projected to drop over the EPO. toughness through analysis instead of monitoring being fabricated from CASS materials.

techniques. This question is resolved.

143 241 The project team requests that Entergy provide c) JAFNPP performs augmented inspections for The project team finds the applicants the following information with respect to the the following components: response acceptable because the operating experience that is relevant to the applicant provided additional information JAFNP ISI Program: *IGSCC (ASME Section XI B-F, B-J & C-F and clarified which components received weldments augmented inspections based on the c). Provide the following information if it is operating experience for the facility. This determined that Entergy did augment its ISI *Risk-Informed Inservice Inspection (RI-ISI) Class question is resolved.

examination requirements for any given ASME 1, 2, and 3 piping welds (ASME Code Category B-Code Class 1, 2, or 3 component or its F, B-J & C-F) supports (i.e., other than pertinent reactor pressure vessel and internals components, *Main Steam & Feedwater High Stress Welds which have been augmented for inspection inspected in accordance with JAFs TRM Section pursuant to commitments for pertinent BWRVIP 3.4A and Engineering Report JAF-RPT-03-00289, guidelines): (1) identify what component is of Rev. 0, Main Steam and Feedwater Augmented concern and what the relevant operating Inspection Program, and 50.59 Safety Evaluation, experience was that prompted Entergy to JAF-SE-03-0004, Rev. 0, Update of the Main augment ISI examination requirements for the Steam and Feedwater Augmented Inspection component, and (2) clarify what Entergy did to Program.

augment its ISI program requirements for these 87

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components. *Core Spray Augmented Inspection Program - Core spray augmented examinations are welds that have been identified that warrant monitoring of the pump discharge piping for vibration. The exam requirements are to be performed in accordance JAF calculation / JAF-CALC-CSP-00327 Rev. 0, JAF Core Spray Vibration Evaluation Core Spray Pump Discharge Lines, dated 9/27/91

• Feedwater Nozzle Inspection Program - The Feedwater Nozzle Inspection Program at JAF implements enhanced inservice inspection (ISI) of feedwater nozzles in accordance with the requirements of ASME Section XI, Subsection IWB and the recommendation of General Electric (GE)

NE-523-A71-0594.

• Augmented Containment Inspection Program for Examinations Other Than Those Required By IWE-1241 JAF has implemented a sub-tier Augmented inspection plan, based on HPCI and RCIC actuation requiring ultrasonic examination of the Torus from the exterior surface.

144 242 The operating experience discussion states The project team finds the applicants CR-JAF-2004-04472 was written to evaluate this condition.

that the subsurface planar flaw for the Ultrasonic examination of weld 18-34-389 per the response acceptable because the feedwater pipe-to-pump weld was evaluated ISI program identified a subsurface planer applicant clarified that it reconciled the and found acceptable. Clarify what type of indication for evaluation. The evaluation results flaw indication to a recordable slag structural safety assessment was performed to were correlated to conditions accepted by the inclusion indication that was acceptable evaluate this flaw for further service and what construction radiographs; the radiographs were for service in accordance with the Section acceptance criterion was used to set a dispositioned as slag inclusion which was XI flaw evaluation criteria. Since no maximum limit on flaw size (length and depth), acceptable per ASME Section XI IWB-3112(b). structural safety assessment or calculation including adjustments to account flaw growth Because the flaw was acceptable per ASME was required, there is no TLAA required and proximity rules adjustments for adjacent Section XI IWB-3112(b), no structural safety for JAFNPP. This question is resolved.

flaw additions (if they are applicable). Clarify assessment or calculation was required. Because whether the evaluation used to assess the flaw no calculation is required, there is no TLAA for meets the definition of a time-limited aging JAFNPP.

analysis (TLAA), as established according to 88

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the six TLAA definition criteria in 10 CFR 54.3.

Provide your technical basis why the flaw evaluation for the feedwater pipe-to-pump weld is or is not a TLAA in accordance with 10 CFR 54.3.

145 243 Discuss the results of the reviews performed to The results of the reviews performed to identify The project team finds the applicants identify any and all other fracture mechanics fracture mechanics evaluations and flaw response acceptable.

evaluations or flaw evaluations, if any, that evaluations that meet the definition of a TLAA in 10 have the potential to meet the definition of a CFR 54.3 are provided in JAF-RPT-05-LRD03 and For components repaired with weld TLAA in 10 CFR 54.3. If any additional fracture JAF-RPT-05-LRD04, available for review on site. overlays, the applicant provided the mechanics evaluations or flaw evaluations have project team with the SERs that were the potential to meet the definition of a TLAA, Reviews of the following cases were performed, issued on these weld overlays. The provide its technical and regulatory basis for with no TLAAs being identified. More detail is project team's review of the NRC-issued concluding that the specific fracture mechanics provided in Section 2.4 of JAF-RPT-05-LRD04. SERs determined that the NRC did not evaluation or flaw evaluation is or is not a TLAA impose additional fatigue-flaw growth in accordance with 10 CFR 54.3. CRD Return Line Nozzle to End Cap Weld calculations for these weld overlays. For In 2000, JAFNPP discovered a crack on the inside the CRD return line end cap weld overlay, diameter of the weld between the CRD return line the project team concluded that, since the nozzle and the end cap. The NRC staff accepted weld overlay placed the original flaw in the Fitzpatrick plant Mod JD-00-010 and issued an compression, flaw growth would be SER on October 26, 2000. The modification precluded due to the compressive required no calculation involving a time-limited stresses and therefore the analysis did not assumption defined by the current operating term. need to be identified as a TLAA. These Weld overlays of this type put the original flaw in weld overlays are inspected as part of the compression and qualifying evaluations assume applicants IGSCC program, which flaw growth to 360 degrees through wall. Future implements the current augmented acceptability of the weld is assured through inspection criteria of BWRVIP-75A inspections per the guidelines of BWRVIP-75-A. program.

Therefore, no TLAA was identified.

For flaws detected in the other Weld Overlays to Address IGSCC Indications components addressed in the response, the components were either repaired in JAFNPP has applied 21 weld overlays to the accordance with Section XI repair criteria recirculation system piping and 2 overlays to jet or the flaw growth calculations were used pump instrumentation piping to address flaw to define the period between inspection 89

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indications found during inspections performed for intervals and are not defined by the the IGSCC program. The overlays were designed licensed life of the facility. Therefore these and installed in accordance with Generic Letter 88- flaw evaluations do not meet the definition 01, NUREG-0313, Rev. 2, and ASME Code of a TLAA in 10 CFR 54.3. This question requirements and approved by the NRC via a SER. is resolved.

In the qualifying evaluation, the original flaw is assumed to grow to 360 degrees circumferentially and 100% through wall. No credit is taken for the original pipe wall thickness. In addition, the weld metal used is resistant to IGSCC as discussed in BWRVIP-75-A and the specific NRC SER's. Future acceptability of the weld overlay is assured through inspections required by the ISI program and BWRVIP-75-A. There are no TLAA associated with these weld overlays.

There are no welds that are monitored for crack growth under the ISI Program and / or BWRVIP A. All welds that were determined to contain cracking were repaired by weld overlay.

Shroud Cracking JAFNPP performed baseline inspection of the shroud per BWRVIP-76 guidelines during the RO12 and RO13 refueling outages. Calculation JAF-CALC-NBS-04298 determined the inspection intervals to be used for monitoring the noted crack indications. Calculation JAF-CALC-NBS-04298 is not a TLAA since its time-limited assumptions are based on inspection intervals, not the current 40 year operating term. Subsequently, shroud tie-rods were installed to carry the load previously borne by the cracked welds.

Steam Dryer Calculations associated with crack indications on the steam dryer are not TLAA since the associated 90

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calculations justify the time interval between periodic inspections, not the acceptability for the current 40-year operating term.

Core Spray Piping Calculations associated with crack indications on the core spray piping are not TLAA since these calculations justify the time interval between inspections and do not justify operation for the current 40-year operating term. These crack indications are monitored by the BWR vessel internals program per BWRVIP-18A guidelines.

Main Steam Nozzle UT inspection performed as part of the JAFNPP ISI program revealed a subsurface indication on main steam nozzle N3C. There has been no discernable change in the size of the indication during subsequent inspections. This indication is believed to be a flaw remaining from vessel construction and will continue to be monitored by ISI. There is no associated calculation with a time-limited assumption and, therefore, no TLAA is associated with this indication.

Torus Crack In June of 2005 a small through-wall crack was identified in the torus shell in the vicinity of the torus support between bays A and P. Failure analysis indicated that the crack was likely caused by fatigue due to condensation oscillation associated with operation of the HPCI exhaust discharge to the torus. This crack was repaired. In followup inspections, two additional cracks were found. These two cracks were also repaired. No analysis involving a time-limited assumption 91

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defined by the current operating term is associated with the repairs, and therefore, there is no TLAA associated with these torus cracks.

Residual Heat Removal (RHR) Shutdown Cooling Line Through-Wall Crack In July of 2005 a through-wall crack was discovered on the RHR shutdown cooling (SDC) system common suction piping. The cause of this crack was determined to be low stress, high cycle fatigue at the heat affected zone of the weld resulting from increased pipe movement during operation due to inadequate pipe engagement of an adjacent support (PFSK-2084) during original installation. This pipe and the associated support were repaired in accordance with code requirements.. An additional inspection in 2006 discovered two additional cracks which were also repaired. No analysis involving a time-limited assumption defined by the current operating term is associated with the repair, and therefore, there is no TLAA associated with this piping crack.

No JAFNPP flaw growth analyses were identified that would qualify as TLAA (i.e., no other analyses were performed to qualify acceptability of flaws for the current operating term of the plant).

146 244 Identify all BWRVIP Reports including The AMP was based on the previously reviewed The project team finds the applicants components that are within the scope of AMP and approved program described in NUREG-1801. response acceptable because the B.1.7, BWR Vessel Internals. Clarify whether The various applicable BWRVIP reports are listed applicant identified, either directly or BWRVIP-94 and BWRVIP-04 implementation under Scope of Program in NUREG-1801 Section XI.M9. through reference to the BWRVIP reports guidelines are within the scope of this AMP. BWRVIP-04 provides the recommended format and identified in GALL AMP XI.M9, which content of submittals to the United States Nuclear BWRVIP documents are within the scope Regulatory Commission (NRC) for review and of AMP B.1.7. This question is resolved.

approval of core shroud repairs and BWRVIP- 94 provides guidance on implementation of the 92

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BWRVIP reports. BWRVIP-94 is endorsed by procedure Entergy ENN-DC-135.

147 245 Past experience at a BWR station has Entergy will manage the steam dryers in The project team finds the applicant's demonstrated that extended power uprates for accordance with BWRVIP-139 as approved by the response acceptable because the BWRs may cause excessive vibrations of the NRC and accepted by the BWRVIP Executive applicant has amended the LRA in facilitys steam dryers and result in vibration- Committee. LRA Section A.2.1.7 and Section B.1.7 Amendment No. 5, dated February 01, induced cracking (high cycle fatigue-induced will be revised to specify an enhancement to 2007, which includes Commitment No. 22 cracking) of the components. The AMP ensure the effects of aging on the steam dryer are on LRA. This commitment calls for indicates that Entergy has detected relevant, managed in accordance with the guidelines of Entergy to use the NRC-approved version recordable cracking of the JAFNPP steam BWRVIP-139. This requires a LRA amendment. of BWRVIP-139 for augmented dryer. Clarify: (1) whether the steam dryers are inspections of the steam dryer. This within the scope of this AMP and what type of JAF LR Commitment Number 22 will require question is resolved.

aging management strategy(including enhancements to the JAFNPP BWR Vessel identification of the inspection method, Internals Program as described in LRA Section inspection frequency, and inspection sample A.2.1.7 and Section B.1.7.

size) Entergy will be using to manage vibration-induced cracking of the steam dryer at JAFNPP. If the steam dryers are within the scope fo license renewal and Entergy is relying on the guidance of BWRVIP- 139 to manage this aging effect, Entergy will need to provide a commitment to implement the version of BWRVIP-139 that is approved by the NRC, as the topical report is currently under review by the staff for approval.

148 246 Confirm whether or not Entergy has modified During the 1994 Refuel Outage, ten (10) tie-rod The project team finds the applicant the JAFNPP design to include any repair assemblies with associated radial seismic response acceptable because the hardware assemblies for the JAFNPP core restraints (bumpers) were added to the outside of applicant will manage the aging effects in shroud, and if so, identify what type of repair the core shroud to ensure structural integrity of the the core shroud and the core shroud tie-hardware assemblies have been installed at the core shroud in the event of postulated through wall rod assemblies in accordance with Topical facility and identify which core shroud welds the cracking of the circumferential horizontal weld Report BWRVIP-76. The NRC endorsed repair hardware assemblies are assuming the joints (See UFSAR Figure 3.3-19). The tie-rods the augmented inspection methods and loading conditions for and which welds are not attach between brackets mounted in holes guidelines for core shroud and core covered by the repair hardware assemblies. recessed in the shroud top flange and holes in the shroud repair assemblies (including tie rod Clarify, either directly or by reference to shroud support shelf reinforcing gusset plates. The assembly designs) in BWRVIP-76 by SE pertinent BWRVIP guidelines, what type of design of the preloaded tie-rods in conjunction with dated July 27, 2006. No additional 93

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examinations (including examination methods, the radial seismic restraints (bumpers), which limit commitment on BWRVIP-76 is necessary examination frequencies, and examination the lateral movement of the shroud, ensures that for the LRA. This question is resolved.

sample sizes) are being credited for aging the core shroud will perform its design basis management of both the JAFNPP core shroud functions with through wall cracking (360 degree) at structure and repair hardware assemblies. all the existing horizontal core shroud weld joints.

(Section 3.3.4.1 of the UFSAR) JAFNPP manages the core shroud and core shroud repair hardware with the guidelines of BWRVIP-76, without exception. AMP B.1.7-3 will be enhanced to commit to the guidelines of BWRVIP- 76, when approved by the NRC staff. BWRVIP-76 was approved by NRC in a safety evaluation dated July 27, 2006. No additional commitment is necessary.

149 247 The operating experience for JAFNPP indicates a. Type of cracking mechanism found on the JAF The project team finds the applicants that cracking has been detected in some of the core shroud vertical welds is typically IGSCC (i.e., response acceptable because the vertical welds in the JAFNPP core shroud. Core cracking initiates on the heat-affected zone of the applicant clarified that IGSCC was the shroud repair hardware assembly designs weld). mechanism for the cracks detected in the assume the tensile loading conditions for core shroud vertical welds. This is circumferential welds in core shrouds but do consistent with industry experience on not assume the circumferential loading IGSCC-induced cracking in BWR core conditions (hoop stress conditions) for vertical shroud welds. This question is resolved.

welds in the shrouds. Since Entergy has detected recordable indications of cracking in the vertical welds of the core shroud, the staff seeks additional technical clarification for the following:

a.) What type of cracking mechanism was determined to be the root cause of the cracking in the vertical welds?

150 248 The operating experience for JAFNPP indicates b. Belt-line welds SV4A, SV4B, SV5A and SV5B The project team finds the applicants that cracking has been detected in some of the were inspected and sized by UT in R17 (October response acceptable because the vertical welds in the JAFNPP core shroud. Core 2006). There were no indications noted for welds applicant clarified that the flaws in the shroud repair hardware assembly designs SV4A and SV4B. For welds SV5A and SV5B, there vertical welds of the core shroud were assume the tensile loading conditions for is close correlation of flaws from previously seen evaluated in accordance with the flaw circumferential welds in core shrouds but do by EVT-1 in R14, with limited crack growth and no evaluation criteria in BWRVIP-76 and 94

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not assume the circumferential loading through wall indications. There are some additional determined to be acceptable for continued conditions (hoop stress conditions) for vertical flaws (short intermittent) at weld SV5A. All service. The applicant also indicated that welds in the shrouds. Since Entergy has indications were determined acceptable per the reinspections of the core shroud detected recordable indications of cracking in BWRVIP-76. vertical welds will be done in accordance the vertical welds of the core shroud, the staff with BWRVIP-76, which was endorsed for seeks additional technical clarification for the The shroud vertical weld inspections will be done in implementation by NRC letter and safety following: accordance with the requirements of BWRVIP-76 evaluation dated July 27, 2006. This and the NRC SER. question is resolved.

b.) Identify what type of inspection methods were used to re-examine the impacted weld for signs of flaw growth, as visual examinations are not valid methods to verify whether flaw growth is occurring; 151 249 The operating experience for JAFNPP indicates c. Core shroud welds are re-inspected per The project team finds the applicants that cracking has been detected in some of the BWRVIP-76 criteria. An end of interval (EOI) response acceptable because the vertical welds in the JAFNPP core shroud. Core inspection frequency is calculated for each weld applicant clarified that the flaws in the shroud repair hardware assembly designs based on conservative crack growth rate vertical welds of the core shroud were assume the tensile loading conditions for determination and hydraulics, as applicable. The evaluated in accordance with the flaw circumferential welds in core shrouds but do affected vertical welds at JAF have been evaluation criteria in BWRVIP-76 and not assume the circumferential loading determined to be acceptable for further service determined to be acceptable for continued conditions (hoop stress conditions) for vertical (CR-JAF-2006-04238 & 04287). These documents service. The applicant also indicated that welds in the shrouds. Since Entergy has were available for on-site review. the reinspections of the core shroud detected recordable indications of cracking in vertical welds will be done in accordance the vertical welds of the core shroud, the staff with BWRVIP-76, which was endorsed for seeks additional technical clarification for the implementation by NRC letter and safety following: evaluation dated July 27, 2006. This question is resolved.

c.) Clarify why Entergy considers the relevant flaw indications to be acceptable for further service without mandating proper repair of the indications. Provide a technical justification to support your determination; 152 250 The operating experience for JAFNPP indicates d. The indications in the vertical welds at JAF have The project team finds the applicants that cracking has been detected in some of the been determined to be acceptable for further response acceptable because the vertical welds in the JAFNPP core shroud. Core service until RO18 (CR-JAF-2006-04238 & 04287) applicant clarified that the flaws in the shroud repair hardware assembly designs per BWRVIP-76 evaluation guidelines. An Entergy vertical welds of the core shroud were 95

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assume the tensile loading conditions for calculation for belt-line welds SV5A and SV5B will evaluated in accordance with the flaw circumferential welds in core shrouds but do be prepared in 2007 (CR-JAF-2006-04238 CA evaluation criteria in BWRVIP-76 and not assume the circumferential loading 00003). The Entergy calculation will be performed determined to be acceptable for continued conditions (hoop stress conditions) for vertical in accordance with the guidelines of BWRVIP-76. service. The applicant also indicated that welds in the shrouds. Since Entergy has The results of the Entergy calculation will be the reinspections of the core shroud detected recordable indications of cracking in considered in determining inspection methods, vertical welds will be done in accordance the vertical welds of the core shroud, the staff sample size, and inspection frequency. Repair with BWRVIP-76, which was endorsed for seeks additional technical clarification for the contingencies have not been determined since implementation by NRC letter and safety following: significant margin remains before repairs would be evaluation dated July 27, 2006. This required. BWRVIP-76 was approved by NRC in a question is resolved.

d.) If the indications in the vertical welds have safety evaluation dated July 27, 2006. No been determined to be acceptable for further additional commitment is necessary.

service, clarify and discuss what type of non-destructive examination method Entergy will be implementing to reexamine the vertical welds in the core shroud (including identification of the examination method, the examination frequency, and the sample size for the examinations). Clarify what type of repair contingencies Entergy will implement if the indications in the vertical welds are determined to be unacceptable for further service.

153 251 The staffs position in GALL AMP XI.M9, BWR Inspections of the top guide cross hatch area In Commitment No. 21, LRA Amendment Vessel Internals, for inspection top guide cross locations will be performed in accordance with the No. 9, dated April 6, 2007, the applicant hatch areas calls recommends that BWR position in NUREG-1801 Section XI.M9. This committed to perform the inspections of applicants perform enhanced visual program invokes the inspections specified in the top guides recommended in GALL examinations (EVT- 1) of 5-percent of the top BWRVIP-26. Locations selected for examination AMP XI.M9 for the period of extended guide cross hatch locations within 6 years of will be areas that have exceeded the neutron operation. The GALL recommends that entering the period of extended operation fluence threshold for irradiation-assisted stress the top guide inspections include 5 (PEO) and an additional 5-percent of the corrosion cracking (IASCC). The inspections are percent of the grid beam locations within 6 locations within 12 years of entering the PEO. considered sufficient to manage IASCC in the top years of entering the period of extended Clarify whether Entergy will be conforming to guide through the period of extended operation operation with an additional 5 percent the position in GALL AMP XI.M9 for top guide because the BWRVIP activities are based on within 12 years of entering the period of cross hatch areas and explain how the industry-wide BWR operating experience and are extended operation. The applicant also inspections of the top guide cross hatch areas subject to review and approval by the NRC staff. committed to inspect an additional 5 in accordance with this NRC position are percent of the grid beam locations within 8 considered to be sufficient to manage years of entering the period of extended 96

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irradiation assisted stress corrosion cracking operation. This commitment supersedes (IASCC) in the top guide for years 12-20 of the the applicant's response to the project period of extended operation. team's question. This question is resolved.

154 252 Exception 1 states that JAFNPP provides an JAFNPP developed technical justifications for In LRA Amendment No. 9, dated April 6, alternate inspection for the core plate rim hold- deviation from the guidelines of BWRVIP-25 in 2007, the applicant provided LRA down bolts that is technically justified according accordance with the guidance given in Appendix A Commitment No. 23 to address aging to BWRVIP-94. BWRVIP-94 provides the to BWRVIP-94. This appendix does not provide management of the core plate rim hold-BWRVIPs implementation guidelines and does technical justification in and of itself, rather it down bolts and structural integrity of the not provide a BWRVIP-recommended provides administrative guidelines for processing a core plate for the period of extended inspection and flaw evaluation strategy for a technical justification; Entergy is deviating from the operation. The basis for using this particular BWR vessel internal components. guidelines of BWRVIP-25 because the method commitment as the basis for ensuring the Please discuss the following: proposed for core plate rim hold down bolts is not structural integrity of the core plate for the feasible. JAFNPP plans to perform the inspections period of extended operation is discussed a). Provide a technical and regulatory basis to required by ASME Section XI as an alternate in SER section 3.0.3.2.7. This justify why Entergy is deviating from method for inspection of the Core plate rim hold commitment supersedes the applicant's implementing the flaw evaluation and down bolts. response to the project team's question.

inspection guidelines of Topical Report No. This question is resolved.

BWRVIP-25 and clarify why it is acceptable to The examination method, inspection frequency, use BWRVIP-94 as the basis for taking this and inspection sample size for the alternative exception, particularly when Topical Report inspection method will be in accordance with the BWRVIP-94 is the only implementation requirements of ASME Section XI, Table IWB-guideline document; 2500-1, Examination Category B-N-2.

b). Clarify and discuss what types of alternative LRA Section A.2.1.7 and Section B.1.7 will be inspection method, inspect frequency, and revised to include the following enhancement.

inspection sample size will be used to inspect the core plate rim hold down bolts in lieu of the JAFNPP will perform inspections of the core plate recommended BWRVIP-25 examinations; rim hold down bolts in accordance with ASME Section Xl Table IWB-2500-1, Examination c). Clarify, using a technical discussion and Category B-N-2 or in accordance with a future justification, how the examination method, NRCapproved revision of BWRVIP-25 that provides inspection frequency, and inspection sample a feasible method of inspection.

size for the alternative program will be capable of managing cracking in the core support plate This requires a LRA amendment.

rim hold-down bolts for the PEO.

License Renewal Commitment Number 21 specifies implementation of enhancements to the 97

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BWR Reactor Vessel Internals Program described in LRA Section A.2.1.7 and Section B.1.7.

155 255 Exception 2 states that A focused inspection of Yes, JAFNPP will inspect the H9 weld as The project team finds the applicants the bottom surface of the shroud support H9 recommended in BWRVIP-38 (flow chart on page response acceptable because the weld will be performed. The footnote for this 3-17). applicant confirmed that it is applying the inspection states that the examination will be inspection criteria of Topical Report done in accordance with BWRVIP guidelines. BWRVIP-38 for inspection of the H9 weld Confirm whether or not Entergy is referring to in the core shroud. The NRC endorsed the inspection criteria for shroud support BWRVIP-38 for implementation in a SE structures in Topical Report BWRVIP-38. dated March 1, 2001. This question is resolved.

156 256 Exception 3 states, in part, that the inspection Deferral of the top guide hold down assemblies at The project team finds the applicants of the top guide hold down assemblies at the 0 the 0° and 180° from R16 to R17. At JAF, hold- response acceptable because the and 180 azimuthal locations were deferred from down assemblies are inspected with a conservative applicant has been inspecting the top refueling outage 16 (RO16) to refueling outage decision making philosophy. In that, JAF has been guide hold down assemblies in 17 (RO17) with technical justification. State inspecting the hold down assemblies despite accordance with BWRVIP-26A even what the BWRVIP-26 criteria are for inspecting BWRVIP-26-A, Figure A-1 showing that the though the BWRVIPs evaluation of lift these components and provide the details of FitzPatrick plant faulted vertical loads at hold down forces for BWR top guides indicates that the technical basis that was used to defer the assemblies are on the demarcation line between the top guide at FitzPatrick will not lift examinations of the components to RO17 and lift off and will not lift. Therefore, the hold down under a postulated faulted event. Thus, a a justification why this basis formed an assemblies will not lift-off during a postulated one-cycle deferral of the examination is acceptable reason to defer the examinations to seismic event. The deferred inspections from R16 justified and the inspections during RO17 RO17. were completed in R17 (2006). No indications were did not detect any indications of cracking noted. in the top guide rim hold down assemblies.

This question is resolved.

157 257 The BWR Internals Program includes the Details of the technical justification (Deviation The project team finds the applicants following footnote (Footnote 2) on the Disposition) are found in ER# [[::JAF-05-34054|JAF-05-34054]], dated response acceptable because the basis Detection of Aging Effects program attribute 3/17/06, which was available for review on site. for the deviation was documented in a for the AMP, as it pertains to performing the However, JAFNPP inspected the jet pump beams Deviation Disposition, as reported in augmented inspections of jet pump assembly and the high priority welds that were the subject of ERNo. [[::JAF-05-34054|JAF-05-34054]], dated March 17, components under BWRVIP-41. the technical justification by UT in R17 (October 2006, and because the applicant 2006). BWRVIP-41 requires inspection of the inspected the jet pump beams and high Welds at TS-1, TS-3 and TS-4 are inaccessible inaccessible jet pump welds only upon priority jet pump welds by UT in October for inspection. There is no inspection technique development of a feasible inspection method. of 2006. The augmented inspection 98

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developed to inspect the thermal sleeve welds. Therefore, the exception addressed by Footnote 2 recommendations in BWRVIP-41 call for However, the BWRVIP/ EPRI NDE Center has is no longer applicable. Appendix B of the LRA will inspections of inaccessible welds only if a new plans to develop an inspection capability. be revised to delete the exception for the jet pump feasible inspection method is developed.

The BWRVIP is also pursuing analyses which assembly. Therefore, the project team concurs that may reduce or alleviate inspection of the TS-1 Because they are based on industry-wide BWR the exception identified in Footnote (2) of through TS-4 welds. Inspection is operating experience, the inspection activities of the BWR Vessel Internals Program is no recommended when techniques or accessibility BWRVIP-41 are considered sufficient to ensure the longer applicable or necessary.

becomes available. Also, there are other welds integrity of the jet pump assemblies during the mainly along the diffuser lower section where period of extended operation for JAFNPP. The staff has endorsed the inspection and coverage is low due to interference from core flaw evaluation guidelines in BWRVIP-41 shroud gussets, tierods, and others. The This requires an LRA amendment. for jet pump assembly components in a BWRVIP is also pursuing an analysis to reduce safety evaluation dated June 5, 2001 or alleviate inspection of the adapter welds. A (ADAMS Accession No. ML011570460).

technical justification for inspecting inaccessible jet pump welds, and the deferral of The Applicant amended the LRA to clarify beam UT inspection has been prepared per the above as stated in amendment letter BWRVIP-94 guidelines. Finally, several high No. 5, dated February 01, 2007. This priority ranked welds in JP-1,2,3, 4, 19 and 20 question is resolved.

previously scheduled for inspection in RO16, were deferred to RO17 (one cycle deferral) with technical justification.

The technical justification in this exception for justifying deferral of the augmented inspections for the jet pump assembly components covered in Footnote 2 does not credit any inspection-based aging management criteria for these components. Provide your basis for concluding that the deferral of the augmented examinations for those jet pump assembly components addressed in Footnote 2 is valid and that other augmented inspections of other jet pump assembly components performed to date and in the future in accordance with BWRVIP-41 will be sufficient to ensure the integrity of the jet pump assemblies during the period of extended operation for JAFNPP.

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158 258 The GALL XI.M27states that the aging JAF does not utilize a water storage tank for fire The project team finds the applicant's management program applies to water based protection water. The fire water source is Lake response acceptable because JAF does fire protection systems that consist of Ontario. Further details regarding the fire water not utilize a water storage tank for fire sprinklers, nozzles, fittings, valves, hydrants, system are provided in JAF-RPT-05-AMM14, Aging protection water and hence they are not hose stations, standpipes, water storage tanks, Management Review of Fire Protection - Water included in the program. This question is and above ground and underground piping.... System, which was available for review on site. resolved.

The LRA does not mention the water storage tanks. Does JAFNPP have water storage tanks associated with its Fire Water System? If so, what is the justification for not including in AMP B.1.13.2 and how are the aging effects managed?

159 259 The exception for AMP B.1.13.2, "Parameters The method of performing the flow testing is in The project team finds the applicant's Monitored/Inspected" program element states accordance with Chapter 5, Section 11 of the Fire response acceptable because a that the periodic flow testing of the water Protection Handbook, 14th Edition. This is the comparison of Section 11, Chapter 5 of system is performed in accordance with same as the flow test required by NFPA 25. the Fire Protection Handbook and NFPA Section 11, Chapter 5 of the Fire Protection 25 confirmed that the extent of the testing handbook. NUREG -1801, Revision 1, states requirements, the acceptance criteria and that the periodic flow testing of the water the analysis of the test data outlined in system should be performed using the Section 11, Chapter 5 of the NFPA Fire guidelines of NFPA 25. Describe the Protection Handbook followed the differences between these documents. Provide guidance provided in NFPA 25. Overall, the technical basis why flow testing of the water staff noted that the NFPA Fire Protection system performed in accordance with Section Handbook periodic water flow testing 11, Chapter 5 of the Fire Protection handbook is follows the NFPA 25 recommendations acceptable. and is adequate to assess the ability of the system to perform its intended function. This question is resolved.

160 260 The exception for AMP B.1.13.2, "Detection of Per NUREG-1800, Table 2.1-3, gaskets are The project team finds the applicant's Aging Effects" program element states that consumables not subject to aging management response acceptable because visual visual inspection, re-racking and replacement review. Therefore, the exception to the Fire Water inspection, re-racking and replacement of of gaskets in couplings occurs at least once per System program related to annual gasket gaskets is done in accordance with Plant operating cycle. NUREG -1801, Revision 1, inspections incorrectly states an exception to the Technical Requirements Manual and is specifies an annual inspection frequency. inspection frequency. The exception should state the current licensing basis. The applicant Provide a technical basis why the proposed that gaskets are not subject to aging management amended the LRA. See amendment letter frequency is acceptable. review since they are periodically inspected, tested No. 5, dated February 01, 2007, to state 100

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and replaced. that gaskets are not subject to aging Inspection, testing, and replacement of gaskets are management review since they are conducted per JAFNPP Technical Requirements periodically inspected, tested and replaced Manual, Rev. 12, at least once every 18 months based on performance or condition (24 months in high radiation areas) and hydrostatic monitoring. This question is resolved.

tests are performed at least once every 36 months (48 months in high radiation areas).

As stated in Section 2.1.2.4.4 of the LRA, replacements occur based on the results of inspections and testing.

This requires an LRA amendment.

161 261 The program description in GALL XI.M27 states Deluge, dry pipe and preaction sprinkler systems The project team finds the applicant's

...these systems are normally maintained at are not maintained at normal system operating response acceptable because deluge, dry required operating pressure and monitored pressure. The systems are normally dry and will pipe and pre-action sprinkler systems are such that loss of system pressure is only fill with water when a fire is detected. The fire not normally maintained at required immediately detected....where as the LRA hose standpipe located in the MG set fan room is operating pressures. These systems are states ...many of these systems are normally normally maintained dry due to the potential for normally dry and will only fill with water maintained at required operating pressure and freezing. If needed, the standpipe is filled and when a fire is detected. This question is monitored....The use of the phrase many of pressurized by use of a local valve. resolved.

these infers that there are some fire water systems that are NOT normally maintained at required operating pressure. If the foregoing statement is true, what are the fire water systems that are NOT normally maintained at required operating pressures and why?

162 262 The fire hoses were excluded from aging LRA Section B.1.13.2 states the hoses are not The project team finds the applicant's management as an exception to NUREG 1801, subject to aging management since they are response acceptable because inspection, Rev 1, as a category (c) consumable per the periodically inspected, hydrotested, and replaced. testing, and replacement of fire hoses are guidelines of NUREG 1800. Why wasnt it This matches the category (d) criterion of typically conducted per JAFNPP Technical excluded as a category (d) consumable replaced based on performance or condition Requirements Manual, Rev. 12. The instead? monitoring. Inspection, testing, and replacement of applicant amended the LRA to clarify that fire hoses are conducted per JAFNPP Technical fire hoses are replaced based on periodic Requirements Manual, Rev. 12, at least once every performance or condition monitoring and 18 months (24 months in high radiation areas) and are excluded from aging management 101

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hydrostatic tests are performed at least once every review per Table 2.1-3 of NUREG-1800 36 months (48 months in high radiation areas). As Rev. 1.

stated in Section 2.1.2.4.4 of the LRA, replacements occur based on the results of See amendment letter No. 5, dated inspections and testing. February 01, 2007. This question is Section B.1.13.2, exception note 2 of the LRA will resolved.

be revised to state Fire hoses are replaced based on periodic performance or condition monitoring and are excluded from aging management review per Table 2.1-3 of NUREG-1800 Rev. 1.

This requires an LRA amendment.

163 263 The enhancement for wall thickness evaluation Appendix A was written from the perspective of The project team finds the applicant's of fire protection piping is identified in the entry into the period of extended operation. At that response acceptable because it is Appendix A write-up in the present tense, time, all aging management programs will be in appropriate for the UFSAR supplement to meaning the inspections are being performed. place. From that perspective, it is appropriate for be written in present tense to reflect the However the enhancement is addressed in the UFSAR supplement to be written in present condition during the PEO . This question Appendix B (Detection of aging effects) in the tense. A list of commitments is provided during the is resolved.

future tense, meaning the inspections will be license renewal review that clearly shows the performed in the future (before the end of the commitments for program enhancements.

current operating term). The Appendix A should be revised to address this future commitment.

164 264 The enhancement for revising procedures to Section A.2.1 of the LRA states, "All aging The project team finds the applicant's include inspections of hose reels for corrosion management programs will be implemented prior to response acceptable because the is not addressed in Appendix A. Appendix A entering the period of extended operation." This applicant amended the LRA Appendix A to should be revised to address this future includes enhancements to the Fire Water System describe the enhancement. See commitment. Program. For additional clarification, LRA Appendix amendment letter No. 5, dated February A will be revised as follows. 01, 2007. This question is resolved.

Section A.2.1.14, Fire Water System Program, add This program will be enhanced to include inspection of hose reels for corrosion. The acceptance criteria will be enhanced to verify no unacceptable signs of degradation. For sprinkler systems, this program will be enhanced to include visual inspection of spray and sprinkler system 102

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internals for evidence of corrosion. Acceptance criteria will be enhanced for these inspections to verify no unacceptable signs of degradation. A sample of sprinkler heads will be inspected using guidance of NFPA 25 (2002 Edition) Section 5.3.1.1.1. This program will be enhanced to include wall thickness evaluations of fire protection piping using non-intrusive techniques (e.g., volumetric testing) to identify evidence of loss of material due to corrosion. These enhancements will be implemented prior to the period of extended operation.

This requires a LRA amendment.

165 265 FSAR Section 9.8.3.1.5 and LRA Section Aging management review of foam systems is The project team finds the applicant's 2.3.3.5 states that a manually initiated water provided in Table 3.3.2-5 (environment - fire response acceptable because the AMR of foam system is provided as backup to the HPCI protection foam) with discussion in Section 2.3.3.5. foam systems is provided in Table 3.3.2-5 pump room water spray system. Currently there The aging effects from fire protection foam are less (environment - fire protection foam) with is no discussion of aging management review than the aging effects of raw water and are discussion in Section 2.3.3.5. This performed for the foam system in the LRA. managed by the Fire Water System Program. question is resolved.

Please discuss the aging management review for the foam system. The staff requests the applicant to provide a technical justification of why an AMP is not required or provide an AMP that contains the required ten elements.

166 266 The basis provided for exceptions to The flash point test is performed at JAF for the The project team finds the applicant's "Parameters Monitored or Inspected" program emergency diesel engine oils in addition to filter response acceptable because a flash element is not valid since the Flash Point of an residue or particle count, viscosity, total acid/base point reading of the West Diesel Fire industrial lubricant is an important test to (neutralization number), water content, and metals Pump engine lubricant is taken annually determine if light-end hydrocarbons are getting content. The flash point test is one method for the with an engine oil change of every six into the oil through seal leaks or other means. It detection of oil that has been contaminated with years. Since the lubricating oil in the is an effective way to monitor seal performance light-end hydrocarbons such as fuel oil. While it is engines of the security backup generator in light end hydrocarbon compressors. Low important from an industrial safety perspective to and the emergency diesel generator are Flash Points pose a safety hazard in the event monitor flash point, it has little significance with changed on a regular basis these of component failure that can generate heat respect to the effects of aging. As such it is only components do not require the flash point above the flash point of the oil, such as bearing utilized in scope components such as diesel tests specified in this section of the GALL 103

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failure. Justify the reason for not monitoring the engines which have the potential for hydrocarbon Report. Since the West Diesel Fire Pump flash point of lubricating oil and why this accumulation such as fuel oil. Flash point is engine is the only in-scope component of exception is acceptable to manage the effects determined for the lubricating oil of the West Diesel concern, the exception, is not needed.

of aging for which it is credited. Fire Pump once per year. In addition, a 6 month oil The applicant committed to amend the sample is taken and tested to check for LRA to remove this exception. In its contaminants. The West Diesel Fire Pump has a response dated February 1, 2007, the scheduled 6 year oil change frequency, but will be applicant revised the LRA Section B.1.20 changed more often if the 6 month sample deems to delete this exception. This question is necessary. The Security Generator oil is changed resolved.

annually and therefore, does not require a flash point test. Therefore, the exception listed in the LRA B.1.20 is not required and will be removed.

This requires an LRA amendment.

167 268 LRA Section 2.3.3.6 describes the carbon As noted in Table 3.3.2-6 of the application, the The project team finds the applicant's dioxide (CO2) fire suppression system as being aging effects of the fire protection - CO2 system response acceptable because it will in scope of the license renewal and subject to components are managed by the Bolting Integrity include CO2 within the scope of the an AMR. The AMP for CO2 fire suppression Program (Section B.1.30) and by the Fire program. Specifically, in its response system does not appear in LRA Section Protection Program (B.1.13.1). The Fire Protection dated February 1, 2007, the applicant B.1.13.1, Fire Protection Program. Program is consistent with NUREG-1801 Section amended the LRA (Amendment No. 5)

XI.M26 which as noted in the question includes "program description" Section B.1.13.1 to The NUREG-1801, GALL Report Section activities to manage the effects of aging on the state "The program also includes Plant XI.M26, Fire Protection, describes the intended functions of the fire protection - CO2 CO2 fire suppression system valve position requirements for aging management of the CO2 system. A review of station operating experience checks and operational tests, CO2 storage fire suppression system. It requires that an identified no aging-related degradation adversely tank level and pressure checks, system AMP be established to evaluate the periodic affecting the operation of the CO2 system. functional checks, and external surface visual inspection and function test is performed inspections,"

at least once every six months to examine the CO2 fire suppression valve position check and signs of degradation of CO2 fire suppression operational tests are performed quarterly (once per In addition, the applicant added an system. Material conditions that may affect the 92 days). In addition, CO2 storage tank level and exception to LRA Section B.1.13.1 to performance of the system, such as corrosion, pressure are checked monthly in accordance with perform the full CO2 system functional test mechanical damage, or damage to dampers, surveillance test ST-76A. Full CO2 system on a 24-month basis rather than the six-are observed during these tests. The staff functional tests are performed once per 24 months month periodicity listed in NUREG-1801 requests that the applicant describe AMP and in accordance with the station's current licensing element "detection of aging effects. The operating experience for the CO2 fire basis. An inspection of external surfaces of the current licensing basis (CLB) for JAFNPP suppression system in LRA Section B.1.13.1 CO2 fire suppression system is performed at least is to perform the full CO2 system functional once every six months to check for signs of test on a 24-month basis in accordance degradation. with JAFNPP TRM Section 3.7.J. The 104

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A reference to the plant CO2 fire suppression code of record for the CO2 fire suppression systems will be added in the program description of system is NFPA 12, 1968 Edition. This LRA Section B.1.13.1 (Fire Protection Program). In edition did not specify any frequency for addition, an exception to the six-month periodicity the CO2 fire suppression system functional listed in NUREG-1801 for the full CO2 system test. The surveillance frequency for the functional test will be added to LRA Section CO2 fire suppression system to perform B.1.13.1 to perform this functional test on a 24- functional test provided in the GALL month basis as listed in the current licensing basis Report is based on the current NFPA 12.

for JAF. This frequency is considered sufficient to ensure system availability and operability based on The 24-month CO2 fire suppression station operating history and to ensure that aging functional test frequency is part of the CLB related effects will be properly managed through and the review of JAFNPP operating the period of extended operation. The NRC Staff, experience indicated that this frequency is as documented in the SER for Oyster Creek, has reasonable to manage the aging effects.

accepted the position that, in the absence of aging- The 24-month frequency is considered related events adversely affecting system operation sufficient to ensure system availability and and provided that visual inspections of component operability based on the plant operating external surfaces are performed every six months, history, and that there has been no aging-the periodicity specified in the current licensing related event that has adversely affected basis for functional testing of the CO2 system is system operation. Because these aging sufficient to ensure system availability and effects occur over a considerable period of operability. time, the project team concluded that the 24-month inspection interval will be These items each require an LRA amendment. sufficient to detect aging of CO2 fire suppression system. This question is resolved.

168 269 UFSAR 9.8.3.11 states that Halon System is The Emergency and Plant Information Computer The project team finds the applicant's used for fire protection in the Emergency and (EPIC) system is not credited for a safe shutdown response acceptable because Halon Plant Information Computer (EPIC) Room in any fire scenarios to demonstrate compliance System has no intended function for where it is not desirable to use a water spray or with 10 CFR 50.48. Therefore, the Halon System license renewal. This question is resolved.

a sprinkler system. Is this system credited for a has no intended function for license renewal.

safe shutdown in any fire scenarios to demonstrate compliance with 10 CFR 50.48? If so, provide a technical justification of why an AMP is not required or provide an AMP that contains the required ten elements.

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169 271 The enhancements are not addressed in the Section A.2.1 of the LRA states, All aging The project team finds the applicant's Appendix A program description. Please management programs will be implemented prior to response acceptable because the provide justification or reasons for not placing entering the period of extended operation. This applicant amended the LRA Section the enhancements in section A.2.1.13 of the includes enhancements to the Fire Protection A.2.1.13 to clearly identify the program LRA? Program. For additional clarification, LRA Appendix enhancements. See amendment letter No.

A will be revised as follows. 5, dated February 01, 2007. This question is resolved.

Section A.2.1.13, Fire Protection Program, add This program will be enhanced to inspect fire barrier walls, ceilings, and floors at least once every refueling outage. Inspection results will be acceptable if there are no visual indications of degradation such as cracks, holes, spalling, or gouges. This program will be enhanced to inspect at least one randomly selected seal of each type every 24 months. These enhancements will be implemented prior to the period of extended operation. This requires a LRA amendment.

170 272 The "Operating Experience" section states that The issues identified in the OE report deal The project team finds the applicant's inspections and tests from 2000-2004 identified specifically with fire door gaps that were beyond response acceptable because the signs of degradation of fire barriers. Please their required values and minor cracking found in operating experience issues identified did describe the corrective actions taken to ensure masonry walls. These issues do not adversely not adversely impact the ability of the that components will continue to perform its impact the ability of the barriers to satisfy their fire barriers to satisfy their fire protection intended safety function. protection function. In all cases the barriers or function and the applicant is addressing doors were repaired. Periodic inspections are any degradation issues via the plant performed to ensure any issues are identified and corrective action process. This question is corrected in a timely manner. resolved.

171 278 Generic Question on AMRs - Sections 3.1 to The One-Time Inspection Program is credited in The project team finds the applicant's 3.4 (1) the Table 2 AMR entries when it is used to verify response acceptable because the the effectiveness of other AMPs in the LRA. A effectiveness of the water chemistry

1. The staff noted that certain Table 1 AMR plant-specific note is included for the each Table 2 control program associated with each line-items correctly credit the OTI program to line item crediting a water chemistry control AMR line item is confirmed by the One-verify the effectiveness of the Water Chemistry- program. This note indicates that the One-Time Time Inspection Program, irrespective of BWR AMP, when necessary. However, the Inspection Program will verify the water chemistry whether the One-Time Inspection Program Table 2 AMR line-items corresponding to these control programs effectiveness. Since the One- is one of the AMPs, a note indicating its Table 1 line-items do not credit the OTI Time Inspection Program is a sampling program, inclusion as one of the AMPs, or water 106

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program. Instead, a plant-specific note is every individual component is not subject to an chemistry control program alone. It should included for the Table 2 line-items indicating inspection. Consequently, the One-Time Inspection be understood that including the One-that the OTI program will verify the Program is more appropriately associated with the Time Inspection Program in a note rather effectiveness of the Water Chemistry-BWR applicable water chemistry program. The plant- than in the Aging Management Program program. This is inconsistent with the guidance specific note is intended to simplify the tables in column of the tables does not minimize its provided in NUREG-1801, Revision 1 and NEI Sections 3.1 through 3.4 of the LRA. Since the importance. To implement this AMP, the 95-10, Revision 6. plant specific note is applied to every line item entire list of components crediting water crediting a water chemistry control program, it chemistry control programs for aging The staff has three concerns with the approach should be understood by the reader that management will have to be considered to used in the JAFNPP LRA for crediting the OTI effectiveness of the water chemistry program determine the representative sample for program as a verification program. associated with each line item is confirmed by the inspection. Therefore, the One-Time One- Time Inspection Program. Inspection Program cannot be overlooked

i. The plant-specific note used for the Table 2 even though it is not listed in the Aging AMR line-items does not provide a clear This is not inconsistent with NUREG-1801, Management Program column of the commitment as to how the OTI program will be Revision 1, which does not prescribe how the Table 2 AMR line-items. This question is resolved.

implemented to verify the effectiveness of the tables in Sections 3.1 through 3.4 of the LRA AMP credited for that AMR. The staff finds this should look, but merely states that water chemistry plant-specific note is vague and, therefore, control AMPS are to be augmented by verifying unacceptable. the effectiveness of water chemistry control. See Chapter XI.M32, One-Time Inspection, for an ii. Crediting the OTI via a plant-specific note acceptable verification program. The LRA clearly minimizes the importance placed on this indicates that this is the case as described above.

verification inspection. When OTI is credited to verify the effectiveness of an AMP, the staff It is also not inconsistent with NEI 95-10, Revision considers this a critical element for accepting 6 which also does not prescribe how the tables in the AMR. Including the OTI in a note does not Sections 3.1 through 3.4 of the LRA should look, reflect the importance level placed on this but merely states that Sections 3.1 through 3.4 of verification by the staff. the LRA contain tables that summarize the aging management reviews for the systems. This iii. The staff is concerned that the OTI could be subsection also contains a summary of the overlooked if it is not included directly in each materials, environments, aging effects requiring of the Table 2 AMR line-items for which it is management and aging management programs for credited. Please explain why the OTI program each subsystem. NEI 95-10, Revision 6 also does is not credited in the Table 2 AMR entries when not indicate how plant-specific notes should be it is used to verify the effectiveness of other used, but states only that, Any notes the plant AMPs in the LRA. In the response, please requires that are in addition to the standard notes address each of the aforementioned staff will be identified by a number and deemed plant-concerns with this approach. This applies to specific.

Sections 3.1 through 3.4 of the LRA.

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Each of the staffs concerns with this approach is addressed below.

I. That is correct, the plant-specific note used for the Table 2 AMR line-items does not provide a clear commitment as to how the One-Time Inspection program will be implemented to verify effectiveness of the water chemistry control programs. However, listing the One-Time Inspection Program in the Aging Management Program column of the table for each line item crediting a water chemistry control program also does not provide a clear commitment as to how the One-Time Inspection Program will be implemented.

The commitment to implement the One-Time Inspection Program is contained in LRA Section B.1.21 and in LRA Appendix A.

II. As stated above, the plant-specific note is not intended to obfuscate use of the One-Time Inspection Program. It is intended to simplify the tables in Sections 3.1 through 3.4 of the LRA.

Since the plant specific note is applied to every line item crediting a water chemistry control program, it should be understood by the reader that effectiveness of the water chemistry control program associated with each line item is confirmed by the One-Time Inspection Program.

Including the One-Time Inspection Program in a note rather than in the Aging Management Program column of the tables does not minimize its importance. See response to iii, below.

III. The commitment to implement the One-Time Inspection Program is contained in LRA Section B.1.21 and in Appendix A. In accordance with NUREG-1801, XI.M32, with which the One-Time Inspection Program is consistent, the inspection includes a representative sample of the population, 108

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and, where practical, focuses on the bounding or lead components most susceptible to aging due to time in service, severity of operating conditions, and lowest design margin. Engineering report JAF-RPT-05-LRD-02, Aging Management Program Evaluation Report, (AMPER) is available for onsite review. The description of this one-time inspection activity in Attachment 2 of the AMPER states that, A representative sample of components crediting water chemistry control programs for aging management will be inspected. However, due to a history of low oxygen and high iron (magnetite) content in the Reactor Building Closed Loop Cooling System, a specific sample of components in this system will be inspected. To implement this activity, the entire list of components crediting water chemistry control programs for aging management will have to be considered to determine the representative sample. Therefore, the One-Time Inspection Program cannot be overlooked even though it is not listed in the Aging Management Program column of the Table 2 AMR line-items.

172 279 2. In reviewing the AMR line-items presented in Oil Analysis One-time Inspection Activities to For in-scope components that are subject Sections 3.2, 3.3, and 3.4 of the JAFNPP LRA, confirm the effectiveness of the Oil Analysis to AMR and are exposed to diesel fuel oil, the staff noted that the Diesel Fuel Monitoring Program will be added to the One-Time Inspection the applicants periodic visual testing in Program (AMP B.1.9) and the Oil Analysis Program and applicable sections of the LRA accordance with its Diesel Fuel Oil Program (AMP B.1.20) are correctly credited to revised. This requires an amendment to the LRA. Monitoring Program. This is consistent manage loss of material for components with the [Detection of Aging Effects]

exposed to fuel oil and lubricating oil, Diesel Fuel Monitoring One-time Inspection program element in GALL AMP XI.M30, respectively. NUREG-1801, Revision 1, Fuel Oil Chemistry, and is acceptable.

recommends that the effectiveness of these The inspections that are being credited in lieu of a Thus, a one-time time inspection of the programs be verified, and a one-time inspection one-time inspection include visual inspections of diesel fuel oil tanks is not necessary (OTI) of selected components at susceptible components at the most susceptible locations for because the visual examinations of the locations is noted to be an acceptable method components containing fuel oil such as the bottom diesel fuel oil tank is performed on a of verification. The further evaluations in the of tanks. The aging effects of loss of material and periodic basis when the tank is drained for LRA state that during the past five years, many cracking can only occur in the presence of water. If cleaning. As has been indicated in the visual inspections of components have been significant water accumulation is not allowed to applicants response, the applicant also 109

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performed during corrective and preventive occur, then these aging effects cannot occur. The performs additional inspection of diesel maintenance activities. These past inspections use of visual inspections is an effective and generator components that go beyond the at JAFNPP serve in lieu of a one-time appropriate method for detecting loss of material, recommendations of GALL. This is inspection to provide confirmation of the fouling and cracking which would be indicative of acceptable.

effectiveness of the Diesel Fuel Monitoring an ineffective aging management program.

Program and the Oil Analysis Program. The staff has the following concerns with crediting The sample population includes the most past inspections performed as part of corrective susceptible locations for water accumulation, which and preventive maintenance activities to serve are the low points in systems such as the bottom of in lieu of a one-time inspection. tanks or drain lines where aging effects such as loss of material or cracking would most likely occur.

I. A one-time inspection includes several If aging effects are not detected at these locations elements regarding the sample size, inspection then it is highly unlikely that they would be locations, examination techniques, and follow- occurring in other portions of the systems. This up inspections that may not be met by provides objective evidence of the effectiveness of inspections performed during corrective and the aging management programs. Unacceptable preventive maintenance. The staff considers inspections will be evaluated under the site each of these elements to be important in corrective action program and the inspection verifying the effectiveness of an AMP. Unless population will be expanded.

all elements are addressed, the staff would consider the approach unacceptable. The Diesel Fuel Monitoring Program applies to all the systems that contain fuel oil including the ii. Both AMPs ( B.1.9 and 1.20) described in the emergency diesel generators (EDG), and the fire LRA include enhancements that will be protection diesel. The aging effect managed by the implemented prior to the period of extended Diesel Fuel Monitoring Program is loss of material.

operation. As such, inspections performed Three of the four EDG fuel oil storage tanks have during the past five years may not be been inspected since 2001 with the most recent in representative of the AMPs effectiveness for 2004. These inspections occur every 10 years and the period of extended operation, which will revealed no abnormal conditions such as include implementation of the enhancements. corrosion. In addition, components on the EDG's that contain fuel oil are routinely inspected during Please provide the technical justification for engine overhauls. These inspections have also not crediting inspections performed during the past revealed any instances of significant loss of five years as part of corrective and preventive material. These inspections are periodic activities maintenance to serve in lieu of a one-time that occur on an ongoing basis rather than just one inspection for the purpose of verifying the time. The performance of these inspections within effectiveness of AMPs B.1.9 and B.1.20. In the past five years is sufficient since the operating your response, please address each of the license for JAFNPP expires in 2014 and the staffs concerns with this approach. This inspections being credited have been performed 110

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applies to Sections 3.1 through 3.4 of the LRA. since 2001. This provides almost 30 years of operation and exposure to the environments such that latent aging effects would be apparent. In addition, this is consistent with GALL XI.M34 which credits inspections performed during the 10 years prior to the period of extended operation. The enhancements for the Diesel Fuel Monitoring Program will improve the programs such that aging effects are more effectively managed. Past inspection results have found that the existing programs are effective in managing aging effects.

The enhancements to the program will only improve the effectiveness of the program and have no adverse impact on the program such.

Current periodic inspections are credited in lieu of one-time inspection associated with the Diesel Fuel Monitoring Program and are consistent with the One-Time Inspection Program as described in GALL Section XI.M32.

173 280 3. LRA Tables 3.3.2.14- 1, 2, 3,4,7, 8, 10, 14, Section 14 includes all the systems that have The project team reviewed the applicants 16, 17, 19, 20, 21, 22, 42, and 44 address intended functions that meet 10 CFR 54.4(a)(2) for response and determined that this nonsafety- related components affecting safety- physical interaction. To indicate individual systems approach to presenting the AMRs for related systems. However, these Tables included in the aging management review for systems that have intended functions that address all such systems in section 3.3, (a)(2), Table 3.3.2-14 is subdivided by system. For meet 10 CFR 54.4(a)(2) for physical Auxiliary Systems, even though some of these example, Table 3.3.2-14-22 is for the circulating interaction impedes the review process systems belong to Section 3.2, ESF systems water system, a system which only has rather than facilitating it since the SER and Section 3.4, Steam Power Conversion components included for (a)(2). For the core spray preparation is based on systems as Systems. This LRA format is inconsistent with system, Table 3.3.2-14-8 shows the components defined in SRP-LR, which includes six NUREG 1800, Revision 1 and NEI 95-10, included for (a)(2) but since the system is also in specific sections. Each reviewer focuses Revision 6. The staffs SER is written based on scope for other reasons, Table 3.2.2-2 shows the on a specific section, and all of the systems as defined in SRP and GALL Report components included for 54.4(a)(1) and (a)(3). systems included in that section.

Sections 3.2, 3.3, and 3.4. As written in the Therefore, the approach used in this LRA LRA, it will make the SER documentation makes the review more cumbersome difficult and confusing because the SER The aging management review of the systems that since the reviewers must also review Sections 3.2 and 3.4 will include Tables from have functions that met 10 CFR 54.4(a)(2) for Section 3 on auxiliary systems to ensure Section 3.3. physical interaction was done separately from the that all systems in their scope are Please justify why the non-safety systems review of systems with intended functions that met addressed. However, the project team 111

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associated with ESF and Steam Power 10 CFR 54.4 (a)(1) or (a)(3). The results of this determined that this approach is Conversion Systems were included in the review were presented separately so that they administrative in nature, and does not Auxiliary System. could be reviewed separately on the basis of impact the technical accuracy of these physical proximity rather than system function. This AMRs. Therefore, the project team finds allows a reviewer to clearly distinguish which it acceptable for this LRA. This question component types in a system were included for 10 is resolved.

CFR 54.4(a)(2) for physical interaction. Since most of these systems are auxiliary systems they were added as part of the auxiliary systems section.

174 281 The aging management program column of the The aging management program column entries in The project team finds the applicants AMR line item states that the inservice Table 3.1.1 (in fact entries for all but the discussion response acceptable because the inspection program and water chemistry column) are quoted from GALL. In line 3.1.1-49, applicant is using the BWR Vessel program will be credited with aging GALL recommends the ISI program and water Internals Program and the augmented management of SCC, IGSCC, and IASCC in chemistry while the Discussion column entry inspection criteria of BWRVIP-38 for the the access hole covers. In contrast the indicates JAFNPP has chosen to credit the BWR inspections of shroud support discussion column of the AMR line item states internals program along with water chemistry. components, including the shroud that the BWR Internal Program and the Water This difference of programs is reflected in the use manway covers (i.e, access hole covers).

Chemistry Program will be used for aging of note E in the next to last entry on page 3.1-55 of BWRVIP-38 was endorsed by the NRC for management of SCC, IGSCC, and IASCC. the application. The comparison of the manway use in a safety evaluation dated March 1, Resolve the difference between the column covers (access covers) portion of this line is to 2001. The BWRVIP-38, as endorsed by entries and clarify which inspection-based GALL item IV.B1-5 using the BWR Vessel Internals the staff provides a basis for the AMP, along with the Water Chemistry Program, and water chemistry programs, consistent with inspections of the manway covers. Refer will be used to manage these cracking other parts of the shroud support that are to Item 135 for additional bases for mechanisms in the access hole covers. compared to IV.B1-2. acceptance. This question is resolved.

175 282 The discussion section in GALL AMR line item JAFNPP does not have a piping and The project team finds the applicants IV.B1-5 (R-94) states that because cracking instrumentation diagram that shows the core response acceptable because the plant-initiated in crevice regions is not amenable to support plate access hole covers. They are shown specific configuration in JAFNPP drawing visual inspection, for BWRs with a crevice in (by sketch) in BWRVIP-15, Section 10. Excerpts 5.02-16 provides sufficient evidence that the access hole covers, an augmented from Section 10 are attached below. Note in the the weld configuration for the manway inspection is to include ultrasonic testing (UT) blow-up portion of Figure 2.10.2.4 that the access cover (access hole cover) does not create or other demonstrated acceptable inspection of hole cover is welded to the shroud support ledge a creviced region. Based on this the access hole cover welds. In the discussion with a full penetration weld that leaves no crevice evidence, the project team concludes that of AMR-line item 3.1.1- 49, Entergy states that behind the weld. The JAFNPP plant specific the augmented UT examination JAFNPP has welded access hole covers with configuration is shown on drawing 5.02-16. recommended in GALL AMR IV.B1-5 (R-112

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no crevice behind the weld. It is not clear how 94) does not need to be performed for the the access hole cover could be welded to the period of extended operation, and the support plate without creating a creviced region augmented inspections recommended in in the access hole cover design. Demonstrate, BWRVIP-38 are adequate to use as the using an appropriate piping and instrumentation basis for inspecting the manway cover.

diagram (P&ID), how and why the welded This question is resolved.

access hole cover configuration does not create a creviced region in the core support plate design. If upon further review it is determined that the welded configuration does create a creviced region in the support plate design, the staff requests that the inspection-based program for the access hole covers (i.e.

presumably the BWR internals program) be augmented to include a UT examination of the access hole cover weld, as is recommended by the NRC position established in GALL AMR line item IV.B1-5.

176 283 LRA Section 3.5.2.2.1.4 ( Loss of material due As stated in Section 3.5.2.2.1.4, JAFNPP This question is closed to RAI 3.5.2-2.

to General, Pitting and Crevice Corrosion) - inspections of the drywell shell below floor level Please explain the last statement in this section identified no evidence of corrosion of the drywell The applicant provided its response to this Therefore, significant corrosion of the drywell shell. The drywell shell steel has a coated surface question in staff's RAI 3.5.2-2 in LRA shell is not expected. What does this mean? and no degradation of this coating was identified. Amendment No. 6 dated February 12, Does this mean that JAFNPP has identified The statement in question is not addressing the 2007.

some corrosion, but not significant? Define current condition but rather the conditions expected what is "significant corrosion." Provide a in the future. It is difficult to say there will be The specific details of RAI 3.5.2-2 also discussion of the inspections performed and absolutely no corrosion in the future, but there is pertain to the programs and activities for actions taken to prevent corrosion. reasonable assurance that corrosion, if any, will not managing corrosion in the drywell shell.

be significant or meaningful with respect to degradation.The staffs basis for resolving RAI 3.5.2-2 Reference RAI 3.5.2-2. is deferred to and given in SER Section 3.5.2.3.1.

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177 284 LRA Section 3.5.2.2.1.4 (Loss of material due For JAFNPP, the sand cushion area at the base of This item is closed to RAI 3.5.2-1.

to General, Pitting, and Crevice Corrosion) - the drywell is drained to protect the exterior surface Discuss how JAFNPP compares to ISG-2006- of the drywell shell at the sand cushion interface In LRA Amendment No. 6, dated February 01, Plant specific aging management program from water that might enter the air gap. To ensure 12, 2007, the applicant responded to for inaccessible areas of boiling water reactor the drywell shell exterior remains dry during RAI 3.5.2-1 and stated that there has been mark I steel containment drywell shell, refueling evolutions, the drywell to reactor building no observed leakage causing moisture in proposed action (4). bellows assembly separates the refueling cavity the vicinity of the sand cushion drain line filled with water from the exterior surface of the visual examination of the exterior of the drywell shell. Any leakage through the bellows torus and torus room in accordance with assembly is directed to a drain system which is IWE requirements.

equipped with an alarm for notification of operators.

Functional checks are performed on the alarm The specific details of RAI 3.5.2-1 also system and the air gap drains are monitored twice pertain to the programs and activities for every refuel outage, once after flood-up and again managing corrosion in accessible regions prior to flood-down at the end of the outage. of the drywell shell. The staffs basis for JAFNPP inspects the liner drains for the water resolving RAI 3.5.2-1 is deferred to and reservoirs on the refuel floor (e.g., spent fuel pool, given in SER Section 3.5.2.3.1.

dryer/separator pool, and reactor cavity) for leakage. Leakage into the liner drains could be a precursor for water leaks which could wet the drywell shell exterior surface. These drains are examined for leakage after filling the refueling cavity.

178 285 LRA Section 3.5.2.2.1.4 (Loss of material due To ensure the drywell shell exterior remains dry The project team finds the applicant's to General, Pitting, and Crevice Corrosion) - during refueling evolutions, the drywell to reactor response acceptable because the Discuss how JAFNPP compares to ISG-2006- building bellows assembly separates the refueling applicant has completed all required 01, Plant specific aging management program cavity filled with water from the exterior surface of inspections in accordance with ASME for inaccessible areas of boiling water reactor the drywell shell. A backing plate surrounds the Section XI requirements and ISG-2006-01 mark I steel containment drywell shell, outer circumference of the bellows to protect it and and the applicant's observations of proposed action (5) provide a mechanism for testing and monitoring of absence of water leakage into the drywell leakage. Any leakage through the bellows shell area. In addition, the Operating assembly is directed to a drain system which is experience review at JAF found no equipped with an alarm for notification of operators. occurrences of leakage into the annulus Functional checks are performed each refueling air gap. This question is resolved.

outage on the flow switch associated with this alarm system. If moisture/leakage is detected in In addition, this item is closed to RAI the inaccessible area on the exterior of the drywell 3.5.2-1. The applicant responded to RAI shell JAFNPP will: 3.5.2-1 in LRA Amendment No. 6, dated 114

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February 12, 2007, the applicant (a)Identify the component source which may have responded to RAI 3.5.2-1. The specific introduced the moisture/leakage and include the details of RAI 3.5.2-1 also pertain to the component in an aging management review programs and activities for managing program, corrosion in the inaccessible regions of (b)Identify the surface areas requiring examination the drywell shell. The staffs basis for and implement augmented inspections for the resolving RAI 3.5.2-1 is deferred to and period of extended operation in accordance with given in SER Section 3.5.2.3.1.

the American Society of Mechanical Engineers (ASME)Section XI IWE-1240 as identified in Table IWE-2500-1, Examination Category E-C and, (c)Demonstrate through use of augmented inspections performed in accordance with ASME Section XI IWE that corrosion is not occurring, or that corrosion is progressing so slowly that the aggregated degradation will not jeopardize the intended function of the drywell shell through the period of extended operation. Operating experience review at JAF found no occurrences of leakage into the annulus air gap. In addition, no leakage has been found through the refueling bellows into the area monitored by the air gap leakage detection system. Functional checks are performed prior to each refueling on the instrumentation associated with this leakage detection system.

179 286 LRA Section 3.5.2.2.2.1 (Aging of structures As stated in LRA Section 3.5.2.2.2.1, JAF has no The project team finds the applicant's not covered by Structures Monitoring Program) structures that are not covered by structures response acceptable because the plant

- Are there JAFNPP-specific OE related to this monitoring program that are within the scope of operating experience did not reveal any area? Please, provide the details. license renewal and subject to aging management degradation not bounded by the industry review. operating experience and the applicant The operating experience for concrete structures has addressed the degradation issues not covered by the Structures Monitoring Program through their corrective action process.

indicates signs of minor degradation (concrete), This question is resolved.

and cracks and separations (block wall). But, none affected the structural integrity of the walls. The separations and cracks were repaired prior to the loss of intended function.

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180 287 LRA Section 3.5.2.2.2.1.8 ( Lock Up due to Lubrite plates are used for the Drywell main radial The applicant amended the LRA Section wear for Lubrite Radial beam Seats in BWR beam shell connections at elevations 269-6 and B.1.27.2 to enhance the Structures drywell and other Sliding Support Surfaces) - 290-4. Lubrite plates are used for the Torus Monitoring Program to include guidance Please identify applicable design drawings for column support connections at the floor level. for performing periodic inspections to project team's review. As indicated in this Although Lubrite plates are included in Structural confirm the absence of aging effects of section that ...lock-up due to wear is not an Maintenance Rule Monitoring, the Drywell main lubrite surfaces. See amendment letter aging effect requiring management at JAFNPP. radial beams and connections are non-pressure No. 5, dated February 01, 2007. This However, Lubrite plates are included within the retaining parts and were designed per the AISC question is resolved.

Structures Monitoring Program and Inservice Manual of Steel Construction (Ref, Structural Inspection (ISI-IWF) Programs... Please, General Design Criteria GDCD-S-5).

provide the cross references between these two programs. There is no cross-reference between Structures Monitoring Program and Inservice Inspection (ISI-IWF) Programs relative to lubrite plates. Lubrite plates are included within the Structures Monitoring Program and not Inservice Inspection (ISI-IWF).

This is license renewal commitment 16. This requires an LRA amendment.

181 288 LRA Section 3.5.2.2.2.6 (Aging Support not Bolting material at JAFNPP consist of the following The project team finds the applicant's covered by Structures Monitoring Program) - combination A325 - Type 1 conforming to ASTM- response acceptable, because bolting Please provide the following information: A325 and ASTM-A307 per JAFNPP specification used in structural applications at JAFNPP A-8 Structural Steel. The nominal yield for A325 is are not susceptible to SCC, and (a.) More information is needed about bolting 92 ksi and for A307 is 60 ksi. For structural bolting consequently do not require any materials used in structural applications application JAFNPP is consistent with NUREG augmented inspection. As applicable, including Group B1.1 applications at JAFNPP. 1801 for bolting integrity by managing aging with either the Structures Monitoring Program (I) What are the materials used for bolting? the structures monitoring program or ISI (IWF) as or ISI (IWF) manage aging of structural (ii) What are the nominal yield strengths and applicable. No JAFNPP structural bolting have bolting.

upper-bound as-received yield strengths? been identified that is susceptible to SCC.

(iii) Describe the JAFNPP resolution of the This question is resolved.

bolting integrity generic issue, as it relates to structural bolting.

(iv). Was any structural bolting identified as potentially susceptible to cracking due to SCC?

Was any structural bolting replaced as part of the resolution?

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182 289 LRA Section 3.5.2.2.2.6 (Aging Support not JAFNPP has not identified Class MC pressure The project team finds the applicant's covered by Structures Monitoring Program) - retaining bolts having a yield stress >150 ksi within response acceptable, because the Please provide the following information: the boundaries for structural applications. As a applicant has adequately described how result loss of preload is not an aging effect loss of preload is managed. The service b.) Describe the scope and aging management requiring management. temperature for the structural bolting is review performed for Class MC Pressure In general, JAF manages loss of material for below the 700°F threshold temperature for Retaining Bolting. How is loss of preload bolting with visual inspections. For structural initiation of creep-induced stress managed? bolting, the visual inspections are part of the relaxation, as identified in ASME Code, Structures Monitoring Program. Loss of preload Section II, Part D, Table 4. Thus, the due to stress relaxation (creep) would only be a project team concludes that loss of concern in very high temperature applications (> preload resulting from creep-induced 700°F) as stated in the ASME Code,Section II, stress relaxation is not an aging effect Part D, Table 4. No JAFNPP structural bolting requiring management for these structural operates at >700°F. Therefore, loss of preload due bolts (i.e., Class MC pressure retaining to stress relaxation (creep) is not an applicable bolts).

aging effect for structural bolting. Other causes of loss of preload include inadequate bolted joint The applicant manages loss of preload design and ineffective maintenance practices. Loss due to other causes by incorporation of of preload due to these causes is prevented by industry guidance for good bolting incorporation of industry guidance for good bolting practices into JAF procedures for design practices into JAF procedures for design and and maintenance of bolted joints. The maintenance of bolted joints. project team finds this acceptable.

183 290 Item 3.5.1 In Table 3.5.2-1 on Page 3.5-58 Table 3.5.2-1 on Page 3.5-58 of the LRA, for The applicant amended the LRA Table of the LRA, for component Bellows, the AMPs component Inner refueling bellows is not 3.5.2-1 line item inner refueling bellows shown is CII-IWE, which is a plant-specific consistent with the referenced NUREG-1801 Vol. 2 and the corresponding line item in Table AMP. A Note C has been assigned to this AMR item. The Table 3.5.2-1 line item inner refueling 2.4-1 is deleted. The inner refueling line item, Component is different, but bellows and the corresponding line item in Table bellows perform no license renewal consistent with material, environment, aging 2.4-1 should be deleted. The inner refueling intended function. See amendment letter effect, and aging management program for bellows perform no license renewal intended No. 5, dated February 01, 2007. This NUREG-1801 line item. AMP is consistent with function. These components are not safety-related question is resolved.

NUREG-1801 the GALL description. and are not required to demonstrate compliance with regulations identified in 10 CFR 54.4(a)(3).

Provide drawings showing how the LRA line Failure of these bellows will not prevent satisfactory item bellows are different from the GALL Table accomplishment of a safety function. Leakage, if 1 Line Item 3.5.1-13 bellows. Explain how the any, through the bellows is directed to a drain plant-specific CII-IWE AMP is consistent with system that prevents the leakage from contacting the GALL specified AMP. the outer surface of the drywell shell.

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This requires an amendment to the LRA.

184 291 Item 3.5.1 In Table 3.5.2-1 on page 3.5-64 The Structures Monitoring Program, AMP The project team finds the applicant's of the LRA for Primary Containment Electrical B.1.27.2 [Ref. LRA Table 3.5.2-1 Page 3.5-64], will response acceptable because the Penetration seals and sealant, the AMP shown manage aging effect of the drywell moisture barrier. applicant has clarified that CII-IWE is Containment Leak Rate. The applicant is The Containment Leak Rate program, AMP B.1.8 program is not used to manage the aging asked to confirm that AMP CII-IWE will not be [Ref. LRA Table 3.5.2-1 Page 3.5-64], will manage of the moisture barrier. This question is used to manage the aging of the moisture aging effect of the Primary Containment Electrical resolved.

barrier. Penetration seals and sealant.

185 292 Item 3.5.1 In Table 3.5.2-4 on Page 3.5-84 Table 3.5.2-4 on Page 3.5-84 of the LRA, for The applicant has amended the LRA to of the LRA, for component seals and gaskets, component seals and gaskets (doors, manways correct the Note. See amendment letter material rubber in a protected from weather and hatches), material rubber in a protected from No. 5, dated February 01, 2007. This environment; the aging effects are cracking and weather environment; the aging effects are question is resolved. This amendment change in material properties. One of the aging cracking and change in material properties. The clarified that the Footnote for this AMR management programs shown is Structures LRA will be clarified to indicate that Note A line item is A (Not E). Thus, the change in Monitoring. The GALL line item referenced is applies to the line for SMP. the LRA designates that this AMR Item is III.A6-12 and the Table 1 reference is 3.5.1-44. entirely consistent with GALL. The The note shown is E, different AMP than shown This will require an amendment to the LRA. amendment of the LRA makes the AMR in GALL. However, GALL Line Item III.A6-12 item consistent with the project teams and Table 1 Line Item 3.5.1-44 both specify the determination.

Structures Monitoring Program. Explain why the note shown is not A instead of E.

186 294 Item Number 3.5.1 Under the discussion JAFNPP uses a moisture barrier to seal the joint The project team finds the applicant's column, it states that seals and gaskets are not between the containment drywell shell and drywell response acceptable because the included in the Containment Inservice concrete floor. Moisture barrier is listed in LRA applicant has clarified that Structures Inspection Program at JAFNPP. One of the Table 3.5.2-1 as moisture barrier. As indicated in Monitoring Program includes drywell components for this item number is moisture LRA Table 3.5.2-1, aging effects on the moisture interior inspections of moisture barrier.

barriers. Explain how JAFNPP seals the joint barrier will be managed under the Structures This question is resolved.

between the containment drywell shell and the Monitoring Program (AMP B.1.27.1). The drywell concrete floor if there is no moisture Structures Monitoring Program includes drywell barrier. Explain why the inspection of this joint interior inspections. Program inspections have is not part of the Containment Inservice confirmed no visible evidence of water collection or Inspection Program at Fitzpatrick? equipment leakage have been noted in the area of the moisture barrier caulk seal that would challenge the capability of the seal. The moisture barrier was noted to be in good condition and capable of 118

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performing its design function to provide an effective barrier to moisture from entering the interface between the concrete floor and steel shell.

187 295 3.5.1 For LRA Table 3.5.1, Item Number The maximum bulk area ambient temperatures for The project team finds the applicant's 3.5.1-33, provide the maximum temperatures Groups 1-5 occurs in the drywell and is an average response acceptable because the that concrete experience in Group 1-5 temperature of 150°F, reference UFSAR Table 5.2- applicant has described the maximum structures. 3. For structures outside the drywell the bulk area temperatures that concrete experience in maximum temperature applied to structures 120°F Group 1-5 structures. This question is for Groups 1-5 structures based on Section 7.1.12 resolved.

of JAFNPP UFSAR. Concrete within the drywell consist of the reactor pedestal, sacrificial shield wall and the drywell floor. Assurance that bulk concrete temperatures within the drywell remain below 150 degrees F is obtained through maintaining average bulk containment temperature within the limits allowed by JAFNPP Technical Specification Section B3.6.1.5. Although upper elevations of the drywell may exceed 150°F, the concrete of the drywell is at lower elevations. The drywell cooling system provides cooling to ensure temperature limits are not exceeded. The highest concrete in the drywell is the sacrificial shield wall.

The concrete in this wall is not load bearing.

188 296 In LRA, Table 3.6.2-1, under Cable connections Basis for Program Scope: The project team finds the applicant's (metallic parts), you have stated that no aging response acceptable because the effects requiring management and no AMP is Based on the November 30, 2006 meeting with the applicant amended the LRA. See required. Further, in LRA, Table 3.6.1 under NRC, the revised or alternate XI.E6 program will be amendment letter No. 5, dated February discussion of cable connection metallic parts, a one-time inspection of a representative sample of 01, 2007. In this amendment, the you have stated that cable connections outside cable connections subject to aging management review.applicant provided an AMP with ten of active devices are taped or sleeved for The LR project identified connections to include in elements. The project team finds that the protection and operating experience with the aging management program by evaluating the AMP will manage the potential aging of metallic parts of electrical cable connections at JAFNPP non-EQ cable connections that meet the cable connections. The applicant will Fitzpatrick indicated no aging effects requiring criteria of being a bolted connection. implement this AMP prior to the PEO (

management. NUREG 1800, Rev. 1 identifies Switchyard connections are not addressed in this Commitment No. 24, Amendment 9, dated the following aging stressors for electrical cable program, since these connections operate at a April 6,2007. ). This question is resolved.

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connections (metallic parts): thermal cycling, much higher voltage (>35KV); they are addressed ohmic heating, electrical transients, vibration, separately as part of the switchyard commodity types.

chemical contamination, corrosion, and oxidation. Provide a justification for why an Connections for all voltage levels are considered in AMP is not necessary or provide an AMP with scope. As discussed during the November 30, the ten elements for cable connections. 2006 meeting and during the JAF AMR audit, that bolted connections are the main concern.

The stressors thermal cycling, ohmic heating, and electrical transients are potential stressors only for high load connections.

Thermal cycling, ohmic heating, and electrical transients are not potential stressors for low load connections. Low-load connections located in a controlled environment can be screened out, because vibration, chemical contamination, corrosion and oxidation are not a concern. Low-load in-scope field instrumentation connections such as pressure transmitters, RTDs, and flow transmitters are not subject to AMR, because the in-scope instrumentation located in a harsh environment, are typically EQ, and the non-EQ sensitive instrument circuit (high radiation and neutron monitoring) connections which are included in the XI.E2 program. All connections associated with circuits that do not have an intended function, such as general lighting, are not subject to AMR.

Methods To Identify Cable Connections The methods used to identify cable connections to include in the AMP were based on discussions in the November 30, 2006 NEI meeting with the NRC.

The types of circuits considered for identifying cable connections were electrical and I&C penetrations, DC load centers, inverters, battery chargers, motors, MCCs, switchgear, circuit breakers, transformers, metal-enclosed bus, and field components. All of the electrical and I&C penetrations are EQ; therefore, all of the 120

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connections for these penetrations were excluded.

The field components considered includes current /

potential transformers (CTs/PTs), and power supplies. The assumption made for the non-EQ high load connections was that all of these connections are bolted.

The basis discusses the stressors that are being addressed. Plant information (single line drawings, switchyard drawings) was searched to determine the potential population of bolted connections. The criterion used for determining the high load connections was identifying power circuits for all voltage levels. The types of cable connections that were determined to meet the definition of a high load connection are subject to AMR. In addition to the one-time inspection program, many of the JAFNPP cable connections are inspected or tested by PMs. The maintenance procedures (PMs) for the following components were searched to determine if the PM evaluated the field cable connections associated with the active components.

• 480 VAC MCCs and Switchgear (MP-056.01 AC Motor Control Center Maintenance)* 600 VAC MCCs and Switchgear (MP-056.01 AC Motor Control Center Maintenance)* 4160 VAC Switchgear (MP-054.02 4.16kV Bus and Metal-Clad Switchgear)* AC Motors (MP-059.83 Motor Power Monitoring (MPM) Testing and Analysis) DC Motors (MP-059.83 Motor Power Monitoring (MPM)

Testing and Analysis)

• 125 VDC Distribution and Lighting Panels (MP.200.16 Maintenance and Subcomponent Replacement of GE 7700 Series DC Motor Control Centers)

• Battery Control Boards (MP.200.16 Maintenance and Subcomponent Replacement of GE 7700 Series DC Motor Control Centers) 121

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• 125 VDC MCCs (MP.200.16 Maintenance and Subcomponent Replacement of GE 7700 Series DC Motor Control Centers)

• Battery Chargers

• Reserve Transformers (MP-071.42 Station Service Transformer Maintenance)

The maintenance procedures for these component types have details to detect degradation of bolted connections.

The maintenance rule indicators for the systems that contain these commodities do not show problems or issues that have not been resolved.

There is no plant OE that identified degraded connections where the degradation was a result of aging.

Conclusion JAFNPP will have a one-time inspection program that will inspect or test a representative sample of the connection types. The one-time inspection program will verify that there are no aging effects that require management during the period of extended operation. The program will have the following information.

Scope of Program Non-EQ connections associated with cables in scope of license renewal are included in this program. This program does not include the higher voltage (>35KV) switchyard connections. The inscope connections are screened for applicability of this program.

Parameters Monitored/Inspected This program will focus on the metallic parts of the cable connections. The one-time inspection verifies 122

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that the loosening of bolted connections due to thermal cycling, ohmic heating, electrical transients, vibration, chemical contamination, corrosion, and oxidation do not require a periodic aging management program. A representative sample of the electrical cable connection population subject to aging management review will be inspected and tested. The sample will include each type of electrical cable connection. The following factors will be considered for sampling:

voltage level (medium and low voltage), circuit loading (high loading), and location (high temperature, high humidity, vibration, etc.). The technical basis for the sample selected will be documented.

This is listed in the JAF Commitment List #24.

189 297 In LRA, Table 3.6.2-1, under switchyard bus As stated in LRA section 3.6.2.2.3, Connection The project team finds the applicants (switchyard bus for SBO) and connections you surface oxidation for aluminum switchyard bus is response acceptable because switchyard have stated no aging effects requiring not applicable since switchyard bus connections bus connections requiring AMR are management and no AMP is required. NUREG requiring AMR are welded connections. flexible conductor connections that are 1801, Rev. 1 and NUREG 1800, Rev. 1, welded to the switchyard bus and bolted to Section 3.6.2.2.3 identifies loss of preload is an Connection surface oxidation and loosening of other switchyard components. The flexible aging effect for switchyard bus connections. In bolted connections for aluminum switchyard bus is conductors, are included in the infrared addition, EPRI document TR-104213, Bolted not applicable since the switchyard bus PM of the 115 kV switchyard. The Heat Joint Maintenance & Application Guide, connections requiring AMR are welded created by increased resistance of recommends inspection of bolted joints for connections. However, the flexible conductors, switchyard bus connections due to evidence of overheating, signs of burning or which are welded to the switchyard bus, are bolted corrosion or bolt loosening will be detected discoloration, and indication of loose bolts. to the other switchyard components. These using the annual infrared PM. This PM will Provide a discussion why torque relaxation for switchyard component connections are also maintain the integrity of switchyard bus bolted connections of switchyard bus is not a included in the infrared PM of the 115 kV connections The applicant amended the concern for Fitzpatrick. switchyard, which verifies the effectiveness of the LRA 3.6.2.2.3 to clarify that the flexible connection design and installation practices. The conductors will be added to the switchyard infrared PM is performed at least once every year. bus commodity for completeness. See The flexible conductors were not considered part of amendment letter No. 5, dated February the switchyard bus in the application, but these 01, 2007. This question is resolved.

flexible conductors will be added to the switchyard bus commodity for completeness. These flexible 123

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conductor bolted connections are assembled similar to the transmission conductor bolted connections discussed in question 299. For environmental conditions at JAFNPP, no significant aging has been identified that could cause a loss of intended function for the period of extended operation. Vibration is not applicable since flexible connectors connect switchyard bus to active components.

Although not specifically stated, the switchyard connections requiring AMR are welded and bolted connections. Neither of these connection types require aging management, because the loosening of bolted connections is not a significant aging effect.

This requires an LRA amendment.

190 298 In LRA, Table 3.6.2-1, under Transmission The most prevalent mechanism contributing to loss The project team finds the applicants conductors and connections, you have stated of conductor strength of an ACSR (aluminum response acceptable because test data that no aging effects requiring management conductor steel reinforced) transmission conductor from Ontario Hydroelectric, which is and no AMP is required. NUREG 1801, Rev. is corrosion, which includes corrosion of the steel bounded by the types of conductors at 1, Section 3.6.2.2.3 identifies loss of conductor core and aluminum strand pitting. For ACSR JAFNPP, illustrates that transmission strength due to corrosion is the aging effect of conductors, degradation begins as a loss of zinc conductors will have ample strength high voltage transmission conductors. Explain from the galvanized steel core wires. Corrosion through the period of extended operation.

why loss of conductor strength due to corrosion rates depend largely on air quality, which includes Based on this information, the staff is not an aging effect requirement management suspended particles chemistry, SO2 concentration concludes that loss of conductor strength for transmission conductors at Fitzpatrick. in air, precipitation, fog chemistry and is not a significant aging effect requiring Include test data and plant specific acceptance meteorological conditions. Tests performed by management at JAFNPP This question is criteria for transmission conductor strength in Ontario Hydroelectric showed a 30% loss of resolved.

your response. composite conductor strength of an 80 year old ACSR conductor due to corrosion.

RSST 71T-3 is connected to the 115 kV switchyard with overhead transmission lines. The overhead transmission conductors are 336.4 MCM ACSR 18/1 conductors with a 7 AWG alumoweld static wire. This specific conductor type was not included in the Ontario Hydroelectric test, but this type is 124

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bounded by the types that are included. There is a set percentage of composite conductor strength established at which a transmission conductor is replaced. As illustrated below, there is ample strength margin to maintain the transmission conductor intended function through the period of extended operation.

The National Electrical Safety Code (NESC) requires that tension on installed conductors be a maximum of 60% of the ultimate conductor strength. The NESC also sets the maximum tension a conductor must be designed to withstand under heavy load requirements, which includes consideration of ice, wind and temperature. These requirements are reviewed concerning the specific conductors included in the AMR. The conductors with the smallest ultimate strength margin (4/0 ACSR) will be used as an illustration.

The ultimate strength and the NESC heavy load tension requirements of 4/0 (212 MCM) ACSR are 8350 lbs. and 2761 lbs. respectively. The margin between the NESC Heavy Load and the ultimate strength is 5589 lb.; i.e., there is a 67% of ultimate strength margin. The Ontario Hydroelectric study showed a 30% loss of composite conductor strength in an 80 year old conductor. In the case of the 4/0 ACSR transmission conductors, a 30% loss of ultimate strength would mean that there would still be a 37% ultimate strength margin between what is required by the NESC and the actual conductor strength. The 4/0 ACSR conductors have the lowest initial design margin of transmission conductors included in the AMR.

This illustrates with reasonable assurance that transmission conductors will have ample strength through the period of extended operation.

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There are no applicable aging effects that could cause loss of the intended function of the transmission conductors for the period of extended operation.

A review of industry OE and NRC generic communications related to the aging of transmission conductors ensured that no additional aging effects exist beyond those previously identified. A review of plant-specific OE did not identify any unique aging effects for transmission conductors.

Numerous previous applicants (Oconee, Turkey Point, North Anna and Surry, Peach Bottom, St.

Lucie, Fort Calhoun, McGuire and Catawba, and Virgil C. Summer) reached this conclusion that no aging management program is required for the transmission conductor aging effects of loss of conductor strength and loss of material. The Staff, as documented in these applicants SERs, accepted this position.

There are no applicable aging effects requiring management for JAFNPP transmission conductors.

191 299 Provide a discussion why torque relaxation and The design of the transmission conductor bolted The project team finds the applicants oxidation of bolted connections of transmission connections precludes torque relaxation, and the response acceptable because the design conductors are not a concern for Fitzpatrick. plant specific OE supports this statement. The OE of transmission connections using Bellville report did not identify any failures of switchyard washer will eliminate the potential torque connections due to aging. The typical design of relaxation of bolted connections. The use switchyard bolted connections includes Bellville of anti-oxidant compound will prevent the washers and is no-ox coated. The type of bolting formation of oxides on the metal surface plate and the use of Bellville washers is the and to prevent moisture entering the industry standard to preclude torque relaxation. connections thus reducing the chances of This combined with the proper sizing of the corrosion. This question is resolved.

conductors virtually eliminates the need to consider this aging mechanism, therefore, there will be no 126

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significant aging. The in-scope transmission conductors at JAFNPP are limited to the connections from the 115 kV switchyard to the station service transformer for the SBO recovery path. JAFNPP performs infrared inspection of the 115 kV switchyard connections as part of a PM task that is performed at least once each year.. This PM and the absence of plant OE confirms that no significant aging is occurring for JAFNPP. Based on this information, torque relaxation of transmission connections does not require aging management for JAFNPP.

Loss of material due to corrosion of connections due to surface oxidation is an applicable aging mechanism, but is not significant enough to cause a loss of intended function. The components in the switchyard are exposed to precipitation, but these components do not experience any appreciable aging effects in this environment, except for minor oxidation, which does not impact the ability of the connections to perform their intended function. At JAFNPS, switchyard connection surfaces are coated with an anti-oxidant compound (i.e., a grease-type sealant) prior to tightening the connection to prevent the formation of oxides on the metal surface and to prevent moisture from entering the connections thus reducing the chances of corrosion. Based on operating experience, the method of installation has been shown to provide a corrosion resistant low electrical resistance connection. In addition, the infrared inspection of the 115KV switchyard verifies that this aging effect is not significant for JAFNPP.

Therefore, it is concluded that general corrosion resulting from oxidation of switchyard connection surface metals does not require management at JAFNPP.

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192 300 In Section 3.6.2.2.3 of the LRA, you have Transmission conductor vibration, or sway, would The project team finds the applicants stated that loss of material that could be be caused by wind loading. Wind loading that can response acceptable because wind caused by transmission conductor vibration or cause a transmission line and insulators to vibrate loading that can cause a transmission line sway are found not to be applicable aging is considered in the design and installation. Loss of and insulator to vibrate is considered in effects in that they would not cause a loss of material (wear) and fatigue that could be caused by the design and installation. In addition, intended function if left unmanaged for the transmission conductor vibration or sway are found the applicant confirmed that no OE or extended period of operation. Explain why not to be applicable aging effects in that they would staffs generic communication related to transmission conductor vibration or sway would not cause a loss of intended function if left loss of material of transmission not cause a loss of intended function if left unmanaged for the period of extended operation. conductors due to vibration or sway was unmanaged for the extended period of identified. This question is resolved.

operation. A review of industry OE and NRC generic communications related to the aging of transmission conductors ensured that no additional aging effects exist beyond those previously identified. A review of plant-specific OE did not identify any unique aging effects for transmission conductors.

Numerous previous applicants (Oconee, Turkey Point, North Anna and Surry, Peach Bottom, St.

Lucie, Fort Calhoun, McGuire and Catawba, and Virgil C. Summer) reached this conclusion that no aging management program is required for the transmission conductor aging effects of loss of conductor strength and loss of material.

The Staff, as documented in these applicants SERs, accepted this position.

193 301 Are all electrical and I&C containment The JAFNPP electrical and I&C penetration The project team finds the applicants penetrations EQ? If not, provide AMRs and assemblies are all included in the EQ program. response acceptable because all electrical AMPs for non-EQ electrical and I&C and I&C penetration assemblies are in the containment penetrations. The AMRs should applicant's EQ program and they do not include both organic ( XLPE, XLPO, and SR require any AMRs. This question is internal conductor/pigtail insulation, etc.,) as resolved.

well as inorganic material (such as cable fillers, epoxies, potting compounds, connector pins, plugs, and facial grommets).

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194 302 In LRA, Table 3.6.2-1, under "Electrical cables Moisture was included in the aging management The project team finds the applicants and connections not subject to 10 CFR 50.49 review for these two items. This was an omission response acceptable because the EQ requirements and Electrical cables not from the two table rows. The statement will be applicant clarified that moisture was subject to 10 CFR 50.49 EQ requirements used revised to heat, radiation, or moisture and air. included in the aging management review in instrumentation and circuits," you have for these two items and this was omission identified heat or radiation and air are the This requires a LRA amendment. in the LRA. The applicant corrected this environments of these electrical components. error in its amendment letter No. 5, dated NUREG-1801, Rev. 1 (GALL) identified heat, February 01, 2007. The revised radiation, or moisture in the presence of oxygen environments are now consistent with are the environments and moisture intrusion is GALL Report. This question is resolved.

the aging effect/mechanism. Revise Table 3.6.2.-1 to be consistent with GALL or provide a technical justification of why moisture in the presence of oxygen is not an aging effect for cables and connections.

195 310 Explain why the 60-year CUF value of 0.11 is a The fatigue calculation included in the original In accordance with 10CFR54.21(c)(ii), the valid CUF value for the tie rods, particularly stress analysis for the tie rods was based on applicant analyzed the CUF to project up when 60-year projection was based solely on alternating loads due to an Operating Basis to 60years and indicated the 60-year CUF the maximum allowable design basis value of Earthquake and 3 transients: Startup/Shutdown, of 0.11 based on the worst case change in 233 for a single-type shutdown transient (and Loss of Feedwater Pumps (with Isolation Valves allowable cycles for Startups and not on the 60-year cycle projections for all Closed) and Turbine Generator Trip (with Isolation Shutdowns.

design basis transients analyzed for in the Valves Open). The original calculated 40-year CUF original 40-year CUF calculation). If 0.11 is not for the tie rods was .0575. The allowable number of However, the adequacy of the 40-year a valid 60-year CUF value for the tie rods, cycles for 2 of these 3 transients has increased for CUF values for the Class 1 components is provide an updated 60-year CUF value for the 60 years of operation and the allowable number of pending acceptable resolution of RAI tie rods based on the 60-year cycle projections cycles for one of the transients has been 4.3.1-1, on cycle counting. This question for all design basis transients analyzed for in decreased since the original stress analysis was is closed to RAI 4.3.1-1 on cycle counting.

the original 40-year analysis. performed. The allowable number of Startup/Shutdown cycles has increased by 94%

from 120 to 233 cycles. The allowable number of Loss of Feedwater Pumps (with Isolation Valves Closed) has increased 20% from 10 to 12 cycles.

The allowable number of Turbine Generator Trip (with Isolation Valves Open) cycles has decreased by 70% from 40 to 12 cycles. Conservatively, the 40-year CUF for the tie rods was increased by 94%

to project the 60-year CUF of 0.11 based on the 129

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worst case change in allowable cycles for Startups and Shutdowns. This tie rod CUF value was conservatively projected for 60 years of operation.

196 311 Section 4.3.1.2 identifies that the jet pump The jet pump assembly diffuser adapter is not a The project team finds this response assembly diffuser adapter is the limiting RV Class 1pressure boundary component. Therefore, acceptable because the applicant has internal for CUF and provides a 40-year CUF its CUF is not listed among the maximum CUFs for clarified that it has included the CUF for value of 0.65 for this component. This appears Class1 components in Table 4.3-1. The core the core shroud supports within the scope to conflict with information in LRA Table 4.3-1 shroud support is welded into the reactor vessel by for the CUF values reported for the reactor which identifies that the Core Shroud Support the vessel manufacturer, and is analyzed for CUF pressure vessel components, and is the limiting Class 1 component (and as part of the reactor vessel stress report. Since because the CUF value for the core therefore limiting RV internal) for CUF (with a the vessel is a Class 1 component, the attached shroud support is the limiting 40-year CUF 40-year CUF value of 0.90). Clarify which core shroud support CUF is included in the Class 1 value for ASME Code Class 1 Class 1 component analyzed in accordance component CUFs in Table 4.3-1. components. This question is resolved.

with ASME Section III CUF methodology is the limiting CUF component for fatigue and state The highest (most limiting) CUF for the reactor Note: The adequacy of the 40-year CUF what the 40-year, non-environmentally vessel, based on the analyzed number of design values for the Class 1 components is impacted CUF value for this component (i.e., transients, prior to any environmentally assisted pending acceptable resolution of RAI the 40-year CUF value before any potential Fen fatigue adjustment, is 0.90 for the shroud support. 4.3.1-1, on cycle counting.

modification of the value is made if the (LRA Table 4.3-1) component is a NUREG/CR-6260 component).

Confirm that the 40-year CUF value provided As discussed above, the 40-year CUF value of for the jet pump diffuser adapter in LRA Section 0.65 for the jet pump diffuser adapter discussed in 4.3.1.2 appropriately supplements the 40-year LRA Section 4.3.1.2 is in addition to the Class 1 CUFs for the commodity groups that are component CUFs in Table 4.3-1.

provided in LRA Table 4.3-1.

197 312 Identify which components/commodity groups Table 3.1.2-1 is for the reactor vessel. All of the The project team finds that the applicants in AMR Tables 3.1.2-1, -2, and -3 were reactor vessel components were built to ASME response, when taken into context with designed to ASME Section III. Clarify which Section III, 1965 edition thru winter 1966 addenda. the applicants response to Items 198 and components/commodity groups received an 199 below, is acceptable because the ASME Section III CUF calculation, and identify Table 3.1.2-2 is for the reactor vessel internals. applicant has clarified which Class 1 which commodity group listing in LRA Table The reactor vessel internals are not code components in the reactor coolant 4.3-1 provides the applicable CUF result. If no components and while various codes were used for pressure boundary were designed in CUF calculation was performed, justify the guidance in designing and building the internals, accordance with ASME Section III and basis for exclusion and propose an acceptable they are not built in compliance with any specific codes.which components were designed to ANSI AMP to manage the aging effect cracking Table 3.1.2-3 is for the reactor coolant system B31.1 standards. The responses clarify 130

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fatigue in accordance with the criterion in 10 pressure boundary. In accordance with the which components were required to be CFR 54.21(c)(1)(iii). If an exclusion from guidelines of NUREG-1801, the commodity groups analyzed in accordance with the ASME performing a CUF calculation is based on an in Table 3.1.2-3 are grouped based on material and Section III fatigue analysis methodology ASME Section III, provide the paragraph in the environment, not on design code. The codes for and which were required to be assessed Code table 3.1.2-3 (piping and in-line components, and for fatigue in accordance with the ANSI non-piping components) are discussed in the next B31.1 maximum allowable stress 2 questions. reduction methodology. This question is resolved.

198 313 Identify which components in AMR Tables Table 3.1.2-1 is for the reactor vessel. None of the The project team finds that the applicants 3.1.2-1, -2, and -3 were designed in reactor vessel components were built to ANSI response, when taken into context with accordance with B31.1. Clarify whether the B31.1. the applicants response to Items 197 and commodity groups were evaluated for an Table 3.1.2-2 is for the reactor vessel internals. 199, is acceptable because the applicant allowable stress reduction assessment based The reactor vessel internals are not code has clarified which Class 1 components in on the 7000 thermal cycles in accordance with components and while various codes were used for the reactor coolant pressure boundary B31.1. Identify whether: (1) the allowable stress guidance in designing and building the internals, were designed in accordance with ASME reduction analysis remains bounded under 10 they are not built in compliance with any specific Section III and which components were CFR 54.21(c)(1)(I), (2) the allowable stress codes. designed to ANSI B31.1 standards.

range needs to be reduced in accordance with Table 3.1.2-3 is for the reactor coolant system the stress reduction criteria in B31.1 to comply pressure boundary. In accordance with the The responses clarify which components with 10 CFR 54.21(c)(1)(ii), or (3) the aging guidelines of NUREG-1801, the commodity groups were required to be analyzed in effect cracking - fatigue needs to be managed in Table 3.1.2-3 are grouped based on material and accordance with the ASME Section III for the period of extended (EPO) operation in environment, not on design code. However, all the fatigue analysis methodology and which accordance with 10 CFR 54.21(c)(1)(iii) and piping and in-line components on this table are built were required to be assessed for fatigue in propose an acceptable AMP to manage the to B31.1 and therefore do not require CUF accordance with the ANSI B31.1 aging effect. calculations. Non-piping components are discussed maximum allowable stress reduction in question #314. methodology. This question is resolved.

199 314 For non-piping components/commodity groups Table 3.1.2-1 is for the reactor vessel. All of the The project team finds the applicant's in LRA Tables 3.1.2-1, -2, and -3 that were not reactor vessel components were built to ASME response acceptable because the designed to ASME Section III or B31.1, identify Section III, 1965 edition. applicant has identified: (1) those Class 1 which design code applies to the particular components that were built to Code other commodity group and clarify whether the Table 3.1.2-2 is for the reactor vessel internals. than ASME Section III or ANSI B31.1, (2) design code required a metal fatigue analysis. The reactor vessel internals are not code whether fatigue-induced damage is an If a metal fatigue analysis was required, components and while various codes were used for applicable aging effect for these summarize what type of metal fatigue guidance in designing and building the internals, components, and (3) what type of TLAAs calculation was required to be performed and they are not built in compliance with any specific or AMPs will be used to manage fatigue-discuss how: (1) the analysis remains bounding codes. induced damage in these components, if 131

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under 10 CFR 54.21(c)(1)(I), (2) has been fatigue-induced damage is an applicable projected to the expiration of the EPO and Table 3.1.2-3 is for the reactor coolant system aging effect for the components. This remains acceptable pursuant to 10 CFR pressure boundary. In accordance with the question is resolved.

54.21(c)(1)(ii), or (3) whether an AMP needs to guidelines of NUREG-1801, the commodity groups be proposed to manage the aging effect of in Table 3.1.2-3 are grouped based on material and cracking - fatigue for the EPO and state which environment, not on design code. Therefore these AMP will be used to manage the aging effect. If entries may represent multiple design codes. To a metal fatigue analysis was not performed and answer this question, the components must be cracking -fatigue needs to be manage for the reviewed on a component by component basis, not EPO, propose an acceptable AMP for the a commodity group basis.

management of the aging effect in accordance with the criterion in 10 CFR 54.21(c)(1)(iii). The RCSPB components in question are:

• Fatigue is not an aging effect requiring management for the stainless steel control rod drive mechanisms (pressure boundary) because they are maintained below the 270 degree F threshold for fatigue of stainless steel.

• The control rod drive accumulators are not subject to fatigue as they never exceed 140 °F.

• The control rod drive scram discharge header has component IDs of 03TK-1A and 03TK-1B; however, these tanks actually consist of sections of large diameter piping inserted into the scram discharge piping. All the scram discharge piping, including the scram discharge headers are built to ANSI B31.1. It will not exceed 7000 cycles and therefore remains acceptable for the period of extended operation.*The reactor recirculation pump (driver mount, casing, cover, and thermal barrier) are not built to ASME Section III and no fatigue analyses for these parts were found. The driver mount is not exposed to hot water and therefore is not susceptible to fatigue. Cracking of the casing and cover (including thermal barrier) is managed by a combination of Water Chemistry Control, Inservice Inspection, and BWR Stress Corrosion 132

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Cracking programs.

• The main steam flow restrictors are not pressure boundary parts and thus are not built to the ASME code, and therefore have no TLAA for fatigue.

Cracking, due to both SCC and fatigue, of these components is managed by the One-Time Inspection Program.

200 315 Section 4.3.2 of the JAFNP LRA provides The piping and in-line components in Tables 3.2.2- The project team finds the applicant's Entergys TLAA on Metal Fatigue of Non-Class X, 3.3.2-X and 3.4.2-X, including cyclone response acceptable because the 1 components. In this section Entergy provides separators, drain pots, expansion joints, flow applicant has identified: (1) those Non-the metal fatigue analysis for the Non-Class 1 elements, mufflers, orifices, piping, rupture disks, Class 1 components that were built to components that were designed in accordance steam traps, strainers, strainer housings, ASME Section III or VIIII or ANSI B31.1, with B31.1. For each non-piping thermowells, T-quenchers, tubing and valve bodies or to Codes other than ASME Sections III components/commodity group in AMR Tables are identified with a TLAA for fatigue, and are or VIII or ANSI B31.1, (2) whether fatigue-3.2.2-X, 3.3.2-X and 3.4.2-X that is within the discussed in Section 4.3.2 of the LRA. These induced damage is an applicable aging scope of a fatigue-based AMR line item, components were designed to the applicable effect for these components, and (3) what identify which design code applies to the ASME Section III, Section VIII or ANSI B31.1 code. type of TLAAs or AMPs will be used to particular commodity group and clarify whether Since the TLAA remains valid per manage fatigue-induced damage in these the design code required a metal fatigue 10CFR54.21(c)(1)(I), no aging management components, if fatigue-induced damage is analysis. If a metal fatigue analysis was program is required to manage cracking due to an applicable aging effect for the required, summarize what type of metal fatigue fatigue. components. The applicants response is calculation was required to be performed and consistent with the AMRs in the discuss how: (1) the analysis remains bounding For those components In Tables 3.2.2-X, 3.3.2-X, application. This question is resolved.

under 10 CFR 54.21(c)(1)(I), (2) has been and 3.4.2-X, that were not designed to any ASME projected to the expiration of the EPO and or ANSI code, cracking-fatigue, as an aging effect, remains acceptable pursuant to 10 CFR will be managed by the applicable aging 54.21(c)(1)(ii), or (3) whether an AMP needs to management program; One-Time Inspection, Fire be proposed to manage the aging effect of Protection, or Periodic Surveillance and Preventive cracking - fatigue for the EPO and state which Maintenance (PSPM). These components are on AMP will be used to manage the aging effect. If air or exhaust systems and since no design code a metal fatigue analysis was not performed and applies, review for a TLAA is not applicable.

cracking -fatigue needs to be manage for the EPO, propose an acceptable AMP for the management of the aging effect in accordance with the criterion in 10 CFR 54.21(c)(1)(iii).

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201 317 LRA Table 4.3-2 indicates that the LRA Table 4.3-2 is for projected cycles, Table 4.3-3 The project team finds the applicants environmentally-impacted CUF values for the is for environmentally adjusted CUFs. Note that response to be acceptable because the RV shell, RV feedwater nozzle safe end, RV Table 4.3-3 does not indicate that 40 year CUFs applicant amended the LRA on April 06, recirculation inlet nozzle thermal sleeve, and will exceed 1.0 with the EAF adjustment because 2007, and placed Commitment No. 20 on RV recirculation outlet nozzles are all projected the EAF adjustment is not applied until the period the application to ensure that to exceed a value of 1.0 prior to the expiration of extended operation. However, some of the CUFs environmentally-assisted fatigue would be of the current operating period. On pages 4.3-7 will exceed 1.0 at the beginning of the period of adequately analyzed for or managed for and 4.3-8, Entergy provides its corrective extended operation when environmentally assisted the period of extended operation.

action plan to address this issue. The fatigue is added to the CUF calculation. The Commitment No. 20 replaces the corrective action program for the corrective action plan in LRA Section 4.3.3 on applicant's response to the project team's environmentally impacted CUF factor Page 4.3-7 and 4.3-8 is revised to read as follows question. This question is resolved.

components (i.e., the Class 1 components at and is included on the JAFNPP license renewal JAFNP that correspond to those analyzed for commitment list as Commitment 20.

fatigue in NUREG/CR-6260) needs to be included as a commitment on the JAFNP LRA. At least 2 years prior to entering the period of extended operation, for the locations identified in NUREG/CR-6260 for BWRs of the JAFNPP vintage, JAFNPP will implement one or more of the following:

(1) Refine the fatigue analyses to determine valid CUFs less than 1 when accounting for the effects of reactor water environment. This includes applying the appropriate Fen factors to valid CUFs determined in accordance with one of the following.

1. For locations, including NUREG/CR-6260 locations, with existing fatigue analysis valid for the period of extended operation, use the existing CUF to determine the environmentally adjusted CUF.

2. More limiting JAFNPP-specific locations with a valid CUF may be added in addition to the NUREG/CR-6260 locations.

3. Representative CUF values from other plants, adjusted to or enveloping the JAFNPP plant specific external loads may be used if demonstrated applicable to JAFNPP.

4. An analysis using the NRC-approved ASME 134

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code 2001 edition up to and including 2003 addendum, may be performed to determine a valid CUF.

The determination of Fen will account for operating time with normal water chemistry and operating time with hydrogen water chemistry.

(2) Manage the effects of aging due to fatigue at the affected locations by an inspection program that has been reviewed and approved by the NRC (e.g., periodic non-destructive examination of the affected locations at inspection intervals to be determined by a method acceptable to the NRC).

(3) Repair or replace the affected locations before exceeding a CUF of 1.0.

Should JAFNPP select the option to manage the aging effects due to environmental-assisted fatigue during the period of extended operation, details of the aging management program such as scope, qualification, method,. and frequency will be submitted to the NRC at least 2 years prior to the period of extended operation. This requires an LRA amendment.

202 318 The applicant is requested to provide the The JAFNPP GE Mark I containment includes a The project team finds the applicants design codes for the liner plate, torus down steel drywell with no liner plate. The design code response to be acceptable because the comer/vent header and torus-attached piping, for the drywell shell is ASME Code,Section III applicant provided the requested and SRV piping for review. (1968 Edition including the Summer1968 Addenda) information regarding the design codes for

[Ref. UFSAR Section 5.2.3.1]. The design code for the liner plate, torus down comer/vent the torus is ASME Code,Section III including the header and torus-attached piping, and Summer 1968 Addenda [Ref. UFSAR Section SRV piping for review. No issues were 5.2.3.1]. The torus was later evaluated to the identified during the review of this requirements of ASME Section III, Division I, with information. This question is resolved.

addenda through Summer 1977 and code case N-197 as part of the Mark 1 Containment Upgrade 135

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Program [Ref. TES doc. TR-5321-1].

Torus downcomer/vent Header :

The original design code for the 48 pairs of torus downcomers, eight vent pipes and vent header is ASME Code,Section III (1968 Edition including the Summer1968 Addenda) [Ref. UFSAR Section 5.2.3.1]. The torus downcomers were later evaluated to the requirements of ASME Section III, Division I, with addenda through Summer 1977 and code case N-197 as part of the Mark 1 Containment Upgrade Program [Ref. TES doc. TR-5321-1].

Torus attached piping:

The design code for the torus attached piping is ANSI B 31.1 (1967 Edition thru 1969 Addenda).

The torus attached piping was later evaluated to include the additional Mark 1 upgrade loading effects to the requirements of ASME Section III (1977 Edition) as part of the Mark 1 Containment Upgrade Program. Pipe support analysis was performed to Section III Subsection NF [Ref. TES doc. TR-5321-2].

SRV discharge piping:

The design code for the safety relief valve discharge piping was ANSI B 31.1 (1967 Edition thru 1969 Addenda). The safety relief valve discharge piping was later evaluated to include the additional Mark 1 upgrade loading effects to the requirements of ASME Section III (1977 Edition) as part of the Mark 1 Containment Upgrade Program

[Ref. TES doc. TR-5321-2].

203 319 The applicant is requested to provide a Based on a review of plant operating data from The project team finds the applicants 136

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statement indicating that the estimate of the October, 1974 to November 4, 2006, SRVs at response to be acceptable because the total number of 60-year SRV actuations used in JAFNPP have undergone a total of 564 lifts. This applicant provided the requested the design fatigue analysis remains valid and represents approximately 32 years of operation. information regarding estimate of the total conservative, based on the actual SRV Conservatively assuming each of the 11 valves number of 60-year SRV actuations used in actuations counted thru 2006. have lifted on every actuation, the estimated the design fatigue analysis and clarified number of lifts for each valve for 60 years is (60/32) that it remains valid and conservative, times 564 = 1058 lifts in 60 years. based on the actual SRV actuations counted thru 2006. No issues were TR-5321-2, Mark 1 Containment Program Plant- identified during the review of this Unique Analysis Report of the Torus Attached information. This question is resolved.

Piping for James A. Fitzpatrick Nuclear Power Station, Revision 1, November, 1984 (page 13) states that 7500 cycles are allowed for the SRV discharge line penetration into the torus. The estimated total number of SRV actuations for 60 years is less than the number of actuations assumed in the design fatigue analysis. The estimate is based on actual SRV actuations counted thru November 4, 2006. The design fatigue analysis remains valid. Based upon this, the projected CUF for 60 years is calculated as 0.141.

204 320 The applicant is requested to provide a The augmented Class 2/3 fatigue methodology is The project team finds the applicants description or a reference to the augmented an approach developed to evaluate Mark I response to be acceptable because the Class 2/3 fatigue methodology that was Containment Program loadings and acceptance applicant provided the requested developed to account for cycle mechanical criteria for fatigue effects and to define a course of information regarding the Class 2/3 fatigue loads. action for a generic Mark I response to NRC methodology that was developed to concern regarding cyclic stress due to mechanical account for cycle mechanical loads. No loads. The approach was developed along the lines issues were identified during the review of of the Class 2/3 piping design methods. The this information. This question is resolved.

methodology is described in report MPR 751.

Augmented Class 2/3 methodology described in MPR-751 was applied to JAF via two plant specific calculations performed for JAFNPP by Teledyne Engineering Services (TES).

TR-5321-1 Plant Unique Analysis Report of the Torus Suppression Chamber TR-5321-2 Plant 137

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Unique Analysis Report of the Torus Attached Piping Teledyne Engineering Services document TR-5321-2 documents stress evaluations for the SRV piping for various load combinations, but does not include a fatigue analysis. The fatigue analysis of the SRV piping along with all the other torus attached piping. (TAP) is bounded by Mark 1 Upgrades generic report MPR-751, prepared by GE. MPR-751 concluded that for all plants and piping systems considered, in all cases the fatigue usage factors for an assumed 40-year plant life was less than 0.5. In a worst-case scenario, extending plant life for an additional 20 years would produce usage factors below 0.75. Since this is less than 1.0, the fatigue criteria are satisfied. The MPR-751 generic fatigue analysis is thus protected for the period of extended operation in accordance with 10 CFR 54.21(c)(1)(ii)

A JAF plant specific analysis addresses the SRV discharge piping and its supports, as well as the main vent penetration through which the SRV discharge enters the torus. This analysis states that the SRV penetrations are qualified for 7500 cycles of maximum load while the SRVs are expected to see less than 50 cycles at maximum load and less than 4500 cycles at partial load. The TR-5321-2 report concludes "Since the 7500 cycles of maximum load bounds both of these by such a large margin and since no other significant loads are imposed on the line, the penetration was assumed acceptable for fatigue without further evaluation." Increasing the 40 year cycles by 1.5 for the period of extended operation would still be only 75 maximum load cycles and 6750 low load cycles for a total of 6850 mixed load cycles, less than the 7500 maximum load cycles permitted. The fatigue analysis for torus penetrations thus remains valid for the period of extended operation in 138

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accordance with 10 CFR 54.21(c)(1)(I).

The JAF plant-specific analysis (TR-5321-2) references the generic GE Mark 1 Containment program for other torus attached piping. The results of the generic GE Mark 1 containment program (based on 40 years of operation) were that 92% of the TAP would have cumulative usage factors of less than 0.3, and that 100% would have usage factors less than 0.5. Conservatively multiplying the CUFs by 1.5 shows that for 60 years of operation, 92% of the TAP would have CUFs below 0.45, and 100% would have CUFs below 0.75. These calculations have thus been projected through the period of extended operation in accordance with 10 CFR 50.21(c)(ii).

Hard copies of the two Teledyne reports were available onsite for review.

205 321 LRA Table 3.3.2-5, Fire Protection-Water Hydrants are subject to aging management review The project team finds the applicants System Summary of Aging Management and are included in the component type valve response acceptable because the Evaluation, does not list yard fire hydrants for body in Table 3.3.2-5. A hydrant is a valve body in applicant clarified that hydrants are the Fire Protection-Water system. Fire hydrants Table 3.3.2-5. The corresponding line items in subject to aging management review and are considered passive and long-lived Table 3.3.2-5 are listed as valve body with material are included in the component type valve components in accordance with 10 CFR 54.21. of gray cast iron, and environment of raw water body in Table 3.3.2-5. This question is If they are excluded from an AMR, provide (int.). The corresponding NUREG-1801 Volume 2 resolved.

justification for the exclusion or describe how line items are VII.G-14 and VII.G-24. Hydrants are the aging of those hydrants will be managed shown on drawing LRA-FB-49A.

and the aging management program for the period of extended operation.

206 322 The LRA Table 3.3.2-5, Fire Protection-Water Sprinkler heads are subject to aging management The project team finds the applicants System Summary of Aging Management review. In Table 3.3.2-5, sprinkler heads are listed response acceptable because the Evaluation, does not list sprinkler heads for the as component type "nozzle". Materials are carbon applicant clarified that sprinkler heads are Fire Protection-Water system. Provide steel and copper alloy > 15% Zn. subject to aging management review and justification for the exclusion or address how are listed as component type "nozzle" in 139

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the aging of those hydrants will be managed Sprinkler heads are shown on drawing LRA-FB- LRA Table 3.3.2-5. This question is and the aging management program for the 49A. resolved.

period of extended operation.

207 323 LRA Section 4.3.1.3 states that all reactor There was no Code exception taken for the main The project team finds the applicants coolant pressure boundary (RCPB) piping is steam flow restrictors or for the reactor water response to be acceptable based on the designed and analyzed in accordance with recirculation pumps. The exception for the main following justifications/bases:

ANSI B31.1. In the ANSI B31.1 code, fatigue is steam flow restrictors and the reactor water addressed by using stress range reduction recirculation pumps indicates that the JAFNPP (1) The flow restrictors are not ASME factors to reduce the stress allowable (SA). The design codes (code of record) for these Section III or ANSI B31.1 pressure LRA states that since the RCPB components components did not require a fatigue analysis. boundary components; it is acceptable to will not exceed 7000 full temperature cycles in Consequently, cracking due to fatigue has no TLAA use a one-time examination to inspect for 60 years of operation, the existing stress for JAFNPP. There is only one line entry for any cracking that may be induced by analyses remain valid for the period of cracking for these components; a line entry that fatigue, as fatigue-induced cracking is not extended operation, in accordance with 10 CFR includes cracking due to any applicable expected to occur in these components.

54.21(c)(1)(I). However, LRA Section 3.1.2.2.1 mechanism. Cracking due to fatigue will be states exceptions for the steam line flow managed by the same programs that manage (2) The Class 1 piping at JAFNPP was restrictors and reactor water circulating pumps, cracking due to other mechanisms. designed to ANSI B31.1 not to ASME which also require no fatigue analysis. The Section III. The recirculation pumps would One-Time Inspection Program is credited to Cracking and loss of fracture toughness of the be designed in accordance with some manage cracking due to fatigue for the main main steam flow restrictors will be managed by the other Code other than ANSI B31.1 or steam line flow restrictors, and the ISI Program One-time Inspection Program. ASME Section III and the Code of is credited for the reactor water circulating Construction may not have required a pumps. In LRA Table 3.1.1, items 3.1.1-55 and The flow restrictors are not pressure boundary fatigue analysis for the pump casings.

3.1.1-57, the same AMPs are also credited to parts and as such are not covered by the ISI Therefore, it is acceptable to use the manage loss of fracture toughness due to Program. ASME Section XI, Table IWB-2500-1 thermal aging embrittlement for these two One-time inspection is considered adequate for the Category B-L-1 and B-L-2 requirements as RCPB components. Please provide the main steam flow restrictors as they are not a basis for managing any cracking in the following information: pressure boundary parts. pump casings that may be induced by fatigue. This question is resolved.

a) Clarify why exceptions are taken for the Cracking and loss of fracture toughness of the steam line flow restrictors and the reactor water recirculation water pump casings are managed by circulating pumps. the Inservice Inspection Program.

The pump casing welds are examined per IWB-2500-1 Category B-L-1 while the pump casing itself is examined per IWB-2500-1 Category B-L-2.

140

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208 324 LRA Section 4.3.1.3 states that all reactor The One-Time Inspection Program does not The basis for Item 207 also applies to Item coolant pressure boundary (RCPB) piping is manage cracking due to fatigue for the main steam 208. This question is resolved.

designed and analyzed in accordance with line flow restrictors, as indicated in response to part ANSI B31.1. In the ANSI B31.1 code, fatigue is a) above. The scope of the One-Time Inspection addressed by using stress range reduction Program is described in LRA Appendix B, Section factors to reduce the stress allowable (SA). The B.1.21. Activities of the One-Time Inspection LRA states that since the RCPB components Program are used to confirm that loss of material, will not exceed 7000 full temperature cycles in cracking, and reduction of fracture toughness (as 60 years of operation, the existing stress evidenced by cracking), as applicable, are not analyses remain valid for the period of occurring or are so insignificant that an aging extended operation, in accordance with 10 CFR management program is not warranted. The One-54.21(c)(1)(I). However, LRA Section 3.1.2.2.1 Time Inspection Program comprises combinations states exceptions for the steam line flow of nondestructive examinations (including visual, restrictors and reactor water circulating pumps, ultrasonic, and surface techniques) that will be which also require no fatigue analysis. The performed by qualified personnel following One-Time Inspection Program is credited to procedures that are consistent with Section XI of manage cracking due to fatigue for the main ASME B&PV Code and 10CFR50, Appendix B, steam line flow restrictors, and the ISI Program looking for the presence of, and evaluating the is credited for the reactor water circulating extent of, cracking. Cracking is considered to be pumps. In LRA Table 3.1.1, items 3.1.1-55 and symptomatic of a reduction in fracture toughness 3.1.1-57, the same AMPs are also credited to (and reduced toughness allows existing cracks to manage loss of fracture toughness due to propagate at higher rates). Therefore, by managing thermal aging embrittlement for these two cracking, the One-Time Inspection Program is RCPB components. Please provide the credited with managing reduction in fracture following information: toughness for the main steam flow restrictors.

b) Discuss the specific activities in the One-Time Inspection AMP that will manage both cracking due to fatigue and loss of fracture toughness due to thermal aging embrittlement for the main steam line flow restrictors.

209 325 Section 3.1 -1c Reactor Vessel, Internals and The ISI Program does not manage cracking due to The basis for Item 207 also applies to Item Reactor Coolant System fatigue for the reactor water recirculating pumps, as 209. This question is resolved.

indicated in response to part a) above. The scope LRA Section 4.3.1.3 states that all reactor of the ISI Program is described in LRA Appendix B, coolant pressure boundary (RCPB) piping is Section B.1.16.2. The ISI Program manages designed and analyzed in accordance with cracking, loss of material, and reduction of fracture 141

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ANSI B31.1. In the ANSI B31.1 code, fatigue is toughness (as evidenced by cracking), as addressed by using stress range reduction applicable, of reactor coolant system components, factors to reduce the stress allowable (SA). The including the reactor water recirculating pumps, LRA states that since the RCPB components using NDE techniques specified in ASME Section will not exceed 7000 full temperature cycles in XI, Subsections IWB, IWC and IWD examination 60 years of operation, the existing stress categories. Cracking is considered to be analyses remain valid for the period of symptomatic of a reduction in fracture toughness extended operation, in accordance with 10 CFR (and reduced toughness allows existing cracks to 54.21(c)(1)(I). However, LRA Section 3.1.2.2.1 propagate at higher rates). Therefore, by managing states exceptions for the steam line flow cracking, the ISI Program is credited with restrictors and reactor water circulating pumps, managing reduction in fracture toughness for the which also require no fatigue analysis. The reactor water recirculating pumps.

One-Time Inspection Program is credited to manage cracking due to fatigue for the main steam line flow restrictors, and the ISI Program is credited for the reactor water circulating pumps. In LRA Table 3.1.1, items 3.1.1-55 and 3.1.1-57, the same AMPs are also credited to manage loss of fracture toughness due to thermal aging embrittlement for these two RCPB components. Please provide the following information:

c) Discuss the specific activities in the ISI Program that will manage both cracking due to fatigue and loss of fracture toughness due to thermal aging embrittlement for the reactor water circulating pumps.

210 326 The further evaluation in LRA Section 3.1.2.2.2, Yes. The further evaluation in LRA Section The project team finds the applicants item 2, and the discussion column in Table 3.1.2.2.2 and the discussion in Table 3.1.1, item response to be acceptable because the 3.1.1, item 3.1.1-13, states that, although 3.1.1-13, are applicable only to steel components applicant has confirmed that this further JAFNPP does not have an isolation condenser, exposed to reactor coolant. NUREG-1801 has no evaluation in LRA Section 3.1.2.2.2 and loss of material due to general, pitting, and other line item for BWR reactor pressure boundary discussion in Table 3.1.1 are applicable crevice corrosion for other steel components steel components with the aging effect loss of only to steel components exposed to exposed to reactor coolant will be managed by material due to corrosion. Applicable line items are reactor coolant. GALL Item IV.C.1-6 the Water Chemistry Control - BWR Program those in Table 3.1.2-3 referencing Item 3.1.1- 13. recommends that the water chemistry is to and the One-Time Inspection Program. SRP As shown in Table 3.1.2-3, those line items are be credited to manage loss of materials 142

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Section 3.1.2.2.2, item 2, recommends the Piping and fittings < 4" NPS, Piping and fittings >or due to crevice, pitting or crevice corrosion water chemistry program and an augmented = 4" NPS, tank (CRD accumulator and CRD scram in steel isolation surfaces that are inspection program for the management of loss discharge volume), valve bodies < 4 NPS, and exposed to treated water. The GALL item of material due to general, pitting, and crevice valve bodies > or = 4 NPS. recommends that a one-time inspection be corrosion for both steel and stainless steel performed to verify the effectiveness of isolation condenser components. Please the Water Chemistry Program to manage provide the following information: this aging effect. Although, the JAFNPP design does not include isolation a) Confirm that this further evaluation in LRA condensers, the applicant has credited Section 3.1.2.2.2 and discussion in Table 3.1.1 these programs in Class 1 steel piping, are applicable only to steel components tanks, and valves that are exposed to the exposed to reactor coolant. treated water of the reactor coolant. This is conservative and acceptable. Crediting of the one-time inspection program is accomplished through Footnote 107 on LRA Table 3.1.2-3. This question is resolved.

211 327 The further evaluation in LRA Section 3.1.2.2.2, SRP Section 3.1.2.2.2, Item 2 states, "A one-time Loss of material due to pitting and crevice item 2, and the discussion column in Table inspection of select components at susceptible corrosion could occur in stainless steel 3.1.1, item 3.1.1-13, states that, although locations is an acceptable method to determine BWR isolation condenser components JAFNPP does not have an isolation condenser, whether an aging effect is not occurring or an aging exposed to reactor coolant. Loss of loss of material due to general, pitting, and effect is progressing very slowly such that the material due to general, pitting, and crevice corrosion for other steel components component's intended function will be maintained crevice corrosion could occur in steel exposed to reactor coolant will be managed by during the period of extended operation. Activities BWR isolation condenser components.

the Water Chemistry Control - BWR Program of the One-Time Inspection Program include The existing program relies on control of and the One-Time Inspection Program. SRP combinations of nondestructive examinations reactor water chemistry to mitigate Section 3.1.2.2.2, item 2, recommends the (including visual, ultrasonic, and surface corrosion. However, control of water water chemistry program and an augmented techniques) that will be performed by qualified chemistry does not preclude loss of inspection program for the management of loss personnel following procedures that are consistent material due to pitting and crevice of material due to general, pitting, and crevice with Section XI of ASME B&PV Code and corrosion at locations of stagnant flow corrosion for both steel and stainless steel 10CFR50, Appendix B. As described in LRA conditions. Therefore, the effectiveness of isolation condenser components. Please Appendix B, the elements of the One-Time the chemistry control program are verified provide the following information: Inspection Program include (a) determination of the to ensure that corrosion is not occurring.

sample size based on an assessment of materials The GALL Report recommends further b) Discuss the evaluation performed to of fabrication, environment, plausible aging effects, evaluation of programs to verify the conclude that the activities in the one-time and operating experience; (b) identification of the effectiveness of the chemistry control inspection AMP are consistent with the inspection locations in the system or component program. The one-time inspection of 143

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augmented inspections recommended in the based on the aging effect; (c) determination of the select components at susceptible SRP, including the activities performed to examination technique, including acceptance locations is an acceptable method to manage aging, the sample population criteria that would be effective in managing the determine whether an aging effect is not inspected, and the inspection locations. aging effect for which the component is examined; occurring or an aging effect is progressing and (d) evaluation of the need for follow-up very slowly such that the components examinations to monitor the progression of any intended function will be maintained during aging degradation. the period of extended operation. This question is resolved.

212 328 The further evaluation in LRA Section As part of the BWR Vessel Internals Program, This question is resolved through 3.1.2.2.11 addresses cracking due to flow- visual inspections of the steam dryer are conducted incorporation of Commitment No. 22 on induced vibration in the stainless steel steam on a periodic basis to assess component condition, the LRA, which was provided in dryers. The BWR Vessel Internals Program is and ultrasonic (UT) or enhanced visual (EVT-1) Amendment No. 9, dated April 6, 2007. In credited to manage this aging effect. The inspections are performed as necessary to Commitment No. 22, the applicant further evaluation also states that JAFNPP will characterize cracking. These visual and volumetric committed to implementing the evaluate BWRVIP-139 for the steam dryer, inspections are based on the guidance in NRC IN recommendations given in Report when it is approved by the staff, and include 2002-26 and its supplements, GE SIL 644 and its BWRVIP-139 to mange potential appropriate recommendations in the BWR supplements and the latest operating experience vibrational-induced cracking of the vessels internals program. SRP Section (Ref. JAF-RPT-NBS-04394, JAF-RPT-NBS-01848). JAFNPP steam dryer during the period of 3.1.2.2.11 states that cracking due to flow- The inspections are compliant with GE SIL 644, extended operation. This report provided induced vibration could occur for the BWR Revision 1. Any indications during the inspections the BWRVIPs recommendations for stainless steel steam dryers and recommends are evaluated and either justified for a subsequent inspecting and managing potential aging further evaluation of a plant-specific aging cycle or repaired. JAFNPP will incorporate the effects in BWR steam dryers. The management program to ensure that this aging recommendations of BWRVIP-139 once it is commitment will require the applicant to effect is adequately managed. Please provide approved by the NRC staff. use the NRC-approved version of the the following information: report. This question is resolved.

License Renewal Commitment #22.

a) Discuss the current aging management activities that are being performed to address steam dryer cracking, and indicate which, if any, GE recommendations given in SIL 644, Revision 1 are used.

213 329 The further evaluation in LRA Section No concerns were raised with respect to steam The applicant confirmed that there were 3.1.2.2.11 addresses cracking due to flow- dryer cracking as a result of the power uprate (4% no concerns with respect to steam dryer induced vibration in the stainless steel steam uprate in 1996) performed several years ago at cracking as a result of the power uprate dryers. The BWR Vessel Internals Program is JAFNPP. The baseline inspection of the (4% uprate in 1996) performed several credited to manage this aging effect. The recommended steam dryer locations was years ago at JAFNPP. The baseline 144

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further evaluation also states that JAFNPP will completed in R17. None of the identified indications inspection of the recommended steam evaluate BWRVIP-139 for the steam dryer, have been attributed to flow-induced vibration. dryer locations was completed in R17.

when it is approved by the staff, and include Relevant industry operating experience has been None of the identified indications have appropriate recommendations in the BWR considered in the program, and FIV/uprate related been attributed to flow-induced vibration.

vessels internals program. SRP Section cracking is considered a non-issue for the JAFNPP Based on this, the project team finds this 3.1.2.2.11 states that cracking due to flow- steam dryer. acceptable. See also the response for induced vibration could occur for the BWR item 212. This question is resolved.

stainless steel steam dryers and recommends further evaluation of a plant-specific aging management program to ensure that this aging effect is adequately managed. Please provide the following information:

b) Discuss how steam dryer cracking was addressed as part of the evaluation performed for the extended power uprate (EPU) at JAFNPP, and whether any concerns were raised and how they were addressed.

214 330 The further evaluation in LRA Section As described in response to question 3.b) above, The applicant confirmed that power uprate 3.1.2.2.11 addresses cracking due to flow- power uprate is considered a non-issue for the is considered a non-issue for the JAFNPP induced vibration in the stainless steel steam JAFNPP steam dryers, based on a lack of steam dryers, based on a lack of dryers. The BWR Vessel Internals Program is indications attributable to FIV. Therefore, the indications attributable to FIV in 1996.

credited to manage this aging effect. The resolutions of the NRC EPU related comments to Therefore, the resolutions of the NRC further evaluation also states that JAFNPP will the SIL 644 revision are not applicable to JAFNPP. EPU related comments to the SIL 644 evaluate BWRVIP-139 for the steam dryer, JAF completed a 4% uprate in 1996. revision are not applicable to JAFNPP.

when it is approved by the staff, and include This is acceptable to the audit team. The appropriate recommendations in the BWR basis for Item 212 is also applicable to vessels internals program. SRP Section Item 214. This question is resolved.

3.1.2.2.11 states that cracking due to flow-induced vibration could occur for the BWR stainless steel steam dryers and recommends further evaluation of a plant-specific aging management program to ensure that this aging effect is adequately managed. Please provide the following information:

c) The staff reviewed SIL 644, Rev. 1, and 145

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comments were sent to the BWROG in a letter dated January 12, 2005. Most of these comments were related to EPU. Please discuss the resolutions to these NRC comments as they apply to JAFNPP.

215 331 LRA Table 3.1.1, item 3.1.1-40, addresses The only variances from NUREG-1801 in LRA The project team finds the applicants cracking due to SCC, IGSCC, and cyclic tables 3.1.2-1, 3.1.2-2 and 3.1.2-3 items response to be acceptable. The CRD stub loading for stainless steel and nickel alloy referencing 3.1.1-40 are for the CRD stub tubes tubes are not treated as vessel penetrations for CRD stub tube and the incore housings. attachments which contain portions instrumentation, jet pump instrumentation, SLC, internals to the reactor vessel. BWRVIP-flux monitor and drain lines exposed to reactor Although NUREG-1801 Section IV calls for the 47A provides the BWRVIPs inspection water. The AMR credits the Water Chemistry BWR Penetrations Program to manage cracking of and flaw evaluation guidelines for the Control - BWR program and either the BWR the CRD stub tubes and the incore housings, the reactor vessel internal lower plenum Penetrations, BWR Vessel Internals or BWR Penetration Program described in NUREG- components. The CRD stub tubes and Inservice Inspection Program. NUREG-1801 1801, XI.M8 does not address either of these incore housings are reactor vessel internal recommends the BWR Penetration and Water components. Therefore, JAFNPP did not credit the low plenum components. Thus, the BWR Chemistry programs. Please discuss the BWR Penetrations Program for managing this Vessel Internals and BWRVIP-47A are evaluation performed to conclude that the cracking. appropriate programs to credit for activities in the BWR Vessel Internals and managing cracking due to IGSCC, SCC or Inservice Inspection AMP are consistent with Cracking of the CRD stub tubes is managed by the cyclical loading in the CRD stub tubes and the activities in the BWR Penetration AMP BWR Vessel Internals Program, which incorporates incore housings. The applicant also recommended by NUREG-1801 for the the guidelines of NRC approved BWRVIP-47A for credits its ISI program to manage these components addressed by this AMR, including the CRD stub tubes. The BWR Vessel Internals aging effects in the incore housings. The the activities performed to manage aging, the Program has been reviewed for consistency with ISI program calls for a volumetric or sample population inspected, and the GALL and the applicable BWRVIPs and there are surface examination of 10% of the incore inspection locations. no exceptions to BWRVIP-47A. housing welds. This is acceptable. The applicant made the applicable amendment Cracking for the incore housings is managed by the of the LRA in LRA Amendment No. 5, Inservice Inspection Program. We will modify the dated February 1, 2007. This question is LRA to show this cracking is also managed by the resolved.

BWR Vessel Internals Program. Similar to the CRD stub tubes, the BWR Vessel Internals Program includes the BWRVIP-47A recommendations for the incore housings without exception.

ISI performs volumetric or surface examination of 10% of the peripheral CRD housing welds. In 146

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addition, periodic leak testing of the reactor vessel lower head including both the CRD stub tubes and the incore housing.

216 332 LRA Table 3.1.1, item 3.1.1-41, addresses The BWR Stress Corrosion Cracking Program is The project team finds the applicants cracking in stainless steel, nickel alloy and applicable to stainless steel reactor vessel nozzle response to be acceptable. The BWR steel clad with stainless steel components safe ends greater than 4 NPS (core spray, jet Stress Corrosion Cracking Program is exposed to reactor coolant, which is managed pump instrument, and recirc inlet/outlet nozzles); based on recommendations of NUREG-by several programs. For some components of RWR flow elements, pump casings and covers; 0313, Revision 2, and GL 88-01, as the reactor vessel and reactor coolant pressure and piping, fittings and valve bodies of the RCPB modified through staff approval of boundary, the LRA credits the BWR Stress that are greater than 4 NPS. The BWR Stress guidelines in BWRVIP-75A, and is only Corrosion Cracking and Water Chemistry Corrosion Cracking Program is not applicable to applicable to piping, piping elements, and Control - BWR AMPs to manage cracking, any other pipe fittings made from stainless steel.

further supplemented by the Inservice components. The feedwater, core spray, and RWR The response clearly clarifies that the Inspection Program, which is Consistent with nozzle thermal sleeves are not part of the thermal sleeves for the feedwater inlet, NUREG-1801. For other components, to which BWRSCC program because they are not part of the core spray, and recirculation inlet (RWR) the BWR Stress Corrosion Cracking Program is Code-required pressure boundary. The thermal piping penetrations are not welded not applicable, cracking is managed by the sleeves employ press-fit or threaded connections. components and thus are not within the Water Chemistry Control - BWR Program, and scope of Class piping welds covered either the Inservice Inspection, One-Time The ISI Program was evaluated as a plant-specific under the NUREG-0313 Inspection, BWR Feedwater Nozzle or BWR program; the One-Time Inspection Program was recommendations. Table 3.1.2-1 of the Vessel Internals Program. Please identify the evaluated for consistency with the NUREG-1801 LRA is clear the applicant credits the BWR components to which the BWR Stress One-Time Inspection and Small-bore Piping AMPs; Feedwater Program for the application is Corrosion Cracking Program is not applicable the BWR Feedwater Nozzle Program was clear for the feedwater inlet thermal sleeve and discuss the evaluation performed to evaluated for consistency with the NUREG-1801 and the BWR Vessel Internals Program for conclude that the activities in the Inservice BWR Feedwater Nozzle AMP; and the BWR the core spray and recirculation inlet Inspection, One-Time Inspection, BWR Vessel Internals Program was evaluated for nozzles. This question is resolved.

Feedwater Nozzle or BWR Vessel Internals consistency with the NUREG-1801 BWR Vessel AMPs are consistent with the activities in the Internals AMP. Each of these programs was BWR Stress Corrosion Cracking AMP determined effective at managing the aging effects recommended by NUREG-1801 for the noted for the associated material and environment components addressed by this AMR, including combinations. Note E was used in Tables 3.1.2-1 the activities performed to manage aging, the and 3.1.2-3 in all of these cases because a sample population inspected, and the different program than the one identified in item inspection locations. 3.1.1-41 is credited for aging management.

217 333 LRA Table 3.1.1, item 3.1.1-47, addresses loss As listed in LRA Tables 3.2.1-2 and 3.1.2-3, the This question is resolved because the of material due to pitting and crevice corrosion reactor vessel internals components with a applicant amended the LRA for AMR Item 147

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in stainless steel and nickel-alloy reactor vessel pressure boundary function are the incore flux 3.1.1-47, as given in LRA Amendment No.

internals. The LRA credits the Water Chemistry monitor dry tubes, local power range monitors and 5, dated February 1, 2007. In this LRA Control - BWR and One-Time Inspection guide tubes. As described in LRA Section 2.3.1 amendment, the applicant amended LRA Programs to manage this aging effect. NUREG- (pages 2.3.1&2), the incore flux monitor guide Item 3.1.1-47 to credit the BWRVIP 1801 recommends the water chemistry and tubes extend from the top of the incore flux monitor Vessel Iternals Program, in addition to the Inservice Inspection (IWB, IWC, and IWD) housings, in the lower plenum, to the top guide. Water Chemistry Program and the One-programs. The LRA states that the One-Time The power range detectors for the power range time Inspection Program, as the basis for Inspection Program will verify the effectiveness monitoring units and the dry tubes for the source managing loss of material due to crevice of the Water Chemistry Control Program to range monitoring and intermediate range or pitting corrosion in nickel alloy and manage loss of material. The LRA also states monitoring (SRM/IRM) detectors are inserted stainless steel BWR RV internal that the Inservice Inspection Program is not through the guide tubes. These components inside components. The BWR Vessel Internals applicable to most reactor vessel internal the reactor vessel are, via the housings in the lower Program prescribes augmented components since they are not part of the plenum, connected to penetrations in the reactor inspections proposed by the BWRVIP and pressure boundary. Please identify the reactor vessel and, therefore, are a part of the reactor approved by the staff for the vessel vessel internals that are part of the pressure coolant pressure boundary. Even though JAFNPP internal components. The BWRVIP boundary and, therefore, are subject to is performing all the inservice inspections required inspections for RV and RV internal Inservice Inspection. For those components, by Section XI of the ASME code, JAFNPP is not components include and go beyond the please clarify why Inservice Inpsection is not crediting the Inservice Inspection Program for the inservice inspections for RV and RV credited for this AMR. Also, please discuss the management of aging for these components due to internal components that are required in evaluation performed to conclude that the their location inside the reactor vessel. The One- accordance the ASME Code Section XI.

activities in the One-Time Inspection AMP are Time Inspection Program, which is credited for consistent with the activities in the Inservice these components inside the vessel, has not been Inspection AMP recommended by NUREG- evaluated for consistency with the NUREG-1801 1801 for the components addressed by this Inservice Inspection (ISI) AMP, but instead was AMR, including the activities performed to evaluated for consistency with the NUREG-1801 manage aging, the sample population One-Time Inspection and Small-bore Piping AMPs.

inspected, and the inspection locations. A Note E was used in Table 3.1.2-2 because a different program than the one identified in item 3.1.1-47 is credited for aging management.

JAFNPP performs all the inspections required by the ASME Section XI Inservice Inspection Program, but this program is not credited for managing loss of material because it does not specifically inspect many of the reactor vessel internal components.

JAFNPP credits the BWR Vessel Internals Program which incorporates the requirements of ASME Section XI, the approved BWRVIP 148

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documents, and other approved industry documents such as vendor letters and NUREGs.

Changes will be made to the License Renewal Application as indicated below.

218 334 LRA Table 3.1.1, item 3.1.1-49, addresses The BWR Vessel Internals Program has been The project team finds the applicants cracking due to SCC, IGSCC, IASCC in nickel- evaluated for consistency with the NUREG-1801 response to be acceptable because the alloy core shroud and core plate welded access BWR Vessel Internals AMP. A Note E was used in response clarifies that the BWR Vessel hole cover with no crevice. The LRA credits the Table 3.1.2-2 because a different program than the Internals Program is the program that is Water Chemistry Control - BWR and BWR one identified in item 3.1.1-49 is credited for aging credited to manage cracking in the core Vessel Internals Program to manage this aging management. shroud and core plate welded access hole effect. NUREG-1801 recommends the cover in lieu of the ISI Program. The Inservice Inspection and Water Chemistry The Inservice Inspection Program requires only a BWRVIP Vessel Internals Program programs. Please discuss the evaluation visual inspection of the shroud support plate prescribes augmented inspections for the performed to conclude that the activities in the access hole covers (as acknowledged in GALL vessel internals that include and go BWR Vessel Internals AMP are consistent with item IV.B1-5). The JAFNPP BWR Vessel Internals beyond the requirements of Section XI.

the activities in the Inservice Inspection AMP program includes the visual examinations required During the project teams AMR audit recommended by NUREG-1801 for the by ASME Section XI as well as any other performed in December 2006, the components addressed by this AMR, including requirements found in approved BWRVIP applicant provided the audit team with a the activities performed to manage aging, the documents, and other industry documents. plant diagram of the welded access hole sample population inspected, and the JAFNPP has credited the BWR vessel internals cover. The diagram provided sufficient inspection locations. program rather than ISI because BWR vessel evidence of the weld configuration for the internals is the governing program for management access hole cover did not create a of the vessel internals. creviced region behind the weld. Thus, the project team concludes that no augmented UT is necessary for the access hole cover weld, as would otherwise be recommended by GALL AMR Line Item IV.B1-5 (i.e. Item R-94) if the weld configuration were to create creviced region behind the weld. This question is resolved.

219 335 LRA Table 3.1.1, item 3.1.1-52, addresses JAFNPP has stainless steel and low alloy steel, The project team finds the applicants cracking due to SCC, loss of material due to carbon steel RCPB bolting. Stainless steel and low response to be acceptable because the wear, loss of preload due to thermal effects, alloy steel, carbon steel RCPB bolting items are applicant has clarified that AMR Item gasket creep and self-loosening for RCPB included in LRA Table 3.1.2-3 (page 3.1-57). The 3.1.1-52 in the LRA covers both stainless 149

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bolting in high pressure and high temperature first sentence of the discussion for LRA Table steel and steel (i.e., low alloy steel or systems. The LRA credits the Bolting Integrity 3.1.1, item 3.1.1-52, is specific to stainless steel carbon steel) bolting. This question is AMP to manage these aging effects, which is bolting. The remaining discussion addresses both resolved.

consistent with NUREG-1801 stainless steel and low alloy steel (or similar material).

recommendations. Please provide the following information: Also, due to more applicable aging mechanisms for loss of material (e.g., general, crevice and pitting a) The LRA only addresses stainless steel corrosion) and SCC not being applicable to alloy bolting. Please confirm that JAFNPP does not steel bolting that is not high-strength, the low alloy have any steel or low alloy carbon steel RCPB steel, carbon steel RCPB bolting was compared to bolting. a NUREG-1801 item (V.E-4), which corresponds to NUREG-1800 item 3.2.1-23, and a Note C is used in Table 3.1.2-3.

220 336 LRA Table 3.1.1, item 3.1.1-52, addresses Loss of material due to wear is not a significant The project team finds the applicants cracking due to SCC, loss of material due to aging effect for RCPB bolting because wear is the response to be acceptable. GALL wear, loss of preload due to thermal effects, result of relative motion between two surfaces and TableIV.C1 includes AMR items IV.C1-12 gasket creep and self-loosening for RCPB any relative displacements or movements during and -13 that specify that loss of material bolting in high-pressure and high temperature normal plant operations are small and the resulting due to wear may be an applicable aging systems. The LRA credits the Bolting Integrity loss of material minimal. The relative motion effect for bolting in Class 1 pumps or AMP to manage these aging effects, which is between bolting and the connected surface that valves. While the response indicates that consistent with NUREG-1801 can occur during periodic assembly/disassembly the applicant does not consider loss of recommendations. Please provide the following for inspection maintenance are not related to material to be an issue for its Class 1 information: normal aging. As described in LRA Table 3.1.1, bolting, it is clear from the AMR Item on item 3.1.1-52, occasional thread failures, such as bolting in LRA Table 3.1.2-3 that the b) The LRA states that industry operating galling (or improper fitup/assembly), are event applicant is crediting the Bolting Integrity experience indicates that loss of material due driven conditions that are resolved as required. Program to manage mechanisms that can to wear is not a significant aging effect for Therefore, loss of material due to wear of RCPB lead to loss of material in the steel bolting bolting. Please provide the technical bolting, both stainless steel and low alloy steel, for its Class 1 pumps and valves. This justification and the operating experience data carbon steel, is not a significant aging effect. would cover any loss of material by wear to support this conclusion. and is consistent with the GALL. The Industry operating experience documented in ASME Section XI requirements discussed various sources, such as the Non-Class 1 in the [Detection of Aging Effect] program Mechanical Implementation Guideline and element of GALL AMP XI.M18, Bolting Mechanical Tools, Revision 3, EPRI, Palo Alto, CA: Integrity, are considered to be sufficient 2001. 1003056 (Mechanical Tools), supports that to manage loss of material in this bolting.

the most common failures of pressure retaining This question is resolved.

bolting in safety-related applications were attributed 150

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to boric acid wastage and a few instances of stress corrosion cracking. No instances of bolting wear have been identified in site or industry documentation that were attributable to normal aging, whereas event driven bolting failures are known to occur, and are corrected in the short-term. Furthermore, the operating experience discussion for the Bolting Integrity Program in NUREG-1801, Revision 1,Section XI.M18 does not address bolting wear as an aging mechanism for bolting.

221 337 LRA Table 3.1.1, item 3.1.1-52, addresses As described in LRA Table 3.1.1, item 3.1.1-52, The project team finds the applicants cracking due to SCC, loss of material due to loss of preload would only be a concern in very response to be acceptable as the JAFNPP wear, loss of preload due to thermal effects, high temperature applications (> 700ºF), per ASME operates at approximately 550EF and gasket creep and self-loosening for RCPB Code Section II, Part D, Table 4. No JAFNPP 1000 psig pressure and the applicant has bolting in high-pressure and high temperature systems operate at > 700ºF so no JAFNPP bolting used an applicable materials source systems. The LRA credits the Bolting Integrity is exposed to the high temperatures that could document to screen whether its Class 1 AMP to manage these aging effects, which is result in a loss of preload. At elevated low alloy steel bolting for loss of preload consistent with NUREG-1801 temperatures (thermal effects), a fastener will due to stress relaxation. This question is recommendations. Please provide the following produce less and less clamping force with time, resolved.

information: referred to as relaxation. A bolted joint at 1200ºF can lose as much as 50% of preload.

c) The LRA states that loss of preload is a design driven effect and not an aging effect Furthermore, elevated temperature behavior, e.g.,

requiring management. Please provide the where relaxation might occur, begins at 700ºF for technical justification for concluding that low alloy steels, and higher for austenitic stainless thermal cycles, gasket creep and self-loosening steels (Ref. Volume 11 of the Metals Handbook, are not aging mechanisms that could lead to 9th Edition, Failure Analysis and Prevention).

this aging effect. Gasket creep and self-loosening, that are not a product of thermal effects, typically occur shortly after initial loading and early in the service life with actions taken to prevent recurrence.

222 338 LRA Table 3.1.1, item 3.1.1-52, addresses Good bolting practices in accordance with EPRI The basis for item 221 applies to Item cracking due to SCC, loss of material due to NP-5067, "Good Bolting Practices, A Reference 222. In addition, the applicant has clarified wear, loss of preload due to thermal effects, Manual for Nuclear Power Plant Maintenance that no instances of operating experience gasket creep and self-loosening for RCPB Personnel," volume 1: "Large Bolt Manual," 1987 with loss of preload/stress relaxation has 151

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bolting in high-pressure and high temperature and volume 2: "Small Bolts and Threaded occurred in the Class1 bolting at JAFNPP.

systems. The LRA credits the Bolting Integrity Fasteners," 1990, have been implemented for the The applicant has credited the Bolting AMP to manage these aging effects, which is Bolting Integrity Program of JAFNPP with further Integrity Program to manage aging in the consistent with NUREG-1801 enhancement to include guidance from EPRI NP- Class 1 steel bolting at JAFNPP. The recommendations. Please provide the following 5769, Degradation and Failure of Bolting in Nuclear applicants implementation of the Bolting information: Power Plants, Volumes 1 and 2, April 1988 and Integrity for the Class 1 steel bolting at EPRI TR-104213, Bolted Joint Maintenance & JAFNPP should be sufficient to detect any d) The LRA states that proper joint preparation Application Guide, Electric, December 1995 loss of preload that may occur in this and make-up in accordance with industry planned for license renewal, as described in LRA bolting. This question is resolved.

standards is expected to preclude loss of Appendix B, Section B.1.30. No instances of a loss preload and this is confirmed by operating of bolt preload that occurred as a result of aging experience at JAFNPP. Please discuss and have been identified for JAFNPP, which provides provide the plant operating experience confirmation that the bolting practices, along with justifying this conclusion. the RCS temperatures below 700ºF, have precluded a loss of preload (ref. JAF-RPT LRD05, Attachment 5). Nevertheless, the JAFNPP Bolting Integrity Program includes the aging management activities specified in NUREG-1801,Section XI.M18.

223 339 LRA Table 3.1.1, item 3.1.1-55, addresses loss ASME Code Case N-481 is not applicable to the The project team finds the applicants of fracture toughness due to thermal aging JAF ISI Program for reactor recirculation Pump response to be acceptable with the embrittlement in CASS Class 1 pump casing Casings. exception that states the ASME Section XI and valve bodies and bonnets exposed to does not include any NDE requirements reactor coolant. JAF has no welds in the recirculation pump casing. for Class 1 valves less than 4 inches NPS.

The ISI program is applicable for Valve bodies > 4 The 2001 Edition of ASME Section XI, The LRA credits the ISI for pumps and One- for visual examination of internal surfaces, Table IWB-2500-1, Examination Category Time Inspection for valves to manage this pressure testing and leak testing. This is credited B-M-1, Inspection B12.30 requires a aging effect. Please clarify whether JAFNPP for managing aging effects. surface examination once every ten- year will use ASME Code Case N-481 as an ISI interval for welds in valve bodies less alternative for pump casing. Also, please clarify Valves # 4 have no required NDE inspections than 4 inches in NPS. Subsequent to the why One-Time Inspection is credited for valves. under the ASME Section XI Code or the ISI audit, the applicant stated that it will program, but are required to be visually inspected amend the LRA Table 3.1.2 .3 for line item (VT-2) in accordance with the pressure testing 3.1-55 to add the ISI program along with program conducted every refuel outage. This visual one -time inspection program to manage inspection requirement also applies to Pump the reduction of fracture toughness for Casings because they are included in the pressure valve bodies <4 NPS, with CASS testing program. material. The project team finds this 152

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The One-Time Inspection Program will be response acceptable since it is consistent addressed by utilizing industry initiatives for with GALL Report recommendations. The program and inspection development. project team's review is discussed in SER Section 3.1.2.1.6. This question is resolved.

224 340 LRA Table 3.1.1, item 3.1.1-57, addresses loss The One-Time Inspection Program has not been The project team finds the applicants of fracture toughness due to thermal aging evaluated for consistency with the NUREG-1801 response to be acceptable as the main embrittlement in CASS Class 1 piping Thermal Aging Embrittlement of CASS AMP, but steam flow restrictors are not Class 1 component, and piping elements and CRD was instead evaluated for consistency with the reactor coolant pressure boundary pressure housings exposed to reactor coolant. NUREG-1801 One-Time Inspection and Small-bore components. The project team concludes The LRA credits the One-Time Inspection AMP Piping AMPs. A Note E was used in Table 3.1.2-3 that a one-time examination of the main to manage this aging effect for the main steam because a different program than the one identified steam flow restrictors is sufficient to flow restrictors, which are the only CASS in item 3.1.1-57 is credited for aging management. determine whether cracking has occurred component in the scope of this AMR. NUREG- The One-Time Inspection Program will detect in the components. Consistent with the 1801 recommends the Thermal Aging cracking that is symptomatic of reduction of basis in GALL for Class 1 pump casings Embrittlement of CASS program. Please fracture toughness using established visual and valve bodies made from CASS as discuss the evaluation performed to conclude nondestructive examination (NDE) techniques. given in the NRC letter (i.e., Chris Grimes that the activities in the One-Time Inspection Reduction of fracture toughness does not cause letter) to NEI dated, May 19, 2000, the AMP are consistent with the activities in the cracking, but the reduced toughness allows staffs position is that loss of fracture Thermal Aging Embrittlement of CASS AMP existing cracks to propagate at higher rates. The toughness due to thermal aging needs to recommended by NUREG-1801 for the sample population includes all of the main steam be addressed in the main steam flow components addressed by this AMR, including flow restrictors. NUREG-1801 XI.M12 program is restrictors if the one-time examination the activities performed to manage aging, the applicable to primary pressure boundary and indicates the cracking has occurred in the sample population inspected, and the reactor vessel internal components. components. This question is resolved.

inspection locations.

225 341 LRA Table 3.1.2-1 includes a line item on The ISI Program manages loss of material for The project team finds the applicants reactor vessel external attachments that reactor vessel external attachments by surface response to be acceptable because the addresses the loss of material of structural low examination using NDE techniques specified in applicant has clarified which ASME alloy and carbon steel exposed to an air-indoor ASME Section XI, Subsection IWB; specifically Section ISI Category and examination (external) environment. The LRA credits the ISI IWB-2500 category B-K. The current inspection method is used to monitor for loss of AMP for managing this aging effect. Generic frequency is once an interval (10yrs) on the material in the reactor vessel external note H is cited, indicating that this aging effect recommended sample size of 100% of the total attachments. The surface examinations is not addressed in NUREG-1801. Please population. mandated by the ASME Code Section XI, discuss the specific ISI AMP activities that will Examination Category B-K requirements be performed to manage this aging effect. are sufficient to monitor for and detect any indications of surface-induced loss of 153

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material effects that, if present, could potentially threaten the structural integrity of these attachments. This question is resolved.

226 342 LRA Table 3.1.2-1 includes a line item on As stated in LRA Section B.1.23, the Reactor Head The project team finds the applicants reactor vessel closure flanges that addresses Closure Studs Program is consistent with the response to be acceptable based on the the loss of material of high-strength low-alloy program described in NUREG-1801, Section determination that the program attributes steel exposed to an air-indoor (external) XI.M3, Reactor Head Closure Studs. (There is one for the applicants Reactor Head Closure environment. The LRA credits the Reactor exception but it is not related to wear detection.) As Studs, as defined in the bases document Head Closure Studs AMP for managing aging stated in NUREG-1801,Section XI.M3, under for AMP B.1.23, were consistent with of this component. Generic note H is cited, Detection of Aging Effects, inspection can reveal those recommended in GALL AMP XI.M3 indicating that this aging effect is not addressed cracking, loss of material due to corrosion or wear, and provided a sufficient summary of the in NUREG-1801. Please discuss the specific and leakage of coolant. Specifically, visual activities that will be performed to manage activities in the Reactor Head Closure Studs inspections specified in ASME Section XI, Table both loss of material and cracking in the AMP that will be performed to manage this IWB-2500-1 detect loss of material. reactor vessel closure studs and their aging effect. assembly components. This question is resolved.

227 343 LRA Table 3.1.2-1 includes two line items to The reactor vessel flange leak detection system The project team finds the applicants address the reactor vessel closure flange consists of lines attached to two separate drilled response to be acceptable because the leakoff nozzle; one line item addresses penetrations in the vessel flange, one between the applicant has clarified which materials and stainless steel and the other carbon steel. reactor vessel O-rings and one outside of the outer specifications were used to fabricate the Please clarify with sketches how the reactor O-ring. Therefore, materials for the reactor vessel two flange leak-off lines; sketches are not flange leakoff nozzle at JAFNPP has closure flange leakoff nozzles were based on the necessary for the project teams components made out of these two different connecting piping material specifications. The determination, since the material materials. connecting piping for nozzle N13 was identified as specifications are sufficient to designate stainless steel (A376 Type 304), and for nozzle the material types for these lines. This N14, carbon steel (A106 Grade B). question is resolved.

228 344 LRA Table 3.1.2-3 includes line items to There are nine line entries in JAFNPP LRA Table The project team noted that, in LRA address cracking for various components 3.1.2-3 that reference Table 3.1.1-1 Item 3.1.1-48. Table 3.1.2-3, for AMR line items that (including condensing chambers, CRD, CRD Five of these entries reference Water Chemistry reference Table 3.1.1, Item 3.1.1-48, filter housing, instrumentation orifices, etc.) Control - BWR, the OTI-Small Bore Piping cracking of condenser chambers, CRD constructed of stainless steel and exposed to program, and the ISI program, consistent with filter housings, and orifices are managed reactor coolant. In some cases, the LRA credits GALL item IV.C1-1. JAFNPP will modify the license by the Water Chemistry Control-BWR the Water Chemistry Control - BWR and One- renewal application to add ISI to the three line Program and the One-Time Inspection 154

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Time Inspection AMPs, while for other cases, items (Condensing chambers, CRD filter housings, Program. Also, cracking of the control rod the LRA credits the Water Chemistry Control - and Orifices) that do not currently have this drive unit pressure boundary components BWR and Inservice Inspection AMPs to program. This will make 8 of the 9 entries list all 3 are managed by the Water Chemistry manage cracking. However, all line items refer programs and be consistent with GALL entry Control-BWR Program and the Inservice to Table 1 item 3.1.1-48, which credits the IV.C1-1. Note that these entries will retain a note E Inspection Program.

Water Chemistry Control - BWR, Inservice because the JAFNPP ISI program is considered a Inspection and One-Time Inspection AMPs for plant specific program. During the audit and review, the applicant managing cracking in stainless steel RCPB There was no GALL line that made a good committed to amend the LRA to add the components. Please clarify these discrepancies comparison for the Control Rod Drives. JAFNPP Inservice Inspection Program to the AMRs where only two out of three AMPs are credited decided that IV.C1-1 was the closest GALL line for components condensing chambers, for RCPB components. item and therefore used it for comparison. CRD filter housings and orifices. In However, because the drives are not small bore February 01, 2007, the applicant amended piping, the One-Time Inspection for ASME Code LRA Table 3.1.2-3, for AMRs that Class 1 Small Bore Piping does not apply to the reference line Item 3.1.1-48, to add the drives. The CRDs are inspected by ISI in Inservice Inspection Program to the AMRs accordance with ASME Section XI, and therefore for condensing chambers, CRD filter the ISI program is credited. The note for this entry housings and orifices. The team finds this is E, both because the OTI Small Bore program is LRA amendment acceptable since it will not listed and because the ISI program is plant specific. make these AMRs consistent with the recommendations in the GALL Report.

Note 107: The program credited in NUREG-1801, IV.C1-1 is the One-Time Inspection of ASME Code For the AMR line items addressing the Class 1 Small Bore Piping, not the One-Time CRD units, the applicant stated that since Inspection to verify the effectiveness of Water these components are not small bore Chemistry Control. GALL item IV.C1-1 does not piping, the One-Time Inspection Program call out the One-time inspection to verify water does not apply. Therefore, the Inservice chemistry control, consequently JAFNPP did not Inspection Program along with the Water add Note 107 as the nine entries calling out IV.C1- Chemistry Control-BWR Program are 1 are consistent with that GALL item without OTI adequate to manage cracking. The project for WCC verification. team reviewed the applicants Inservice Inspection Program and found that this AMP includes periodic inspections that will be effective for detecting cracking in the CRD units. The team finds that the applicant's Inservice Inspection Program along with the Water Chemistry Control-BWR Program, will provide adequate assurance that cracking due to SCC, IGSCC, and IASCC will be managed 155

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for these components.

The team finds that, for the components piping and pipe elements less than 4 inches NPS, condensing chambers, CRD filter housings, orifices, and CRD pressure boundary components addressed by this AMR, the use of the Water Chemistry Control-BWR Program, Inservice Inspection Program, and One-Time Inspection Program will effectively manage cracking due to SCC, IGSCC and cracking due to thermal and mechanical loading. On this basis, the team finds the AMR results for this line item acceptable.

This question is resolved.

229 345 LRA Table 3.1.2-2 includes a line item to a) [Refer to response to Item 256.] At JAF, hold- The project team finds the applicants address cracking of the reactor top guide down assemblies are inspected with a conservative response acceptable because the assembly. The LRA credits the Water decision making philosophy. In that, JAF has been applicant has been inspecting the top Chemistry Control-BWR, BWR Vessel inspecting the hold down assemblies despite guide hold down assemblies in Internals, and One-Time Inspection AMPs to BWRVIP-26-A (A version approved by the NRC), accordance with BWRVIP-26A even manage this aging effect. The description of the Figure A-1 showing that the FitzPatrick plant though the BWRVIPs evaluation of lift BWR Vessel Internals program in Section B.1.7 faulted vertical loads at hold-down assemblies are forces for BWR top guides indicates that of the LRA includes an exception stating that on the demarcation line between lift off and will the top guide at FitzPatrick will not lift the inspection of the hold-down assemblies of not lift. Therefore, the hold down assemblies will under a postulated faulted event. Thus, a the top guide at 0degree and 180degree are not lift-off during a postulated seismic event. one-cycle deferral of the examination is deferred from RO16 to RO17. NUREG-1801 justified and the inspections during RO17 recommends augmented inspections for top Accessible areas of top guide hold-down did not detect any indications of cracking guides with neutron fluence exceeding the assemblies at 0° and 180° were inspected in R17 in the top guide rim hold down assemblies.

IASCC threshold (5E20. E>1MEV) before or (Fall 2006) by VT-1 visual method with no This question is resolved.

after entering the period of extended operation. recordable indications noted. R17 inspections also Please provide the following information: included top guide grid beam and beam-to-beam crevice slot at three locations by VT-3/VT-1 with no a) Discuss the current condition of the top recordable indications noted.

guide, including any degradation or cracking that has been observed and any corrective 156

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actions performed.

230 436 LRA Table 3.1.2-2 includes a line item to b) FitzPatrick plans to continue implementing the The project team finds the applicants address cracking of the reactor top guide inspection requirement per BWRVIP-26-A, response to be acceptable because the assembly. The LRA credits the Water including NRC SER dated December 7, 2000. applicant has clarified that it is crediting Chemistry Control-BWR, BWR Vessel the inspection recommendations in Internals, and One-Time Inspection AMPs to BWRVIP-26A for future inspections of the manage this aging effect. The description of the top guides, including inspections of the 0 BWR Vessel Internals program in Section B.1.7 degree and 180 degree top guide hold-of the LRA includes an exception stating that down assembly locations. The staff the inspection of the hold-down assemblies of approved the inspection and flaw the top guide at 0degree and 180degree are evaluation guidelines for top guides, as deferred from RO16 to RO17. NUREG-1801 provided in BWRVIP-26A, for recommends augmented inspections for top implementation by letter to NEI dated guides with neutron fluence exceeding the 12/07/2000. This question is resolved.

IASCC threshold (5E20. E>1MEV) before or after entering the period of extended operation.

Please provide the following information:

b) Based on past operating experience, provide the technical basis for concluding that the BWR vessel internals, water chemistry, and one-time inspection AMPs are adequate for maintaining the structural integrity of the top guide, specifically the hold-down assemblies, during the period of extended operation.

231 347 LRA Table 3.1.2-2 includes a line item to c) See the responses to questions 251 and 252 for The project teams basis for acceptance is address cracking of the reactor top guide additional information on the top guide inspections. based on License Amendment No. 9, assembly. The LRA credits the Water The fluence threshold for IASCC of 5E20 was dated April 6, 2007. In this amendment, Chemistry Control-BWR, BWR Vessel exceeded after approximately the first 5 years of Entergy placed Commitment No. 21 on the Internals, and One-Time Inspection AMPs to operation. Ten (10) percent of the top guide cross LRA. Commitment No. 21 will require the manage this aging effect. The description of the hatch area locations will be inspected using applicant to:

BWR Vessel Internals program in Section B.1.7 enhanced visual inspection technique, EVT-1, of the LRA includes an exception stating that within the first 12 years of the period of extended Enhance the BWR Vessel Internals the inspection of the hold-down assemblies of operation, with at least one-half of the inspections Program to inspect fifteen (15) percent of the top guide at 0 and 180 are deferred from to be completed within the first 6 years of the the top guide locations using enhanced RO16 to RO17. NUREG-1801 recommends period of extended operation. Locations selected visual inspection techniques, EVT-1, 157

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augmented inspections for top guides with for examination will be areas that have exceeded within the first 18 years of the period of neutron fluence exceeding the IASCC threshold the neutron fluence extended operation, with at least one-third (5E20. E>1MEV) before or after entering the threshold. Inspections of 10 percent of the top of the inspections to be completed within period of extended operation. Please provide guide cross hatch area locations within the first 12 the first six (6) years and at least two-the following information: years of the period of extended operation provides thirds within the first 12 years of the period assurance that the program will be sufficient to of extended operations. Locations c) Discuss any augmented inspections that are manage IASCC in the top guide for the PEO. selected for examination will be areas that being performed now, or will be performed have exceeded the neutron fluence during the period of extended operation to threshold.

monitor the condition of the top guide.

This commitment is consistent and goes beyond the recommendations for top guide grid beam examinations discussed in GALL AMP XI.M9, and is acceptable. This question is resolved.

232 348 LRA Table 3.1.2-2 includes a line item to The flawed vertical welds at JAF have been The project team finds the applicants address cracking of the reactor vessel core determined to be acceptable for further service until response to be acceptable because the shroud. The LRA credits the Water Chemistry R18 (CR-JAF-2006-04238 & 04287). An EOI (end applicant evaluated and will re-evaluate Control-BWR and BWR Vessel Internals AMPs of interval) calculation for belt-line welds SV5A and the flaw indications in the shroud vertical to manage this aging effect. The description of SV5B will be prepared in 2007 (CR-JAF-2006- welds in accordance with the flaw the BWR Vessel Internals AMP in Section 04238 CA 00003) in accordance with BWRVIP-76 evaluation guidelines in BWRVIP-76.

B.1.7 of the LRA includes a discussion of guidelines. BWRVIP-76 was recently approved by There are no corrective actions (repairs) operating experience, which states that crack- the NRC in a letter dated 7/27/2006. There are no anticipated at the present time since like indications were identified at four core corrective actions (repairs) anticipated at the significant margin remains for structural shroud vertical welds in RO14. Also, a line item present time since significant margin remains for evaluations. The staff-approved inspection on shroud stabilizers in LRA Table 3.1.2-2 structural evaluations. and flaw evaluation guidelines for core indicates that the shroud has cracks, which shrouds, as recommended in BWRVIP-76, were repaired in the past and are being in a safety evaluation to NEI, dated July, managed by plant programs. Please provide 27, 2006. This question is resolved.

the following information:

a) Discuss the current condition of the core shroud, including any degradation or cracking detected and corrective actions taken.

233 349 LRA Table 3.1.2-2 includes a line item to FitzPatrick plans to continue core shroud The project team finds the applicants address cracking of the reactor vessel core inspections per BWRVIP-76 requirements, response to be acceptable because the 158

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shroud. The LRA credits the Water Chemistry including a future A version when issued. applicant evaluated and will re-evaluate Control-BWR and BWR Vessel Internals AMPs BWRVIP-76 was recently approved by the NRC in the flaw indications in the shroud vertical to manage this aging effect. The description of a letter dated 7/27/2006. welds in accordance with the flaw the BWR Vessel Internals AMP in Section evaluation guidelines in BWRVIP-76. The B.1.7 of the LRA includes a discussion of staff-approved inspection and flaw operating experience, which states that crack- evaluation guidelines for core shrouds, as like indications were identified at four core recommended in BWRVIP-76, in a safety shroud vertical welds in RO14. Also, a line item evaluation to NEI, dated July, 27, 2006.

on shroud stabilizers in LRA Table 3.1.2-2 This question is resolved.

indicates that the shroud has cracks, which were repaired in the past and are being managed by plant programs. Please provide the following information:

b) Based on past operating experience, provide the technical basis for concluding that the BWR vessel internals and water chemistry AMPs are adequate for maintaining the structural integrity of the core shroud during the period of extended operation.

234 350 LRA Table 3.1.2-2 includes a line item to See response to Item 246. The JAFNPP BWR The project team finds the applicants address cracking of the reactor vessel core Reactor Vessel Internals Program includes actions response to be acceptable because the shroud. The LRA credits the Water Chemistry specified in approved and applicable BWRVIP applicant evaluated and will re-evaluate Control-BWR and BWR Vessel Internals AMPs reports including BWRVIP-76, which addresses the flaw indications in the shroud vertical to manage this aging effect. The description of core shroud inspections. BWRVIP-76 was welds in accordance with the flaw the BWR Vessel Internals AMP in Section approved in July 2006. evaluation guidelines in BWRVIP-76. The B.1.7 of the LRA includes a discussion of staff-approved inspection and flaw operating experience, which states that crack- evaluation guidelines for core shrouds, as like indications were identified at four core recommended in BWRVIP-76, in a safety shroud vertical welds in RO14. Also, a line item evaluation to NEI, dated July, 27, 2006.

on shroud stabilizers in LRA Table 3.1.2-2 This question is resolved.

indicates that the shroud has cracks, which were repaired in the past and are being managed by plant programs. Please provide the following information:

c) Discuss any augmented inspections that are 159

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being performed now, or will be performed during the period of extended operation to monitor the condition of the core shroud.

235 351 LRA Table 3.1.2-2 includes a line item to JAF verified the structural integrity of the top The project team finds the applicants address cracking of the core support rim bolts. locking engagement of all 72 installed bolts per response to be acceptable because the The LRA credits the Water Chemistry Control- drawing configuration. This included a 100% applicant has summarized the type of BWR and BWR Vessel Internals AMPs to baseline of all bolts by VT-3 inspection in 1998 (R13). NDE examinations that have been manage this aging effect. The description of the performed on the core plate hold-down BWR Vessel Internals AMP in Section B.1.7 of JAF also verified the structural integrity of the top bolts and clarified that no indications in the the LRA includes an exception, which states locking engagement of 20 bolts by the VT-1 bolts were detected as a result of NDE that JAFNPP provides an alternate inspection method in December 1994 (R11). There were no examinations performed on the bolts in for the core plate rim hold-down bolts that is recordable indications noted on these exams. 1994 and 1998.

technically justified according to BWRVIP- 94.

Please provide the following BWRVIP-94 provides guidance on implementation The applicant amended the LRA in information: of the BWRVIP reports. BWRVIP-94 provides Amendment No. 9 dated April 6, 2007, administrative guidelines on how justifications of and placed Commitment No. 23 on the a) Discuss the current condition of the core alternate inspections should be prepared but does LRA relative to aging management of the support rim bolts, including any degradation or not provide technical bases. BWRVIP-94 is core plate hold-down bolts. The cracking detected and corrective actions taken. endorsed by procedure Entergy ENN-DC-135. commitment will require Entergy either to install wedges in the core plate design prior to entering the period of extended operation or submit an inspection plan for the core plate hold-down bolts to the NRC for review and approval at least two years prior to entering the period of extended operation.

These activities will ensure the structural integrity of the core plate for the period of extended operation. Refer to Section 3.0.3.2.7 of the staffs SER for additional details. This question is resolved.

236 352 LRA Table 3.1.2-2 includes a line item to FitzPatrick plans to inspect the core support rim The project team finds the applicants address cracking of the core support rim bolts. bolts during the PEO either by ASME Code Section response to be acceptable because the The LRA credits the Water Chemistry Control- XI or by BWRVIP-25 provided there is a viable applicant has summarized the type of BWR and BWR Vessel Internals AMPs to inspection method and BWRVIP-25 received NDE examinations that have been 160

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manage this aging effect. The description of the approval by NRC. performed on the core plate hold-down BWR Vessel Internals AMP in Section B.1.7 of bolts and clarified that no indications in the the LRA includes an exception, which states Refer to response to AMP audit question 252. bolts were detected as a result of NDE that JAFNPP provides an alternate inspection JAFNPP developed technical justifications for examinations performed on the bolts in for the core plate rim hold-down bolts that is deviation from the guidelines of BWRVIP-25 in 1994 and 1998.

technically justified according to BWRVIP- 94. accordance with the guidance given in Appendix A Please provide the following information: to BWRVIP-94. This appendix does not provide The applicant amended the LRA in technical justification in and of itself, rather it Amendment No. 9 dated April 6, 2007, b) Based on past operating experience, provide provides administrative guidelines for processing a and placed Commitment No. 23 on the the technical basis for concluding that the BWR technical justification. Entergy is deviating from the LRA relative to aging management of the vessel internals and water chemistry AMPs are guidelines of BWRVIP-25 because the method core plate hold-down bolts. The adequate for maintaining the structural integrity proposed for core plate rim hold down bolts is not commitment will require Entergy either to of the core support rim bolts during the period feasible. JAFNPP plans to perform the inspections install wedges in the core plate design of extended operation. required by ASME Section XI as an alternate prior to entering the period of extended method for inspection of the core plate rim hold operation or submit an inspection plan for down bolts. the core plate hold-down bolts to the NRC for review and approval at least two years The examination method, inspection frequency, prior to entering the period of extended and inspection sample size for the alternative operation.

inspection method will be in accordance with the requirements of ASME Section XI, Table IWB- These activities will ensure the structural 2500- 1, Examination Category B-N-2. integrity of the core plate for the period of extended operation. Refer to Section LRA Section A.2.1.7 and Section B.1.7 will be 3.0.3.2.7 of the staffs SER for additional revised to include the following enhancement. details. This question is resolved.

JAFNPP will perform inspections of the core plate rim hold down bolts in accordance with ASME Section XI Table IWB-2500-1, Examination Category B-N-2 or in accordance with a future NRC-approved revision of BWRVIP-25 that provides a feasible method of inspection.

237 353 LRA Table 3.1.2-2 includes a line item to FitzPatrick plans to inspect the core support rim The project team finds the applicants address cracking of the core support rim bolts. bolts during the PEO either by ASME Code Section response to be acceptable because the The LRA credits the Water Chemistry Control- XI or by BWRVIP-25 provided there is a viable applicant has summarized the type of BWR and BWR Vessel Internals AMPs to inspection method and BWRVIP-25 is approved by NDE examinations that have been manage this aging effect. The description of the NRC. The NRC has accepted the reference of performed on the core plate hold-down 161

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BWR Vessel Internals AMP in Section B.1.7 of BWRVIP-25 in License Renewal Applications. bolts and clarified that no indications in the the LRA includes an exception, which states Refer to EPRI letter 2001-006 and NRC letter dated bolts were detected as a result of NDE that JAFNPP provides an alternate inspection 12/7/2000. examinations performed on the bolts in for the core plate rim hold-down bolts that is 1994 and 1998.

technically justified according to BWRVIP- 94. Refer to response to AMP audit question 252.

Please provide the following information: JAFNPP developed technical justifications for The applicant amended the LRA in deviation from the guidelines of BWRVIP-25 in Amendment No. 9 dated April 6, 2007, c) Discuss any augmented inspections that are accordance with the guidance given in Appendix A and placed Commitment No. 23 on the being performed now, or will be performed to BWRVIP-94. This appendix does not provide LRA relative to aging management of the during the period of extended operation to technical justification in and of itself, rather it core plate hold-down bolts. The monitor the condition of the core support rim provides administrative guidelines for processing a commitment will require Entergy either to bolts. technical justification. install wedges in the core plate design Entergy is deviating from the guidelines of prior to entering the period of extended BWRVIP-25 because the method proposed for core operation or submit an inspection plan for plate rim hold down bolts is not feasible. JAFNPP the core plate hold-down bolts to the NRC plans to perform the inspections required by ASME for review and approval at least two yearsSection XI as an alternate method for inspection of prior to entering the period of extended the core plate rim hold down bolts. operation.

The examination method, inspection frequency, These activities will ensure the structural and inspection sample size for the alternative integrity of the core plate for the period of inspection method will be in accordance with the extended operation. Refer to Section requirements of ASME Section XI, Table IWB- 3.0.3.2.7 of the staffs SER for additional 2500-1, Examination Category B-N-2. details. This question is resolved.

LRA Section A.2.1.7 and Section B.1.7 will be revised to include the following enhancement.

JAFNPP will perform inspections of the core plate rim hold down bolts in accordance with ASME Section XI Table IWB-2500-1, Examination Category B-N-2 or in accordance with a future NRC-approved revision of BWRVIP-25 that provides a feasible method of inspection. The NRC has accepted the reference of BWRVIP-25 in License Renewal Applications, however, it provides no viable inspection method for the core plate rim hold down bolts. Refer to EPRI letter 2001-006 and NRC letter dated 12/7/2000.

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238 354 LRA Table 3.1.2-2 includes a line item to a) FitzPatrick inspected all twenty jet pump beams The project team finds the applicants address cracking of the jet pump assemblies. by UT in R17 with no recordable indications noted. response to be acceptable because the The LRA credits the Water Chemistry Control- Also in R17, FitzPatrick inspected by UT (ID 360º applicant has clarified that it performed the BWR and BWR Vessel Internals AMPs to tooling) high priority welds at jet pump diffuse and augmented inspection of all 20 jet pump manage this aging effect. The description of the adapter/lower ring assembly of all 20 jet pumps. hold down beams during refueling outage BWR Vessel Internals AMP in Section B.1.7 of Indications were recorded at welds DF-2 (JP#1 & 3) 17 and summarized the results of the the LRA includes an exception, which states that and AD3b/DF-3 (JP# 12 & 17). All indications were examinations. All indications were inspections for inaccessible welds, beam (UT), determined acceptable (CR-JAF2006-04531). determined acceptable (CR-JAF2006-and scheduled inspections of high ranked welds 04531). The applicant is using the for the jet pump assemblies have been deferred, recommended inspection and flaw but the deferrals are technically justified. Please evaluation criteria in BWRVIP-41 for these provide the following information: examinations and for the evaluations of any relevant indications that result from the a) Discuss the current condition of the jet pump examinations. The staff approved assemblies including any degradation or BWRVIP-41 for implementation in a safety cracking detected and corrective actions taken. evaluation to NEI dated June 5, 2001. This question is resolved.

239 355 LRA Table 3.1.2-2 includes a line item to b) Refer to response to AMP audit question 257. The project team finds the applicants address cracking of the jet pump assemblies. FitzPatrick plans to continue inspecting jet pump response to be acceptable because the The LRA credits the Water Chemistry Control- assembly welds by BWRVIP-41, Revision 1 applicant has clarified that it performed the BWR and BWR Vessel Internals AMPs to guidelines and by a future NRC approved A augmented inspection of all 20 jet pump manage this aging effect. The description of the version, when available. The BWRVIP NDE Center hold down beams during refueling outage BWR Vessel Internals AMP in Section B.1.7 of has an action item to develop techniques and 17 and summarized the results of the the LRA includes an exception, which states tooling for access to inaccessible welds. The examinations. The applicant is using the that inspections for inaccessible welds, beam JAFNPP BWR Reactor Vessel Internals Program recommended inspection and flaw (UT), and scheduled inspections of high ranked requires implementation of the inspections evaluation criteria in BWRVIP-41 for these welds for the jet pump assemblies have been specified by applicable and approved BWRVIP examinations and for the evaluations of deferred, but the deferrals are technically reports, including BWRVIP-41 for the jet pump any relevant indications that result from justified. Please provide the following assemblies. The BWRVIP is based on past the examinations. The staff approved information: operating experience throughout the BWR fleet. BWRVIP-41 for implementation in a safety evaluation to NEI dated June 5, 2001.

b) Based on past operating experience, provide This question is resolved.

the technical basis for concluding that the BWR vessel internals and water chemistry AMPs are adequate for maintaining the structural integrity of the jet pump assemblies, including the inaccessible welds, during the period of 163

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extended operation.

240 356 LRA Table 3.1.2-2 includes a line item to c) Fitzpatrick will continue inspections in The project team finds the applicants address cracking of the jet pump assemblies. accordance with BWRVIP-41, Revision 1 response to be acceptable because the The LRA credits the Water Chemistry Control- guidelines and by a future NRC approved A applicant has clarified that it will continue BWR and BWR Vessel Internals AMPs to version, when available. No inspections beyond its inspection of the jet pump assemblies manage this aging effect. The description of the BWRVIP-41 are planned. The JAFNPP BWR in accordance with the recommended BWR Vessel Internals AMP in Section B.1.7 of Reactor Vessel Internals Program requires inspection and flaw evaluation guidelines the LRA includes an exception, which states implementation of the inspections specified by of BWRVIP-41. The staff approved that inspections for inaccessible welds, beam applicable and approved BWRVIP reports, BWRVIP-41 for implementation in a safety (UT), and scheduled inspections of high ranked including BWRVIP-41 for the jet pump assemblies. evaluation to NEI dated June 5, 2001.

welds for the jet pump assemblies have been This question is resolved.

deferred, but the deferrals are technically justified. Please provide the following information:

c) Discuss any augmented inspections that are being performed now, or will be performed during the period of extended operation to monitor the condition of the jet pump assemblies.

241 357 LRA Table 3.1.2-1 and Table 3.1.2-2 include (a) FitzPatrick performs inspections of the The project team finds the applicants line items to address cracking of core spray Feedwater, Core spray per BWRVIP-48A, 18A and response to be acceptable because the lines and feedwater lines, including spargers per response to NUREG 0619 as applicable. The applicant has clarified: (1) that it is using and thermal sleeves. The LRA credits the current condition of Core spray and Feedwater BWRVIP-48A for its augmented Water Chemistry Control-BWR, BWR Vessel piping and spargers are satisfactory with no examinations of the core spray Internals, BWR Feedwater Nozzle and One- degradation / cracking noted based on current attachments, (2) that it is using BWRVIP-Time Inspection AMPs to manage this aging inspection results. Previously identified indication in 18 for the inspections of the core spray effect. Please provide the following information: Loop (B) Core Spray piping was weld repaired piping, (3) that it is using NUREG-0619 for utilizing a Clamp repair in 1988 per modification F1- the inspections of the feedwater piping a) Discuss the current condition of the core 88-199. and nozzles. The current condition of spray lines and feedwater lines, including Core spray and Feedwater piping and spargers and thermal sleeves, in terms of any spargers are satisfactory with no degradation or cracking detected and corrective degradation / cracking noted based on actions taken. current inspection results. Previously identified indication in Loop (B) Core Spray piping was weld repaired utilizing a Clamp repair in 1988 per modification F1-164

Question and Answer Database Audit and Review Related to the License Renewal Application for James A. Fitzpatrick Nuclear Power plant Applicant's No. Audit Questions Applicants Response Project Team's Evaluations Ref. No.88-199. The project team also finds the response to be acceptable because it clarifies that the most recent inspections of the core spray and feedwater lines did not detect any relevant indications in these components. This question is resolved.

242 358 LRA Table 3.1.2-1 and Table 3.1.2-2 include (b)The BWR FW nozzles have been modified The project team finds the applicants line items to address cracking of core spray based on the recommendations of NUREG 0619. response to be acceptable because the lines and feedwater lines, including spargers This includes cladding removal in the radius and applicant has clarified: (1) that it is using and thermal sleeves. The LRA credits the bore regions, change out of the thermal sleeve to a BWRVIP-48A for its augmented Water Chemistry Control-BWR, BWR Vessel triple sleeve double piston ring, and implementation examinations of the core spray Internals, BWR Feedwater Nozzle and One- of the alternative enhanced UT examinations attachments, (2) that it is using BWRVIP-Time Inspection AMPs to manage this aging based on GE-NE-523-A71-0594, Alternative BWR 18 for the inspections of the core spray effect. Please provide the following information: Feedwater Nozzle Inspection Requirements. This piping, (3) that it is using NUREG-0619 for report has been approved by the NRC. These the inspections of the feedwater piping b) Based on past operating experience, provide enhancements and inspections of the feedwater and nozzles. The project team also finds the technical basis for concluding that the BWR nozzles, thermal sleeves and spargers are part of the response to be acceptable because it vessel internals, BWR feedwater nozzle (for the industrys and JAFs aging management to clarifies that the most recent inspections feedwater lines only) and water chemistry maintain the structural integrity of the feedwater of the core spray and feedwater lines did AMPs are adequate for maintaining the nozzles and lines. not detect any relevant indications in structural integrity of the core spray and these components. This question is feedwater lines, specifically the sparger The BWR Vessel Internals Program manages the resolved.

assemblies and thermal sleeves, during the core spray lines (including the spargers and period of extended operation. thermal sleeves) in accordance with the guidelines of NRC-approved BWRVIP-18A. As explained in Appendix B to the LRA, JAFNPP takes no exceptions to the recommendations of this approved BWRVIP.

243 359 LRA Table 3.1.2-1 and Table 3.1.2-2 include The Feedwater nozzles, spargers and thermal The project team finds the applicants line items to address cracking of core spray sleeves at JAF are inspected through response to be acceptable because the lines and feedwater lines, including spargers implementation of the, Alternative BWR Feedwater applicant has clarified: (1) that it is using and thermal sleeves. The LRA credits the Nozzle Inspection Requirements, General Electric BWRVIP-48A for its augmented Water Chemistry Control-BWR, BWR Vessel Report GE-NE-523-A71594 Rev.1. Reference examinations of the core spray Internals, BWR Feedwater Nozzle and One- BWROG - Safety Evaluation of Proposed attachments, (2) that it is using BWRVIP-Time Inspection AMPs to manage this aging Alternative to BWR Feedwater Nozzle Inspections 18 for the inspections of the core spray 165

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effect. Please provide the following information: (TAC M94090) dated June 5, 1998. This is piping, (3) that it is using NUREG-0619 for scheduled once every 10 years as required by the the inspections of the feedwater piping c) Discuss any augmented inspections that are GE topical report and ASME XI Code Category B- and nozzles. The project team also finds being performed now, or will be performed D. These inspections will be continued into the the response to be acceptable because it during the period of extended operation to period of extended operation. clarifies that the most recent inspections monitor the condition of these components. The core spray lines (including the spargers and of the core spray and feedwater lines did thermal sleeves) will continue to be inspected in not detect any relevant indications in accordance with NRC-approved BWRVIP-18A these components. This question is through the period of extended operation. These resolved.

inspections will adequately manage cracking of these lines for the period of extended operation.

244 360 LRA Table 3.1.2-3 includes a line item to The feedwater thermal sleeves are entered both in The project team finds the applicants address cracking of FW thermal sleeves. The Table 3.1.2-1 (the reactor vessel) and in Table response to be acceptable, as the LRA credits the Water Chemistry Control-BWR 3.1.2-3 (the reactor coolant system pressure applicant amended the LRA in program alone to manage this aging effect. boundary). The thermal sleeves are handled more Amendment No.5, dated February 01, Please provide the technical justification for completely in Table 3.1.2-1 and will be deleted 2007. In this license amendment, the concluding that the water chemistry control- from Table 3.1.2-3. The feedwater thermal sleeve applicant deleted the AMR line items for BWR AMP alone is adequate to manage entry in table 3.1.2-1 credits the BWR Feedwater feedwater (FW) thermal sleeves from cracking of these components with no Nozzle Program in addition to Water Chemistry Table 3.1.2-3 of the LRA. This leaves the associated inspection. Control for managing cracking. See also the AMR line items for the FW thermal response to questions 357, 358 and 359. sleeves in LRA Table 3.1.2-1 as the applicable AMR line items. The applicant This requires a change to the LRA. credits the BWR Feedwater Nozzle program for managing cracking in the feedwater nozzle, including the thermal sleeves. This question is resolved.

245 361 The further evaluation presented in Section An inspection will be performed during the 10 year The project team finds the applicant's 3.2.2.2.3, Item 2, of the LRA addresses loss of period immediately prior to the period of extended response acceptable because the material from pitting and crevice corrosion for operation. applicant amended the LRA to be stainless steel piping and piping components This point will be clarified by inserting the following consistent with GALL Report exposed to a soil environment. The further after the third sentence of Section 3.1.B.4.b of recommendations. See amendment letter evaluation states that an inspection of buried JAF-RPT-05-LRD02. If an inspection did not No. 5, dated February 01, 2007. This components will be performed within ten years occur, a focused inspection will be performed prior question is resolved.

of entering the period of extended operation. to the period of extended operation. The FSAR Please confirm that an inspection will also be supplement for AMP B.1.1 will also be clarified to performed during the ten-year period reflect this inspection.

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immediately prior to entering the period of extended operation. This requires an LRA amendment.

246 362 The further evaluation presented in Section The PSPM program replaces the One-time The applicant stated that the Periodic 3.2.2.2.8, Item 1 of the LRA addresses loss of Inspection Program for this line item. The PSPM Surveillance and Preventive Maintenance material due to general, pitting and crevice program is described in Section 3.2.2.2.8 for Program replaces the one-time inspection corrosion for BWR steel piping and management of components at the waterline in the for management of components at the components in ESF systems exposed to suppression chamber that are not completely waterline in the suppression chamber that treated water. The further evaluation states that wetted. A periodic inspection is specified since the are not continuously wetted. The Periodic the Periodic Surveillance and Preventive Water Chemistry Control-BWR Program alone is Surveillance and Preventive Maintenance Maintenance Program supplements the Water not adequate to manage the effects of aging on Program is credited for these components Chemistry Control-BWR program for steel piping and components at the water line in the since a periodic inspection is needed to components at the waterline in the suppression suppression chamber. monitor aging of these components. The chamber and for components subject to project team determined that it includes erosion. Please clarify whether the PSPM periodic inspections that are consistent program is in addition to the one-time with a one-time inspection and will be inspection program, or whether it replaces the effective to verify the effectiveness of the one-time inspection program for the water chemistry program for components components addressed by this AMR. at the waterline in the suppression chamber. The project team finds the applicant's response acceptable because a periodic inspection is appropriate for these components since they are intermittently wetted, which could make them more susceptible to degradation.

This question is resolved.

247 363 The further evaluation presented in Section An inspection will be performed during the 10 year The project team finds the applicant's 3.2.2.2.9 of the LRA addresses loss of material period immediately prior to the period of extended response acceptable becausethe due to general, pitting, crevice, and MIC for operation. applicant amended the LRA in steel (with or without coating or wrapping) This point will be clarified by inserting the following Amendment No. 5, dated February 1, piping buried in soil in ESF systems. The after the third sentence of Section 3.1.B.4.b of 2007, to address this issue. In this further evaluation states that an inspection of JAF-RPT-05-LRD02. If an inspection did not amendment, the applicant indicated that it buried components will be performed within ten occur, a focused inspection will be performed prior will perform a focused inspection of the years of entering the period of extended to the period of extended operation. buried components during the period of operation. Please confirm that an inspection will extended operation if an opportunistic also be performed during the ten-year period The FSAR supplement for AMP B.1.1 will also be inspection is not implemented within ten immediately prior to entering the period of clarified to reflect this inspection. This requires an years of entering the period of extended 167

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extended operation. amendment to the LRA. operation. This is acceptable because it is consistent with the recommendations in GALL AMP XI.M34, Buried Piping and Tanks Inspection. See amendment letter No. 5, dated February 01, 2007. This question is resolved.

248 364 AMR line-item 3.2.1-19 addresses wall thinning The core spray, HPCI and RCIC piping included in The applicant stated that augmented due to flow-accelerated corrosion for steel this line item are administratively controlled in the inspections are performed at JAFNPP on piping, piping components, and piping elements Flow Accelerated Corrosion program, but are selected piping components that are not exposed to steam or treated water. The AMR inspected using NDE techniques such as UT in the part of the inspections required by states that the Periodic Surveillance and Periodic Surveillance and Preventive Maintenance applicant's Generic Letter 89-08 program, Preventive Maintenance program provides program. This is being done because the aging which are performed under the GALL augmented inspections for flow wall thinning. effect for these components is loss of material due AMP XI.M17 Program. These inspections Please discuss the augmented inspections to erosion and not loss of material due to flow are the same as those performed under performed and why they are not included in the accelerated corrosion. It would therefore not be the FAC Program, but are included in the Flow-Accelerated Corrosion AMP. appropriate to manage using the Flow Accelerated Periodic Surveillance and Preventive Corrosion program. Therefore these components Maintenance Program for administrative are managed by the Periodic Surveillance and reasons since the aging effect is not FAC.

Preventive Maintenance program.

The project team reviewed the applicants Periodic Surveillance and Preventive Maintenance Program and determined that this aging management program includes measurement of wall thickness for the RCIC piping to detect loss of material due to erosion. This is the same activity that would be performed under the FAC program, and acceptance criteria are established in accordance with the FAC Program. Since these inspections are the same as those performed under the FAC Program, the activities are consistent with the recommendations in GALL AMP XI.M17 to manage wall thinning due to flow-accelerated corrosion for steel components exposed to steam or treated water. On this basis, the project team 168

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finds the AMR results for this line item acceptable. This question is resolved.

249 365 AMR line-item 3.2.1-24 addresses loss of a) Gasket creep and self-loosening are The applicant stated that this position is preload due to thermal effects, gasket creep, mechanisms that could lead to loss of preload for consistent with the EPRI Mechanical and self-loosening. The AMR states that this is steel closure bolting, but are not considered aging Tools report (EPRI 1010639); however, not applicable since loss of preload is a design- mechanisms. Operating experience indicates that the bolting integrity program is currently driven effect and not an aging effect requiring these mechanisms occur in relatively short order in used at JAFNPP to monitor these management. A discussion of thermal effects is applications with improper bolted joint design or components. The applicant committed to provided. Please provide the following installation. This is consistent with the EPRI amend the LRA to delete Not Applicable information with regard to this AMR, a) discuss Mechanical Tools (EPRI 1010639) that do not from this AMR line item.

why gasket creep and selfloosening are not consider loss of preload an aging effect for bolted aging mechanisms that could lead to loss of closures. Gasket creep will normally occur shortly In its letter dated February 1, 2007, the preload for steel closure bolting in the ESF after initial loading, which allows for addressing this applicant amended the LRA to delete Not systems at JAFNPP, and b) discuss JAFNPP's effect by installation practices and subsequent Applicable from this AMR line item. The operating experience with steel closure bolting maintenance of the joint and is therefore not project team reviewed the applicants in the ESF systems. related to aging. Self-loosening is also not an aging bolting integrity program and determined effect but is an event-driven effect that occurs due that it is consistent with the to improper joint design or installation that doesnt recommendations in GALL AMP XI.M18, properly consider the potential for this effect. This and includes activities that will manage would also be detected early in component service loss of preload for these components. On life and actions would be taken to prevent recurrence. this basis, the staff finds this AMR b) A review of JAFNPP site operating experience acceptable. This question is resolved.

over five years was performed. Search results were screened to determine whether the identified condition was related to pressure boundary bolting that may have experienced cracking or loss of preload. The majority of the search results involved event-driven conditions that required no further review. The review found instances of loss of material due to corrosion, loose bolting due to improper maintenance practices, and cracking of Class 1 bolting, but no evidence of cracking or loss of preload for non-Class 1 pressure boundary bolting.

AMR line item 3.2.1-24 state not applicable in the discussion section that describes loss of preload 169

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due to thermal effects, gasket creep, and self-loosening. The term not applicable will be removed from the discussion section of these line items.

This requires an amendment to the LRA.

250 366 AMR line-item 3.2.1-35 addresses loss of AMR line-item 3.2.1-35 addresses components The project team finds the applicant's material due to general, pitting, crevice, and included in containment isolation penetrations for response acceptable because the microbiologically-influenced corrosion, and drains from the drywell floor and equipment sumps. environment for these components is not fouling for steel containment isolation piping The internal raw water environment for these raw water from the ultimate heat sink and and component internal surfaces exposed to components is drainage from containment, which is thus, the components are not within the raw water. The AMR credits the Periodic not the raw lakewater in the Open-Cycle Cooling scope of the Open-cycle Cooling Water Surveillance and Preventive Maintenance Water System AMP XI.M20. Therefore, the actions Program. The project team considers the Program instead of the Open-Cycle Cooling from Generic Letter 89-13 that are described in Periodic Surveillance and Preventive Water System AMP, which is recommended by NUREG-1801 XI.M20 are not appropriate for these Maintenance Program to be capable of NUREG-1801. Please discuss the evaluation items (See Table 3.0-1, page 3.0-9 of the LRA). managing these aging effects of the performed to conclude that the activities in the For this environment the Periodic Surveillance and components addressed in AMR line item Periodic Surveillance and Preventive Preventive Maintenance Program manages the 3.2.1-35 because the program calls for Maintenance AMP are consistent with the aging effects in these components. Visual or NDE both periodic visual and non-visual NDE activities in the Open-Cycle Cooling Water techniques will be used to detect aging effects on techniques of these containment isolation AMP recommended by NUREG-1801 for the internal surfaces at a specified interval of 5 years. penetration drain components every 5 components addressed by this AMR, including These techniques will be applied on a years. This should be an adequate the activities performed to manage aging, the representative sample basis to detect degradation inspection frequency given that these are sample population inspected, and the prior to loss of intended function. This inspection drain line components. This question is inspection locations. will be done in the internal piping and valve bodies resolved.

of containment penetration X-18 and X-19.

251 367 AMR line-item 3.2.1-36 addresses loss of AMR line-item 3.2.1-36 addresses components The project team finds the applicant's material due to general, pitting, crevice, included in the standby gas treatment system that response acceptable because the galvanic, and microbiologically-influenced are drains for water accumulation or condensation environment for these components is not corrosion, and fouling for steel heat exchanger from the various components in the system (filter raw water from the ultimate heat sink and components exposed to raw water. For piping demisters, fans, steam packing exhausters, thus, the components are not within the components of the standby gas treatment condenser air removers and stack analyzer sample scope of the Open-cycle Cooling Water system, the AMR credits the Periodic chambers). The internal raw water environment for Program. The project team considers the Surveillance and Preventive Maintenance these components is condensation and drainage Periodic Surveillance and Preventive Program instead of the Open-Cycle Cooling not lake water. The components are not in the Maintenance Program to be capable of 170

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Water System AMP, which is recommended by Open-Cycle Cooling Water System. Therefore, the managing these aging effects of the NUREG-1801. Please discuss the evaluation actions from Generic Letter 89-13 that are components addressed in AMR line item performed to conclude that the activities in the described in NUREG-1801 XI.M20 are not 3.2.1-36 because the program calls for Periodic Surveillance and Preventive appropriate for these items (See Table 3.0-1, page both periodic visual and non-visual NDE Maintenance AMP are consistent with the 3.0-9 of the LRA). For this environment, the techniques of these standby gas treatment activities in the Open-Cycle Cooling Water Periodic Surveillance and Preventive Maintenance drain line components every 5 years. This AMP recommended by NUREG-1801 for the Program manages the aging effects in these should be an adequate inspection components in the standby gas treatment components. Visual or NDE techniques will be frequency given that these are drain line system addressed by this AMR, including the used to detect aging effects on internal surfaces at components. This question is resolved.

activities performed to manage aging, the a specified interval of 5 years. This inspection will sample population inspected, and the be done in the internal piping and valve bodies of inspection locations. these drains in the standby gas treatment system.

252 368 AMR line-item 3.2.1-52 addresses glass piping A review of five years of JAFNPP operating The project team finds the applicant's elements exposed to air-indoor uncontrolled experience did not identify aging effects for response acceptable because, consistent (external), lubricating oil, raw water, treated components with these material and environment with industry research data and operating water, or treated borated water. The AMR combinations. The operating experience review is experience, JAFNPP operating experience states that there are no aging mechanisms or documented in JAF-RPT-05-LRD05, JAFNPP did not identify aging effects for effects for these material/environment License Renewal Operating Experience Review components with these material and combinations, which is consistent with NUREG- Report, which is available for onsite review. environment combinations. This question 1801. Please discuss the JAFNPP plant- JAFNPP operating experience with these material is resolved.

specific operating experience with components and environment combinations is consistent with containing these material/environment the industry experience of no aging effects combinations. reflected in NUREG-1801 and the Mechanical Tools [Non-Class 1 Mechanical Implementation Guideline and Mechanical Tools, Revision 4, EPRI, Palo Alto, CA: 1010639].

253 369 AMR line-item 3.2.1-53 addresses stainless A review of five years of JAFNPP operating The project team finds the applicant's steel and copper alloy piping, piping experience did not identify aging effects for response acceptable because, consistent components, and piping elements exposed to components with these material and environment with industry research data and operating air-indoor uncontrolled (external). The AMR combinations. The operating experience review is experience, JAFNPP operating experience states that there are no aging mechanisms or documented in JAF-RPT-05-LRD05, JAFNPP did not identify aging effects for 171

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effects for these material/environment License Renewal Operating Experience Review components with these material and combinations, which is consistent with NUREG- Report, which is available for onsite review. environment combinations. This question 1801. Please discuss the JAFNPP plant- JAFNPP operating experience with these material is resolved.

specific operating experience with components and environment combinations is consistent with containing these material/environment the industry experience of no aging effects combinations. reflected in NUREG-1801 and the Mechanical Tools

[Non-Class 1 Mechanical Implementation Guideline and Mechanical Tools, Revision 4, EPRI, Palo Alto, CA: 1010639].

254 370 AMR line-item 3.2.1-56 addresses steel and A review of five years of JAFNPP operating The project team finds the applicant's stainless steel piping, piping components, and experience did not identify aging effects for response acceptable because, consistent piping elements exposed to gas. The AMR components with these material and environment with industry research data and operating states that there are no aging mechanisms or combinations. The operating experience review is experience, JAFNPP operating experience effects for these material/environment documented in JAF-RPT-05-LRD05, JAFNPP did not identify aging effects for combinations, which is consistent with NUREG- License Renewal Operating Experience Review components with these material and 1801. Please discuss the JAFNPP plant- Report, which is available for onsite review. environment combinations. This question specific operating experience with components JAFNPP operating experience with these material is resolved.

containing these material/environment and environment combinations is consistent with combinations. the industry experience of no aging effects reflected in NUREG-1801 and the Mechanical Tools [Non-Class 1 Mechanical Implementation Guideline and Mechanical Tools, Revision 4, EPRI, Palo Alto, CA: 1010639].

255 371 Table 3.2.2-1 in the LRA includes a line-item for Wear is a mechanism caused by relative motion The project team finds the applicant's Heat Exchanger (tubes) in the Residual Heat between adjacent components. Water chemistry response acceptable because wear is not Removal Systems constructed of stainless cannot prevent the conditions that cause wear. a mechanism that deteriorates metallic steel and exposed to treated water >140F. The These heat exchangers are included in the Service materials as a result of a chemical effect.

aging effect identified is loss of material-wear Water Integrity Program since they are cooled by Instead, wear is a mechanism that results and the AMP credited is Service Water Integrity the service water system. Although loss of material in loss of material as a result of metal (AMP B.1.26). Please clarify why AMP B.1.26, due to wear occurs on the external surface of the abrasion (i.e., metal to metal surface which addresses components exposed to tubing (which is exposed to treated water) this contact). Thus, a chemical monitoring service water, is credited for this AMR instead aging effect will be managed by eddy current program will not include the type of of a water chemistry AMP. testing of the tubes in the Service Water Integrity inspection-based techniques that are Program. capable of detecting aging as a result of wear. Since the heat exchangers are 172

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cooled by the service water system, the Service Water Integrity Program is adequate to manage the aging effect because the program will use a volumetric inspection technique (i.e, eddy current testing) to monitor whether loss of material due to wear is occuring in these tubes. This question is resolved.

256 372 The further evaluation presented in Section Surveillance testing to ensure the drywell and The project team finds the applicant's 3.2.2.2.7 of the LRA addresses loss of material suppression chamber spray nozzles are response acceptable because the due to general corrosion and fouling for steel unobstructed is completed at JAFNPP by aligning surveillance testing is an adequate drywell and suppression chamber spray system service air to each of the spray headers in the performance monitoring program that is nozzle and flow orifice internal surfaces drywell and suppression chamber spray system capable of verifying whether or not exposed to air-indoor uncontrolled (internal). and verifying air flow from each spray nozzle. This adequate spray system nozzle flow The further evaluation states that at JAFNPP surveillance test is performed once every 10 years capability is being maintained during the the spray nozzles are copper alloy and are not in accordance with the JAFNPP Inservice period of extended operation or whether subject to loss of material due to general Inspection Program. The testing detected some implementation of corrective actions is corrosion in an indoor air environment. Industry cases of nozzle blockage. The amount of blockage necessary should blockage of the system operating experience has shown that corrosion was below the acceptance criteria for the be verified as a result fo the surveillance products from piping upstream of these nozzles surveillance. The blockage was removed after test. This is consistent with NRC Branch can detach and cause blockage of the nozzles. testing. Continued surveillance testing will ensure Technical Position RLSB in (NUREG-Please provide the following information related that the active function of flow control is assured. 1800, Revision 1, on how performance to this further evaluation: a) discuss the testing monitoring programs may be used to performed to ensure the drywell and ensure aging management during the suppression chamber spray nozzles are period of extended operation . This unobstructed, including the nature and question is resolved.

frequency of this testing; b) discuss the results of previous tests performed, including whether any blockage of nozzles was observed, the cause of the blockage, and the corrective actions taken; and c) discuss how nozzle blockage due to corrosion products from upstream piping will be managed at JAFNPP.

257 373 AMR line-item 3.2.1-50 addresses aluminum JAFNPP operating experience with components in The project team finds the applicant's 173

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piping, piping components, and piping elements the auxiliary systems containing this material and response acceptable because the plant-exposed to air-indoor uncontrolled (external). environment combination is consistent with the specific operating experience did not The AMR states that there are no aging industry experience of no aging effects reflected in identify any aging effects and it is mechanisms or effects for these NUREG-1801 and the Mechanical Tools [Non- consistent with GALL Report. This material/environment combinations, which is Class 1 Mechanical Implementation Guideline and question is resolved.

consistent with NUREG-1801. The LRA also Mechanical Tools, Revision 4, EPRI, Palo Alto, CA:

states that the only components to which this 1010639].

NUREG-1801 line-item applies are in the auxiliary systems. Please discuss the JAFNPP The review of JAFNPP operating experience did plant-specific operating experience with not identify aging effects for auxiliary systems components in the auxiliary systems containing components with this material and environment these material/environment combinations. combination. The operating experience review is documented in JAF-RPT-05-LRD05, JAFNPP License Renewal Operating Experience Report, which was available onsite for review.

258 374 The further evaluation presented in Section Inspection of the exhaust system components is The project team finds the applicant's 3.3.2.2.3, Item 3, of the LRA addresses included in the Periodic Surveillance and response acceptable because the cracking due to SCC in stainless steel diesel Preventive Maintenance program as discussed in applicant amended the LRA to state that engine exhaust piping exposed to diesel JAF-RPT-05-LRD-02 Attachment 3. the PSPM program will verify the absence exhaust. The further evaluation states that at Conservatively, these components will be of cracking in the stainless steel exhaust JAFNPP, the stainless steel exhaust inspected for loss of material once every five years components. See amendment letter No. 5, components are oriented vertically, which during the period of extended operation. Because dated February 01, 2007. This question is precludes pooling of water. Therefore, cracking there is no potential for the accumulation of water, resolved.

due to SCC is not an aging effect requiring there is no moisture available for the concentration management for the stainless steel diesel of contaminants such as chlorides which would engine exhaust piping. Please discuss the provide an environment conducive for the initiation JAFNPP plant-specific operating experience of cracking. This evaluation is in accordance with with stainless steel diesel engine the EPRI Mechanical Tools for the determination of exhaust piping, and the results of the most aging effects. Further evaluation section 3.3.2.2.3 recent inspection performed on these will be revised to state that the PSPM program will components. As part of the response, please verify the absence of cracking in the stainless steel address the reason for not performing a one- exhaust components.

time inspection of these components to confirm that cracking is not occurring. This requires an amendment to the LRA.

259 375 The further evaluation presented in Section In 2005, nine Boral coupons from JAFNPP spent The project team finds the applicant's 3.3.2.2.6 of the LRA addresses reduction of fuel racks were subjected to nondestructive testing. response to be acceptable because the neutron-absorbing capacity for Boral spent fuel The condition of the coupons was as expected, results of non-destructive testing provide storage racks. The further evaluation states with the exception of some localized pitting and an adequate basis to support the that plant operating experience with Boral some blistering of the aluminum skin of those applicants conclusion that reduction in coupons inspected in 2005 is consistent with coupons exposed to pool water. neutron absorption capacity is not an the staff's conclusion that the reduction of These conditions were attributed to the following: aging effect requiring management. The 174

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neutron-absorbing capacity is insignificant, and

• the pitting was attributed to residual carbon steel use of non-destructive testing is consistent an aging management program is not required chips left on the surface of the Boral during with the guidance presented in Section for this effect. Please provide additional details assembly of the capsules. A.1.2.1 of NUREG 1800, which specifies on the JAFNPP plant-specific operating

• the blisters were attributed to hydrogen formed by that the determination of applicable aging experience with Boral coupons, and the results reaction between the pool water and internal effects should be based on degradations of the coupon tests performed in 2005 that surfaces of the aluminum. that could cause structure and component support the conclusion that an aging degradation. The Water Chemistry management program is not required. These conditions of appearance did not affect the Control - BWR Program includes activities intended function of the boral material. The areal that are consistent with recommendations densities determined by neutron attenuation in NUREG-1801, and is adequate to measurements and verified by wet chemical manage loss of material and cracking for analysis were, in every case, in excess of the Boral spent fuel storage racks exposed to minimum as-fabricated values which confirms that a treated water environment. The staff reduction in neutron absorption capacity is not an concurs with the applicants conclusion aging effect requiring management. Loss of that reduction of neutron-absorbing material and cracking are managed by the Water capacity is insignificant and requires no Chemistry Control program. This testing is aging management. This question is documented in CR-JAF-2005-00631, which was resolved.

available for review on site.

260 376 The further evaluation presented in Section See response to AMP Audit Question No.52 The project team finds the applicant's 3.3.2.2.8 of the LRA addresses loss of material response acceptable because the due to general, pitting, crevice and MIC for applicant amended the LRA in a letter carbon steel (with or without coating or dated February 01, 2007, to state that if wrapping) piping and components buried in soil an opportunistic inspection did not occur, in the auxiliary systems at JAFNPP. The further a focused inspection will be performed evaluation states that an inspection of buried prior to the period of extended operation in components will be performed within ten years accordance with GALL Report of entering the period of extended operation. recommendations. This question is Please confirm that an inspection will also be resolved since the applicant is consistent performed during the ten-year period with the guidance in GALL AMP B.1.1.

immediately prior to entering the period of extended operation.

261 377 AMR line-item 3.3.1-45 addresses loss of a) This is consistent with the EPRI Mechanical The project team finds the applicant's preload due to thermal effects, gasket creep, Tools (EPRI 1010639) that do not consider loss of response acceptable because the and self-loosening. The AMR states that this is preload to be an aging effect for bolted closures. applicant amended the LRA to credit not applicable since loss of preload is a design- Gasket creep will normally occur in 10 to 20 Bolting Integrity Program to manage the driven effect and not an aging effect requiring minutes after initial loading, which allows this effect aging effect of loss of preload in these management. A discussion of thermal effects is to be addressed by installation practices and bolted connections. See amendment provided. Please provide the following subsequent maintenance of the joint and is letter No. 5, dated February 01, 2007. This information with regard to this AMR, a) please therefore not related to aging but is event driven. question is resolved.

provide a discussion of why gasket creep and Self-loosening is also not an aging effect but is an self-loosening are not aging mechanisms that event driven effect that occurs due to improper joint 175

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could lead to loss of preload for steel closure design or installation that doesnt properly consider bolting in the auxiliary systems at JAFNPP, and the potential for this effect. This would also be b) please provide a discussion of JAFNPP's detected early in component service life and operating experience with steel closure bolting actions would be taken to prevent recurrence.

in the auxiliary systems. b) A review of JAFNPP site operating experience over five years was performed. Search results were screened to determine whether the identified condition was related to pressure boundary bolting that may have experienced cracking or loss of preload. The majority of the search results involved event-driven conditions that required no further review. The review found instances of loss of material due to corrosion, loose bolting due to improper maintenance practices, and cracking of Class 1 bolting, but no evidence of cracking or loss of preload for non-Class 1 pressure boundary bolting.

AMR line item 3.3.1-45 states not applicable in the discussion section that describes loss of preload due to thermal effects, gasket creep, and self-loosening. The term not applicable will be removed from the discussion section of these line items, since these components are inspected under the Bolting Integrity Program.

This requires an amendment to the LRA.

262 378 AMR line-item 3.3.1-62 addresses loss of As identified in line item 3.3.1-62, the only The project team finds the applicant's material due to pitting and crevice corrosion for components to which this NUREG-1801 line item response acceptable because the aluminum piping, piping components, and applies are included in scope under criterion 10 applicant clarified that the aluminum piping elements exposed to raw water. The CFR 54.4(a)(2) and are listed in the series 3.3.2- component addressed by line item 3.3.1-LRA credits the one-time inspection program to 14-xx tables. As indicated in the tables, the 62 is in the radwaste system. Therefore, manage this aging effect; however, NUREG- aluminum component addressed by line item 3.3.1- the fire protection program is not 1801 recommends the Fire Protection program. 62 is in the radwaste system. As such, the fire appropriate to manage the effects of aging Please discuss the justification for using the protection program is not appropriate to manage on this component. In addition, based on one-time inspection program instead of the Fire the effects of aging. Aluminum is a corrosion industry research and operating Protection program to manage this aging effect. resistant material that is not expected to experience, the project team recognizes experience significant loss of material in this that aluminum is a corrosion resistant environment. As described in LRA Appendix B, the material that is not expected to experience One Time Inspection Program will confirm that loss significant loss of material in this of material is not occurring or is so insignificant that environment. Therefore, One-Time an aging management program is not warranted. Inspection Program is appropriate for Therefore the one-time inspection program is managing this aging effect. This question appropriate for managing this aging effect. is resolved.

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263 379 AMR line-item 3.3.1-71 addresses loss of As described in LRA Section 3.0, the "Discussion" The project team finds the applicant's material due to general, pitting, and crevice column in Table 1 provides a discussion of how the response acceptable because the corrosion for steel piping, piping components, line item compares to the corresponding line item applicant amended the LRA to credit and piping elements exposed to moist air or in NUREG-1801, Volume 1. In the case of line item PSPM program to manage the aging condensation (internal). The LRA states that 3.3.1-71, either of two programs which are different effect. See amendment letter No. 5, dated the Periodic Surveillance and Preventive than the one listed in the corresponding GALL line February 01, 2007.

Maintenance and One-Time Inspection item may be used to manage the specified aging programs are used to manage this aging effect. effects wherever this material environment The program attributes and the visual NUREG-1801 recommends the Inspection of combination appears in the Table 2 entries. The inspection criteria in the PSPM to manage Internal Surfaces in Miscellaneous Piping and use of and is not meant to imply that both loss of material in these components are Ducting Components program. While this Table programs are required to manage the aging effects. consistent with the program attributes in 1 line-item indicates that both AMPs are used Selection of either the One-Time Inspection or GALL AMP XI.M38, Inspection of Internal together to manage this aging effect, a review Periodic Surveillance and Preventive Maintenance Surfaces in Miscellaneous Piping and of the Table 2 AMR line-items shows that only (PSPM) program is based on the environment, and Ducting Components and are acceptable the OTI program or the PSPM program is the type and configuration of components . This question is resolved.

credited; not both. Please clarify this apparent described in the Table 2 entries.

discrepancy between Table 1 line item 3.3.1-71 and the corresponding Table 2 line items in The One-Time Inspection program is used in terms of which AMPs are credited. Also, if the situations where the goal is to confirm that loss of OTI or PSPM program will be used alone to material is not occurring or is so insignificant that manage this aging effect, please discuss the an aging management program is not warranted.

evaluation that was performed to determine The PSPM program is used in situations where the that the activities in each of these programs are aging effect is likely and therefore requires aging consistent with the Inspection of Internal management. The line items that compare to GALL Surfaces in Miscellaneous Piping and Ducting line item 3.3.1-71 in Table 3.3.2-14-41 and credit Components program recommended in the One-Time Inspection program are in error.

NUREG-1801. These line items should have credited the Periodic Surveillance and Preventive Maintenance program.

This change requires an amendment to the LRA.

NUREG-1801 states that XI.M38 "Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components" is used for components that are not covered by other aging management programs. This GALL program uses visual inspections to manage aging effects. The Periodic Surveillance and Preventive Maintenance (PSPM)

Program described in Appendix B also uses visual inspections to manage loss of material and is consistent with the attributes described for the program in NUREG-1801 XI.M38.

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264 380 AMR line items 3.3.1-73 and 3.3.1-74 address No evaluation was performed to determine whether The project team finds the applicant's loss of material due to general corrosion and the PSPM and SMP are consistent with the response acceptable because the wear, respectively, for steel crane components Inspection of Overhead Heavy Load and Light Load applicant identified appropriate programs exposed to air-indoor uncontrolled (external). (related to refueling) Handling Systems Program. to manage the aging effect of crane The LRA states that these components are The AMR identified appropriate AMPs to manage components in Section 3.5 of the LRA.

evaluated as structural components in Section aging effects. In this case, reactor building steel This question is resolved.

3.5, and that the Periodic Surveillance and crane structural girders used in load handling are Preventive Maintenance and Structures inspected under the Periodic Surveillance and Monitoring programs are credited to manage Preventive Maintenance Program (PSPM) these aging effects. However, NUREG-1801 identified in Section B.1.22 of the application.

recommends the Inspection of Overhead Turbine building complex and yard structures crane rails Heavy Load and Light Load (Related to Refueling) Handling Systems program. Please and girders are inspected under the Structures discuss the evaluation that was performed to Monitoring Program as identified in Section B.1.27.

determine that the activities in the Periodic The Structures Monitoring Program will be Surveillance and Preventive Maintenance and enhanced, as identified in Section B.1.27, to Structures Monitoring programs are consistent address crane rails and girders.

with the Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling These programs when enhanced will include visual Systems program. inspections of the crane rails and girders which is consistent with XI.M23 for managing loss of material.

265 381 AMR line item 3.3.1-76 addresses loss of Line Item 3.3.1-76 specifies the Periodic The project team finds the applicant's material for steel piping, piping components, Surveillance and Preventive Maintenance (PSPM) response acceptable because the and piping elements exposed to raw water. The Program instead of XI.M20, Open-Cycle Cooling environment for these components is not LRA states that for some of these components, Water System Program, in line items where the raw water from the ultimate heat sink and the Periodic Surveillance and Preventive environment of raw water is used to identify thus, the components are not within the Maintenance program is credited to manage untreated water that is not part of the service water scope of the Open-cycle Cooling Water this aging effect. However, NUREG-1801 system. The affected components are not part of Program. The project team considers the recommends the Open Cycle Cooling Water the open cycle cooling water system, therefore, the Periodic Surveillance and Preventive System program. Please discuss the evaluation actions from the Open Cycle Cooling Water Maintenance Program to be capable of that was performed to determine that the System Program described in NUREG-1801 managing these aging effects of the activities in the PSPM are consistent with the XI.M20 are not appropriate for these items. components addressed in AMR line item Open Cycle Cooling Water System program. 3.2.1-76 because the program calls for The five year PSPM frequency is acceptable both periodic visual and non-visual NDE because (1) Aging effects for carbon steel, even in techniques of these auxiliary system drain raw water, are not fast acting; (2) PSPM inspection line components every 5 years. This activities are preformed on (a)(2) systems that should be an adequate inspection have been in service for the life of the plant without frequency given that these are drain line required inspections per the JAFNPP corrective components. This question is resolved.

action program; and (3)The consequences of failure due to loss of material are low. SRP 178

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Appendix A, Section A.1.2.2 states that risk significance may be considered in developing the details of an aging management program (see excerpt below).

The risk significance of a structure or component could be considered in evaluating the robustness of an aging management program. Probabilistic arguments may be used to assist in developing an approach for aging management adequacy.

However, use of probabilistic arguments alone is not an acceptable basis for concluding that, for those structures and components subject to an AMR, the effects of aging will be adequately managed in the period of extended operation.

Thus, risk significance may be considered in developing the details of an aging management program for the structure or component for license renewal, but may not be used to conclude that no aging management program is necessary for license renewal. Therefore, periodic inspections of non-safety related systems conducted on a five year frequency or less is acceptable.

266 382 AMR line item 3.3.1-77 addresses loss of The Table 1 line item says that both programs are The project team finds the applicant's material for steel heat exchanger components used, not that both are used together in every response acceptable because the exposed to raw water. The LRA states that instance. The use of the word and was intended applicant clarified the use of the PSPM Service Water Integrity and Periodic to identify that these two programs are credited and Service Water Integrity Programs for Surveillance and Preventive Maintenance individually in specific line items to manage aging managing a loss of material for steel heat Programs manage this aging effect. NUREG- effects. The PSPM program is specified in line exchanger components exposed to raw 1801 recommends the Open Cycle Cooling items where the environment of raw water is used water. This question is resolved.

Water System program. While this Table 1 line to identify untreated water (drain water, HVAC item indicates that both AMPs are used drain water) that is not part of the service water together to manage this aging effect, a review system. The Service Water Integrity Program is of the Table 2 AMR line-items shows that only specified for those line items where the attributes of the Service Water Integrity program is credited NUREG-1801 XI.M20, Open-Cycle Cooling Water to manage loss of material for heat exchanger System Program, apply.

bonnets, and only the PSPM program is credited to manage heat exchanger shells.

Please clarify this apparent discrepancy between Table 1 line item 3.3.1-77 and the corresponding Table 2 line items in terms of which AMPs are credited. Also, if the PSPM program will be used alone to manage this 179

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aging effect, please explain why the PSPM Program is credited.

267 383 AMR line-items 3.3.1-79 and 3.3.1-81 address The Periodic Surveillance and Preventive The project team reviewed the LRA and loss of material for stainless steel and copper Maintenance (PSPM) Program and the One-Time bases documents and determined that the alloy piping, piping components, and piping Inspection (OTI) Program are not intended to be components addressed by the AMR line elements exposed to raw water. The LRA combined for the management of aging effects. items that credit the Periodic Surveillance states that for some components, the Periodic The use of the word and was intended to identify and Preventive Maintenance Program are Surveillance and Preventive Maintenance and that these two programs are credited individually in in the radwaste and plant drains system, One-Time Inspection programs are used to specific line items to manage aging effects. The and the service water system. The project manage this aging effect. NUREG-1801 PSPM or OTI programs are specified in line items team also reviewed the applicants recommends the Open-Cycle Cooling Water where the environment of raw water is used to Periodic Surveillance and Preventive System program. While these Table 1 line identify untreated water further defined as drain Maintenance Program and determined items indicate that both AMPs are used water, radwaste water, ventilation system drain that this program includes inspections of together to manage this aging effect, a review water, potable water, and chemical treatment components in the radwaste and drains of the Table 2 AMR line items shows that only water. Since Service Water Integrity is not system, and the service water system, the OTI program or the PSPM program is applicable for these raw water environments, using visual and other proven NDE credited; not both. Please clarify this apparent PSPM or OTI appropriately manage aging effects techniques that are appropriate for discrepancy between Table 1 line items 3.3.1- for these environments. The PSPM program is managing loss of material. The 79 and 3.3.1-81 and their corresponding Table specified where the component is primarily wetted inspections are performed every 10 years 2 line items in terms of which AMPs are and the material-environment combination is more for stainless steel drain tanks, and every credited. Also, if the OTI or PSPM program will susceptible to aging effects. The OTI program is five years for stainless steel components be used alone to manage this aging effect, specified for stainless steel or copper alloy used in chemical treatment in the service please explain why the PSPM or OTI programs components that are not susceptible to significant water system. Any significant loss of are credited. aging effects. material detected will be evaluated to determine if corrective actions are required. The project team finds these activities adequate to manage loss of material for these components. On this basis, the project team finds that the AMR results addressed by this line item that credit the Periodic Surveillance and Preventive Maintenance Program are acceptable.

The project team also reviewed the LRA and bases documents and determined that the components addressed by this AMR line items that credit the One-Time Inspection Program are in the raw water treatment system, the plumbing, sanitary and lab system, and the city water system. The project team reviewed the 180

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applicants One-Time Inspection Program and determined that this program includes inspections of components in these systems using visual and other proven NDE techniques that are appropriate for detecting loss of material. The inspections will be performed during the 10-year period immediately prior to entering the period of extended operation to confirm that no significant aging degradation is occurring in these components. Any significant loss of material detected will be evaluated to determine if corrective actions, including expansion of the inspection sample size, are required. The project team finds these activities acceptable to manage loss of material for these components since, based on industry research and operating experience, this material/environment combination is not susceptible to corrosion. In addition, the components exposed to drains are not continuously wetted, which further reduces their susceptibility to corrosion. On this basis, the project team finds that AMR results addressed by this line item that credit the One-Time Inspection Program are acceptable.

This question is resolved.

268 384 AMR line item 3.3.1-83 addresses reduction of The Service Water Integrity, Periodic Surveillance The project team finds the applicant's heat transfer due to fouling for copper alloy and Preventive Maintenance (PSPM), and Fire response acceptable because the PSPM heat exchanger tubes exposed to raw water. Protection Programs are not intended to be Program includes periodic performance The LRA states that the Service Water combined for the management of aging effects. monitoring testing of the copper control Integrity, Periodic Surveillance and Preventive The use of the word and was intended to identify room chiller condenser tubes to monitor Maintenance and Fire Protection programs are that these programs are credited individually in for evidence of fouling; this would meet used to manage this aging effect. NUREG- specific line items to manage aging effects. The the performance monitoring option 1801 recommends the Open-Cycle Cooling PSPM program attributes are described in LRA recommendation in the [Detection of Water System program. While these Table 1 Section B.1.22 and the Fire Protection Program Aging Effects] program element in GALL line items indicate that all three AMPs are used attributes are described in LRA Section B.1.13.1. AMP XI.M20, Open Cycle Cooling Water together to manage this aging effect, a review System, and thus provides an acceptable of the Table 2 AMR line items shows that only The PSPM program is specified for management of alternative to GALL AMP XI.M20. This 181

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one of the programs is credited for each line fouling in copper alloy heat exchanger tubes question is resolved.

item. Please clarify this apparent discrepancy (control room chiller condenser) exposed to raw between Table 1 line item 3.3.1-83 and the water (service water) in LRA Table 3.3.2-7, Heating corresponding Table 2 line items in terms of Ventilation and Air Conditioning Systems. The which AMPs are credited. Also, if the PSPM or aging effect loss of material is managed by the Fire Protection Programs will be used alone to Service Water Integrity Program for this manage this aging effect, please discuss the component, however, fouling is not managed under evaluation that was performed to determine this program. Therefore, PSPM is specified for that the activities in each of these programs are management of fouling since determination of heat consistent with the Open-Cycle Cooling Water transfer capability is not performed by the Service System program. Water Integrity Program for this component.

The Fire Protection Program is specified for management of fouling in copper alloy heat exchanger tubes exposed to raw water (system fire water used for engine cooling) per LRA Table 3.3.2-5, Fire Protection - Water Systems. Diesel fire pump cooling uses fire water from Lake Ontario as a cooling source. Testing of the cooling capacity of the heat exchanger is observed during pump testing under the Fire Protection Program and manages the aging effect of fouling of copper alloy heat exchangers cooled by fire water (listed as raw water). The Service Water Integrity program is not applicable to fire water used as a heat sink.

269 385 AMR line item 3.3.1-93 addresses glass piping A review of five years of JAFNPP operating The project team finds the applicant's elements exposed to air, air-indoor uncontrolled experience did not identify aging effects for response acceptable because this (external), fuel oil, lubricating oil, raw water, components in the auxiliary systems with these material/ environment combination has no treated water, or treated borated water. The material and environment combinations. The aging effect and it is consistent with GALL AMR states that there are no aging operating experience review is documented in JAF- Report. This question is resolved.

mechanisms or effects for these RPT-05-LRD05, JAFNPP License Renewal material/environment combinations, which is Operating Experience Review Report, which was consistent with NUREG-1801. Please discuss available for onsite review.

the JAFNPP plant-specific operating experience with components in the auxiliary JAFNPP operating experience with these material systems containing these material/environment and environment combinations is consistent with combinations. the industry experience of no aging effects reflected in NUREG-1801 and the Mechanical Tools [Non-Class 1 Mechanical Implementation Guideline and Mechanical Tools, Revision 4, EPRI, Palo Alto, CA: 1010639].

270 386 AMR line item 3.3.1-94 addresses stainless A review of five years of JAFNPP operating The project team finds the applicant's 182

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steel and nickel alloy piping, piping experience did not identify aging effects for response acceptable because this components, and piping elements exposed to components in the auxiliary systems with these material/ environment combination has no air-indoor uncontrolled (external). The AMR material and environment combinations. The aging effect and it is consistent with GALL states that there are no aging mechanisms or operating experience review is documented in JAF- Report.

effects for these material/environment RPT-05-LRD05, JAFNPP License Renewal combinations, which is consistent with NUREG- Operating Experience Review Report, which was This question is resolved.

1801. Please discuss the JAFNPP plant- available for onsite review.

specific operating experience with components in the auxiliary systems containing these JAFNPP operating experience with these material material/environment combinations. and environment combinations is consistent with the industry experience of no aging effects reflected in NUREG-1801 and the Mechanical Tools [Non-Class 1 Mechanical Implementation Guideline and Mechanical Tools, Revision 4, EPRI, Palo Alto, CA: 1010639].

271 387 AMR line item 3.3.1-96 addresses steel and A review of five years of JAFNPP operating The project team finds the applicant's stainless steel piping, piping components, and experience did not identify aging effects for response acceptable because this piping elements in concrete. The AMR states components in the auxiliary systems with these material/ environment combination has no that there are no aging mechanisms or effects material and environment combinations. The aging effect and it is consistent with GALL for these material/environment combinations, operating experience review is documented in JAF- Report. This question is resolved.

which is consistent with NUREG-1801. Please RPT-05-LRD05, JAFNPP License Renewal discuss the JAFNPP plant-specific operating Operating Experience Review Report, which was experience with components in the auxiliary available for onsite review.

systems containing these material/environment combinations. JAFNPP operating experience with these material and environment combinations is consistent with the industry experience of no aging effects reflected in NUREG-1801 and the Mechanical Tools [Non-Class 1 Mechanical Implementation Guideline and Mechanical Tools, Revision 4, EPRI, Palo Alto, CA: 1010639].

272 388 AMR line item 3.3.1-97 addresses steel, A review of five years of JAFNPP operating The project team finds the applicant's stainless steel, aluminum, and copper alloy experience did not identify aging effects for response acceptable because this piping, piping components, and piping elements components in the auxiliary systems with these material/ environment combination has no exposed to gas. The AMR states that there are material and environment combinations. The aging effect and it is consistent with GALL no aging mechanisms or effects for these operating experience review is documented in JAF- Report. This question is resolved.

material/environment combinations, which is RPT-05-LRD05, JAFNPP License Renewal consistent with NUREG-1801. Please discuss Operating Experience Review Report, which was the JAFNPP plant-specific operating available for onsite review.

experience with components in the auxiliary systems containing these material/environment JAFNPP operating experience with these material combinations. and environment combinations is consistent with 183

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the industry experience of no aging effects reflected in NUREG-1801 and the Mechanical Tools [Non-Class 1 Mechanical Implementation Guideline and Mechanical Tools, Revision 4, EPRI, Palo Alto, CA: 1010639].

273 389 AMR line item 3.3.1-98 addresses steel, A review of five years of JAFNPP operating The project team finds the applicant's stainless steel, and copper alloy piping, piping experience did not identify aging effects for response acceptable because this components, and piping elements exposed to components in the auxiliary systems with these material/ environment combination has no dried air. The AMR states that there are no material and environment combinations. The aging effect and it is consistent with GALL aging mechanisms or effects for these operating experience review is documented in JAF- Report. This question is resolved.

material/environment combinations, which is RPT-05-LRD05, JAFNPP License Renewal consistent with NUREG-1801. Please discuss Operating Experience Review Report, which was the JAFNPP plant-specific operating available for onsite review.

experience with components in the auxiliary systems containing these material/environment JAFNPP operating experience with these material combinations. and environment combinations is consistent with the industry experience of no aging effects reflected in NUREG-1801 and the Mechanical Tools [Non-Class 1 Mechanical Implementation Guideline and Mechanical Tools, Revision 4, EPRI, Palo Alto, CA: 1010639].

274 390 The further evaluation presented in Section The PSPM program as described in LRA Section The project team finds the applicant's 3.3.2.2.5, Item 1, of the LRA addresses B.1.22 is a program that requires periodic response acceptable because the cracking and change in material properties due inspection of a sample of elastomers in each applicant clarified that there are no to elastomer degradation in elastomer flexible system crediting this program. Because the locations that provide an environment that connections of auxiliary systems and other program requires periodic inspections, the would make the elastomer materials systems exposed to air-indoor. The further detection of aging effects will be ensured. The significantly more susceptible to aging evaluation states that these aging effects are inspection frequencies and acceptance criteria for effects. In addition, the applicant clarified managed by the Periodic Surveillance and these components are described in Attachment 3 that sample size methodology is based on Preventive Maintenance Program. to JAF-RPT-05-LRD02. Because these established industry standard (EPRI Please provide the technical justification for components are elastomer materials exposed to document 107514, Age Related concluding that the PSPM program will provide the same environment of indoor air there are no Degradation Inspection Method and reasonable assurance that the effects of aging locations that provide an environment that would Demonstration) which outlines a method will not compromise any intended function be significantly more susceptible to aging effects. to determine the number of inspections during the period of extended operation for These inspections are new such that the details on required for 90% confidence that 90% of these components. The response should the sample size are not available. However, the the population does not experience address a) how an appropriate sample size will sample size will be selected from all elastomer degradation (90/90) . The program be assured, b) how the selection of inspection components that credit this program, it will consider provides for increasing inspection sample locations that include the most susceptible operating experience in the selection of the sample size and locations in the event that aging components will be assured, c) the criteria that size and it will be a statistically appropriate sample effects are detected. This question is will be used to determine if corrective actions size. The site corrective action program will control resolved.

are required based on inspection results, and the assignment of corrective actions including 184

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d) the administrative controls that will be follow-up inspections and expansion of inspection implemented to assure that follow-up sites should aging effects be detected.

inspections, or an expansion of the inspection population is performed should aging be Refer to response for question # 334 regarding detected. sample plan.

275 391 Table 3.3.2.3 includes an AMR line item for This particular line item is in reference to a specific The project team finds the applicant's elastomer duct flexible connections exposed to component (the diesel intake air flexible response acceptable because the air-indoor (internal) in the emergency diesel connection) and is only applicable to the interior applicant clarified that the line item is in generator system. The AMR states that there surface of the component. The reason why there reference to a specific component (the are no aging mechanisms or effects for these are no aging effects for the interior surface is diesel intake air flexible connection) and is material/environment combinations. NUREG- explained by note 309. In accordance with the only applicable to the interior surface of 1801 Volume 2 item VII.F1-7 is cited, which EPRI Structural Tools for the evaluation of aging the component. In addition, the applicant recommends a plant-specific aging effects for elastomer materials, if an elastomer is clarified that the elastomer material will management program. A plant specific note not exposed to temperatures above 95°F or not experience aging effects since it is not (309) in the LRA states that changes of ultraviolet light the material will not experience exposed to temperatures above 95°F or material properties and cracking in elastomers aging effects. The exterior surface of this same ultraviolet light. This question is resolved.

are results of exposure to ultra-violet light or component (duct flexible connection exposed to elevated temperatures (>95oF). The note indoor air (ext)) is identified in Table 3.3.2.3 and further states that the interior surfaces of these includes the aging effects of cracking and change components are not exposed to ultra-violet light in material properties since it is exposed to and are part of the air intake that is not ultraviolet light. It will be managed by the PSPM exposed to elevated temperatures. However, program visual inspections. This line item is only the staff notes that there are other elastomer meant to identify that there will be no aging on the duct flexible connections exposed to similar inside of the expansion joint. However, the outside environments in other systems that have been is susceptible to aging and will be inspected.

identified as being susceptible to aging and requiring aging management, for example in the HVAC systems (Table 3.3.2-7). Please clarify why the elastomer duct flexible connections addressed in this AMR are not susceptible to aging while other elastomer duct flexible connections in other systems are identified as requiring aging management.

276 392 The further evaluation presented in Section The Periodic Surveillance and Preventive The project team finds the applicant's 3.3.2.2.7, Item 3, of the LRA addresses loss of Maintenance (PSPM) Program is described in LRA response acceptable because the material due to general (steel only) pitting and Appendix B, Section B.1.22. The PSPM Program applicant clarified that inspections required crevice corrosion for carbon steel and stainless will be effective for managing aging effects since it by the PSPM program include separate steel diesel exhaust piping and components consists of proven monitoring techniques, periodic inspections for both the EDG and exposed to diesel exhaust in the emergency acceptance criteria, corrective actions, and Security Generator exhaust subsystems.

diesel generator and security generator administrative controls. Prior to the period of These inspections will be adjusted as systems. The further evaluation states that extended operation, program activity guidance required based on the inspection In these aging effects are managed by the documents will be enhanced as necessary to addition, the applicant clarified that 185

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Periodic Surveillance and Preventive assure that the effects of aging will be managed sample size methodology is based on Maintenance Program. Please provide the such that applicable components will continue to established industry standard (EPRI technical justification for concluding that the perform their intended functions consistent with the document 107514, Age Related PSPM program will provide reasonable current licensing basis for the period of extended Degradation Inspection Method and assurance that the effects of aging will not operation. The inspection frequencies and Demonstration) which outlines a method compromise any intended function during the acceptance criteria for these components are to determine the number of inspections period of extended operation for these described in Attachment 3 to JAF-RPT-05-LRD02. required for 90% confidence that 90% of components. The response should address a) The inspections required by the PSPM program the population does not experience how an appropriate sample size will be include separate periodic inspections for both the degradation (90/90) . The program assured, b) how the selection of inspection EDG and Security Generator exhaust subsystems. provides for increasing inspection sample locations that include the most susceptible These inspections will be adjusted as required size and locations in the event that aging components will be assured, c) the criteria that based on the inspection results. This will ensure effects are detected. This question is will be used to determine if corrective actions the intended function of the components is resolved.

are required based on inspection results, and maintained for the period of extended operation.

d) the administrative controls that will be The sample size will be selected from all implemented to assure that follow-up components that credit this program. It will consider inspections, or an expansion of the inspection operating experience in the selection of the sample population is performed should aging be size and be a statistically appropriate sample size.

detected. The site corrective action program will control the assignment of corrective actions including follow-up inspections.

Refer to response for question #475 regarding sample plan.

277 393 The further evaluation presented in Section The Periodic Surveillance and Preventive The project team finds the applicant's 3.3.2.2.10, Item 6, of the LRA addresses loss Maintenance (PSPM) Program and the One-Time response acceptable because the of material due to pitting and crevice corrosion Inspection Program are not intended to be applicant clarified the use of the PSPM for copper alloy piping and components combined for the management of aging effects. and One time inspection programs for exposed to internal condensation. The further The use of the word and was intended to identify managing the effects of aging.

evaluation states that these aging effects are that these two programs are credited individually in Specifically, The PSPM program is managed by the Periodic Surveillance and specific line items to manage aging effects. The specified for materials requiring periodic Preventive Maintenance and the One-Time PSPM program is specified for materials requiring inspections to manage aging effects. The Inspection programs. periodic inspections to manage aging effects. The One-Time Inspection Program will verify One-Time Inspection Program is specified for the absence of significant aging and is However, the Table 2 AMR line items materials where insignificant aging effects are specified for materials where insignificant associated with this further evaluation only expected. The One-Time Inspection Program will aging effects are expected. In addition, the credit the PSPM program. Please clarify this verify the absence of significant aging effects. applicant clarified that sample size apparent discrepancy between the further The One-Time Inspection Program, as described in methodology is based on established evaluation and the Table 2 AMRs. Also, please LRA Appendix B, Section B.1.21, will be consistent industry standard (EPRI document provide the technical justification for concluding with the program described in NUREG-1801, 107514, Age Related Degradation that the PSPM program alone will provide Section XI.M32, One-Time Inspection. Inspection Method and Demonstration) reasonable assurance that the effects of aging which outlines a method to determine the will not compromise any intended function The PSPM Program is described in LRA Appendix number of inspections required for 90%

186

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during the period of extended operation for B, Section B.1.22 and will be effective for confidence that 90% of the population these components. The response should managing aging effects since it consists of proven does not experience degradation (90/90) .

address a) how an appropriate sample size will monitoring techniques, acceptance criteria, The program provides for increasing be assured, b) how the selection of inspection corrective actions, and administrative controls. inspection sample size and locations in locations that include the most susceptible Prior to the period of extended operation, program the event that aging effects are detected.

components will be assured, c) the criteria that activity guidance documents will be enhanced as This question is resolved.

will be used to determine if corrective actions necessary to assure that the effects of aging will be are required based on inspection results, and managed such that applicable components will d) the administrative controls that will be continue to perform their intended functions implemented to assure that follow-up consistent with the current licensing basis for the inspections, or an expansion of the inspection period of extended operation. The inspection population is performed should aging be frequencies and acceptance criteria for these detected. components are described in Attachment 3 to JAF-RPT-05-LRD02. These inspections are new such that the details on the sample size are not available. However, the sample size will be selected from all components that credit this program, it will consider operating experience in the selection of the sample size and be a statistically appropriate sample size. Components that are in susceptible locations such as low points will be included in the sample. The site corrective action program will control the assignment of corrective actions including follow-up inspections and expansion of inspection sites should aging be detected.

Refer to response for question #475 regarding sample plan.

278 394 The further evaluation presented in Section The External Surfaces Monitoring, Periodic The project team finds the applicant's 3.3.2.2.10, Item 3, of the LRA addresses loss Surveillance and Preventive Maintenance (PSPM) response acceptable because the of material due to pitting and crevice corrosion Program, and the Service Water Integrity Program applicant clarified the use of the External for copper alloy components exposed to are not intended to be combined for the Surfaces Monitoring, PSPM and Service condensation (external) in the HVAC and other management of aging effects. The use of the word Water Integrity programs for managing the systems. The further evaluation states that and was intended to identify that these programs effects of aging. Specifically, The PSPM these aging effects are managed by the are credited individually in specific line items to program is specified for materials requiring External Surfaces Monitoring, Periodic manage aging effects. Also, in contexts where periodic inspections to manage aging Surveillance and Preventive Maintenance, and copper alloy zinc content is not required to be effects. The One-Time Inspection Service Water Integrity programs. The Table 2 defined, as in the further evaluation discussion of Program will verify the absence of AMR line items credit only one of the three Section 3.3.2.2, the phrase copper alloy may be significant aging and is specified for programs. Please clarify this apparent used broadly to identify all three commonly defined materials where insignificant aging effects discrepancy between the Table 1 line item and variations [i.e., copper alloy, copper alloy >15% are expected. In addition, the applicant the Table 2 line items in regard to which AMPs zinc, and copper alloy >15% zinc (inhibited)]. In clarified that sample size methodology is are credited. Also, for AMRs that credit the Table 3.3.2-7, Heating Ventilation and Air based on established industry standard 187

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PSPM program alone to manage this aging Conditioning Systems, for the condensation (EPRI document 107514, Age Related effect, please provide the technical justification (external) environment, External Surfaces Degradation Inspection Method and for concluding that the PSPM program will Monitoring is specified for copper alloy tubing, Demonstration) which outlines a method provide reasonable assurance that the effects while the Service Water Integrity or PSPM program to determine the number of inspections of aging will not compromise any intended is specified for management of aging effects for required for 90% confidence that 90% of function during the period of extended copper alloy >15% zinc heat exchanger tubes. the population does not experience operation for these components. The response degradation (90/90) . The program should address a) how an appropriate sample As described in LRA Appendix B, Section B.1.22, provides for increasing inspection sample size will be assured, b) how the selection of program activity guidance documents will be size and locations in the event that aging inspection locations that include the most enhanced as necessary to assure that the effects effects are detected. This question is susceptible components will be assured, c) the of aging will be managed such that applicable resolved.

criteria that will be used to determine if components will continue to perform their intended corrective actions are required based on functions consistent with the current licensing basis inspection results, and d) the administrative for the period of extended operation. The PSPM controls that will be implemented to assure that Program will be effective for managing aging followup inspections, or an expansion of the effects since it consists of proven monitoring inspection population is performed should techniques, acceptance criteria, corrective actions, aging be detected. and administrative controls. The inspection frequencies and acceptance criteria for these components that credit PSPM are described in Attachment 3 to JAF-RPT-05-LRD02. These inspections are new such that the details on the sample size are not available. However, the sample size will be selected from all components that credit the PSPM program, it will consider operating experience in the selection of the sample size and be a statistically appropriate sample size.

Components that are in susceptible locations such as low points will be included in the sample. The site corrective action program will control the assignment of corrective actions including followup inspections and expansion of inspection sites should aging be detected.

279 395 AMR line items 3.3.1-5, 3.3.1-37 and 3.3.1-38 There is no discrepancy between the Table 1 and The project team finds the applicant's address cracking for stainless steel piping, Table 2 AMR line items. The Table 1 discussion in response acceptable because the piping components, and piping elements the LRA provides explanations applicable applicant clarified that the one-time exposed to treated water. The LRA credits the generically to all items that reference the specific inspection program will be used to verify Water Chemistry Control-BWR program. The line item. As stated in the discussion sections of the effectiveness of the water chemistry LRA also states that the one-time inspection AMR line items 3.3.1-5, 3.3.1-37 and 3.3.1-38, the control aging management programs. This program will be used to verify the effectiveness One-Time Inspection program will be used to verify question is resolved.

of the water chemistry program. However, the the effectiveness of the Water Chemistry Control-Table 2 AMR line items associated with these BWR program. Therefore, by this reference, all Table 1 entries do not credit the one-time Table 2 line items that reference these Table 1 line 188

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inspection program. Please clarify this items also credit the One-Time Inspection discrepancy between the Table 1 and Table 2 Program. In addition, as stated in section B.1.21 of AMR line items. the LRA, the One-Time Inspection Program includes an activity to verify the effectiveness of the water chemistry control aging management programs. Therefore, in addition to the explicit statements in the Table 1 items, it is implied that everywhere the Water Chemistry Control-BWR program is called out as an aging management program in the Table 2 line items it also includes a One-Time Inspection to verify the effectiveness of the program.

Plant specific notes in Table 2 line items are included where GALL identified Water Chemistry Control - BWR augmented by One-time Inspection as the applicable aging management program.

Therefore, the plant specific note is used to clarify specific applicability to the GALL line items. Where water chemistry control is the only aging management program specified in GALL line items, no plant specific note applies.

280 396 Table 3.3.2-7 includes an AMR line item to The Service Water Integrity Program includes The project team finds the applicant's address fouling of aluminum heat exchanger activities to visually inspect components (fins) or response acceptable because the fins exposed to condensation (external) in the verify the heat transfer capability of safety-related applicant clarified that since the heat HVAC systems. Generic note G is cited, heat exchangers cooled by service water. The heat exchangers referred to in this line item are indicating that this environment is not exchangers referred to in this line item are room room coolers that are cooled by service addressed in NUREG-1801. The LRA credits coolers that are cooled by service water so they water, they are included in the Service the Service Water Program to manage this are included in the Service Water Integrity Water Integrity Program. In addition, the aging effect. Please describe the specific Program. These heat exchangers are either applicant stated that the Service Water activities in the Service Water Program that will visually inspected for fouling or are performance Integrity Program includes activities to be used to manage fouling of the external tested to detect fouling. visually inspect components (fins) or verify surface of heat exchanger fins. Also, please the heat transfer capability of safety-discuss why the Service Water Program was related heat exchangers cooled by service selected as the most appropriate AMP for this water. This question is resolved.

MEA combination.

281 397 Table 3.3.2-3 includes an AMR line item to As discussed in the response to Audit question The project team finds the applicant's address loss of material of aluminum valve No.279, activities to confirm the effectiveness of response acceptable because the bodies exposed to lube oil (internal) in the EDG the Oil Analysis Program will be added to the One- applicant amended the LRA Table 3.3.2-3 systems. Generic note G is cited, indicating Time Inspection Program. This requires an to clarify that one-time inspection program that this environment is not addressed in amendment to the LRA. will be used to verify the effectiveness of 189

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NUREG-1801. The LRA credits the Oil Analysis the lube oil program. See amendment Program to manage this aging effect. Please letter No. 5, dated February 01, 2007. This clarify why a one-time inspection is not credited question is resolved.

also to verify the effectiveness of the lube oil program.

282 398 Table 3.3.2-3 includes AMR line items to A review of five years of JAFNPP operating The project team finds the applicant's address aluminum lubricator housings and experience did not identify aging effects for response acceptable because aluminum motor housings exposed to air-untreated components with this material and environment exposed to indoor uncontrolled air (internal) in the EDG systems. The LRA states combinations. The operating experience review is environment does not require aging that there are no aging effects requiring documented in JAF-RPT-05-LRD05, JAFNPP management . This is consistent with management. Generic note G is cited, License Renewal Operating Experience Review research data,(EPRI 1010639), plant-indicating that this environment is not Report, which was available for onsite review. specific and industry operating addressed in NUREG-1801. Please discuss the JAFNPP operating experience with this material experience. This question is resolved.

JAFNPP plant-specific operating experience and environment combinations is consistent with with components containing this the industry experience of no aging effects material/environment combination. reflected in the Mechanical Tools [Non-Class 1 Mechanical Implementation Guideline and Mechanical Tools, Revision 4, EPRI, Palo Alto, CA:

1010639].

283 399 Table 3.3.2-4 includes AMR line items to A review of five years of JAFNPP operating The project team finds the applicant's address aluminum flame arrestors exposed to experience did not identify aging effects for response acceptable because aluminum air-outdoor (internal and external) in the fuel oil components with this material and environment exposed to indoor uncontrolled air systems. The LRA states that there are no combinations. The operating experience review is environment does not require aging aging effects requiring management. Generic documented in JAF-RPT-05-LRD05, JAFNPP management . This is consistent with note G is cited, indicating that this environment License Renewal Operating Experience Review research data,(EPRI 1010639), plant-is not addressed in NUREG-1801. Please Report, which was available for onsite review. specific and industry operating discuss the JAFNPP plant-specific operating JAFNPP operating experience with this material experience. This question is resolved.

experience with components containing this and material/environment combination. environment combinations is consistent with the industry experience of no aging effects reflected in the Mechanical Tools [Non-Class 1 Mechanical Implementation Guideline and Mechanical Tools, Revision 4, EPRI, Palo Alto, CA: 1010639].

284 400 Table 3.3.2-8 includes AMR line items to A review of five years of JAFNPP operating The project team finds the applicant's address aluminum heat exchanger coils and experience did not identify aging effects for response acceptable because aluminum stainless steel tanks exposed to liquid nitrogen components with these material and environment and stainless steel exposed to liquid (internal) in the containment systems. The LRA combinations. The operating experience review is nitrogen (internal) do not require aging states that there are no aging effects requiring documented in JAF-RPT-05-LRD05, JAFNPP management . This is consistent with management. Generic note G is cited, License Renewal Operating Experience Review research data,(EPRI 1010639), plant-indicating that this environment is not Report, which was available for onsite review. specific and industry operating 190

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addressed in NUREG-1801. Please discuss the JAFNPP operating experience with these material experience. This question is resolved.

JAFNPP plant-specific operating experience and environment combinations is consistent with with components containing these the industry experience of no aging effects material/environment combinations. reflected in the Mechanical Tools [Non-Class 1 Mechanical Implementation Guideline and Mechanical Tools, Revision 4, EPRI, Palo Alto, CA:

1010639].

285 401 Table 3.3.2-9 includes an AMR line items to The One-Time Inspection Program will verify the The applicant credits one-time inspection address cracking of aluminum/boron carbide effectiveness of the Water Chemistry Program to program to verify the effectiveness of the neutron absorber exposed to treated water manage cracking of the aluminum/boron carbide water chemistry control aging (external) in the fuel pool cooling and cleanup neutron absorbers. As described in section B.1.21 management programs. This is consistent system. The LRA credits the water chemistry- of the LRA: One-time inspection activities will verify with GALL Report recommendation. This BWR program to manage this aging effect. the effectiveness of the water chemistry control question is resolved.

Generic note H is cited, indicating that this aging management program by confirming that aging effect is not addressed in NUREG-1801. unacceptable cracking is not occurring.

Please discuss how the effectiveness of the water chemistry-BWR program for managing this aging effect will be verified for this component.

286 402 Table 3.3.2-14-41 includes AMR line items to The components in this line item are included in The project team finds the applicant's address cracking due to fatigue of carbon steel scope only for structural support of the safety- response acceptable, because the one-compressor housings, piping, and valve bodies related components in the EDG air start time inspection activity will confirm thru exposed to air-untreated (internal) in the EDG subsystem. This aging effect was conservatively visual or other NDE techniques that systems. The LRA credits the one-time identified due to the potential for high temperature fatigue cracking of components providing inspection program to manage this aging effect. thermal cycling of the discharge piping. The one- structural support to the EDG air start Generic note H is cited, indicating that this time inspection activity will confirm thru visual or subsystem is not occurring. The project aging effect is not addressed in NUREG-1801. other NDE techniques that cracking is not occurring team concurs with the applicants Please discuss how the one-time inspection or is so insignificant that an ongoing aging assessment that it is conservative to program will manage cracking due to fatigue for management program is not warranted. If consider these component/aging effect these components throughout the period of significant cracking is detected corrective actions combinations. This question is resolved.

extended operation. will be taken in accordance with the site corrective action program.

287 403 Table 3.3.2-5 includes AMR line items to The Fire Protection Program will include periodic The project team finds the applicant's address cracking due to fatigue of carbon steel inspections and testing of the diesel-driven fire response acceptable because in mufflers, piping, and valve bodies exposed to pump including exhaust system components to Amendment Letter No. 5, dated February exhaust gas (internal) in the fire protection- ensure that diesel engine components can perform 01, 2007, the applicant amended the LRA water system. The LRA credits the Fire their intended functions. These inspections and to enhance the Fire Protection Program. It Protection program to manage this aging effect. testing will identify cracking through the use of will include periodic inspections and Generic note H is cited, indicating that this visual observations. This requires an LRA testing of the diesel-driven fire pump aging effect is not addressed in NUREG-1801. amendment. including exhaust system components, to 191

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Please discuss how the Fire Protection ensure that diesel engine components can program will manage cracking due to fatigue for perform their intended functions. The these components throughout the period of inspections and testing will identify extended operation. cracking through the use of visual observations.

While visual observation typically can detect cracking only in an advanced stage, the specific components being addressed (mufflers, piping, and valve bodies in the exhaust system) are judged by the project team to be capable of performing their intended functions with significant cracks, detectable by visual observation.

On this basis, this question is resolved.

288 404 Table 3.3.2-13 includes AMR line items to As identified in Appendix B of the LRA and section The project team finds the applicant's address cracking due to fatigue of carbon 4.17 of JAF-RPT-05-LRD-02, the PSPM Program response acceptable, because the piping and silencers and stainless steel will periodically use visual or other NDE techniques applicant identified in the LRA and in expansion joints exposed to exhaust gas to inspect a representative sample of security Section 4.17 of JAF-RPT-05-LRD-02, that (internal) in the security generator. The LRA generator exhaust components to manage the PSPM Program will periodically credits the Periodic Surveillance and cracking. These inspections will be adequate to inspect a representative sample of Preventive Maintenance program to manage verify no unacceptable cracking on the security security generator exhaust components this aging effect. Generic note H is cited, generator exhaust components. using visual or other NDE techniques, to indicating that this aging effect is not addressed manage cracking.

in NUREG-1801. Please discuss how the PSPM program will manage cracking due to While visual inspection typically can fatigue for these components throughout the detect cracking only in an advanced period of extended operation. stage, the project team concurs with the applicants assessment that it will be adequate to verify no unacceptable cracking on the security generator exhaust components.

On this basis, this question is resolved.

289 405 Table 3.3.2-7 includes an AMR line item to The heat exchangers crediting the Service Water The project team finds the applicant's address loss of material due to wear of copper Integrity Program for the management of aging response acceptable because the Service alloy heat exchanger tubes exposed to gas effects in Table 3.3.2-7 represent the condensers Water Integrity Program which includes (external) in the HVAC systems. The LRA of the control room chillers. Each condenser GL 89-13 commitments is adequate to credits the Service Water Integrity program to utilizes emergency service water as a heat sink detect loss of material due to wear on the manage this aging effect. Generic note H is and is inspected per the requirements of GL 89-13 copper alloy tubes. This question is 192

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cited, indicating that this aging effect is not by the Service Water Integrity Program which resolved.

addressed in NUREG-1801. Please discuss the includes eddy current testing. These inspections rational for crediting the Service Water Integrity will be used to detect loss of material due to wear program to manage this aging effect for on the copper alloy tubes.

components exposed to gas throughout the period of extended operation instead of the Heat Exchanger Monitoring program.

290 406 Table 3.3.2-7 includes an AMR line item to The heat exchanger described by this line item is The project team finds the applicant's address loss of material due to wear of copper an evaporator. A water chemistry program by itself response acceptable because the alloy heat exchanger tubes exposed to treated would not be adequate to manage loss of material applicant amended the LRA to credit the water (external) in the HVAC systems. The due to wear on the external tube surface. Heat Exchanger Monitoring program to LRA credits the Periodic Surveillance and manage the aging effect. See amendment Preventive Maintenance program to manage The PSPM program was incorrectly credited for letter No. 5, dated February 01, 2007. This this aging effect. Generic note H is cited, managing loss of material due to wear. Instead the question is resolved.

indicating that this aging effect is not addressed Heat Exchanger Monitoring program should have in NUREG-1801. Please discuss the rational for been credited for management of this aging effect.

crediting the PSPM program to manage this aging effect for components exposed to treated This requires an amendment to the LRA.

water throughout the period of extended operation instead of the Heat Exchanger Monitoring or Water Chemistry program.

291 407 Table 3.3.2-3 includes an AMR line item to This line item addresses wear on the external The project team finds the applicant's address loss of material due to wear of copper surface of tubes in the EDG jacket water heat response acceptable because the Service alloy heat exchanger tubes exposed to treated exchanger. A water chemistry program cannot Water Integrity Program which includes water (external) in the EDG systems. The LRA manage loss of material due to wear. These heat GL 89-13 commitments and eddy current credits the Service Water Integrity program to exchangers are included in the Service Water testing is adequate to detect loss of manage this aging effect. Generic note H is Integrity Program since they are cooled by the material due to wear on the copper alloy cited, indicating that this aging effect is not service water system and are part of GL 89-13 tubes. This question is resolved.

addressed in NUREG-1801. Please discuss the commitments. Although loss of material due to rational for crediting the Service Water Integrity wear occurs on the external surface of the tubing program to manage this aging effect for (which is exposed to treated water) this aging effect components exposed to treated water will be managed by eddy current testing of the throughout the period of extended operation tubes in the Service Water Integrity Program.

instead of the Heat Exchanger Monitoring or Water Chemistry program.

292 408 Table 3.3.2-12 includes AMR line items to The review of recent site experience documented The project team finds the applicant's address fiberglass piping and tanks exposed to in JAF-RPT-05-LRD05 Operating Experience response acceptable because fiberglass is air-indoor, raw water, and soil in the Radwaste Review Report did not identify degraded a highly corrosion resistant material and and Plant Drains systems. The LRA states that conditions or failures that would indicate the does not require any aging management.

there are no aging effects requiring presence of aging effects for fiberglass This is consistent with research 193

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management for these material/environment components. This is consistent with the EPRI data,(EPRI 1010639), plant-specific and combinations. Generic note F is cited, Mechanical Tools which state that fiberglass is a industry operating experience. This indicating that this material is not addressed in highly corrosion resistant material. The question is resolved.

NUREG-1801. Please discuss the JAFNPP components are monitored by system engineering plant-specific operating experience with walkdowns with no aging effects identified.

components containing this material/environment combination, including For additional information, see Section 3.0 of JAF-inspections performed, degradation detected, RPT-05-LRD05 for review of aging effects at and any failures that have occurred. JAFNPP.

293 409 Table 3.3.2-5 includes AMR line items to The Fire Protection Program will include periodic The project team finds the applicant's address cracking due to fatigue of gray cast inspections and testing of the diesel-driven fire response acceptable because in iron turbocharger housings and stainless steel pump including exhaust system components to Amendment Letter No. 5, dated February expansion joints exposed to exhaust gas ensure that diesel engine components can perform 01, 2007, the applicant amended the LRA (internal) in the fire protection-water system. their intended functions. These inspections and to enhance the Fire Protection Program. It The LRA credits the Fire Protection program to testing will identify cracking through the use of will include periodic inspections and manage this aging effect. Generic note H is visual observations. This requires an LRA testing of the diesel-driven fire pump cited, indicating that this aging effect is not amendment. including exhaust system components, to addressed in NUREG-1801. ensure that diesel engine components can perform their intended functions. The Please discuss how the Fire Protection inspections and testing will identify program will manage cracking due to fatigue for cracking through the use of visual these components throughout the period of observations.

extended operation.

While visual observation typically can detect cracking only in an advanced stage, the specific components being addressed (turbocharger housing, expansion joints in the exhaust system) are judged by the project team to be capable of performing their intended functions with significant cracks, detectable by visual observation.

On this basis, this question is resolved.

294 410 Table 3.3.2-3 includes AMR line items to As stated in LRA Section B.1.20, The Oil Analysis The project team finds the applicant's address cracking of stainless steel strainers Program maintains oil systems free of response acceptable because the exposed to lube oil (internal and external) in the contaminants (primarily water and particulates) applicant provided sufficient justification to EDG system. The LRA credits the Oil Analysis thereby preserving an environment that is not support the conclusion that the Oil program to manage this aging effect. Generic conducive to loss of material, cracking, or fouling. Analysis Program will manage cracking of note H is cited, indicating that this aging effect Sampling frequencies are based on vendor these components through the period of is not addressed in NUREG-1801. Please recommendations, accessibility during plant extended operation. This question is 194

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discuss how the Oil Analysis program will operation, equipment importance to plant resolved.

manage cracking for these components operation, and previous test results. Therefore, the throughout the period of extended operation. Oil Analysis Program will manage cracking of these components through the period of extended operation.

295 411 The LRA does not list the following The east diesel fire pump (76-P-4) serves as a The project team finds the applicant's components: east diesel fire pump and backup to the main diesel fire pump and the response acceptable because the Screenwell Building fire suppression system electric fire pump and is not required to comply with applicant clarified that the AMR results for and associated components; the jockey pump the requirements of 10 CFR 50.48 as described in the identified components are described in and its associated components; manual water Technical Requirements Manual (TRM) Section B LRA Table 3.3.2-5. This question is spray systems provided in HPCI and RCIC 3.7.H. The screenwell building fire suppression resolved.

pump rooms, reactor feed-pump turbine areas, system, including suppression in the east diesel hydrogen seal oil unit, and turbine generator fire pump room, is subject to aging management bearing boxes and oil piping area; and review with its components included in LRA Table preaction sprinkler systems and its associated 3.3.2-5.

components provided in the recirculation The motor driven jockey fire pump (76-P-3) pumps motor generator set room, and in the maintains fire system pressure during standby emergency diesel generator rooms. operations. As shown at coordinates C-3 of drawing LRA-FB-48A, this component is outside Confirm whether the are in the scope of license the quality class M (augmented quality) renewal. If they are excluded from the scope of boundary. Automatic water spray systems in the license renewal and not subject to an AMR, HPCI pump rooms, RCIC pump rooms, reactor provide justification for the exclusion. If not, feed pump turbine areas, hydrogen seal oil unit, describe your aging management reviews and and turbine generator bearing boxes and oil piping the aging management programs. area are subject to aging management review and their components are included in LRA Table 3.3.2-5.

Pre-action sprinkler systems and associated components in the recirculation pumps MG set room and EDG rooms are subject to aging management review and their components are included in LRA Table 3.3.2-5.

296 412 JAFNNP is required to meet Appendix A to As shown on LRA-FB-49A at location E-3, the The project team finds the applicant's Branch Technical Position (BTP) Auxiliary and automatic water deluge system protecting station response acceptable because the AMR Power Conversion Systems Branch (APCSP) reserve transformer (T-3) is subject to aging results are described in LRA Table 3.3.2-9.5-1, Guidelines for Fire Protection for management review and is included in LRA Table 5. This question is resolved.

Nuclear Power Plants, May 1, 1976, August 3.3.2-5.

23, 1976. According to JAFNPP commitments to satisfy Appendix A to BTP APCSP 9.5-1, JAFNPP letter dated January 11, 1977, states that the transformer is protected by an automatic water spray deluge system in 195

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accordance with NFPA 13. If automatic water deluge system is excluded from the scope of license renewal and not subject to an AMR, provide justification for the exclusion. If not, describe your aging management reviews and the aging management programs.

297 413 LRA Section 3.4.2.2.4 (Reduction of Heat As described in the UFSAR section 10.9.3, two The project team finds the applicants Transfer due to Fouling) - states that the steam thermosiphon heat exchangers (one per tank) were response acceptable because and power conversion systems at JAFNPP originally provided, but now have been retired in thermosiphon heat exchangers and its have no heat exchanger tubes with an intended place. The tank nozzles for the thermosiphon components are not subject to aging function of heat transfer and associated aging heater are located in the upper half of the tank management review since they have been effect of fouling. Drawing LRA-FM-33D depicts (above the required reserve supply) such that their retired in place. This question is resolved.

Thermosiphon heat exchanger A/B associated failure would not affect the ability of the tank to with each condensate storage tank perform its functions. Therefore the piping to and respectively. Should this heat exchanger be from these components is not subject to aging included in the aging management program, if management review.

not why?

298 414 Table 3.5.2-4, Bulk Commodities Summary of Structural fire barriers (walls, ceilings, floors and The project team finds the applicants Aging Management Evaluation, that the slabs) are identified as in-scope of license renewal response acceptable because the structural fire barriers (walls, ceilings, floors, and are listed within the tables of the associated applicant has clarified that the structural and slabs) are within in the scope of license structures with an intended function FB". barriers are within the scope of license renewal in accordance with 10 CFR 54.4(a) and renewal and that their aging effect is subject to an AMR in accordance with 10 CFR The aging management program for these managed by the Fire Protection Program.

54.21(a)(1). If these structural fire barriers are commodities is the Fire Protection Program. This question is resolved.

excluded from the scope of license renewal and not subject to an AMR, provide justification for the exclusion. If not, describe your aging management reviews and the aging management programs.

299 415 In LRA, Table 4.3-2 listed current Design Basis As explained in Section 2.3 of LRD04, these The resolution of this question is Cycles for Design Transients. transients/cycles are obtained from JAFNPP addressed under RAI 4.3.1-1 on cycle technical specifications, UFSAR, and plant counting.

Part A: Are these transients/cycles extracted drawings. The original design basis cycles have from Design Specification, or other basis been updated based on actual plant transient In a letter dated April 06, 2007, the documents? Provide basis for these history from start-up to June 30, 2001. applicant stated that a response to RAI transients/cycles. 4.3.1-1 will be provided no later than June 30, 2007. This question is closed to RAI 4.3.1-1.

300 416 In LRA, Table 4.3-2 listed current Design Basis The CUFs in Table 4.3-1 are calculated based on The resolution of this question is 196

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Cycles for Design Transients. the analyzed number of design cycles. The CUFs addressed under RAI 4.3.1-1 on cycle are valid for the analyzed number of design cycles counting.

Part B: What is the CUFs in Table 4.3-1? Is independent of how many years it takes to accrue these CUFs for 60 years or just for current those cycles. Projections indicate that actual In a letter dated April 06, 2007 the design cycles as indicated in Table 4.3-2? design cycles for 60 years of operation will not applicant stated that a response to RAI exceed the analyzed number of cycles. Since 4.3.1-1 will be provided no later than June these design cycles will not be exceeded in either 30, 2007. This question is closed to RAI 40 years or 60 years, these CUFs are good for 4.3.1-1.

both 40 years and 60 years.

301 417 In LRA, Table 4.3-2 listed current Design Basis Yes, the feedwater nozzle area is subject to the The resolution of this question is Cycles for Design Transients. leakage bypass transients described in NUREG- addressed under RAI 4.3.1-1 on cycle 0619. The calculated CUF for the feedwater nozzle counting.

Part C: Does the feedwater nozzle area subject inner blend radius includes rapid cycle fatigue due to leakage bypass transient which was to the leakage past the thermal sleeve. In a letter dated April 06, 2007 the described in NUREG-0619? If the answer is applicant stated that a response to RAI yes, the CUF evaluation does count this actual As shown in LRA Table 3.1.2-1, cracking of the 4.3.1-1 will be provided no later than June leakage bypass transient, or not? feedwater nozzles is managed by the BWR 30, 2007. This question is closed to RAI Feedwater Nozzle Program. As discussed in LRA 4.3.1-1.

Appendix B, this program incorporates the recommendations of GE-NE-523-A71-0594 as approved by the NRC SER of June 5, 1998. These inspections will detect cracking due to various mechanisms, including fatigue.

302 418 LRA Table 4.3-2 defines the design basis This response will be provided in a submittal letter The resolution of this question is transients for JAFNPP and provides the for RAI 4.3.1-1. addressed under RAI 4.3.1-1 on cycle updated 60-year design basis value for these counting.

transients. The table also provides the projected number of cycles based on the In a letter dated April 06, 2007 the recorded transients. The staff requests the applicant stated that a response to RAI following additional information: 4.3.1-1 will be provided no later than June 30, 2007. This question is closed to RAI Part A: For each transient in LRA Table 4.3-2, 4.3.1-1.

clarify how many operational cycles have been recorded up to the time that the 60-year transient projections were calculated, as given in the Updated 60 Year Cycle Projection column of LRA Table 4.3-2. Provide a technical discussion to clarify how the 60-year projections were performed based on recorded transient data. In particular, if a particular transient category in LRA Table 4.3-2 is made up of more than one specific transient, clarify 197

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which specific transient is used to define the transient and clarify how the total number of cycles were used to derive the 60 year cycle projections. In addition, clarify how the cycles were recorded prior to 1988 when JAFNPP did not implement a plant computer to track transient events.

Part B: Page 19 of General Electric (GE)

Design Calculation EAS-149-1286 / DRF B13-01391 discusses GEs evaluation of 12 transients (i.e., nine reactor SCRAMS, one turbine trip, two feedwater pump trips) that had been grouped into the Shutdown transient for the plant. The report stated that the change in reactor coolant temperature (T) for six of these events had exceeded the T value for this transient. The staff noted that the bases provided on page 19 for justifying why these events can be categorized as plant heatups or cooldowns are based on qualitative analysis without using any temperature gradient data.

Justify why these six transients can be grouped intoShutdown transient for the plant when the T values for these six events were determined to excessive and the temperature gradients for the transients are not defined.

In particular, for the scram event that occurred on November 4, 1984, a T of -297 F and a T of +437 F occurred on the same day. Please define when did T events occur and what were the actual temperature gradients associated with these events.

Clarify how your response to this part (Part B) factors into your response to Part A, particularly with respect to the number of recorded occurrences for the transient Categories in LRA Table 4.3-2.

Part C: In the GE stress report, GE characterized 12 unidentified operational transients as reactor SCRAMS. GE identified that 63 occurrences of these transients had 198

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occurred prior to 1987. Confirm whether or not this is true. In addition, Entergy projects that the number of SCRAM events occurring through 60 years of operation for the All Other SCRAM events will be 62. Justify how the number of cycles projected through 60 years of operation can be 62 when 63 occurrences had been recorded through 1987. In the GE stress report, GE also mentioned that the change in reactor coolant temperature (T) associated with these 12 unidentified transients was approximately 330 F. Please define these unidentified transients and list the pressure-temperature data for these transients. Also please define the pressure-temperature (P-T) data that were used for the limiting SCRAM event used in Structural Integrity Associatess (SIAs) updated 60-year cumulative usage factor calculations. Justify how these 12 transients are characterized based on the analyzed P-T limit data used in SIAs updated CUF calculations.

Clarify how your response to this part (Part C) factors into your response to Part A, particularly with respect to the recording the number of cycles for the transients defined in LRA Table 4.3-2 and using this data to project the 60-year cycles for the transients.

303 442 Fitzpatrick FSAR Section 8.2.1 states that an The three sources of normal AC power for JAF are The project team finds the applicants alternate source of AC power, from the 345kV the normal, reserve, and emergency sources. The response acceptable because back system, is available to provide power to plant normal source is the Normal Service Station feeding from 345kV is not credited for auxiliaries during plant shutdown. The power is Transformer (NSST) 71T-4. The reserve source is SBO offsite recovery. The two 115kV supplied to plant 4.16kV emergency buses by the Reserve Service Station Transformers (RSST) buses which are energized from back feeding from the 345kV system via main 71T-2 and 71T-3. The emergency source is the independent 115kV transmission lines transformer, isolated phase bus duct, and the Emergency Diesel Generators. provide power to the 4.16kV safety buses normal station transformer. Back feeding is during startup, shutdown, and SBO identified as a qualified alternate source of AC In Section 8.3 of the JAF UFSAR, the 115KV recovery. This design is consistent with 10 power to 4.16kV safety buses and therefore, system has the safety objective to provide a supply CFR 50, Appendix A, General Design should be included in the scope of license of offsite power for the engineered safeguard loads. Criteriion 17. An alternate source of ac renewal. Provide a technical justification why The 115KV system has the power generation power back feeding from the 345kV the alternate AC source to 4.16kV safety buses objective to provide two sources of offsite AC system is not credited for SBO offsite from the 345kV system does not need an AMP/ power to the Plant Service AC Power Distribution recovery and therefore, an AMP is not 199

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System for plant startup, operating and shutdown required. This question is resolved.

power including adequate power to the emergency service buses for the safe shutdown of the reactor.

The 115KV bus at JAF is energized from two 115KV transmission lines as shown in SAR Figure 8.3-2. This provides the GDC- 17 criteria for the Reserve Service Station Transformers. Section 8.11 of the JAF UFSAR, addresses Station Blackout (SBO). Station Blackout (SBO) is defined in 10 CFR 50.2 as a complete loss of alternating current (AC) electric power to essential and non-essential switchgear buses. Offsite power is assumed to be lost concurrently with a main turbine trip and unavailability of the on-site emergency AC power system. Station Blackout does not include loss of AC power to buses fed by the station batteries through inverters and does not assume a concurrent single failure or design basis accident.

Section 8.2.1 of the JAF UFSAR, states that An alternate source of AC power, from the 345KV system, is available to provide power to plant auxiliaries during plant shutdown. The power is supplied to plant 4.16KV buses by back feeding from the 345KV system via main transformers, isolated phase bus duct, and the normal station service transformer. The main generator is isolated by removing the isolated phase bus duct disconnect links. This alternate source is only used during outages for maintenance on the Reserve Service Station Transformer. This source of offsite AC power is not credited for recovery from Station Blackout.

The two sources of offsite AC power is the two independent 115KV lines that feed the RSST transformers. There is a cross feed circuit that can be closed to provide power to both of the 4.16KV safety buses in the plant in the case of loss of one 115KV line. This cross-tie can be closed in less than ten minutes when needed. This source will be much faster than installing the feedback source which takes at least 12 hours0.5 days <br />0.0714 weeks <br />0.0164 months <br />. No other source is needed or required.

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304 443 When is the one time inspection and hardness This is a new program that will be implemented The project team finds the applicants measurement mentioned in the "scope" of the prior to entering the period of extended operation response acceptable because the one program performed? as described in Commitment 15. No inspections or time inspection and hardness hardness testing to identify the presence of measurements are performed in selective leaching for components included in the accordance with GALL AMP XI.M33 scope of license renewal have been performed at recommendations prior to the PEO as the current time. Hardness testing of the shown in Commitment No. 15 to the LRA.

components will be performed on the surface This question is resolved.

exposed to the environment with potential for causing selective leaching.

305 444 What preventive actions does the applicant In accordance with NUREG-1801 XI.M33 and AMP The project team finds the applicants plan to take in reducing selective leaching to B.1.25 section B.2 there are no preventive actions response acceptable because the address GALL element? associated with this program. This program is only applicant's Selective Leaching Program is an inspection and verification program. consistent with GALL AMP XI.M33 recommendations. This question is If selective leaching is detected during the resolved.

inspections the corrective action program at JAF will initiate corrective actions. However, monitoring of water chemistry to control pH and concentration of corrosive contaminants and minimizing dissolved oxygen in water as part of the JAF Water Chemistry programs described in Appendix B Section B.1.29 of the JAF license renewal application are effective in reducing selective leaching.

306 445 What acceptance criteria does the applicant The implementation of this program including The project team finds the Selective plan to use for hardness testing? acceptance criteria is license renewal commitment Leaching Program "acceptance criteria" 15 that will be implemented prior to the period of element consistent with GALL AMP extended operation. XI.M33. This program is identified as Commitment No. 15 to be implemented prior to the PEO. This question is resolved.

307 446 Provide industry operating experience Since this is a new program there is no plant The project team finds the applicants considered for selective leaching program and specific operating experience for the program. A response acceptable because the plant-plant specific operating experience for review of condition reports at JAF did not locate specific operating experience did not components in the program. any examples of selective leaching occurring at the reveal any degradation not bounded by site. Within the industry Information Notice 84-71 industry operating experience. This documented the occurrence of graphitization of question is resolved.

cast iron occurring in the salt water system at Calvert Cliffs Nuclear Plant. JAF does not have any 201

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salt water systems but will consider industry operating experience during the development of the program.

308 447 NRC audit team requests clarification to Add to wording of Note 1 for exception listed in B.1.23: The applicant amended the LRA in exception listed for this program. This is applicable to the current (third) ISI interval amendment letter No. 5, dated February which is based on the ASME Section XI Code 1989 01, 2007. The applicant entered the 4th version. The code of record for the fourth interval 10-Year Inservice Inspection (ISI) Interval (2001 Edition / 2003 Addenda) has deleted the for FitzPatrick in January 2007. The requirements for surface exams. This requires a project team finds the applicants revision to JAF-RPT-05-LRD02 and an amendment response and amendment of the LRA to to the LRA. be acceptable because the applicant has clarified that the need for surface examinations of the closure studs, when removed, was eliminated from ASME Section Table IWB-2500-1 in the 2001 Edition of the Code and that the 2001 Edition of ASME Section XI is the edition that is applicable to the 4th 10-year ISI Interval for FitzPatrick. Thus, as stated in the amendment of the LRA, the exception is not applicable to the current ISI interval for the facility. This question is resolved.

309 448 Provide verification that the Medium Voltage A search was performed of the Electrical Cable and The project team finds the applicants Cables that go to the RHR and Core Spray Raceway Information System Controlled Database response acceptable because the Pump Motors are Environmentally Qualified. (ECRIS) for cables going to the RHR and Core applicant provided verification that the Spray Pump Motors to identify the Cable Marks for RHR and Core Spray pump cables are in the Medium Voltage Cables (NFF-44, NFF-46, EQ master list. This question is resolved.

NFY-07 and NFY-08)

The applicable environmental qualification files for these cable marks are identified. (QDR 06.10 for NFF-44 and NFF-46 and QDR 06.19 for NFY-07 and NFY-08). QDRs 06.10 and 06.19 identify the corresponding commodity IDs for the cables.

(Cable Marks NFF-44 and NFF-46 are identified as CABLE-12 on the Environmental Qualification Component List (EQCL. Cable Marks NFY-07 and NFY-08 are identified as CABLE-25 on the EQCL.)CABLE-12 and CABLE-25 were verified listed on the EQCL.

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310 449 LRA Section A.2.1.18 provides the following LRA Section A.2.1.18 will be revised in a later The applicant amended the LRA in UFSAR Supplement summary description for the update to delete the relevant information for the 3rd amendment letter No. 5, dated February ISI Program: Ten-Year ISI interval for JAFNPP and to incorporate 01, 2007. The applicant entered the 4th 10-the relevant information for the 4th Ten- Year ISI Year Inservice Inspection (ISI) Interval for The ISI Program is based on ASME Inspectin Interval for JAFNPP. FitzPatrick in January 2007. The project Program B (Section xi, IWA-2432), which has team finds the applicants response to this 10-year inspection intervals. Every 10 years the This requires a LRA amendment. audit question and the amendment of the program is updated to the latest ASME Section LRA to be acceptable because the XI code edition and addendum approved in applicant has clarified that the 2001 Edition 10CFR50.55a. On September 28, 1997, of ASME Section XI is the edition that is JAFNPP entered the third ISI interval. The code applicable to the 4th 10-year ISI Interval for edition and addenda used for the third interval is FitzPatrick. Thus, as stated in the the 1989 Edition with no Addenda. amendment of the LRA, the exception is The program consists of periodic volumetric, not applicable to the current ISI interval for surface, and visual examination of components the facility. This question is resolved.

and their supports for assessment, signs of degradation, flaw evaluation, and corrective actions.

The JAFNPP is scheduled to enter the 4th 10-year ISI Interval in January 2007. The version of the ASME Code,Section XI required for the 4th 10-year ISI interval is the 2001 Edition of the ASME Code,Section XI, inclusive of the 2003 Addenda. The staff requests that the LRA Section A.2.1.18 be amended to delete the relevant information for the 3rd Ten-Year ISI interval for JAFNPP and to incorporate the relevant information for the 4th Ten-Year ISI Interval for JAFNPP.

311 450 Has any inspection ever been performed on Yes. The FAC program is guided by industry and The project team finds the applicants systems that have been excluded based on low plant experiences. Portions not explicitly response acceptable because the applicant operating time of <2% of plant operating time to recommended but recognized, via industry and plant has included items that have potential for make sure that there is no wear on these lines. experiences, as having potential for FAC or Erosion FAC or Erosion have been included in the have been included in the augmented portion of the augmented portion of the JAF FAC JAF FAC Inspection program. inspection program consistent with the industry practice and the GALL Report In addition, regardless of system run time, if a recommendations. This question is component is analyzed using our predictive code resolved.

(CHECWORKS SFA 2.1) and is found to have a low time to T-critical, it is included into our outage scope.

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312 451 For AMP B.1.14 -3 Flow-Accelerated There are 1729 modeled components in the JAF The project team finds the applicants Corrosion, specify the number of inspection predictive code. To date, 456 individual response acceptable because the locations for piping. components have been inspected. The selections applicant has identified the number of are based on the shortest time to T-critical for piping inspection locations for the FAC those components with no inspection history and program including the number of re-inspections for those components driven by a components inspected to-date. This calculated remaining service life. The R-17 JAF question is resolved.

outage scope included 85 large bore components for inspection. Of these 85, over 40% were first time inspections. This number of first time inspections was greatly influenced by Industry OE associated with the Mihama accident.

313 452 AMP B.1.14 -4 Flow-Accelerated Corrosion 1. There is no specific percentage that is used for The project team finds the applicants Provide the following: scope expansion when unexpected wear is response acceptable because the detected. The locations are assessed individually. applicant is implementing its program in

a. Percentage increase of inspection when Scope expansion unexpected thinning is detected accordance with plant procedures and unexpected thinning is detected. provided by ENN-DC-315 R.1 Section 5.12 engineering specifications. This question "Sample Expansion" is resolved.

b. Basis for replacement of piping when wall thinning is at 30% of nominal wall thickness is 2. The Basis for replacement of piping when wall detected (Class 1); and 20% of nominal wall thinning is at 30% of nominal wall for Class 1 and thickness is detected (Class 2 and Class 3) 20% of nominal wall for Class 2 and Class 3 is given in Engineering Specification ENN-CS-S- 008

c. Basis for replacement of piping when the wall Pipe Wall Thinning Structural Evaluation. The thickness is at the threshold of the minimum Methodology employed in writing ENN-CS-S-008 thickness required by the code. Has been conditionally accepted in Reg. Guide 1.147, Rev. 14. Entergy will adhere to all 5 conditions specified in the Reg. Guide.

3. Replacement is performed if the remaining service life does not support continued service based on Code minimums through the next operating cycle.

314 454 Identify all JAF operating experience with 1. There are a few recent examples of JAF The project team finds the applicants regard to FAC requiring replacement. Confirm operating experience (i.e. unusual system line-up, response acceptable because the that the FAC program is subject to appropriate valve leaking by, etc) with regard to FAC requiring plant-specific operating experience did not quality assurance review or their equivalents. pipe replacement. They are as follows: reveal any degradation not bounded by Summarize the latest quality review - The piping downstream of 31LCV-122A MSR industry operating experience and the determination. DRAIN TANK 4A BYPASS DRAIN TO MAIN applicant was addressing degradation 204

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CNDSR LEVEL CNTRL VALVE due to valve issues through their plant corrective action leaking by. process. This question is resolved.

- The piping downstream of 31MOV-CA2 MSR A CROSS AROUND PIPING DRAIN VALVE

• It should be noted that in both instances, large bore and small, the pipe was replaced with non-susceptible materials. (SA335 p22) (2.25% Cr)

2. QA Audit QA-8-2005-JAF-1 dated March 9, 2005 conlcuded the following: Based on the sample reviewed, the auditors concluded that the scope element FAC Program is Satisfactory.

3. The two most recent FAC program assessments are as follows:

- LO-JAFLO-2005-00069 / Focused Self Assessment / Sept. 26 thru Sept. 30, 2005

- LO-WPOLO-2003-00050 / Self-Assessment /

Feb. 9 thru Feb. 13, 2004 In general, the following conclusions were drawn:

- The FAC program is consistent with other FAC programs among the Entergy Nuclear South plants and throughout the industry. Any guidance provided by the NRC has been and is being followed appropriately.

- Several strengths were identified in the level of documentation and ownership of data, details and content of the CHECWORKS models, and use of advanced structural methods as a standard practice to qualify thinned piping and components.

- No weaknesses or deficiencies were identified that would indicate that the JAF FAC program could impact long-term monitoring of FAC or result in a challenge to nuclear or personnel safety, equipment reliability, or station performance.-

There are no gaps between the JAF FAC program attributes and those of the applicable INPO Engineering Program Excellence Guide 315 455 Entergy is scheduled to enter the 4th 10-year The 2001 edition of ASME Section XI, inclusive of The applicant amended the LRA in ISI Interval for JAFNPP in January 2007. For the 2003 Addenda, will be the new ASME Section amendment letter No. 5, dated February the 4th 10-year ISI Interval Entergy is required XI code of record for those JAFNPP AMPs 01, 2007. The applicant entered the 4th under 10 CFR50.55a to update the ASME referencing or crediting Section XI requirements. 10-Year Inservice Inspection (ISI) Interval Section XI Code of record to the 2001 Edition for FitzPatrick in January 2007. The of ASME Section XI, inclusive of the 2003 LRA Section A.2.1.18 will be amended with an project team finds the applicants 205

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addenda. This is the Edition of Section XI update to delete the relevant information for the 3rd response to this audit question and the endorsed in GALL. Clarify whether the 2001 Ten-Year ISI interval for JAFNPP and to amendment of the LRA to be acceptable edition of ASME Seciont XI, inclusive of the incorporate the relevant information for the 4th Ten- because the applicant has clarified that 2003 Addenda, will be the new ASME Section Year ISI Interval for JAFNPP. LRIS Open Item the 2001 Edition of ASME Section XI is XI code of record for those JAFNPP AMPs #267 tracks this issue. the edition that is applicable to the 4th 10-referencing or crediting Section XI year ISI Interval for FitzPatrick. Thus, as requirements. If an older edition of ASME This will be revised during the annual update of the stated in the amendment of the LRA, the Section XI will still be used for a particular AMP LRA. exception is not applicable to the current referencing or using ASME Section XI criteria, ISI interval for the facility. This question is identify what the AMP is and justify its use for resolved.

aging management as an exception to the Edition of Section XI endorsed in GALL.

The version of the ASME Code,Section XI required for the 4th 10-year ISI interval is the 2001 Edition of the ASME Code,Section XI, inclusive of the 2003 Addenda. The staff requests that the LRA Section A.2.1.18 be amended to delete the relevant information for the 3rd Ten-Year ISI interval for JAFNPP and to incorporate the relevant information for the 4th Ten-Year ISI Interval for JAFNPP.

316 456 The staff requests that each commitment The JAF Commitment List has been revised to add The applicant submitted the Commitment docketed on the JAFNPP LRA be referenced in the Appendix A reference to each commitment that List in a letter dated December 6, 2006.

the appropriate LRA Appendix A UFSAR involves Appendix A. In this amendment, the applicant provided Supplement summary description section. an updated commitment list for the The JAF Commitment List will be submitted with application. This question is resolved.

the first amendment.

317 457 GALL preventive action of the AMP states that The JAFNPP Fire Protection Program contains The project team finds the applicants normal fire protection programs include measures for the prevention and mitigation of fire response acceptable because the measures for mitigating or preventing fire events. Preventive programs such as ignition and JAFNPP Fire Protection Program contains events at the plant. Clarify whether the combustible control are in place. Additionally, fixed measures for the prevention and JAFNPP fire protection includes such and portable systems are present to assure early mitigation of fire events and they are measures, and if so, state what they entail. If fire detection and suppression in areas based upon consistent with JAF Fire Hazards Analysis such measures do not exist, justify why not fire hazards present and safety significance. Safe and the JAF Fire Protection Plan. This identified as an exception to the preventive shutdown strategies are present to ensure plant question is resolved.

action element of the AMP with a technical shutdown in the event of a single fire. Reference basis. JAF Fire Hazards Analysis and the JAF Fire Protection Plan for a description of specific systems and/or administrative elements.

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318 458 Identify the BWRVIPs used for "acceptance The bases for the "Acceptance Criteria" element of The project team finds the applicants criteria" element of AMP B.1.6 AMP B.1.6 is BWRVIP-48-A, Section 3.3, response acceptable because the "Inspection Acceptance Criteria". BWRVIP-14, applicant has identified BWRVIP-48-A, BWRVIP-59 and BWRVIP-60 are used as BWRVIP-14, BWRVIP-59, and BWRVIP-applicable to evaluate crack growth. 60 are within the scope of this AMP as applicable inspection and flaw evaluation guidelines and because this is consistent with the recommendations in GALL AMP XI.M4. This question is resolved.

319 459 B.1.6 -3 BWR Vessel ID Attachment Weld FitzPatrick has satisfactorily incorporated all The project team finds the applicants CR-WPO-LO-2005-069 states that JAFNPP recommendations identified in CR-WPO-LO-2005- response acceptable because the CR was BWRVIP Program is not in compliance with the 069. This CR was generated as a result of a Self - generated to address inspection coverage BWRVIP requirements. Clarify if all Assessment performed on the JAF-BWRVIP issues with the ID attachment welds and recommendations have been incorporated. Inspection program. Inspections were performed because the applicant has addressed this during Refuel Outage 17, as required by the by implementing the enhanced ultrasonic associated corrective actions and per the testing (UT) and visual examinations for established BWRVIP guidelines. Enhanced visual reactor vessel ID attachment welds in techniques and ultrasonics were incorporated to BWRVI-48-A. The staff has endorsed address inspection coverage issues. The BWRVIP BWRVIP-48-A for use in a safety program is in compliance with the BWRVIP evaluation dated January 17, 2001 program requirements and applicable guidelines. (ADAMS Accession No. ML010180493).

This question is resolved.

320 460 Enhancements for the parameter monitored/ Significant corrosion was intended to mean The project team finds the applicants inspected and acceptance criteria uses the unacceptable signs of degradation. The first two response acceptable because the phrase "verify no significant corrosion". What is enhancements listed for AMP B.1.13.2 will be applicant amended the LRA to clarify the meant by this phrase? revised to read as follows. phrase as "unacceptable signs of degradation." See amendment letter No.

Procedures will be enhanced to include inspection 5, dated February 01, 2007. This question of hose reels for corrosion. Acceptance criteria will is resolved.

be enhanced to verify no unacceptable signs of degradation.

Procedures for sprinkler systems will be enhanced to include visual inspection of spray and sprinkler system internals for evidence of corrosion.

Acceptance criteria will be enhanced to verify no unacceptable signs of degradation.

This requires an LRA amendment.

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321 462 B.1.4-1 BWR Penetrations The site has confirmed that there is no plant The project team finds the applicant Is there a plant specific fatigue evaluation for specific fatigue evaluation. response to be acceptable because the the Standby Liquid Control Delta P sensing line applicant has confirmed that the CLB does as discussed in BWRVIP-27A. not include any CUF-based fatigue evaluation for the standby liquid control/core. This question is resolved.

322 463 Provide a listing of the Medium Voltage cables The list of Medium Voltage cables installed for JAF The project team finds the applicants installed and how they were screened for GALL were provided to NRC. response acceptable because JAFNPP XI.E3. does not have any non-EQ inaccessible A summary of cable screening is listed below. medium-voltage cables in scope of GALL XI.E3. To be included in GALL Program The 4KV cables for RHR Service Water are located XI.E3, cables within scope of license within a building and run in conduit that is renewal have to be non-EQ, medium-surrounded by concrete. This conduit run is not voltage (2kV to 35kV), and are subjected underground and not susceptible to moisture. to significant moisture (installed in duct banks, cable trend underground) and The Core Spray Cables and RHR Cables are EQ significant voltage (energized more than and managed by the EQ Program. 25% of the time). This question is resolved.

There are some installed spare 4KV cables that are not connected and not energized.

The EDG cables are in conduit in a building and are not in duct bank underground. The EDG cables are not energized >25% of the time.

The 4KV Neutral Grounding Resistor Cabling is installed on the RSST transformers and is tied to plant ground. These cables are low voltage and not susceptible to moisture and water treeing.

Therefore, JAF does not have any 4KV cables that would require a GALL XI.E3 program. The 4KV cables that are in scope of license renewal are managed by the GALL XI.E1 program.

323 464 Provide a testing method for the insulating oil in JAF will address the aging management of the oil- The applicant provided response to RAI the Oil Filled Cable System. filled cable system in response to RAI 3.6.2-1. 3.6.2-1 in a letter dated February 01, This requires an LRA amendment. 2007. This response addressed aging management for oil filled cable system.

This question is closed to RAI 3.6.2-1.

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324 465 JAF-RPT-05-LRD02 Page 23 of 279 under Enclosure assembly elastomers will be visually Applicant amended the LRA. See Parameters Monitored/Inspected states that inspected. JAF-RPT-05-LRD02 and Appendix amendment letter No. 5, dated February where applicable, enclosure assembly B.1.17 will be revised to omit the wording "where 01, 2007. In this amendment, the elastomers will be visually inspected and applicable". applicant removed the phrase where manually flexed to manage cracking and applicable. The project team finds the change in material properties. GALL referred This requires a LRA amendment. applicants response acceptable and it is structural monitoring program for inspecting the consistent with GALL Report elastomers. Do you intend to inspect the recommendations. This question is enclosure assembly elastomer? If you do, resolved.

remove the phrase as applicable. If you do not, provide justification why elastomer is not subject to aging.

325 466 GALL XI.E4 under Operating Experience Appendix B.1.17 gives the correct "Operating The project team finds the applicants states that industrial experience has shown Experience" discussion. JAF-RPT-05-LRD02 will response acceptable because the that failures have occurred on MEBs caused by be revised to agree with the "Operating applicant revised operating experience cracked insulation and moisture or debris Experience" discussion in Appendix B. and the basis document is now in buildup internal to the MEB. Experience also agreement with the GALL Report and the has shown that bus connections in the MEBs LRA. This question is resolved.

exposed to appreciable ohmic heating during operation may experience loosening due to repeated cycling of connected loads. JAF-RPT-05-LRD02 under the same attribute states that MEB Inspection Program at JAFNPP is a new program for which there is no operating experience. Address industry and plant specific operating experience in the basis document 326 467 GALL XI.E2 under Detection of Aging Effects JAF-RPT-05-LRD02 will be revised to be The project team finds the applicants states that in cases where a calibration or consistent with Appendix B.1.18 as follows: response acceptable because the surveillance program does not include the applicant has revised the plant basis cabling system in the testing circuit, or as an "In accordance with the corrective action program, document to agree with GALL Report and alternative to the review of calibration results, an engineering evaluation will be performed when LRA, Appendix B.1.18. This question is that the test frequency of these cables shall be test acceptance criteria are not met and corrective resolved.

determined by the applicant based on actions, including modified inspection frequency, engineering evaluation, but the test frequency will be implemented to ensure that the intended shall be at least once every ten years. The functions of the cables can be maintained basis document page 30 of 279 under the consistent with the current licensing basis for the same attribute states that the first test shall be period of extended operation".

completed before the period of extended operation and subsequent tests will occur at least every 10 years. Explain how engineering evaluation will be considered in evaluating the test frequency to be consistent with the GALL.

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327 468 GALL XI.E2 under Operating Experience Appendix B.1.18 provides the correct "Operating The project team finds the applicants states that the vast majority of site specific and Experience" discussion for this program. JAF-RPT- response acceptable because the industry wide operating experience regarding 05-LRD02 will be revised to agree with Appendix applicant has revised the plant basis neutron flux instrumentation circuits is related B.1.18. document to agree with the operating to cable/connector issues inside of containment experience discussion in LRA Appendix near the reactor vessel. JAF-RPT-05-LRD02 B, Section B.1.18 and the GALL Report.

Page 32 of 279 under the same attribute states This question is resolved.

that the Non-EQ Instrumentation Circuits Review Program at JAFNPP is a new program for which there is no operating experience.

Address industrial and plant specific operating experience in the basis document.

328 469 GALL XI.E1 under Operating Experience Appendix B.1.19 provides the correct "Operating The project team finds the applicants states that operating experience has shown Experience" discussion for this program. JAF-RPT- response acceptable because the that adverse localized environment caused by 05-LRD02 will be revised to agree with Appendix applicant has revised the plant basis heat or radiation for electrical cables and B.1.19. document to agree with the operating connections may exist next to or above (within experience discussion in LRA Appendix three feet of) steam generators, pressurized or B, Section B.1.18 and the GALL Report.

hot process pipes, such as feedwater lines. This question is resolved [[::JAF-RPT-LRS02|JAF-RPT-LRS02]] Page 38 of 279 states that the Non-EQ Insulated Cables and Connections Program at JAFNPP is a new program for which there is not operating experience.

Address industrial and plant specific operating experience in the basis document.

329 470 B.1.18-3 Non-EQ Instrumentation Circuits Test The testing for instrumentation circuits will include The project team finds the applicant's Review Program: both cables and connections. response acceptable because the applicant has clarified that the testing of Clarify whether the tests include both cables instrumentation circuit will include both and connections. cables and connections. This is consistent with GALL Report recommendation. This question is resolved.

330 471 Appendix B - All programs in Appendix B state JAF will revise Appendix B to clarify the "is The project team finds the applicant's that the program "is comparable to" a GALL comparable to " statements and to state if the response acceptable because the program. program is new or existing. applicant amended the LRA to clearly state which AMPs are the existing or new This is not acceptable. Appendix B needs to This requires a LRA amendment. ones and which one has the state that the program is new or existing and enhancement or exception or is that it meets one of the following criteria: consistent with GALL Report. See 210

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(1) Consistent with GALL amendment letter No. 5, dated February (2) Consistent with GALL with enhancements, 01, 2007. This question is resolved.

or (3) Consistent with GALL with exceptions The plant specific programs will not need this criteria.

331 472 For AMP B.1.1, Buried Piping and Tanks A search of the condition report (CR) database The project team finds the applicant's Inspection, please describe plant-specific from the early 1990s to present identified only one response acceptable because the operating experience information on any CR (CR-JAF-1993-00502) that provided historical operating experience demonstrates that inspections of buried components performed at operating experience for buried piping and tanks for JAFNPP is not experiencing any aging JAFNPP, including the date of the inspection, JAFNPP. CR-JAF-1993-00502 was written to mechanisms that are not bounded by and any degradation found. evaluate a leak in the H2 supply buried piping industry operating experience. This between the storage facility and the turbine question is resolved.

building. The root cause for this CR recommended replacement of this section of piping, because of poor application of protective coatings. Therefore, this pipe leak was the result of a manufacturing issue not aging.

During a period from the mid-1990s to present, several fire protection system buried valves were excavated through the work order process. None of the excavated valves showed evidence of corrosion; therefore, no CRs were written.

332 473 For AMP B.1.21, One-Time Inspection, please The sample size is based on Chapter 4 of EPRI The sample size is based on explain the inspection sample size for each document 107514, Age Related Degradation EPRI 107514,"Age-Related Degradation inspection and state how it will be expanded if Inspection Method and Demonstration, which Inspection Method and Demonstration,"

degradation is detected. outlines a method to determine the number of Chapter 4. For verification of the inspections required for 90% confidence that 90% effectiveness of the water chemistry of the population does not experience degradation programs, the scope will include a (90/90). Components with the same material- representative sample of the components environment combinations at other facilities may be crediting the Water Chemistry Program.

included in the sample. Since operating experience identified a history of low oxygen and high iron The program provides for increasing inspection content in the reactor building closed loop sample size and locations in the event that aging cooling (RBCLC) system, the sample effects are detected. Unacceptable inspection population will specifically include findings are evaluated in accordance with the components in this system. For JAFNPP corrective action process to determine the confirmation that aging is not occurring or need for subsequent (including periodic) is so insignificant that an AMP is not inspections and for monitoring and trending the required, the table in Attachment 2 results. identifies specific components that will be 211

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inspected in the systems crediting the One-Time Inspection Program. The project team determined that the scope of this program is adequately described.

This question is resolved.

333 474 For AMP B.1.21, One-Time Inspection, please Inspection techniques will be selected from The parameters monitored include wall explain how the specific inspection technique established NDE techniques, including visual, thickness, fouling, and the extent of and location will be determined. ultrasonic, and surface techniques that are cracking. Reduction of fracture toughness performed by qualified personnel following is also a parameter to be monitored by procedures consistent with the ASME Code and 10 inspection of specific CASS components CFR Part 50, Appendix B. for the extent of cracking. Inspection techniques include visual examination, The inspection and test techniques will have a surface techniques, UT testing, and demonstrated history of effectiveness in detecting radiography.

the aging effect of concern. Determination of inspection locations will be based on identification The project team determined that the of low flow/stagnant areas, drains, and low points parameters to be monitored are consistent for system components managed by the program. with the aging effects which the LRA These components are considered the most credits this program. The inspection susceptible to aging effects. techniques are proven methods for detecting loss of wall thickness, fouling, and the extent of cracking, common in the industry, and, therefore, acceptable for the purposes of this AMP.

Determination of inspection locations will be based on identification of low flow/stagnant areas, drains, and low points for system components managed by the program. These components are considered the most susceptible to aging effects. The project team finds this acceptable.

334 475 For AMP B.1.22, PSPM, please explain the The sample size will be based on Chapter 4 of The project team finds the applicant's inspection sample size for each inspection and EPRI document 107514, Age Related Degradation response acceptable because the how it will be expanded if degradation is Inspection Method and Demonstration, which applicant clarified that sample size detected. outlines a method to determine the number of methodology is based on EPRI document inspections required for 90% confidence that 90% and if degradation is detected, sample of the population does not experience degradation expansion and evaluations are based on (90/90). Components with the same material- plant's corrective action process. This environment combinations at other facilities may be question is resolved.

included in the sample.

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The program provides for increasing inspection sample size and locations in the event that aging effects are detected. Unacceptable inspection findings are evaluated in accordance with the JAFNPP corrective action process to determine the need for subsequent (including periodic) inspections and for monitoring and trending the results.

335 476 For AMP B.1.22, PSPM, please explain how Systems within the scope of the PSPM program The project team finds the applicant monitoring and trending of results are are monitored through system engineering response acceptable because the performed. activities per site procedures. Results from program element satisfies the criterion monitoring activities are evaluated against defined in SRP-LR Section A.1.2.3.5. This acceptance criteria and trends are developed by question is resolved.

comparing current results to previous results to predict degradation rates. These predictions are used to confirm that loss of component intended function will not occur prior to the next scheduled inspection. Use of trend data from these activities are used to revise inspection frequencies per the site preventive maintenance processes. All degrading trends will be documented as a Condition Report per the JAF Corrective Action Program in accordance with 10CFR50 Appendix B.

336 478 The Main Condenser that is a component of the The main condenser has no license renewal The project team finds the applicant's Steam and Power Conversion System is not intended function and is not subject to aging response acceptable because the main identified in Section 3.4 of the LRA. How is management review. condenser has no license renewal aging management addressed for this intended function and is not subject to component? aging management review. This question is resolved.

337 479 Why was note E identified in table 2, where the Note "E" is used rather than Note "A" because the The project team finds the applicant's aging management program was the same in NRC and NEI agreed to use Note "E" rather than response acceptable because Note E table 1 for the following line item: Note "A" when GALL specifies a plant-specific indicates the applicant used the plant-program. This indicates the need for the staff to specific AMPs which the project team 3.5.1-5; 3.5.1-11; 3.5.1-12; 3.5.1-18; and 3.5.1- review the acceptability of the program, while Note needs to review the acceptability of the

53. Please explain or make a correction to the "A" would indicate that the use of the program had program. This question is resolved.

table 2. already been accepted as documented in the GALL report.

338 481 Table 3.2.2-5 includes an AMR line item for Augmented inspections are performed at JAFNPP The project team finds the applicant's carbon steel piping exposed to steam. The on selected piping components not part of response acceptable because the PSPM 213

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PSPM program is credited to manage loss of inspections required by Generic Letter 89-08 and program is appropriately credited for material due to flow accelerated corrosion included in the Flow-Accelerated Corrosion management of loss of material due to instead of the FAC program, and Table 1 line Program. Because inspections outside the FAC erosion. This question is resolved.

item 3.2.1-19 is cited. Explain why the PSPM program are performed on these components, the program is consistent with the flow-accelerated PSPM program is credited for management of loss corrosion program for this AMR line item. of material due to erosion.

Plant-specific Note 204 is listed for line items where augmented inspections apply.

339 482 AMR line-item 3.2.1-18 addresses cracking due BWR SCC program is applicable to all BWR piping GALL AMP XI.M7, BWR Stress Corrosion to SCC and IGSCC for stainless steel piping, and piping welds made of austenitic SS and nickel Cracking, states that the scope of the piping components, and piping elements alloy that is 4 in. or larger in nominal diameter and program is applicable to all BWR piping exposed to treated water >60C (>140F). The contains reactor coolant at a temperature above and piping welds made of austenitic SS AMR credits the Water Chemistry-BWR and 93°C (200°F) during power operation, regardless of and nickel alloy that is 4 in. or larger in One-Time Inspection programs instead of the code classification. The piping components nominal diameter and contains reactor Water Chemistry and BWR Stress Corrosion included in section 3.2 with temperatures above coolant at a temperature above 93°C Cracking programs, which arommended by 200 °F for this line item are less than 4 NPS and (200°F) during power operation, NUREG-1801. Please explain a single are outside the reactor coolant system (RCS) regardless of code classification.

inspection under the one-time inspection pressure boundary. They are, therefore, outside the program is adequate to replace the periodic scope of the BWR SCC program. As a result the The project team finds the applicant's inspections included in the BWR SCC program Water Chemistry Control - BWR program is used. response acceptable because the piping for the AMRs associated with this line item As stated in LRA Section B.1.29.2, the Water components included in section 3.2 with since these are Class 1 pressure boundary Chemistry Control - BWR Program is consistent temperatures above 200°F for this line components. with the program described in NUREG-1801, item are less than 4 inches in diameter Section XI.M2, Water Chemistry. The One-Time and hence, are not within the scope of the Inspection Program, described in LRA Section BWR SCC program. This question is B.1.21 includes inspections to verify the resolved.

effectiveness of the water chemistry control aging management programs (Water Chemistry Control

-Auxiliary Systems, Water Chemistry Control -

BWR, and Water Chemistry Control - Closed Cooling Water) by confirming that unacceptable cracking, loss of material, and fouling is not occurring.

In addition, the components where line item 3.2.1-18 is applicable are included in the scope of the JAFNPP ISI program.

340 483 Section A.2.2.7 of the LRA states that loss of A. The loss of preload analysis does not The project team finds the applicants preload and cracking of the core plate rim hold- specifically manage cracking of the core plate rim response to be acceptable because the down bolts is a TLAA in accordance with the hold down bolts. Instead, the credited BWRVIP-25 applicant amended the LRA in NRCs safety evaluation report on Topical inspections in the Reactor Vessel Internals amendment letter No. 9, dated April 06, Report-25. Program manage cracking. The loss of preload 2007, and placed Commitment No.23 on 214

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analysis discussed in LRA Section 4.7.3.2 in the LRA to address the corrective actions The Section states that JAFNPP commits to conjunction with a plant-specific calculation will that are referenced in the response to this preform a plant-specific calculation prior to the provide the acceptance criteria for cracking of the item. This question is resolved.

period of extended operation unless core plate bolts, i.e. how many intact bolts are required to wedges are installed during the remainder of maintain adequate clamping force.

the current operating period. The staff requests B. The JAFNPP response to RAI 4.7.3.2-1 will the following information relative to LRA address the need for a commitment to perform the Section A.2.2.7: plant-specific analysis required in accordance with LRA Section A..2.2.7. The response to RAI 4.7.3.2-A. Clarify, using a technical discussion, how the 1 will be submitted under oath and affirmation.

TLAA provided in LRA Section 4.7.3.2 1. Install core plate wedges prior to the period of manages cracking in the core plate rim hold- extended operation, or, down bolts. 2. Complete a plant-specific analysis to determine B. The staff request that the LRA be amended acceptance criteria for continued inspection of core to include Entergys commitment to include plate rim hold down bolting in accordance with options for managing or analyzing loss of BWRVIP-25 and submit the inspection plan to the preload (due to irradiation-assisted stress NRC two years prior to the period of extended relaxation) in the core plate rim hold-down operation for NRC review and bolts. approval.

3. Perform inspection of core plate rim hold down bolts in accordance with ASME Code Section XI or in accordance with an NRC-approved version of BWRVIP-25. If Option 2 is selected, the analysis to determine acceptance criteria will address all the requests identified in RAI 4.7.3.2-1.

This requires an LRA amendment.

JAF Commitment 23, Reference RAI 4.7.3.2-1.

341 484 The staff has determined that the JAFNPP The JAF reactor building crane design complies The project team finds the applicants reactor building cranes are within the scope of with the guidelines of CMAA-70 as determined in response to be acceptable because: (1) license renewal and have been screened in for response to NUREG-0612 in the late 1970s. No the applicant has clarified that there is no an aging management review. Clarify whether JAFNPP calculation or analysis related to fatigue evaluation for the reactor building the reactor building crane is designed in cumulative fatigue damage for steel cranes met the cranes, and (2) the applicant has clarified accordance with CMAA-70 and if so, clarify definition of TLAA in 10 CFR 54.3. Steel cranes are that, while the scope of documents for the whether the lift load analysis for the reactor evaluated as structural components in Section 3.5 cranes do not include applicable TLAAs, building crane is a TLAA for the JAFNPP LRA. of the JAFNPP LRA. the number of lift cycles for the cranes Provide your basis for concluding that the lift through 60-years of operations is load analysis is or is not a TLAA for the LRA. If The license renewal rule, in 10 CFR 54.3, defines a projected to be less the number of lift the lift load analysis for the reactor building TLAA as a licensee calculation or analysis that, cycles allowed for in CMAA-70. This crane is a TLAA for the LRA, amend the LRA to among other things, involves time-limited question is resolved.

include the TLAA for staff review assumptions defined by the current operating term.

and provide your basis for concluding why the TLAA for the reactor building crane is The estimated JAFNPP crane cycles in 40 years acceptable in accordance with 10 CFR are 5000 cycles (Section 2.7.1 of LRPD03). The 215

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54.21(c)(1)(I), (ii) or (iii). cycle range for class A cranes in CMAA-70 is 20,000 to 200,000 cycles. If the 5000 cycles is multiplied by 1.5 to project the number of cycles to 60 years, the resulting 7500 cycles is still well below the CMAA-70 Class A cycle limit.

342 485 Section 4.3.3 of LRA provides the TLAA on To satisfy LRA Commitment 20, JAFNPP will The project team finds the applicants environmentally-impacted metal fatigue of perform a fatigue analysis, i.e., calculate a CUF, for response to be acceptable because the ASME Class 1 components. The TLAA the RHR and FW piping and then adjust the CUF applicant amended the LRA in discussion and evaluation in LRA does not for environmentally assisted fatigue. amendment letter No. 9, dated April 06, include any environmentally impacted CUF 2007, and placed Commitment No. 20 on value results for the RHR Class 1 piping or the Commitment 20 is revised to match the wording the LRA to address environmentally-FW line Class 1 piping at JAFNPP. These are proposed for Commitment 31 for PNPS license assisted fatigue of the reactor coolant among the locations identified, as a minimum, renewal. The revised wording for Commitment 20 is pressure boundary components.

in NUREG/CR-6260 for environmental CUF included in the response to Question 317. Commitment No. 20 includes a provision evaluations. Discuss the activities and/or usage to perform new enviromentally-assisted factor calculations that Entergy will conduct, if CUF calculations for the Class 1 portions any, to ensure that environmentally impacted of the residual heat removal and fatigue of the RHR Class 1 piping and FW line feedwater piping. This question is Class 1 piping will be managed in accordance resolved.

with the acceptance criterion in 10 CFR 54.21(c)(1)(iii) or analyzed and projected for the PEO in accordance with 10 CFR 54.21(c)(1)(ii).

In addition, the staff requests that Commitment No.20 on the JAFNPP LRA be amended to be consistent the wording proposed by Entergy Nuclear Operations, Inc. for Commitment No.31 of the LRA for the Pilgrim Nuclear Power Station.

343 487 At the time Entergy performed its revised JAFNPP instituted hydrogen water chemistry The project team finds the applicants environmentally-assisted fatigue analysis, (HWC) in August of 1988. Entergy will re-calculate response to be acceptable because the Entergy used hydrogen water chemistry (HWC) the Fen values accounting for normal water applicant amended the LRA in implementation to establish the oxygen chemistry (NWC) oxygen concentrations (150 - amendment letter No. 9, dated April 06, concentrations (in ppm) used in its Fen 200 ppb) and apply the revised Fen to the 2007, and placed Commitment No. 20 on adjustment factor calculations. Clarify whether appropriate CUF values in LRA Table 4.3-3. The the LRA to address environmentally-Entergy factored in the oxygen concentrations results of the revised calculation will be submitted assisted fatigue of the reactor coolant derived from implementation of normal water as a change to LRA Table 4.3-3. This requires an pressure boundary components.

chemistry (NWC) in the Fen calculations for LRA Commitment No. 20 includes the need to those operational periods when NWC was amendment. use the oxygen concentrations associated being implemented instead of HWC. with normal water chemistry and concentrations associated with hydrogen water chemistry in the calculations of Fen.

This question is resolved.

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344 488 In Table 8 of JAFNPP Document No. EAS-149- The Ke factor is not applicable based on the The project team finds the applicants 1286, dated January 1987, the fatigue following response to be acceptable because the evaluation for the reactor pressure vessel explanation. applicant has provided a valid regulatory (RPV) closure region bolts calculated the Salt basis for demonstrating the ASME Section value according to the following equation: The design of the vessel bolts are based on 1965 III methods for calculating peak stress Salt = Sp/2 ASME code section III paragraph N-416. factors which did not require the applicant The value of Sn was not provided. When Sp = to include Ke factor adjustments fo the 488 ksi, Sn is quite significant and Ke in A. Paragraph N-416-1 (attached) requires that: 1) peak stress factor calculations. This normally higher than 1.0. Please provide the Sn The maximum value of service stress, averaged question is resolved.

value for the first load set and describe how it across the bolt cross section and neglecting stress was calculated. Justify that Ke = 1.0.. This concentrations, shall not exceed two times the question is also applicable to the first load set stress values of Table N-422; 2) The maximum combination in Table 3-1 of JAFNPP Report value of service stress at the periphery of the bolt SIR-02-045, Revision 1. cross section (resulting from direct tension plus bending) and neglecting stress concentrations shall not exceed three times the stress values of Table N-422. Original design calculation page A-114 (attached) shows that both of these limits are met.

B. Paragraph N-416.2 b(1) requires that the peak stresses be calculated using a stress intensification factor of 4.0 (specified in paragraph N-416.4).

Original design calculation page A-107 shows that a stress concentration factor of 4.0 was used to calculate peak stresses.

C. Paragraph N-416.2 b(2) states that Salt is equal to one-half of the stress range (max peak stress minus min peak stress). Original design calculation page A-115 shows that Salt were calculated using this method required by the code.

ASME code in section N-416 does not require an additional correction factor to Salt (the Ke factor stated above). The peak alternating stresses already contain a factor of 4.0 due to stress concentration. Since the stresses in calculation EAS-149-1286 (DRF B13-01391) [Ref 3] were obtained from the original vessel calculations [Ref 1], then the methodology used in the original calculations apply to this calculation also.

References:

1. Combustion Engineering Calculation CENC-1159, Analytical Report for JAF Reactor Vessel, 1969.

2. 1965 ASME Boiler and Pressure Vessel Code 217

Question and Answer Database Audit and Review Related to the License Renewal Application for James A. Fitzpatrick Nuclear Power plant Applicant's No. Audit Questions Applicants Response Project Team's Evaluations Ref. No.

3. GE Calculation EAS-149-1286 (DRF B13-01391), Reactor Pressure Vessel Fatigue Evaluation for the James A. Fitzpatrick Nuclear Power Plant, January, 1987.

345 489 Table 2 of Minor Change Calculation No. DRN- The difference in the CUF values is attributed to: The project team finds the applicants 03-00749 to Calculation 1. The original calculations [1] were performed by response to be acceptable because the very conservative hand computations. These applicant has clarified that the revised No. SIR-02-045, Revision 1, provides a value of calculations computed the CUF to be 0.780. CUF calculation fo the CRD nozzle 0.852 for the original 40-year CUF and a value Subsequently, this CUF value was revised to housing/stub tube junction was performed of 0.0114 for the 60-year CUF value for the account for the Power Uprate conditions [2]. The using applicable ANSYS computer finite CRD nozzle housing/stub tube junction. This is original CUF of 0.780 was multiplied by a factor to element modeling and that the ANSYS a factor of 112 difference between the CUF obtain a CUF of 0.852 for power uprate conditions. modeling applied actual loading and values. Provide your technical basis for the The latest calculations [3, 4] performed utilized a geometry conditions fo the components difference in the CUF values. detailed finite element model to determine the and eliminated some of the conservatisms CUFs for 60-year plant operation. The stresses in in the original methodology for calculating the CRD nozzle region were obtained by the use of the original 40-year CUF value for this ANSYS computer program and this finite element component. This question is resolved.

model. The stresses developed reflect the actual geometry and the loading conditions around the CRD nozzle region. These stresses obtained from the finite element analysis are lower compared to the original calculations [1].

2. The original calculations [1, 2] assumed that all transients result in the maximum calculated peak stresses. Therefore, all transient cycles were added together and this total was divided by the allowable number of cycles based on the maximum alternating stress. This is very conservative.

The latest calculations [3, 4] take into account all different transients and determine stresses and allowable cycles based on each transient. This yields in a lower CUF than the conservative methodology used in the original calculations [1, 2].

References:

1. Combustion Engineering Calculation CENC-1159, Analytical Report for PASNY Reactor Vessel for FitzPatrick Station, 1971

2. GE Report NEDC-32068, RPV Power Uprate Stress Report Reconciliation for the FitzPatrick Power Plant, 3/23/92

3. Structural Integrity Associates SIR-02-045, Updated Fatigue Analysis for JA FitzPatrick Nuclear Power Plant Reactor Pressure Vessel 218

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Components, 9/23/2002

4. Minor Calculation Change No: DRN-03-00794, 7/9/2003 346 498 TLAA on Metal Fatigue: Please provide a 1.Show the chronology of the RPV analysis for the The project team finds the applicants summary for the various metal fatigue analyses following issues: response to be acceptable because the (including minor design calculation changes) applicant has: (1) provided a chronology of performed to date for all Class 1 components a. Discuss CE>>>GE 1987 analysis>>>GE Uprate the design basis CUF-based fatigue (e.g., reactor vessel components, reactor Analysis >>> SIA Analysis - Code of record, Why analyses that were performed in the CLB internals, Class 1 piping, etc.) that have been changed, etc. for the JAFNPP Class 1 components and analyzed in accordance with ASME Section III which of these analyses are the current for fatigue cumulative usage factors (CUF). For b. List all calculations from CE calculation to CUF analyses in the CLB, and (2) each analysis performed to date, identify which present SIA analysis and any margin analysis. summarized the conditions of analysis and vendor (e.g., GE, CE, SIA) performed the Calculation - ASME Code Version - Reason for analysis assumptions for each of the analysis, what the reference document pertains Calculation - Comments analyses summarized in the chronology.

to the analysis, and the date that the analysis Original Combustion Engineering calculations This question is resolved.

was performed. For each component analyzed, Dated 8/30/1971 identify which fatigue analysis is the analysis of ASME Section III, 1965 Edition and addenda record as of todays date and describe the through Winter 1966. Code cases 1332-4, 1335-2, conditions, assumptions, and the applicable 1336 and 1339-2.

Code edition and addenda associated with the Original design calculation analysis. General Electric EAS-149-1286 DRF B13-01391 Dated January 1987 ASME Section III, 1965 Edition and addenda through Winter 1966. Code cases 1332-4, 1335-2, 1336 and 1339-2.

Fatigue analysis was updated based on actual plant operating data for approximately the first eleven years. Fatigue usage factors were calculated and extrapolated to 40 years. Fatigue Usage Factors were updated. Controlling four components were: 1) Closure Region Bolts, 2)

Recirculation Inlet Nozzle, 3) Feedwater Nozzle, and 4) Control Rod Drive Nozzle General Electric NEDC-32068 DRF 137-0010 Dated March 1992 ASME Section III, 1965 Edition and addenda through Winter 1966. Code cases 1332-4, 1335-2, 1336 and 1339-2 ASME Section III 1974 Edition with Addenda to and including Summer 1976 Fatigue analysis was updated for Power Uprate conditions using the bounding components, i.e. the 219

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components with the highest usage factors.

Fatigue Usage Factors were updated for components : 1) Closure Region Bolts, 2)

Recirculation Inlet Nozzle, 3) Feedwater Nozzle, 4)

Control Rod Drive Nozzle, 5) Shroud Support, and

6) Vessel Shell Structural Integrity Associates SIR-02-045, Rev 1Dated 9/23/2002ASME Section III, 1989 Edition Fatigue analysis was updated for a 60-year plant operation based on actual plant transient information Fatigue Usage Factors were updated. Controlling four components were: 1) Closure Region Bolts, 2)

Recirculation Inlet Nozzle, 3) Feedwater Nozzle, and 4) Control Rod Drive Nozzle Entergy Minor Calculation Change No: DRN-03-00794 ASME Section III, 1965 Edition and addenda through Winter 1966 A code reconciliation was performed on SIA calculation SIR-02-045 Rev. 1, to revise CUFs calculated in the SIA calculation The only change in the CUFs were for the 1) Recirculation Inlet Nozzle and, 2) CRD Nozzle

c. Shroud Tie Rod - Analysis of record and any margin calculations (list - with discussion).

The analysis of record for the shroud tie rod fatigue usage factors is:

1.Original MPR design calculation 291-9401-202, Tie Rod Assembly Stress Evaluation, Rev. 1, 10/21/1994. This calculates the maximum CUF as 0.0575 for 40-year operation. This CUF was multiplied by a ratio to obtain the 60-year operation CUF.

2. There are no margin calculations on shroud tie rod fatigue evaluation.

d. Jet Pump Fatigue Evaluation

1. The CUF for the jet pump diffuser adapter was obtained from the UFSAR (pg 16.2-7) maximum value of 0.65 multiplied by a factor of 1.5. The UFSAR states that the fatigue analysis method is described in GE document APED-5460 Design and Performance of GE-BWR Jet Pumps, dated 220

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September 1968.

2. From the 1987 GE Analysis - (EAS-149-1286/DRF B13-01391) provide the following input:

A. Justify the Operating Data Reduction as discussed in Table 2, 3. Actual plant data is listed in Table 2 from initial start-up through 7/3/1986.These events are summarized in Table

3. Based on these actual plant transients, projections were made for 40-year operation.

The actual plant data included the following:

a. Summary of events from operator logs

b. Post trip computer edits if available

c. Recirculation temperature and flow rate strip charts.

d. Feedwater and main steam flow rate strip charts.

e. Reactor Pressure strip charts.

f. Balance of plant logs

g. Closure region tensioning data.

B. Provide justification on page 19 of the 6 transients that exceeded the original design basis.

These events are considered to be less severe than the original design basis events based on the following reasoning:

1) The Ts occur over a finite period of time, i.e.

they are not instantaneous.

2) Whenever data was available from balance of plant logs, it suggested that the temperature changes occurred relatively slowly, i.e. less than 100 o F/hour. Since it is a Technical Specifications requirement to shut down or startup the reactor less than or equal to 100 o F/hour this assumption was used when data was not available. This is conservative.

3) The original analysis (CE analysis) thermal stresses are inherently conservative because they are based on shell interaction equations and use conservative assumptions.

Thus, it is considered conservative to use the original design basis thermal stresses for the 221

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updated fatigue evaluation.

3.Why seismic loading was not included in the RV head bolting fatigue analysis?

The vertical seismic Load Factor of 0.2 gs is in the original design parameters as shown in Attachment 1, pg 3. However, transient conditions stated on page 4 does not include seismic loading. This is due to the fact that the low vertical seismic is compensated by dead weight, resulting in zero tensile stress in the reactor vessel studs.

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